We hope that most of our members have sent in their individual comments to Stevenage BC. Officially the deadline is/was Nov 7th but we expect that any sent soon after have a good chance of being included so don't give up - do it soon.
Our FoFC objection has been submitted and is reproduced below
LACK OF SUSTAINABILITY OF DEVELOPMENT
Bearing in mind Stevenage Borough’s (SBC) motion of June 2019 declaring a Climate Emergency and its consequent aim to be greenhouse gas (GHG) net zero by 2050 and also the Government’s declaration of Climate Emergency and its aim to be GHG net zero by 2050 the construction of 800 houses on this site will act in the inverse direction to these aims as their construction will generate 64,000 tons of GHG (80 tons per house) and their occupation will generate 12,000 tons annually into the distant future (1.2 million tons per 100 years). This latter factor is expanded under Lack of Sustainability of Dwellings below.
As giving planning permission is an act of SBC then any GHG emissions that result from that act count towards the net emissions of SBC and are therefore subject to the terms of SBC’s Declaration of a Climate Emergency and the aims thereof and must be declared in the SBC public report on annual CO2 emissions.
The above amounts derive from a Historic Scotland study that a two-bed cottage generates 80 tons of GHG in its construction.
The annual GHG production figure stems from a total UK figure of 400 million tons of CO2 equivalent divided by the 2016 ONS UK household number of 27.5 million, giving 14.4 tons average per UK household annually.
The National Planning Policy Guidance states:- Addressing climate change is one of the core land use planning principles which the National Planning Policy Framework expects to underpin both plan-making and decision-taking. To be found sound, Local Plans will need to reflect this principle and enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework.
Addressing climate change implies a need for lower GHG emissions. This application has the direct opposite effect and is unsustainable.
A definition of sustainable is given in the NPPF ‘Achieving Sustainable Development’ which states :–
International and national bodies have set out broad principles of sustainable development. Resolution 42/187 of the United Nations General Assembly defined sustainable development as meeting the needs of the present without compromising the ability of future generations to meet their own needs.
The UK Sustainable Development Strategy ‘Securing the Future’ set out five guiding principles of sustainable development the first of which requires living within the planet’s environmental limits to ensure that the natural resources needed for life are unimpaired and remain so for future generations.
The development of this site will speed up a Climate Emergency as a consequence of its inherent GHG emissions and thus will compromise the ability of future generations to meet their own needs as required in resolution 42/187 above.
In addition, this development acts in the direction of exceeding the planet’s environmental limits as determined by UNGA Resolution 42/187.
We point out that at the SBC Local Plan Consultation and Hearing the GHG emissions of this development were not considered. If they had been it is most likely the Plan would have been declared ‘unsound’ for the reason of being ‘unsustainable’ as described above with the likely result that the Green Belt status of this site would not have been removed.
THUS, THIS APPLICATION IS NOT SUSTAINABLE
In addition and in particular this application breaches NPPF 2019 in the following paragraphs:-
Para 7) The purpose of the planning system is to contribute to the achievement of sustainable development. The objective of sustainable development can be summarised as meeting the needs of the present without compromising the ability of future generations to meet their own needs.
Para 8c) an environmental role, to contribute to protecting our natural environment including making effective use of land, helping to improve biodiversity, using natural resources prudently, minimise waste and pollution, and mitigating and adapting to climate change including moving to a low carbon economy.
Para 9) Planning policies and decisions should take an active role in guiding developments to sustainable solutions.
It should also be noted that this site was improperly removed from the Green Belt. The 2012 NPPF para 79 is clear that Green Belt status is permanent. The decision of the Planning Inspector ignored this clear point.
This Application is in breach of NPPF 2012 and 2019 as above
BROWNFIELD SITES AND PREVIOUSLY DEVELOPED LAND
We wish to make it clear that we consider that developed sites in Stevenage could be made available even though they do not appear on the register of previously developed sites.
