Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation)

Summary Document of Representations:

This Document provides a summary of representations received during the Regulation 16 consultation on the Thundridge Neighbourhood Development Plan. This summary does not contain an exhaustive list of every representation and detail received. All comments received during the consultation were sent to the Independent Examiner in their entirety.

Organisation Summary of Comments

Savills on behalf of Thames Thames Water is the statutory sewerage undertaker for part of the Borough and is hence a “specific Water consultation body” in accordance with the Town & Country Planning (Local Development) Regulations 2012.

From the 1st April 2018 all off site wastewater network reinforcement works necessary as a result of new development are delivered by the relevant statutory undertaker. Local reinforcement works will be funded by the Infrastructure Charge which is a fixed charge for water and wastewater for each new property connected.

Policy WAT6 of the East Herts District Plan relates to wastewater infrastructure issues and requires that development proposals must ensure that adequate wastewater infrastructure capacity is available in advance of the occupation of development. To assist with ensuring that any development considers the wastewater infrastructure implications at an early stage and to help ensure that any necessary upgrades to the sewerage network are programmed to align with new development it is suggested that additional text as set out below is added to Policy THFS6 on Infrastructure or supporting text for the Policy.

“In order to ensure that development proposals comply with Policy WAT6 of the East Herts District Plan developers are advised to contact Thames Water at an early stage to discuss the drainage requirements for their development. Details regarding Thames Waters pre-application service can be found at: Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

www.thameswater.co.uk/preplanning “

Historic Historic England welcomes the production of the Thundridge Neighbourhood Plan but do not wish to provide further detailed comments at this stage. Historic England ask to refer to any previous comments submitted at Regulation 14 stage and provide a link for any further detailed advice on successfully incorporating historic environment considerations into a neighbourhood plan . https://historicengland.org.uk/advice/planning/plan-making/improve-your-neighbourhood/

Historic England ask to be notified when the Neighbourhood Plan is made by the District Council and note that this letter does not reflect their obligation to provide further advice on or, potentially, object to specific proposals which may subsequently arise as a result of the proposed NP when they consider there would be an adverse effect on the Historic Environment.

Natural England Natural England is a statutory consultee in neighbourhood planning and must be consulted on draft neighbourhood development plans by the Parish/Town Councils or Neighbourhood Forums where they consider their interests would be affected by the proposals made. Natural England does not have any specific comments on this draft neighbourhood plan. They have provided an attached annex which covers the issues and opportunities that should be considered when preparing a Neighbourhood Plan.

Sport England Government planning policy, within the National Planning Policy Framework (NPPF), identifies how the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Encouraging communities to become more physically active through walking, cycling, informal recreation and formal sport plays an important part in this process. Providing enough sports facilities of the right quality and type in the right places is vital to achieving this aim. This means that positive planning for sport, protection from the unnecessary loss of sports facilities, along with an integrated approach to providing new housing and employment land with community facilities is important.

Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

It is essential therefore that the neighbourhood plan reflects and complies with national planning policy for sport as set out in the NPPF with particular reference to Pars 96 and 97. It is also important to be aware of Sport England’s statutory consultee role in protecting playing fields and the presumption against the loss of playing field land. Sport England’s playing fields policy is set out in our Playing Fields Policy and Guidance document. http://www.sportengland.org/playingfieldspolicy

Sport England provides guidance on developing planning policy for sport and further information can be found via the link below. Vital to the development and implementation of planning policy is the evidence base on which it is founded. http://www.sportengland.org/facilities-planning/planning-for-sport/forward-planning/

Sport England works with local authorities to ensure their Local Plan is underpinned by robust and up to date evidence. In line with Par 97 of the NPPF, this takes the form of assessments of need and strategies for indoor and outdoor sports facilities. A neighbourhood planning body should look to see if the relevant local authority has prepared a playing pitch strategy or other indoor/outdoor sports facility strategy. If it has then this could provide useful evidence for the neighbourhood plan and save the neighbourhood planning body time and resources gathering their own evidence. It is important that a neighbourhood plan reflects the recommendations and actions set out in any such strategies, including those which may specifically relate to the neighbourhood area, and that any local investment opportunities, such as the Community Infrastructure Levy, are utilised to support their delivery.

