Agenda No. HERTFORDSHIRE COUNTY COUNCIL DEVELOPMENT CONTROL COMMITTEE 3 TUESDAY 22 MAY 2012 AT 10.00 AM DISTRICT: EAST HERTS DISTRICT APPLICATION FOR PROPOSED ERECTION OF A BUILDING (FLOORSPACE 1620SQ.M) WITH ASSOCIATED YARD, OFFICES AND WEIGHBRIDGE TO BE USED FOR A MIXED USE OF ELV (END-OF-LIFE VEHICLES) PROCESSING AND TYRE BALING (SUI GENERIS), B1 (OFFICE/LIGHT INDUSTRIAL) AND B8 (STORAGE AND DISTRIBUTION) ON LAND AT UNIT 7D, HADHAM INDUSTRIAL ESTATE, CHURCH END FARM, LITTLE HADHAM, HERTFORDSHIRE SG11 2DY Report of the Director Environment and Commercial Services Author: Felicity J Hart Tel: 01992 556256 Local Member: Councillor Leanda Newlyn 1 Purpose of Report 1.1 To consider planning application ref. 3/0593-12 (CM0935) for the erection of a new building to be used for ELV processing and tyre baling at Church End Farm, Little Hadham. 2 Summary 2.2 This planning application is for the erection of a new building to house an ELV (End of Life Vehicles) processing and tyre baling operation along with ancillary offices and yard. ELV processing is currently taking place on the site within an enclosure without the benefit of planning permission, but this application would involve the removal of the existing structure and the erection of the new one subject of this planning application. 2.3 The site forms part of Church End Farm, situated at the end of Church End, a narrow rural lane, taking access from the north side of the A120, just outside the centre of Little Hadham village. Some of the buildings at Church End Farm, have in recent years been converted to Little Hadham ELV processing 3/0593-12 (CM0935) 1 B1 (office/light industrial) and B8 (storage) uses from their original agricultural uses although the site remains a working farm. 2.4 The ELV facility is proposed to operate from 7am to 6pm Monday to Friday and from 7am to 6pm on Saturdays. 24 staff are proposed to be employed. Maximum annual operational throughput is stated in the application to be 9300 tonnes per annum. The application states that daily average vehicle movements would be 22 (11in, 11out) of which 10 (5in, 5 out) would be HGV. 3 Conclusion 3.1 The proposed development is sited within the Rural Area on land that has not previously been developed. The proposal does not fall into any exception categories for development on land in the Rural Area beyond the Green belt and as such the the proposal is ‘inappropriate’ development’. 3.2 The location of the proposed development at the end of a country lane, would take access past residential properties and listed buildings and would lead to an unacceptable degree of noise and disturbance both to Church End and Hadham Hall. The proposal would also erode the character and appearance of the surroundings and would cause conflict with users of a bridleway which crosses the proposed vehicular route and local footpaths. There would also be significant detriment to highway safety along Church end and at the junction with the A120. 3.3 Material considerations in support of the application include previous permission granted in 2006 and the fact that the proposal would contribute to the waste recycling and re-use of ELVs, car parts and tyres which is encouraged. However, these points have been taken fully into consideration and carefully balanced against the significant harm that would arise if the proposed development were to go ahead. As a result, it is considered that the proposal does not accord with East Herts Local Plan policy or the NPPF. 3.4 It is recommended that permission be refused for the following reasons: 1. The application site lies in the Rural Area, as defined in the East Hertfordshire Local Plan where development will only be allowed for certain specific purposes. The proposal is contrary to the aims and objectives of rural area policies and results in harm to the rural, agricultural character and appearance of the surroundings. The development is thereby contrary to Policy GBC3 and ENV1 of the East Herts Local Plan Second Review 2007. 2. The proposed development would result in a significant number of HGV and other vehicle movements along a narrow rural road unsuited to such traffic. The intensification of the use of Church End Little Hadham ELV processing 3/0593-12 (CM0935) 2 and its junction onto the A120 and the primary road network, which is of insufficient standard, would be detrimental to the free and safe passage of traffic on the A120 and Church End. 3. Traffic generated by the proposal would be detrimental to pedestrian safety along Church End due to its narrowness and lack of footpaths. HGVs and other vehicles accessing the site would need to cross a Bridleway with other public footpaths in the vicinity, leading to an unsafe situation of dangerous conflict between vehicles, walkers and others users of the bridleway. As such the proposal is contrary to Waste Local Plan Policy 39. 4. The location of the proposed development is unsustainable and inappropriate and would be detrimental to residential amenity disturbing local residents from traffic movements and noise from the proposal being contrary to the NPPF and East Herts Local Plan Policy ENV1. 4 Description of the site and proposed development 4.1 The site comprises an open area of land, not previously developed (except for the unauthorised enclosure), situated immediately to the north of an existing group of farm buildings and other light industrial buildings and buildings in storage uses (Church End Farm).The land proposed to be developed has been excavated and lowered in recent years revealing a mainly sandy surface with embankments to the north and east and beyond that, farmland. An enclosure (comprising 3 metre+ high walls with partial roof) has recently been constructed in the northern part of the planning application site, within which unauthorised End-of-Life Vehicle (ELV) processing is currently taking place. 