1. Art and Diseño

Kings Walden Parish Council
Response to the NHDC Local Plan Preferred Options Consultation, January 2015
Dear Sir
Please see below Kings Walden Parish Council’s response to the NHDC Local Plan Preferred Options
Consultation.
Plan Ref
1. Introduction
2. Vision and Objectives
Policy SD1
3, Economy and Town
Centres
Policy ETC1:
Employment Land
ETC2
ETC3
ETC4
ETC5: Tourism
ETC6
ETC7
ETC8
ETC9
ETC10
ETC11
Comment
The parish council recognises the complex balance between housing need and
protection of the environment, especially Green Belt. The parish council
acknowledges the thorough research that has gone into producing the plan.
The parish council acknowledges the provisions of the NPPF and agrees the
plans interpretation of the provisions therein.
The parish council agrees that all development must be sustainable. This
implies the necessary infrastructure must in place at the time of development
and believes developers must not be allowed to delay the provision of
infrastructure. In many cases this means infrastructure must lead
development and arguments regarding viability must not be allowed to skew
the need for infrastructure.
As most residents of the parish work away in towns in Hertfordshire or
Bedfordshire or commute to London, the parish council recognises the need to
invest in the towns. However, this must not be allowed to syphon money away
from the rural community.
There is little employment land in the parish. The parish council looks to the
local plan to encourage the rural economy, making use of for example,
redundant farm sites as centres of small scale employment. Home working is
also an essential part of modern rural life and the delivery of broadband to the
parish is an essential part of creating a sustainable rural community.
Policy ETC1 should give greater recognition to the requirements of rural
employment including mobile and broadband coverage.
Policy supported
Policy supported
Policy supported
Tourism is under invested in North Herts. The parish of Kings Walden offers
some of the most beautiful countryside and the local plan should make greater
benefit of those and not pout the natural beauty at risk. The historic road
infrastructure is part of this heritage and development must only be permitted
where the existing infrastructure is not damaged. The parish council supports
para 3.30 in this respect.
Rural bus services need to be supported which may require subsidy to
encourage tourists such as walkers.
Rural residents use town centre facilities and this policy is supported
No comment
No comment
Policy supported
No comment
The parish council welcomes the support for new shops in existing
communities. The plan should go further by offering business rate relief to
shops serving a community of less than 500 houses.
Countryside and green
belt
CGB1
CGB2
CGB3
CGB4
CGB5
T1: Transport
T2: Parking
HDS1 Housing targets
Kings Walden parish lies wholly within the greenbelt and so this part of the
plan is critical to the parish.
The parish council welcomes the extension of the green belt to include the
additional area between Luton, and Hitchin.
Policy supported
The parish council recognises the need for affordable housing in villages and
supports policy the rural exception policy CGB3.
The parish council is concerned that developers may seek to take advantage
of the apparent loophole for market housing cross subsidizing. Affordable
housing does not equate to no profit and any such claim by a developer must
be robustly analysed and proven. In particular any cross subsidy must be in
the immediate vicinity; it would not be acceptable for market housing in one
village to cross subsidise affordable housing in another location.
The parish council acknowledges the need of some rural businesses to
provide accommodation for rural workers. However, it is known that this
policy has historically been abused. The initial use of temporary dwellings is
supported. The conversion of unused agricultural buildings should be
prioritised over new build. Any housing built under this policy should, if the
rural worker use is no longer relevant, be converted to Affordable Housing
and reserved for those with a local need and not be allowed to leak onto
the open market.
While Policy CGB5 is sensible for single buildings any such development must
take into account sustainability. If not, this policy could lead to substantial
new housing without the concomitant infrastructure.
However, all policies need to be pragmatic and take into account the needs
of the 21st century including the use of modern materials and the upgrading
of old buildings.
While in an ideal world, the use of “sustainable transport” would prevail in it
inevitable that any rural development will require the use of the motor car to
access shops, medical facilities libraries and leisure. Cycling along rural lanes
is not a safe alternative and it is unrealistic to plan for even the current level
of public transport. Sustainable transport therefore must not be allowed to
stifle development and condemn rural locations to dwindle into
unsustainability.
The use of on call mini-buses should be investigated, where communities can
set their own, flexible timetables.
Time has proven that lack of parking provision is not effective ion reducing
the quantity of private cars. As the average age of a house buyer increases,
the number of car per household is likely to exceed the number of bedrooms.