Where such evidence does not already exist then relevant planning policies in a neighbourhood plan should be based on a proportionate assessment of the need for sporting provision in its area. Developed in consultation with the local sporting and wider community any assessment should be used to provide key recommendations and deliverable actions. These should set out what provision is required to ensure the current and future needs of the community for sport can be met and, in turn, be able to support the development and implementation of planning policies. Sport England’s guidance on assessing needs may Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

help with such work. http://www.sportengland.org/planningtoolsandguidance

If new or improved sports facilities are proposed Sport England recommend you ensure they are fit for purpose and designed in accordance with our design guidance notes. http://www.sportengland.org/facilities-planning/tools-guidance/design-and-cost-guidance/

Any new housing developments will generate additional demand for sport. If existing sports facilities do not have the capacity to absorb the additional demand, then planning policies should look to ensure that new sports facilities, or improvements to existing sports facilities, are secured and delivered. Proposed actions to meet the demand should accord with any approved local plan or neighbourhood plan policy for social infrastructure, along with priorities resulting from any assessment of need, or set out in any playing pitch or other indoor and/or outdoor sports facility strategy that the local authority has in place.

In line with the Government’s NPPF (including Section 8) and its Planning Practice Guidance (Health and wellbeing section), links below, consideration should also be given to how any new development, especially for new housing, will provide opportunities for people to lead healthy lifestyles and create healthy communities. Sport England’s Active Design guidance can be used to help with this when developing planning policies and developing or assessing individual proposals.

Active Design, which includes a model planning policy, provides ten principles to help ensure the design and layout of development encourages and promotes participation in sport and physical activity. The guidance, and its accompanying checklist, could also be used at the evidence gathering stage of developing a neighbourhood plan to help undertake an assessment of how the design and layout of the area currently enables people to lead active lifestyles and what could be improved.

NPPF Section 8: https://www.gov.uk/guidance/national-planning-policy-framework/8-promoting-healthy- communities Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

PPG Health and wellbeing section: https://www.gov.uk/guidance/health-and-wellbeing

Sport England’s Active Design Guidance: https://www.sportengland.org/activedesign The Canal & River Trust The Canal & River Trust (the Trust) is the guardian of 2,000 miles of historic waterways across England and Wales. We are among the largest charities in the UK. Our vision is that “living waterways transform places and enrich lives”. We are a statutory consultee in the development management process.

We have reviewed the neighbourhood plan details and confirm that we have no comments to make, as the plan area is some distance from the River Stort and Lee Navigation, which are the nearest waterbodies that we are responsible for.

Jane Orsborn on behalf of Mr Objection is raised to the failure of the NP to have regard to the potential expansion needs of this key Brian Oakley, Oakley employer within the parish by not including currently open land owned by Oakley Horseboxes within the Horseboxes defined village boundary of High Cross. The land to which reference is made is verged red on the submitted location plan reference BO/01 which also illustrates the defined village boundary.

Further letters and statements are provided within the response.

Bidwells on behalf of The St The Submission Neighbourhood Plan for Thundridge fails to meet basic conditions A and D, particularly Albans Diocesan Board of with regard to the Local Green Space (LGS) designation and specifically LGS9 ‘Land at North Drive, High Finance Cross’. The LGS designations do not meet all three criteria set out at paragraph 100 of the NPPF. Therefore, the Local Green Space designations do not fully comply with relevant national policy (basic condition A) and do not contribute towards the achievement of long-term sustainable development (basic condition B). The proposed allocation LGS9 should be removed from the Neighbourhood Plan.

The reference of a potential future Conservation Area for High Cross within Policy THE2 is unjustified and should be deleted from the policy text. This is only an aspiration and so should instead be referenced within supporting text. Furthermore, given the fact that Parish Councils do not have the power to Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

designate Conservation Areas, policy THE2 is not effective.