FoFC have reviewed the SBC Brownfield Land Register. It is noted that the total area is 77.87 hectares and that 66% of this previously developed land is a single Town Centre site.
The following NPPF paragraphs should be read in the context that the application site HO3 is greenbelt.
Para 117 of the 2019 NPPF states:- Strategic policies should set out a clear strategy for accommodating objectively assessed need in a way that makes as much use as possible of previously developed or brownfield land.
Para 118c giving substantial weight to the value of using suitable brownfield land within settlements for homes etc
Para 118d promote and support the development of under-utilised land and buildings, especially if this would help to meet identified needs for housing where land supply is constrained etc.
Para 119 states:- Local planning authorities, and other plan-making bodies, should take a pro-active role in identifying and helping to bring forward land that may be suitable for development needs, including suitable sites on brownfield registers, etc. This should include identifying opportunities to facilitate land assembly, supported where necessary by compulsory purchase powers, where this can help to bring more land forward for meeting development needs and/or secure better development outcomes.
FoFC contend that this has not been done to a sufficient degree
There are several previously developed sites within Stevenage which could be redeveloped to take most of the OAN of 800 houses in this application.
The Icon Building (about 27 hectares) has been under consideration for at least 2 years. The Matalan site in the Town Centre has already been proposed to take 526 new homes. The Leisure Park to the west of the railway station is also under consideration for re-development to include homes. This site is 12 hectares. The Tesco and Asda car parks could be made multi storey and would free up 3 to 4 hectares. All round these sites could release around 40 to 50 hectares which would provide space for 1800 dwellings at the reasonably low figure of 40 dwellings per hectare
This application has the effect of destroying precious Greenbelt land whilst use of alternative sites has not been properly considered.
This Application thus contravenes NPPF requirements.
OBJECTIVELY ASSESSED NEED
This Application has been made in the context of the SBC Local Plan which was written in very different circumstances. At that time population growth in Stevenage between 2011 and 2031 was assessed by the Office for National Statistics as 10,994 representing a 13% increase. The Office for National Statistics is now predicting growth of 10.7% over the same period and the growth curve is trending downwards.
This reduction in growth is about 17% percent. At high level this represents a reduction in need for dwellings at about the same proportion. Thus the overall dwelling increase figure for Stevenage would fall from 7,600 to 6,255, a reduction of 1,345. Such a reduction would obviate the need to remove virtually any Greenbelt from Stevenage. The NPPF states that The Government attaches great importance to Green Belts.
We believe that to continue with a Plan that allows destruction of Greenbelt when the rate of increase in required dwellings is falling is wrong and that it contravenes the NPPF.
This Application thus contravenes NPPF requirements.
NPPF Paras 122 and 123 dictate the need for building at high density where there is an anticipated or existing shortage of land.
At a housing density of 100 dwellings per hectare (dph), which is well below that envisaged for the Icon building only 8 hectares would be required for 800 dwellings.
The Matalan site in the Town Centre has already been proposed to take 526 new homes. The Leisure Park to the west of the railway station is under consideration for re-development to include homes. This site is 12 hectares. Two hectares alone could accommodate 200 to 400 homes. The Tesco and Asda car parks could be made multi storey and would free up 3 to 4 hectares giving a further 300 to 800 homes depending on density and extent of release.
This Application is breach of NPPF 2019 as described above.
Impact on the St Nicolas / Rectory Lane Conservation Area, its setting, and the setting of Rooks Nest House
The St Nicholas / Rectory Lane Conservation Area was expanded in 2007 to include part of the area known locally as ‘Forster Country’. The western boundary of the Conservation Area is the footpath that follows the top of a high ridge of land between Rooks Nest House and the open land that looks out to the Chilterns in the west and to Rooks Nest House in the east. This footpath affords users an appreciation of the setting of Rooks Nest House and enables any member of the public to enjoy the same view of the distant Chilterns shared with the house, and described in the novel Howards End:
‘The whole clan's here now--it's like a rabbit warren. Evie is a dear. They want me to stop over Sunday--I suppose it won't matter if I do. Marvellous weather and the view's marvellous--views westward to the high ground.’