4.2 The site is accessed along Church End which is situated to the north east of Little Hadham village centre. Church End is a narrow country lane which takes access off the main A120 route between Little Hadham and Bishop’s Stortford. Church End is rural in character and provides access to residential properties and to the Grade I Listed St. Cecilia’s Church as well as Church End Farm. There a number of public footpaths and bridleways in the area, one forming part of the Hertfordshire Way. These paths are used in conjunction with Church End as a route through to Little Hadham village. 4.3 Church End Farm is located at the end of Church End and comprises a cluster of buildings ranging from some small Victorian stables to larger more modern farm storage buildings. There is a complex planning history relating to the site and a number of the farm buildings have, over the years, had planning permission granted for change of use from their original agricultural use to alternative uses, mostly B1( light industrial and office) and B8 (storage and distribution) and one small Little Hadham ELV processing 3/0593-12 (CM0935) 3 building having B2 (general industrial). 4.4 The application site is accessed between existing buildings now mainly used for non-agricultural uses. Church End Farm is still a working farm however, but the buildings in agricultural use are mainly sited to the west of the application site, although they are still within the overall cluster of development. The nearest residential properties are sited along Church End and also to the east of the site at Hadham Hall and Baud Close. 4.5 The application site is located on an open piece of ground immediately to the north of the closest non-agricultural building (unit 6). This building is currently vacant but was previously used as a water bottling unit as part of the Hadham Water business. The Hadham Water business was expanding during the 2000’s and in 2006 planning permission was sought for a substantial extension to the existing building (2000 sq.m) to allow for a significantly expanded operation. The proposal was put forward that once operating, it would be able to supply water to the 2012 Olympics. That application was recommended for refusal by East Herts District Council on grounds of inappropriate development on land in the Rural Area beyond the Green Belt as well as detriment to residential amenity and highway safety. However, East Herts District Council granted planning permission in 2006 for the building as it was considered that the proposal constituted special circumstances. 4.6 Hadham Water ceased to trade as a business shortly after and the building granted planning permission as an extension to the water bottling facility in 2006 was never built, although the applicant states that the foundations were constructed. This current planning application proposes a new building and new use on part of that site. The Proposal 4.7 This planning application proposes the erection of a new building with a pitched roof ( 54m x 30m x 10.5m high) partly on the footprint of the building granted planning permission in 2006. The proposed building would be constructed from 80mm thick plastic coated composite cladding and would be accessed from the east side only. The eastern elevation is proposed to have four roller shutter doors as well as some windows and a pedestrian door to be used in connection with the offices. 4.8 Externally, a concrete yard is proposed on the eastern side of the building with a weighbridge and 10 parking spaces. No external working is proposed at the site as it is all proposed to take place within the building. 4.9 Internally, it is proposed to process the End-of-Life Vehicles at the Little Hadham ELV processing 3/0593-12 (CM0935) 4 northern end of the building. Vehicles carrying ELVs would drive into the building to unload. The ELVs would be stored in one corner of the building and in turn would be depolluted using modern de-pollution equipment. When all fluids have been removed, any useable parts would be removed from the vehicles and then the shell would be crushed in a baling machine. The baled vehicles would be collected up into a container and stored awaiting removal by HGV. It is proposed that the doors would be shut apart from when vehicles would be accessing and exiting the building. 4.10 The remaining part of the operation is tyre baling. Waste tyres would be brought to the building for baling and storage along with tyres removed from ELVs. The tyres would be sorted into those for re-use and those for recycling. The tyres for recycling would be baled ready for collection and the other tyres stacked ready for collection to be taken to another outlet retailing part-worn tyres. 5 Consultations 5.1 East Herts District Council have concerns. The application is for a new building for ELV processing, however there is currently an unauthorised building being used for that activity on site which is unauthorised. The site lies in the Rural Area beyond the Green Belt where the aims and objectives of policy are placed firmly on growth restraint, The proposal is contrary to Policy GBC3 and so constitutes “inappropriate development” within the rural area. In addition, the Council is concerned about the impact of the development in terms of noise and disturbance and harm that would arise to the character and appearance of the surrounding area. There are no material considerations to outweigh these issues or to override rural area policy and therefore refusal of the application is recommended. 