In the rural areas any visitors will inevitably use private motor cars. As such
any new development must have at least a ratio of 1.5 parking spaces per
bedroom. Roads on new estates must be designed to permit a degree of
roadside parking. This may require wider roads and/or frequent laybys. To
control unsafe parking, all new development should have traffic regulation
orders preventing junction parking (using double yellow lines) and should be
zoned to ban pavement parking.
Housing need projections have little basis in fact. Historical trends are often if
not usually distorted by many factors such as the economy, birth rates,
East of Luton
HDS2
Suggested village
boundary Ley Green
immigration, migration, all of which are dynamic. As such, any plan must be
capable of variation. In practice houses will only be built if they can be sold.
To this extent housing numbers set by the LPA are meaningless as the LPA is
not a developer. It is unlikely that the market can absorb the numbers
proposed. To do so would require more building than has ever been achieved
in Hertfordshire and for a sustained 2o year period. In practice the market is
unlikely to absorb more than 600 houses per annum peak and so a figure to
2031 of 12,000 will not be achieved (as we are already behind plan by nearly
1000 units). The second issue with these numbers is that the price of housing
will be preventive for Hertfordshire first time buyers and so will inevitably
draw in migration from London.
The parish council believes that the land East of Luton is unsuitable for
development and that land to the west is much more sustainable
proposition. By allocating land in North Herts, the LPA is avoiding the need of
developers to prove their case. Better to risk hostile applications which place
the onus on the developer to make the case and where it can be tested at a
tribunal.
Breachwood Green is designated a Category A village. The definition of a
category A village simply states that it should have a school. But to be a
sustainable village requires more than just a school. A whole range of
facilities (at the very least, a food shop) should be required. The list of villages
designated category A is too long and should be further divided into those
that have a wide range of facilities and those that do not. Ironically the
requirement for villages with minimal facilities is larger development in order
to stimulate the infrastructure and make facilities such as shops viable.
The assumption in HDS2 is that all parishes should take some development
but that it should be in the category A part of the parish. This is to the
detriment of the rest of the parish.
We note that Kings Walden is not listed but in Chapter 12 it is stated as being
a category B village. Why the inconsistency?
As the more rural settlements already make use of the central facility (e.g.
the school) it does not seem unreasonable to allow some development
elsewhere within the parish.
The parish council therefore suggest s that Ley Green is given a village
boundary.
Breachwood Green
Village Boundary
The proposed village boundary goes some way to resolving the issue that the
current development is unusual shape and excluded much of the built
environment. However, the new boundary still excludes much of existing
housing at the north. The parish council has previously expressed support for
a more radical changes to include Darley Road, Windmill Road and Mill Way
as per the map below:
Your proposal
HDS3 Affordable
Housing
HDS4 Density
HDS5 Relatives’ and
dependants’
accommodation.
HDS6 Gypsies and
travellers
Our proposal
The general provisions of policy HDS3 are welcomed. However, it is not
unreasonable that development so less than 10 dwellings should make some
contribution to affordable housing albeit by money collected via a S106
agreement.
It should be a firm policy that the affordable housing should be co-located
with and integrated within the market housing and that to the casual
observer there should be no discernible difference between the two, The use
of commuted sums to fund housing on a remote location is not acceptable.
The policy omits any mention of height. The way to increase density without
increased land take is to make more use of basements and loft spaces. All
new houses should be designed with at least 2.5 storeys. This should not just
be restricted to towns. Historically many village houses had attic rooms.
Basements make better use of land without increasing the visual impact.
Developments should achieve a balance of maximising height while not
detracting from the visual street scene.
The parish council supports this policy but questions the need for point 4.
Rural areas should be treated the same as urban areas.
The policy is too specific. The site at Pulmer water is a single (albeit
extended) family site and is not available to gypsies or travellers from other
families.
The parish council notes that point 2 species that residents must have access
to local shops but notes that this restriction is not being applied to other
types of development: many villages do not have access to a shop (e.g.
Breachwood Green.).
The policy should also state that the same planning considerations will apply
to gypsies and travellers as to the general public.
