Objections

The following issues were the main focus for objections in the 2018 proposal:

Alignment with NHDC Proposed Submission Local Plan

The proposed site for the development is not one of the sites identified for development in the Proposed Submission Local Plan. The Inspector was planning on conducting further Examination Hearings locally in March 2020 however this has been postponed due to the coronavirus emergency. When it is finally adopted by NHDC then this will provide a very strong case for refusing the development. Regardless of the current status of this plan the proposed site for this development is outside existing and future settlement boundaries in a location not tested through either the existing or proposed Local Plan.

Loss of Countryside and Open Views

This was raised as a key concern within the NHDC pre-application letter issued to Gladman prior to the Outline Planning Application in 2018. The application letter refered to the Scarp Slopes South of Royston 228 (Doc 228) produced to inform the North Herts Landscape Study (2011), both undertaken to inform the Proposed Submission Local Plan. It is these documents we are asking you to refer to in your objections – to quote: “…the openness, lack of development (particularly in the west) and the history of this character area make it almost unique in the county. Scarp provides a vantage point for long distance views over Royston to the north” (and hence this area can be seen as a landscape feature from the north as well).

Gladman produced a Landscape and Visual Impact appraisal in support of the site. Within this document it acknowledges the site will have major adverse impacts to the immediate surrounding area without any mitigation proposed; and with mitigation there is still an adverse impact which only reduces to moderate after 10 years, at best.

We contacted a Landscape Architect who was recommended to us, this individual has visited the site and stated that: “In my view there would likely be significant adverse landscape and visual effects from the development on this site – it’s an attractive piece of landscape and the houses would rise up the hill and be locally very visible.” The Landscape Architect made it clear to us that this should form a significant part of the case against the development to be made by the council – we have contacted the council on this but have not had much feedback. Please consider raising this point in your objections.

Impact on Briary Lane, Sun Hill and junctions with Baldock Road and the A10

There was no mention by the Highway Officer on the poor access of Briary Lane and the Briary Lane/Baldock Road junction serving over the recommended number of dwellings, as highlighted in their own planning guidance document (see Roads in Hertfordshire – A Design Guide which states that not more than 300 dwellings…should be served from a single point of access to the wider road network).

We have produced a letter informing Hertfordshire County Council (HCC) on their duties as the highway authority to ensure policy is being adhered to and raising the safety issues of Briary Lane and the junction from Baldock Road. We request residents still also raise any concerns with the proposed access and make reference to HCC policy and the National Planning Policy Framework (NPPF). Based on traffic figures used to support the Air Quality Impact assessment in support of the development in 2018 it showed the increase in the number of vehicles using Briary Lane is estimated as 600 vehicles over just a 24 hour period. This is of concern for all users of this road and also pedestrians who currently access the Heath at the top of Briary Lane and Sun Hill. This will also lead to a greater use of the exit at the bottom of Sunhill to the A10, and potentially a greater number of illegal right turns on to the A10 from vehicles trying to avoid the one-way system.

Other points to consider:

• Existing on-street parking on Briary Lane creates a one-way flow of traffic and potential restrictions to emergency vehicles;
• Emergency access is already and issue and proposed site will put further numbers of future residents also at risk;
• Concern with proposed sustainability of site in transport terms for pedestrians to walk to rail station, and cyclists due to distance and gradient of the proposed access road;
• Distance to local bus stops too far to be sustainable (see Roads in Hertfordshire – A Design Guide which states that all occupied parts of a development should be within 400m of a bus stop). NHDC have proposed a bus stop at the top of Sun Hill for this although it is not clear exactly where; and
• No reference within the Transport Assessment on the amount of construction traffic, access for this traffic and potential conflict with existing road users.

Source Protection Zone

The proposed development site sits above a Major Aquifer which supplies much of the water for Royston. This site, plus some small existing residential areas within proximity to Therfield Heath and a large part of the heath itself are classed as Source Protection Zone 1, whereas most of the rest of Royston has a lower classification.

Groundwater within this location is extremely vulnerable to contamination from substances which are able to pass rapidly through the thin soils and the natural fissures (cracks) in the underlying chalk rock to the groundwater. This makes this an extremely vulnerable site to develop both in the long term and the short term, as potable supplies would be at risk from activities at this site.