My client objects to the identification of Important View 10 and the observation that it is “the most cherished view in High Cross”. There is a lack of compelling evidence to demonstrate this and therefore it should be removed from the Submission version Neighbourhood Plan.

My client considers that the Submission version of the Thundridge Neighbourhood Plan does not meet the basic tests which a Neighbourhood Plan is required to meet and therefore revisions, as detailed in this representation, are needed to ensure that the plan can be adopted.

Fiona Tiplady on behalf of Mr These comments are made to the Regulation 15 Submission on behalf of our client, Addington Holdings David Smith, Addington whom own Land off North Drive. Holdings A copy of the representation made to the Regulation 14 Submission Draft is also again attached as all of the representation comments made still stand. A copy of the promoted land in our clients ownership is contained within the Regulation 14 representation.

It is very disappointing that the comments in our representation to the Regulation 14 Submission Draft have been dismissed with because there is no appetite for carrying out additional consultations prior to the submission of the neighbourhood plan to East Herts Council.

Further, it is incorrect to say that the site has not been put forward for development at any stage in the preparation of the neighbourhood plan. Several documents which form the Regulation 15 Submission discuss the site.

It is agreed that the site is not within the current defined village boundary. However, this is not a constraint when looking for deliverable housing sites in order for the Neighbourhood Plan to provide for its existing community and the continuing vitality of that community by the introduction of appropriately Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

scaled new housing developments.

Policy VILL2 states that prior to a Neighbourhood Plan being prepared, development in Group 2 Villages such as High Cross should be limited to the built up areas. A Neighbourhood Plan can allocated land out with a village boundary. Neighbourhood Plans cannot amend village development boundaries in the Green Belt.

We agree that the development strategy of the Neighbourhood Plan should be to locate new housing development in the north area of the parish which is not designated as Green Belt. High Cross is in the north part of the Parish and land here is designated as being Rural Area Beyond the Green Belt.

We agree that open countryside between High Cross and should be protected to ensure that the settlements do not coalesce.

We object to the omission of Land at North Drive from being allocated for housing development. The land abuts the proposed housing allocation THH3. - The Green houses Site, Off North Drive. It is considered that this site is undeliverable because it is unviable. It is suggested that the site can accommodation around 17 dwellings of which 40% will be affordable. As such, it will deliver 10 market homes. The Neighbourhood Plan suggests policies which seek to provide smaller homes for those downsizing or starting a household. We strongly agree with these sentiments.

THH3 however must made North Drive to adoptable standards, including drainage and lighting before construction takes place. Therefore just 10 small homes must incur a huge cost of putting upgrading the existing un-adopted road. No financial costs will be given to upgrading North Road from the other suggested site for allocation (policy THH2 - Garden at Poplar Close) because that site only delivers one small dwelling and has to made up the access road from 30-36 North Drive to adoptable standards, including drainage and lighting before construction takes place.

Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

There is a need to add additional land and hence deliver additional dwellings to the plan in the location of these proposed allocations in order to achieve suitable development as a whole which can be delivered. The allocation of additional land next to the existing village boundaries, abutting the proposed housing allocations, can help make an appropriately scaled extension to the village viable (in terms of the additional development being able to contribute to the upgrades to North Road).