5.2 Little Hadham Parish Council object to the proposal and consider that the scale, size and bulk of the proposed building to be not in-keeping with this area because it is located on farmland and in a rural situation. Serious concerns are raised about noise, pollution and nuisance of car transporters travelling along a single track road and effect on residents. Also concerns re: the safety of horse riders, cyclists, other drivers and pedestrians, especially children. The acces onto the A120 is dangerous and the proposal will further exacerbate congestion. The facility should not be located in this location and the proposal is wholly unacceptable. 5.3 Environment Agency is satisfied that the geological interpretation presented with soil sample results support the conclusion that the site is unlikley to be affected by contamination and the risks of pollution posed by the proposed use can be made acceptable through regulation Little Hadham ELV processing 3/0593-12 (CM0935) 5 by the Environmental Permitting Regime. Therefore suggest a condition relating to no infiltration of surface water drainage to protect groundwater quality. Additional advice relates to the Environmental Permit application for the current ELV operation. This is still at the application stage and assessing how to regulate the operational details of the site activities. 5.4 5.6 Ramblers’ Association, Hertfordshire & North Middlesex Area objects to the application due to the impact that the proposed development would have on the public using Rights of Way in the vicinity. The bridleways are constricted in places between buildings, fences and ditches so that vehicles cannot keep out of the way of walkers or riders. The proposal is contrary to policy. Hertfordshire County Council – Highways recommends refusal for the following reasons: 1.) To permit this proposal would be contrary to policies contained in the Hertfordshire County Council LTP3 which seek to minimise disruption to the safe and free passage of vehicles on Primary Route Networks. 2.) To permit this proposal will intensify the use of an access road and junction onto the primary road network of insufficient standard, by virtue of width, alignment and junction configuration to safely and satisfactorily accommodate the associated traffic movements without detriment to the free and safe passage of traffic on the A120 and Church End. 3.) The additional traffic associated with the proposal would give rise to conditions detrimental to pedestrian safety along Church End by reason of its narrowness and the lack of footways. 5.7 Hertfordshire County Council – Rights of Way objects to the application on the following grounds; There is the potential for conflict between vehicles accessing the proposed site and walkers and horse riders on Bridleway 37, which crosses the access route through the farm yard, and also with walkers on Footpaths 34 and 38, which exit onto the proposed access. Children are being encouraged to walk to the village school (travel plan) from the Hadham Hall area along footpath 34 and the proposed access road. This is to be encouraged on environmental and health grounds, but could be jeopardised if the application is given the go-ahead because there is no footway alongside the proposed access road, which is relatively narrow. Given the above, I would ask you to refuse this application. Little Hadham ELV processing 3/0593-12 (CM0935) 6 5.8 Hertfordshire County Council – Archaeology raise no objections. 5.9 Hertfordshire County Council –Landscape Officer advises that there may be marginal visual impact from the development on users of various areas around the vicinity of the site which may include from the upper storey windows of properties on Baud Close, although this would be diminished if a belt of trees were to be planted between the site and the residential properties. There may also be associated impacts if large signage were erected or if tree pruning was required to enable high sided vehicles to gain access. The existing signage is already visually intrusive. 5.9 A total of 100 consultation letters were sent out in relation to the application and 28 letters objecting to the application were received with 5 letters in support. The issues of concern can be summarised as: Inappropriate industrial use in a rural area Noise and fumes from the process affecting residents HGV and other vehicle movements affecting residents and highway safety In support: The proposed development is sustainable It fulfils a necessary function in the local area providing jobs. 5.10 Publicity for the application was as follows: In addition to the consultation letter,a site notice was erected on 20th April 2012 and the application was advertised in the Hertfordshire Mercury on 19th April 2012. 