Representations for Housing Options Growth Levels and Locations 2011-2031 Ref. Rep No. Applicant Agent LDF/0025 29 Sustainable Places ,Environment Agency Document Section: South West of Hitchin Comment Representation: The site is underlain by complex superficial (some secondary aquifers) and chalk bedrock (principal aquifer). The depth to chalk is variable. Groundwater depths are variable too due to size of site. There would be the potential for SuDS given the geology but this would need to be supported by a Preliminary Risk Assessment (PRA). Landfills exist on-site as do Source Protection Zones (SPZ) zones 1-3. This is a potentially sensitive site in places. The site is underlain by complex superficial (some secondary aquifers) and chalk bedrock (principal aquifer). The depth to chalk is variable. Groundwater depths are variable too due to size of site. Landfills exist on-site as do SPZ zones 1-3. This is a potentially sensitive site in places. The site borders Oughton Head Common on the wetland sites eastern and southern boundary. The site is groundwater dependant-hence any disturbance of the aquifer in the vicinity has the potential to impact on the wetland. SUDs may well not be appropriate over the whole of the proposed south west of Hitchin site. The site borders a major Public Water Supply (PWS) at Oughton head (situated just north of the development). It also intercepts SPZ1 and 2 for this Source. The site includes a major PWS source in the wellhead vicinity (and associated SPZ 1 and 2) In the vicinity of wellhead/Charlton groundwater levels are very close to the ground surface and in some places where a confining layer exists are known to be artesian. One implication of this is the suitability of SuDS drainage. Fluvial Flood Risk The sites 'Land South-West of Hitchin' and 'Rush Green' are located partly within Flood Zones 2 and 3. Ideally no built development will be situated within Flood Zone 3, however where the sequential (and where necessary the exceptions tests) have deemed this necessary a sequential approach should be taken to the layout of the development to ensure that any 'less vulnerable' developments are situated within the flood risk areas (Please note that in accordance with the National Planning Policy Framework, no development will be permitted within the functional floodplain). Development will also only be permitted where it can be shown that the development does not increase the risk of flooding elsewhere. It should be noted that the identified flood risk at both site locations is associated with 'Non-main River'. In the absence of detailed hydraulic modelling, the development of either site may require further investigation in order to ascertain modelled flood levels and to determine the extent of the functional flood plain associated with each watercourse. Surface Water Drainage A surface water strategy should be carried out to demonstrate that the proposed development will not create an increased risk of flooding from surface water. The surface water strategy should be carried out in accordance with the National Planning Policy Framework and the PPS25 Practice Guide, giving preference to infiltration over discharge to a watercourse, which in turn is preferable to discharge to surface water sewer. For Information - After April 2014 it is anticipated that SuDS Approval Bodies would consider the adoption and maintenance of sustainable drainage assets. This process will be subject to the details described in the Defra commencement order due April 2014. We would advise that early consultation is held with the Lead Local Flood Authority (Hertfordshire County Council) prior to the development of any surface water drainage strategy. In the interim, Hertfordshire County Council have produced an 'Interim SuDS Policy Statement', which states how development will meet SuDS standards in Hertfordshire. Development should be in line with this statement. 4. Water Framework Directive The Water Framework Directive (WFD) came into effect in 2000 and became law in 2003. It recognises that development near water bodies can affect their quality and ecology. WFD established a legal framework for the protection, improvement and sustainable use of the water environment. For planning purposes the framework means that developments affecting any water body will be expected to contribute towards delivering benefits towards WFD objectives. This may include incorporating SUDs and green infrastructure into new developments and/or de-culverting, restoring, re-profiling or naturalising river banks to promote natural flows and improve habitats. 