Development on this site would preserved and enhance the character of the built environment in the village and protect the significance of the heritage assets in the villages. It would provide for additional dwellings to meet the demand for those downsizing and those looking to form a household. It would provide a strategic landscaping buffer to the A10 which would provide biodiversity net gain and beneficial commuting corridors for the existing ecological network. Additional allocated land in this location will allow the existing recreational space at The Green, North Drive to be expanded into a more meaningful space for both the existing and new community. Caddick Land Objectives – Few of the objectives are considered to be positive statements of Land Use Policy THE2 – Criterion (ii) is an aspiration and not policy. It should not be policy in a neighbourhood plan to designate a Conservation Area. THH1 – The first sentence restates the District Plan only. The second sentence is an aspiration. A Green Belt boundary change should be put forward to the District Council as part of a local plan review where exceptional circumstances should be put forward. If a Green Belt boundary change is policy it would conflict with the District Plan if the plan was made. THH2 – This policy is restrictive and not positively written with regards to Housing Land Supply. The policy ignores criterion (iii) of VILL2 in the District Plan. The site should be included in the NP for housing. THH3 – The site is unnecessary and relates more to infill development (Policy THH7). In addition, the access arrangements are unclear. THH4 – There is no evidence that the site is suitable in principle or the access arrangements. No site investigations into trees, ecology or landscape impact has been undertaken. CRPE CPRE Herts supports the production of Neighbourhood Plans. It notes the Plan’s broad scope and policies, Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

the extensive local involvement and would like to congratulate the Parish and all residents on the work involved. The Plan sets out a range of polices which will helpfully guide the consideration of new development proposals as well as providing other ideas for the local villages going forward. There are many positive elements of the plan to supplement District Plan policies such as the highlighted valuable public views, green spaces, Assets of Community Value, rural exception sites and non-designated heritage assets as well as a future action plan.

CPRE Herts has a couple of suggestions for consideration that may support or be added to the proposed action plan. • One proposed action is to reduce speed through the village. Related to this could be to promote the redesign of the former A10, at present a typically highway engineered road rather than designed to be attractive or people friendly. A changed emphasis and design approach would discourage speeding, enhance the public realm for walking and cycling, the spaces around key venues like the Feathers Inn and the distinctive character of the older central areas of Thundridge, Wadesmill and High Cross. This would be a long term project but you may wish to set up a dedicated group to look into this further. The much commended document Traffic in Villages - Dorset could be a useful toolkit and reference for such a review. • Another action is to improve public transport. To assist Herts CC the Parish may wish to work with residents to highlight specific opportunities and priorities for public transport improvements for the villages in the Parish which can then be fed into a future Local Transport Plan and Passenger Transport planning. • The NP can enhance walking and cycling routes in and around the Parish. These are active elements of sustainable transport and bring multiple benefits, health, climate, air quality etc. The Green Corridor along the is identified in Policy THE8 Green Corridor policy; an extension of this to provide a longer distance walking and cycling route that connects Thundridge to the Lea Valley at is suggested. Another longer distance route for walking and cycling might be to connect to the Wodson Park Leisure Centre and the North of Ware currently subject of masterplanning. Identifying Sunday’ access only’ closures for instance could enable quieter road conditions for recreational walking and cycling. With ‘filtered permeability’ this could be along defined leisure routes, quiet lanes within the Parish. I refer to a Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

CPRE produced document Guide to Quiet Lanes. You may wish to set up a dedicated group to develop these local sustainable transport ideas.

The above suggestions would align with the objectives set out within the plan (4.3) to enhance the character of the built environment in the villages

CPRE Herts do not think it appropriate to hold up adoption of the Neighbourhood Plan but hope the above suggestions are of assistance and could be incorporated either as an amendment of Policy or within the Action Plan. Puller Memorial Primary Comments on specific policies within the plan include THH1, THH2 and THH3. School and Victoria Cutmore, M Scott Properties Ltd Both PMPS and MSP consider that TNP fails to meet the basic conditions, given the numerous inconsistencies with national policy and, TNP’s failure to contribute to achieving sustainable development. Specifically, we consider TNP fails to meet the following basic conditions: • It is not in conformity with Strategic Policies within the East Herts District Plan 2018 given it has been formulated on a misinterpretation of Policy VILL2, and, it acts to stifle any sustainable development coming forward in accordance with the District Plan; • TNP does not contribute to achieving sustainable development given it has decided to make two site allocations, unsupported by evidence as to local housing need and therefore whether these meet that. In addition, it falls foul of the social aspect in failing to recognise the issues facing PMPS now and the severe impacts of the prevention of development within the Parish on pupil numbers and the longevity of PMPS. • TNP is contrary to national policy, both the NPPF and PPG, predominantly because it is based on a lack of evidence to support the decisions made and the Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

approach taken.