6 Planning considerations 6.1 The relevant development plan policies are: Hertfordshire Waste Local Plan 1995-2005 Policy 1: Sustainable development Policy 2: Need for Waste Management facilities Policy 13: Criteria for facilities for re-use, recovery, recycling and transfer of waste outside areas of search Policy 29: Scrap metal, including scrap vehicles Policy 33: Landscape Intrusion Policy 34: Impact on landscape features of local importance Policy 39: Rights of way Policy 40: Noise Policy 43: Traffic Policy 44: Proximity to other land uses Little Hadham ELV processing 3/0593-12 (CM0935) 7 East Hertfordshire Local Plan April 1996 Policy GBC3: Rural Area beyond the Green Belt Policy East of England Plan, May 2008 Planning Policy Statement 10: Planning for Sustainable Waste Management National Planning Policy Framework 6.2 The principal issues to be taken into account in determining this application are: The principle of the proposed development and the appropriateness of its location in terms of the rural area and sustainability; Impact on residential amenity; Impact on highway safety; Impact on pedestrian safety. Impact on visual amenity in the rural area. Principle of Development and Sustainablity 6.3 The proposed development comprises a large new industrial building sited on the edge of a cluster of buildings but otherwise in the open countryside. The land is not ‘previously developed land’ (not brownfield) and has not previously been used for any other use except agriculture. Significant excavation works have taken place to the north and east of the application site to remove earth to a depth of at least 5 metres cutting into the field to the north. These unauthorised earth works have recently been refused retrospective planning permission by East Herts District Council (ref.3/12/0296/FP). 6.4 In policy terms the site is situated in the rural area beyond the Green Belt (EHLP Policy GBC3) which aims to restrict inappropriate development in those areas. Certain developments for new buildings in the rural area can be permitted under the terms of the policy, however a new building for industrial use does not accord. Little Hadham ELV processing 3/0593-12 (CM0935) 8 6.5 The National Planning Policy Framework (NPPF) requires that new development should be sustainable and emphasises the importance of our natural and historic environment. The NPPF also promotes planning delivering a strong local economy and economic growth. This current application states that 24 jobs would be created as a result of the proposal, although this does seem a large workforce when compared with similar operations on other sites who seem to employ between 6 and 12 staff. 6.6 The NPPF confirms that applications should still be determined in accordance with the development plan unless material considerations indicate otherwise. The NPPF itself is one of those material considerations. The NPPF does not contain specific policies on waste, but local planning authorities should have regard to relevant policies in the NPPF in determining waste applications. The NPPF states that development that is sustainable should go ahead. The development proposed in this application requires vehicle movements from urban areas to reach the site with deliveries of ELVs and waste tyres. There is no other way of reaching the site other than via the road network though areas of surrounding countryside and along Church End. According to the NPPF, three dimensions to sustainable development must be assessed; the economic role, the social role, and an environmental role. 6.7 In terms of an economic role, the most important factor to be considered is if there is sufficient land of the right type available in the right place. For the social role, the aim is to create a high quality environment supporting residents’ health and social well-being, and for the environmental role it is about contributing to protecting and enhancing our natural, built and historic environment. 6.8 The route to the proposed planning application site would involve HGVs travelling along a narrow country lane past residential properties (one Grade II Listed) and a Grade I Listed church. There is no alternative access to the site and the use of this route by a significant number of vehicles in connection with ELV processing in addition to the existing traffic which accesses the Church End Farm complex would contribute to a detrimental effect on residential amenity due to noise and disturbance which would also be undesirable in the vicinity of the setting of listed buildings and their historic environment. Therefore the proposal would not contribute to protecting or enhancing the built and historic environment in the locality but would instead have the potential to damage it. Therefore it is considered that the proposal would fail to achieve to be classed as sustainable development in terms of the environmental role. 6.9 In terms of the social role, the proposal would in theory create a highquality environment if the site were on a designated existing industrial estate. However, the site is on a farm in a rural area where some of the buildings, mainly small scale, have had change of use planning permission granted over the years to allow use for B1 and B8 uses. One very small building also has B2 permission. These were all granted Little Hadham ELV processing 3/0593-12 (CM0935) 9 permission as they were redundant agricultural buildings that were already in situ. The proposed development would result in a well-used bridleway and footpath being crossed by HGVs and other vehicles interrupting the flow of walkers and horse-riders along the Hertfordshire Way. The route along The Causeway (known as the ancient nut walk) and along Church End (which has no footpaths) is regularly used by schoolchildren whilst walking to Little Hadham Primary School. There are also links between the school and St.Cecilia’s Church which is used by the schoolchildren. The route used by the children to and from the church is on foot along Church End. The use of this lane by HGVs would have significant adverse impact on all the other users of both the road (as a footway), the public footpaths in the vicinity and the bridleway which crosses the entrance to the site. The conflict with