A letter was issued to the Planning Officer on 12th April 2018 raising a series of concerns about the lack of risk assessment undertaken at the site to ensure the protection of the aquifer and local groundwater supplies. We also received a letter from the Environment Agency stating a risk assessment would be required for this site.

Therefore Gladman need to show the necessary risk assessments in accordance with the Environment Agency Groundwater Protection Policy have been undertaken – if they do not, this is justifiable grounds for refusal. If the risk assessments show the discharge of highway runoff and open spaces does pose a risk an alternative method for drainage will need to be provided. If they cannot the site again should be refused. Please therefore continue to raise your concerns regarding the risk to groundwater.

Flood Risk and Drainage

The geo-hydrological impact from the proposed development, overland flow routes and potential subsidence as a result of concentrated surface water inflows are also of serious concern. The Lead Local Flood Authority (LLFA) have approved the Flood Risk Assessment undertaken on behalf of Gladman in 2018. We contacted the LLFA as they failed to address a series of concerns raised by residents at that time and some of the risks are highlighted in the letter issued to NHDC on the 12th April 2018.

Loss of privacy and overlooking

This is relevant for residents whose properties can see or can be seen from any point on the proposed development site.

The proposed site of development is at such an angle and height that future occupants of dwellings on this site would overlook at our property, resulting in an invasion of our privacy.

The District Wide Local Plan, Policy 6.8, states: “New developments will be expected to provide a high  standard of layout and design that ensures adequate privacy for the occupants of the building and of adjacent residential properties.”

Support from the Campaign to Protect Rural England (CPRE)

The CPRE strongly objected to this development in 2018 a formal letter to the NHDC Planning Officer . This letter gives a number of well-referenced reasons for objecting to the site, some of which discuss the emerging local plan. We recommend you read this letter as it may help with your own objections, and you can of course refer to the CPRE objections as well.

Ecology

The ecology assessment produced in support of the development in 2018 failed to detail a number of Biodiversity Action Plan species that are found at the site, including the Brown Hare and Grey Partridge. In addition the site also supports a number of RSPB Red listed UK farmland birds of conservation concern, including Skylark, Yellowhammer, Corn Bunting, Mistle Thrush and Field Fare.

The Natural Environment and Rural Communities (NERC) Act 2006 states local authorities are required to take measures to “promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species.” Priority species listed under Section 41 (S41) as being of principal importance found at the site include the Brown Hare, Grey Partridge, Skylark, Corn Bunting, Yellowhammer, Starling, Song Thrush, Hedgehog and Small Heath butterfly.

The appraisal commissioned by the applicant in 2018 was largely a desktop one and is surprising in its paucity when the landowner has described himself as a wildlife enthusiast in a previous planning objection. The proposal has also not highlighted the disturbance to the surrounding area from not only construction and the new residents, but from their pets as well. Data for the area, from the Animal and Plant Health Agency, suggests that for 120 dwellings their would be 60 cats and 60 dogs – this is right next to the project area for a successful grey partridge recovery programme.

The open nature of the site is vital to many of these species, but also as a foraging area for the Barn Owl. The suggested wildlife mitigation area proposed within the development is not large enough to account for all the diverse requirements of the disturbed species.

Pressure on Local Services

The Education Authority have made it clear that, even with the building of an additional school, there is not capacity for the extra children this development would bring. If you add this to the incredible pressure on transport services that already exist it would be foolish to approve such a development.

Water Supply and Sewage

Royston’s water is supplied by an aquifer with all the developments taking place and greater water usage is the aquifer going to cope with the demand? The developer proposes a new sewer to run down bridleway 13 along Sun Hill to Echo Hill junction where it will be joined to the existing sewer. No contingencies appear to have been looked at, over the disruption to traffic, the 24hour access to the reservoir at Wicker Hall or the inconvenience to local residents especially Sun Hill. Nor if the sewer can be accommodated underground down the bridleway.

There are a number of developments in Royston. Anglia /Affinity water could only say that the treatment works currently has capacity, this could change, with further developments or new environmental rules. It would reflect poorly on the local authorities if, there was a repeat of the sewage  problems faced by residents in Ivy Farm, which were minuted (after a presentation from Anglian water) at a meeting of NHDC on November 29th 2017.