Given the absence of any evidence to support the ‘identified local housing need’ to which numerous reference is made within TNP, we do not consider the two allocations are appropriate, justified, nor do they contribute to achieving sustainable development.

On this basis, the NPG should either seek to robustly identify what the local housing need is, or, altogether remove the allocations from TNP. We consider that the allocations are unsuitable, undeliverable and that it is not necessary to include them within TNP given they could come forward through strategic policies.

TNP could still be an important tool to influence the design and type of development coming forward in the Parish, including the housing mix to ensure this fits with the aims and aspirations of the Parish. In its current form, it acts to stifle any potential for sustainable development to come forward contrary to strategic policies, especially in light of EHDC’s under-delivery of housing within the District.

As set out above, we consider the choice to allocate the two sites within TNP to be little more than an attempt to undermine the aim of plan-making, and to stifle sustainable development within the Parish.

If the allocations are to remain in TNP, robust evidence is required to demonstrated that these are deliverable, viable and represent the most suitable locations for development within the Parish. It would also need to be demonstrated that the fundamental issues regarding access to these sites can be overcome.

In its current form, we consider that TNP should not be allowed to proceed to referendum without further evidence adduced to support the decisions made and the Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

policies contained therein, or, the removal of the site allocations.

In accordance with paragraph: 057 Reference ID: 41-057-20140306 of PPG and in light of the considerable deficiencies in TNP identified within these representations, both PMPS and MSP would request that the independent examination of TNP take place by oral hearing, at which we would also request to participate. JBA Planning Associates on Client is interested in land known as North Drive, High Cross. behalf of Beechwood Homes Procedural Matters – The Policies do not promote the principles of sustainable development and there is no narrative to demonstrate how the policies in the NP accords with those in the DP. THE2 – This policy fails to satisfy the basic conditions and does not meet the criteria of special architectural or historical interest to warrant designation as a Conservation Area. High Cross has no overarching character and no known problems that designation as a Conservation Area would seek to resolve. THE4 – This policy is unduly prescriptive and unhelpful. There is no evidence that is ‘the most cherished in High Cross’ and the text needs to be deleted. THE5 – The rationale for this policy is unclear. There is a lack of evidence and therefore would be implication for sustainable development. LGS9 – This land is not publicly accessible and would be incapable for recreational use. The land is surrounded by development and would be a good candidate for housing development. THE5 – The policy should be deleted. THFS1 – The policy sets out aspirations and should be deleted. This would be better set out as a project within an appendix to the NP. This policy would duplicate and potentially conflict with Policy CFLR8 in the District Plan and should be deleted. THH1 – Insufficient land has been identified in the NP. High Cross is not located within the Green Belt and there is therefore greater scope to identify further land for housing. The policy should be revised to incorporate other housing sites. THH4 – The policy is imprecise and there is no threshold provided. The policy seems unnecessary in view of Policy HOU1 of the East Herts District Plan and should be deleted. Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

THH8 – The reference to the assessment for High Cross to be designated as a Conservation Area should be deleted. Criterion (d) is unduly prescriptive and should be deleted. Environment Agency Thank you for consulting us on the submission publication for the Thundridge Neighbourhood Plan. We aim to reduce flood risk, while protecting and enhancing the water environment.

Having commented previously on this plan we are pleased to see that most of our previous comments have been taken on board.

We note that Groundwater Protection has not been included within the Plan. Thundridge Parish is partially located within a Source Protection Zone 2, where groundwater is vulnerable and is used for drinking water abstraction. Any new development would need to ensure that there are no negative impacts upon groundwater quality, and where appropriate should contribute towards the remediation of any land contamination on the site. This would be in line with Policy WAT3 (Water Quality and the Water Environment) of the East Herts District Plan 2018. The inclusion of this would strengthen the Plan.