pedestrians and other users would reduce the quality of the environment in this area and therefore the development could not be classed as sustainable in terms of its social role. 6.10 As mentioned earlier the proposed development could be classed as sustainable in its economic role, if it were sited on an established industrial estate. There are industrial sites within the local area, located in an urban setting close to the source of the waste ie the ELVs. Although the proposed development would undoubtedly create some jobs, it is considered to not be a factor which would outweigh the requirement to be sited on a more appropriate site in the urban area. Each of the three dimensions referred to (economic, social and environmental for sustainability) is mutually dependent and it can be seen that as well as the development not producing positive improvements in the quality of the local environment, neither would it improve the conditions in which local people live, work, travel or take leisure. The proposed development is therefore considered to be inappropriate, in principle, to be located at the proposed site and is therefore not sustainable. Impact on residential amenity 6.11 The proposed use of the site as an ELV processing facility and tyre baling facility would have an adverse impact on local residents. Vehicles accessing the site and using Church End would pass a number of residential properties en route to the site and the nature of the vehicles towing cars and containing rattly parts would cause disturbance in this rural area. There are existing non-residential vehicle movements along Church End but these are in connection with the farm, the church and the other small units created from vacant agricultural buildings. The vehicle movements proposed in connection with the ELV use would have a significant adverse effect on amenity and would conflict with local walkers, school children and horse-riders using the local area. It is accepted that the planning permission granted in 2006 could still be implemented, and that that could have a similar effect, but from Little Hadham ELV processing 3/0593-12 (CM0935) 10 information put forward with the application it seems unlikely that the (2006) permission will be fully implemented. 6.12 In addition, the current unauthorised operation has led to a number of noise complaints, mainly from houses at the Hadham Hall complex to the east. The planning application proposal has been designed to be contained within a whole building with roller shutter doors and few windows. The purpose of the design is to minimise noise by keeping all operations within the building and the doors shut. The doors are proposed on the eastern elevation facing the rear of the properties on Baud Close and it is considered that two problems could occur with the proposed idea. In practice it is considered that it would be extremely hard to operate the ELV processing completely contained within a building as the very nature of the work requires constant deliveries throughout the day, which in turn leads to removal of waste products throughout the day. At busy times it is proposed that vehicles delivering would arrive, then unload whilst the doors are shut behind them and then the doors would be opened again for the vehicles to exit. It is considered that this would be extremely likely to be unworkable and there would be periods when the doors would remain open allowing the noise to escape. In addition the doors and windows would be likely to be opened in hot weather when the nature of the work and process of the operation would be made difficult to undertake in the heat without fresh air. In addition, the engines of the grab machine, the baler and the fork lift trucks are diesel would produce fumes which would require ventilation by way of opening the doors and windows. If the doors and windows were opened, then based upon the current situation, noise complaints would be likely. It is considered therefore that the proposal would result in harm to local residential amenity. Impact on highway safety 6.13 Vehicles accessing and exiting the proposed site would travel along Church End off the A120. Church End provides access to Church End Farm, the church and some residential properties and is a rural road with no footways on either side. There is very limited scope for widening the carriageway which currently varies from 4.4m to 5.4m.The minimum width required for two cars to pass one another is 4.1m, 4.8m required for a car and an HGv and 5.5m for two HGVs. The desirable road width for an all purpose industrial estate is 6.1m These dimensions illustrate that the old farm track leading to Church End Farm is of significantly inadequate width. Vehicles turning right to and from this road to the A120 will have a significant impact on the performance of the A120 carriageway. 6.14 The A120 is a very busy road with a continuous stream of traffic from 7am to 7pm. Any intensification of the use of Church End will have a significant impact on the free and safe flow of traffic and would impact on Little Hadham ELV processing 3/0593-12 (CM0935) 11 the A120 as a Primary Route. A high number of accidents have been recorded in the vicinity of the junction. 6.15 The highway authority has previously expressed concern that the level of increase in traffic would have a significant impact on the local road network. Planning permission was recommended for refusal in 2006 and although planning permission was granted at that time for an extension to B1/B8 use, it is considered that special circumstances at the time in relation to Hadham Water led to that decision. Since, the Hadham Water operation ceased there have been various applications at Church End farm mainly involving significant HGV movements. The current application is not considered to be of significant importance or special circumstances to warrant a departure from HCC transport policy in terms of road hierarchy and highway capacity and safety. 