D1 Design and
Sustainability
D2 House
Extensions and
Replacement
dwellings
D3 Protecting living
conditions
D4 Air quality
HC1 Healthy
communities
HC2 Green space
NE1 Landscape and
Environmental
Protection
NE2 Green
Infrastructure
NE3 Biodiversity
NE4 Renewable
energy
NE5 sustainable
water supply
NE6 Flood risk
Chapter 12 Kings
Paragraph 7.13 states that “cars should not be a dominant feature at new
developments”. History has shown that placing car parking at a distance or to
the rear of a property does not work. All development, especially in rural
areas where a car is a necessity must have off road parking and roadside
parking restrictions. Use of garages for cars cannot be enforced and
conversion of garages cannot be prevented. Therefore garages should not
count towards parking provision.
New housing developments need to be integrated into existing communities.
As such, cul-de-sacs estates with a single access point and gated communities
should be discouraged.
Paragraph 7.17 is unrealistic. The market will decide on the need for
expanded houses and where the curtilage allows larger extensions I rural
areas should be permitted. Many rural dwellings are small relative to the
plot; this is poor use of land. Paragraph four of the policy regarding isolated
rural location is unnecessary and unnecessarily restrictive.
Pitched roofs may have a pleasing visual appearance but can be poor use of
space. Flat roofs, disguised behind dummy pitched roofs should be
encouraged.
The parish council supports the restriction on building up to the boundary
but this should also apply to single storey extensions.
Replacement of dwellings in rural areas with larger properties should not be
restricted. Such development can be crucial to the sustainability of rural
communities.
No Comment
Policy is supported
Policy is supported
All developments where children are likely to live should include safe, well
designed play areas. In parished areas, a commuted sum should be paid to
the parish council for the ongoing maintenance and upkeep of play areas
with a legal obligation to maintain the equipment in perpetuity.
Policy is supported
Otherwise, policy supported.
Policy is supported
Greater emphasis should be placed on point 1. Renewable energy proposals
that have a detrimental impact on the country side (such as wind and solar
farms) should be resisted, despite the energy benefits. Biomass may be a
more suitable use of land to fulfil the renewable energy remit.
New developments should incorporate solar power cells into the roof as part
of the design.
This policy should be strengthened. The use of grey water (not rainwater) for
flush toilets should be mandatory. Rainwater recycling is a useful supplement
but the amount of rain is insufficient to cover the costs of such systems.
In rural areas, efficient waste disposal can be made using modern technology
without the need for mains drainage, which requires large amounts of water
to transport waste over long distances. Renewable energy plants utilising
waste should be encouraged.
Policy is supported
The parish council notes the site would deliver 2 affordable units. The
Walden
housing needs survey determined a need for 12 units and so by implication
10 units would need to be delivered under the rural exceptions policy.
NE7 Water quality
and environment
NE8 Water
Framework
NE9 Contaminated
land
Policy is supported
HE1 Heritage
ID1 Developer
contributions
ID2 Master plans
Part 1 Kings Walden
Part 2 Cockernhoe
Part 3 West of A1M
Policy is supported
Bringing contaminated land back into use is important. Consideration should
be given to reducing S106 obligations where the viability of a scheme is
threatened.
The parish council recognises the need to manage the historical estate.
However, this must be balanced with the need to live in the 21st century and
sympathetic development and the use of modern material must be
permitted.
Viability calculations should be reassessed at the completion of a scheme as
well as at planning. Where the sale price of units exceeds the planned sale
price, any reduction in planning obligations should be reversed.
No comment
The parish council supports the proposal for KW1.
The parish council objects to the proposal to develop land at Cockernhoe and
to incorporate the villages of Cockernhoe, Tea Green and Mangrove Green
into an eastern extension of Luton. The parish council believes that Luton’s
needs can be met by development west of Luton. Any development to the
east would never provide the infrastructure necessary. Traffic from any new
development would try to find ways out through the narrow lanes of rural
North Herts and would have significant impact on the parish of Kings Walden.
Should it prove necessary to develop east of Luton, for Luton’s needs, Luton
Borough should pay for nomination rights to any affordable housing.
Questions have been raised as to the land value and the LPA has indicated
that CIL could be set at a lower level for this area due to proximately to
Luton. This is a fallacy; the uplift in land value (planning gain) from farmland
to housing would be ample to provide S106 or CIL obligations.
Should it prove necessary to develop west of Stevenage, for Stevenage’s
needs, Stevenage Borough should pay for nomination rights to any affordable
housing.
Questions have been raised as to the land value and the LPA has indicated
that CIL could be set at a lower level for this area due to proximately to
Stevenage. This is a fallacy; the uplift in land value (planning gain) from
farmland to housing would be ample to provide S106 or CIL obligations.