We are pleased to see the inclusion of flood risk within paragraph 5.25. This could be strengthened by including that for any new development in Flood Zones 2 and 3a, a Sequential Test should be undertaken in order for the development to be considered appropriate in this location. Should the site pass the Sequential Test, a Flood Risk Assessment (FRA) will need to be submitted with a planning application, in line with paragraph 103 of the NPPF. The FRA must demonstrate that the development is safe without increasing flood risk elsewhere, and where possible reduces flood risk overall. This would be in line with Policy WAT1 (Flood Risk Management) of the East Herts District Plan 2018.

Further to this, we have no more detailed comments to make in relation to this Plan.

Jane Orsborn on behalf of Objection is raised to:- Mrs Cooper, Landowner a) the probability that the main housing site that has been identified (known as “The Greenhouse site off North Drive, High Cross”) will not deliver the quantum of housing proposed of around 17 dwellings; and Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

b) the failure to include land owned by Mrs Cooper sited to the rear of Canterbury Park within the defined village boundary. Land to which reference is made is verged red on the submitted location plan reference JC/01.

Hertfordshire County Council Summary - Within the document, and as evidence by the references, the Local Transport Plan has not been fully considered in the preparation of the NP. HCC consider, as Highway authority, that significant amendments to the NP are needed to align to the transport objectives set out within the Local Transport Plan and East Herts District Plan to conform to the NPPF.

In addition, HCC feel comments regarding as yet unknown archaeological remains within the parish should also be acknowledged in the NP.

Furthermore, HCC would like an acknowledgement to potential constraints both the minerals and waste sites located within the NP area could have on potential future development.

Strategic Transport and Rail Paragraph 5.40 states “The lack of public transport through the parish is a likely contributor to this number relatively high percentage” It is not obvious why public transport has been singled out as a reason for working from home, no evidence has been provided and the document itself states 91.5% of households have access to one or more cars (identified as being higher than the average for the district), implying if residents needed to travel into work they could. Working from home is becoming increasing popular and indeed encouraged by some employers for environmental and cost savings reasons. Accordingly, this statement could be misleading and should be removed.

Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

An objective to encourage sustainable transport is welcomed however, the wording of Objective H is to “encourage the provision of sustainable transport”. Encouraging sustainable transport is much broader than requiring others to provide it. This limited approach is highlighted by paragraph 5.42 stating the measures to achieve sustainable transport are included in the Action Plan at Appendix I, although none are obvious within this appendix apart from a reference to “campaign to improve the bus service”. Encouraging the use of sustainable modes is not an obvious theme within the document and should be further emphasised.

It is noted that encouraging walking and cycling by for example, new and improved routes or the use of Travel Plans is not mentioned within any of the policies and the provision of cycle parking facilities is only included in respect of Policy THFS3 for staff at existing businesses but not in relation to visitors other facilities or new development (including residential development). Cycle parking for visitors and residents would encourage and assist in decreasing car use and therefore help towards reducing traffic (referenced at Objective H, THFS7 and Appendix I) as well as encouraging people to visit by bike. Policy THFS7 (I) identifies a requirement for developers to submit a traffic assessment but the only requirement relating to sustainable modes is for this assessment to include the potential impact of increased traffic on pedestrians, cyclists and parking. The latter highlighting the stronger emphasis on car parking within the proposed plan, contrary to need to encourage less use of the private car and the polices of Local Transport Plan.

Policy THFS7 (II) is confusing stating that proposals to increase parking for employment and leisure will be supported, thereby potentially encouraging and increasing more car trips and car use as opposed to relieving traffic congestion. Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

It is also in opposition to the potential benefit of the following reference to an increase in sustainable transport provision (albeit followed by a caveat to compliance with other polices).