6.16 Hertfordshire County Council as Highway Authority therefore recommends that planning permission should be refused for the following reasons - : 1). The development is contrary to policies In HCC LTP3 which seeks to minimise disruption to the safe and free passage of vehicles on Primary Route Networks, 2) Intensification of the use of the access road and junction onto the primary road network which is of insufficient standard would be detrimental to the free and safe passage of traffic on the A120 and Church End, and 3) The additional traffic would be detrimental to pedestrian safety along Church End by reason of its narrowness and lack of footways. Impact on pedestrian safety 6.17 It is considered that there is the potential for conflict between vehicles accessing the proposed site and walkers and horse riders on Bridleway 37, which crosses the access route through the farm yard, and also with walkers on Footpaths 34 and 38, which exit onto the proposed access. This is contrary to Waste Local Plan Policy 39. 6.18 In addition, schoolchildren are being encouraged to walk to the village school from the Hadham Hall area along footpath 34 (the nut walk) and the proposed access road along Church End. This is to be encouraged on environmental and health grounds and is sustainable, but could be jeopardised if the application is given the go-ahead because there is no footway alongside the proposed access road, which is relatively narrow which could lead to concerned parents taking children to school by car even though it is a relatively short distance. It is considered that the proposal therefore conflicts with Waste Local Plan Policy 39 and that therefore permission should be refused. 6.19 Both Hertfordshire County Council as Highway Authority and Rights of Way recommend refusal due to the impact of the proposal on walkers and users of Church End and the local footpaths and bridleway. Little Hadham ELV processing 3/0593-12 (CM0935) 12 Impact on the environment in the rural area 6.20 The access road to the proposed development site also provides access to St.Cecilia’s Church, a Grade1 Listed Building. The road has the character and appearance of a country lane and contributes to the wider setting of this and another listed building. The creation of a heavy industrial facility processing ELVs in close proximity, together with significant HGV movements along the road which provides access to the church and is used by pedestrians would have an adverse effect on the character of the area. The NPPF suggests that it is desirable that new development should make a positive contribution to local character and distinctiveness and aim to protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason. It is considered that the proposal would have an adverse effect on the local historic environment which does not conform to the aims of the NPPF and would not be sustainable. 7 Conclusions 7.1 The proposed development is sited within the Rural Area on land that has not previously been developed. There is the potential for the land to be developed in accordance with the 2006 permission, however it seems unlikely, due to the circumstances, that this will happen. The proposal does not fall into any exception categories for development on land in the Rural Area beyond the Green Belt and as such the the proposal is classed as ‘inappropriate’ development’. 7.1 The location of the proposed development at the end of a country lane, would take access past residential properties and listed buildings and would lead to an unacceptable degree of noise and disturbance both to Church End and Hadham Hall residents. The proposal would also erode the character and appearance of the rural surroundings and would cause conflict with users of a bridleway which crosses the proposed vehicular route and local footpaths. There would also be significant detriment to highway safety along Church End and at the junction with the A120. 7.2 Material considerations in support of the application include the previous permission granted in 2006 (Hadham Water) and the fact that the proposal would contribute to the waste recycling and re-use of ELVs, car parts and tyres which is encouraged. The proposal would reduce carbon and provide jobs. However, these points have been Little Hadham ELV processing 3/0593-12 (CM0935) 13 taken fully into consideration and carefully balanced against the significant harm that would arise if the proposed development were to go ahead. The proposal would be detrimental to highway safety, pedestrian safety and the local rural environment. As a result, it is considered that the proposal does not accord with East Herts Local Plan policy. The proposal has been assessed in accordance with the NPPF in relation to sustainability and it has been found to be unsustainable. In addition, it is considered that the proposed development in the location proposed would not be in the public interest. The proposal therefore conflicts with the aims and objectives of the NPPF. Background information used by the author in compiling this report Planning application reference 3/0593-12 Consultee responses Relevant policy documents Appendix 1 – Relevant Little Hadham ELV processing 3/0593-12 (CM0935) development plan policies 14