5. Biodiversity This site includes a SSSI and several county wildlife sites as well as the headwaters of the Rivers Hiz and Oughton and Ippollits and Ash Brooks. All of these sites and their associated wildlife will be sensitive to the impacts of development with the potential for damage to occurr. Numerous public rights of way cross the site, developemnt would affect their use.In addition there may be adverse impacts on wildlife associated with agricultural land. Printed: 28/06/2013 09:12:56 Representations for Housing Options Growth Levels and Locations 2011-2031 Ref. Rep No. Applicant Agent LDF/0027 46 The Chilterns Conservation Board Document Section: South West of Hitchin Comment Representation: The Board is concerned that for the possible strategic site to the west and south west of Hitchin no real account has been taken thus far of the likely implications for the Chilterns AONB and its setting. The site area occupies all of the land between Hitchin and the Chilterns AONB with no break at all. The Board considers that the area to the east of the AONB should either be excluded from the strategic site or specifically excluded from the developable area due to both the site's proximity to the AONB and the sensitivity of the landscape. Furthermore, any bypass route should be located wholly outside the AONB and should start at a point to the east of the AONB boundary where it meets the A505. The text mentions an alignment that might follow the pylons that run to the south of Gosmore. Following this route would bring any road much closer to the AONB and would be likely to impact on a sensitive area of countryside to the south of the A505. A full landscape character and visual impact assessment should be undertaken to feed into the preparation of any future document. It is understood that the Council has instigated the undertaking of some landscape character work in this area and this should clearly feed into the consideration of this site and any bypass. The area to the south of the A505 is high quality, sensitive landscape that may well be worthy of designation as part of the Chilterns AONB should a review of the AONB boundary ever take place in the future. LDF/0034 27 Dimsdale Phillips Planning Services Document Section: South West of Hitchin Comment Representation: This site could in theory deliver between 6,000 and 7,400 new homes. However, it is noted that the site promoter does not own all of the land and has options with only some of the landowners. If this site were to be seriously considered the deliverability of it would need to be investigated fully and assurances in the form of signed agreements provided to demonstrate that all landowners are on board. It seems likely that a development of this scale would take at least 3 ¿ 5 years from adoption of the plan to actually start delivering completions. Therefore if a first build year of approximately 2018 / 2019 were assumed with say 100 in the first year then 200 building up to an average (Buchanan Study) of 330 thereafter the most that could be assumed off this site would be approximately 3,500 by 2031. This assumes that average build rates of 330 could be achieved for a significant period. We submit that given the relatively small scale of Hitchin and its housing market that the market itself is unlikely to absorb this many completions on a strategic site west of the town? LDF/0053 7 Luton Borough Council - Environment and Regeneration Document Section: South West of Hitchin Comment Representation: Of these strategic sites, the key proposals that affect Luton directly are:- South-west of Hitchin (appendix 2) encompasses 442 ha that would straddle the A505 and extend as far as Oughton Farm to the north and Wellhead Farm to the south. The scale of this development would include neighbourhood centres, schools, employment land and a southern bypass linking the A505 to the A602 Wymondley bypass. The proposal for the major strategic development to the south west of Hitchin would have both benefits and drawbacks for Luton. On the plus side it would dramatically improve road access to Luton from the east, delivering a continual dual carriageway road on to the A1 (M) and beyond. Luton would also welcome the opportunity that such a scheme might offer to provide for the needs of Luton residents which cannot be delivered within Luton. However, on the negative side, the improved road access will undoubtedly put additional traffic pressure onto the A505 within Luton which is already suffering from severe congestions during peak periods. LDF/0079 31 Herts & Middlesex Wildlife Trust Printed: 28/06/2013 09:12:56 Representations for Housing Options Growth Levels and Locations 2011-2031 Ref. Rep No. Applicant Agent Document Section: South West of Hitchin Comment Representation: This is an incredibly large site, and the number of houses proposed (6000-7400 homes) would constitute a significant and quite disproportionate increase in the size of Hitchin. There will also be issues of coalescence with surrounding settlements (eg. Charlton, Gosmore, St Ippolyts). Within the proposed strategic site is Oughtonhead Lane SSSI, which is designated based upon its geological interest.