Paragraph 5.71 identifies existing travel patterns and low usage of public transport as reasons for higher parking standards than the EHDC SPD. However, it is entirely possible that use of public transport is low and car use high because car use is being encouraged and sustainable transport is not being facilitated or promoted. Requiring further incentives for car use by providing additional levels of facilities will be a disincentive for the uptake of sustainable transport, reinforcing the cycle of more car trips meaning a need for yet further requirements for car provision with the accompanying sustainability and environmental issues and concerns.

Policy THH9 covering vehicle parking is confusing and appears to be an incentive for increased levels of car use. As referred to above, the policy identifies levels of parking in addition to the EHDC SPD. In addition, it states the amount of parking per dwelling excludes the number of garages provided within the residential development for example, THH9(b) requires four-bedroom dwellings to have 3 parking spaces in addition to any garage provision. This is then contradicted by THH9 (f) which states there should be a presumption against any change of use of garages and parking areas for alternative uses if insufficient space remains for the parking of two cars. Implying a maximum of two spaces are actually required for any property, regardless of size. The purpose of excluding garages from the sum of parking spaces in the first in stance at (a) and (b) is unclear with (f) indicating they are not required as garage space. Likewise, the reason for the yet further requirement at THH9 (d) for all new dwellings to have space for overnight parking of light commercial vehicles, Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

on top of the high level of proposed parking in (a), (b) and (c) is also unclear and unevidenced. This approach cannot be supported as it is contrary to the Local Transport Plan. The Local Transport Plan (LTP) is available online (at https://www.hertfordshire.gov.uk/services/recycling-waste-andenvironment/ planning-in-hertfordshire/transport-planning/local-transportplan. aspx) As identified within the document, the plan is not anti-car and car use is recognised as an important part of the county’s transport system however, car usage cannot increase indefinitely and the LTP aims to facilitate and encourage the use of sustainable transport in preference to the private car. 2.8 For reference LTP Policy 1, which identifies a hierarchy is set out below. It represents a shift in emphasis to increase rates of travel by more sustainable modes, when there is a need to travel.

Policy 1: Transport User Hierarchy To support the creation of built environments that encourage greater and safer use of sustainable transport modes, the county council 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

We welcome the Thundridge Neighbourhood Plan’s inclusion of the historic environment within its policies THE1, THE2 and THE3. THE1 provides for designated heritage assets, with THE2 concerned with conservation areas, and we are supportive of both. Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

Policy THE3 refers to non-designated heritage assets. It is somewhat concerning that only a short list of primarily above ground sites is cited. This neighbourhood plan should also provide for below ground non-designated assets of archaeological interest. Should a development have potential to impact on any such remains an appropriate archaeological investigation should take place, as per NPPF para 189: “Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.” Should remains of significance be identified appropriate steps should be taken to mitigate the impact of development on the identified asset.

Thundridge parish contains within it some of the most significant unscheduled below ground archaeological remains in Hertfordshire, according to the county Historic Environment Record (HER). Cropmarks indicate the presence of a minimum of twelve ring-ditches – probable Bronze Age or Neolithic round barrows – on Burleigh Common. Significant Bronze Age, Iron Age and late Saxon remains were found during excavation in advance of quarrying to the south west of – suggesting that this part of the parish was inhabited in those periods. Ermine Street Roman road bisects the parish from north east to south west. Evidence suggestive of the presence of a Roman building, perhaps a villa, has been found at Youngsbury. High Cross and Wadesmill are both medieval villages, with Thundridge also documented in the Domesday Book, and therefore have consequent potential for archaeological remains of that date.

We would therefore strongly recommend that the wording of policy THE3 be Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

amended to provide for both known and as yet unknown below ground archaeological remains within the parish.