‘The great estates that throttle the south of Hertfordshire were less obtrusive here, and the appearance of the land was neither aristocratic nor suburban. To define it was difficult, but Margaret knew what it was not: it was not snobbish. Though its contours were slight, there was a touch of freedom in their sweep to which Surrey will never attain, and the distant brow of the Chilterns towered like a mountain.’
‘They opened window after window, till the inside, too, was rustling to the spring. Curtains blew, picture-frames tapped cheerfully. […] She admired the view. She was the Helen who had written the memorable letters four years ago.’
Building within the Conservation Area (on parcel E) and immediately to the west (on parcels D2, B2, C2 and C3) will obscure these views both from Rooks Nest House and for the users of the footpaths that follow this ridge of land, causing substantial harm both to Rooks Nest House and the Conservation Area, and their setting. The view from the house out to the Chiltern ridge is symbolic of one of the central themes of the novel, which seeks to reconcile intimate, domestic and personal relationships with connections to the wider world. This theme of the novel is also recognised in the ‘Only Connect’ sculpture at the entrance to Forster Country from St Nicholas churchyard, at precisely the point where the landscape begins to open out. The loss of this view will cause substantial harm to the Conservation Area and to users of the footpaths along this ridge. It will also cause substantial harm to the setting of Rooks Nest House, making it no longer possible to appreciate the view described in the novel.
We are in agreement with Historic England’s comments in their letter commenting on the original application, that:
‘the topography of the proposed development site means that Parcel E, the development within the conservation area, and that outside its boundary in its setting, will have a considerable harmful impact on the character, appearance and significance of the conservation area and its setting, and on the setting of the listed buildings within the conservation area, given the historic interest set out above. It will considerably erode or destroy the open character of the landscape as appreciated visually and spatially today. It will disrupt the long-distance views and diminish the sense of open space it is presently possible to enjoy, and therefore either weaken or eradicate the ability to appreciate the listed buildings and conservation area within their setting. In so doing, it would fundamentally erode and diminish the sense of rural place that, despite the encroachment of modern Stevenage, has remained remarkably intact in this location.’
This application if adopted would cause significant harm to the conservation area and should be rejected.
Forster Country as a Heritage Asset
The NPPF defines a Heritage Asset as a ‘building, monument, site, place, area or landscape identified as having a degree of significance meriting consideration in planning decisions, because of its heritage interest. It includes designated heritage assets and assets identified by the local planning authority (including local listing).’ (NPPF, 2019). Assets identified by the local authority are referred to as ‘non-designated Heritage Assets.’ Applicants are required to describe the significance of all Heritage Assets (designated and non-designated), including the contribution made by setting, and the effect of the application on the significance of the Heritage Asset should be taken into account in determining the Application. Stevenage Council currently does not have a local list of non-designated Heritage Assets. The Council has recently invited residents to nominate buildings for local listing. But Heritage Assets can also include monuments, sites, places and landscapes (NPPF 2019). Forster Country is a landscape valued by local people for its connection with the writer E M Forster – such a connection is described as a historical value - and the network of footpaths which cross it also have communal value. Historical and communal value has weight when determining the significance of Heritage Assets, and indeed are recognised by the Council as one of the aspects to be taken into account when determining the significance of buildings on the local list. The significance of Forster Country is demonstrated by being included by name within the recently adopted Local Plan. We can see no reason why the Council would confine itself to buildings for a local list and believe that the local list should be expanded to cover monuments, sites, places and landscapes. None of the Heritage Impact Assessments undertaken to date have considered the impact of the proposals on Forster Country as a Heritage Asset in its own right, but only as part of the setting of the designated assets. We believe that Forster Country should merit consideration as a Heritage Asset when determining the impact of the proposals.
This application if adopted would destroy Forster country as a heritage asset and should be rejected.