Minerals and Waste Planning The Introduction to the neighbourhood plan makes reference to the local and national planning policy frameworks which the Thundridge NP has been prepared within. As the adopted minerals and waste planning documents form part of the statutory development plan for the county, the county council, as the Minerals and Waste Planning Authority, would like to ask that wording be added to these paragraphs to reflect this. The adopted Minerals and Waste planning documents consist of the following: Hertfordshire Minerals Local Plan Review 2002-2016 (Adopted March 2007) Waste Core Strategy & Development Management Policies Development Plan Document 2011-2026 (Adopted November 2012) Waste Site Allocations Development Plan Document 2011-2016 (Adopted July 2014) Employment Land Areas of Search, Supplementary Planning Document (Adopted November 2015)

Waste The Adopted Waste Local Plan safeguards all operational waste management facilities across the county under Policy 5: Safeguarding of Sites. Within the neighbourhood plan area, this includes the Quarry and Landfill, its associated soil treatment facility and the Ware Household Waste Recycling Centre (HWRC). Therefore, the county council, as Waste Planning Authority, will oppose any proposals for development that would prejudice the operation of these sites. Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

The county council would like the Parish Council to note that the Thundridge NP area encompasses Allocated Site 019 Westmill Quarry and Landfill, as identified in the adopted Waste Local Plan. Allocated Sites are sites which the county council, as Waste Planning Authority, considers to be the most suitable locations to manage the county’s existing and future waste arisings during the period of the adopted Waste Local Plan (2011-2026). Allocated Sites are also safeguarded under Policy 5: Safeguarding of Sites of the adopted Waste Local Plan.

The quarrying operations at Allocated Site 019 have ceased and the last remaining void created by the quarrying activity is being filled. In January 2016 Cemex UK (the landowner) submitted an application to Hertfordshire County Council, for the variation of conditions on the time limit for commencement and restoration of the site. The application was approved in March 2018, which permitted infilling of waste at the site to cease by 31 December 2021, the capping of waste to be completed by 31 December 2022 and the final restoration to be completed by 31 December 2027.

Currently, the Ware HWRC is undergoing redevelopment and is expected to reopen as a ‘super site’ in summer 2020. The site was granted planning permission on 13/03/2018 for the replacement and expansion of the existing Household Waste Recycling Centre. HWRCs play an important role in the management of Local Authority Collected Waste (LACW) and, as a super site, the Ware HWRC will be of higher importance within the network of sites. Details of the planning application can be viewed on the county council’s planning webpages and by searching reference number PL\0862\17(https://www.planning.hertfordshire.gov.uk/). Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

4.6 The NP should make reference to these existing, safeguarded sites and ensure that the Agent of Change Principle is applied regarding any future develops in the vicinity, where appropriate.

Minerals According to British Geological Survey (BGS) data there are deposits of sand and gravel underlying a large proportion of the Thundridge NP area. The county council must be consulted where planning applications fall within identified areas containing sand and gravel deposits except for when the applications fall within the remits of the ‘excluded development list’ as identified in the adopted Supplementary Planning Document: Mineral Consultation Areas in Hertfordshire or under Policy 8: Mineral Safeguarding of the Proposed Submission Minerals Local Plan 2019.

It is understood that the developments outlined in the Thundridge NP are in line with the allocated developments identified in the East Herts Local Plan. Policy THH1- Distribution of Development, states that any development will be concentrated in the Group 2 settlements within the defined village boundaries. Site T23 is located in an area that may contain sand and gravel deposits according to BGS data. The county council, as Minerals Planning Authority, wishes to have the opportunity to comment as and when the planning application for this development comes forward.

East Herts District Council – Policy THH3 – The Greenhouses site, off North Drive, High Cross Housing Development & Page 46 under Policy THH1 – Distribution of Development it states (up to 20 dwellings)- and on page 49 Strategy indicates 17 dwellings please could you clarify if 17 or 20? Policy THH3 – (b) 40% of the units shall be affordable with priority for starter and retirement homes We would expect the affordable housing split to be 84% affordable rent and 16% intermediate of the Summary of Responses to the Thundridge Neighbourhood Plan (Regulation 16 Consultation) Organisation Summary of Comments

affordable housing with our preference of shared ownership Page 50 – Affordable Housing 5.62 “Policy HOU3 is therefore likely to have limited application in the Parish of Thundridge” HOU3 will have an application if 40% will be affordable in accordance with Policy THH3.