My objection to the Plan is the failure of the Council to justify a long series of proposals for the removal of land from the Green Belt around towns and villages. Such justification should have specifically included the demonstration by the Council of the 'exceptional circumstances' for removing land from the Green Belt on a site by site, and settlement by settlement basis, and setting them out in the Plan. Instead, the Council appears to have relied on a blanket assumption that all housing and other development needs, not just in the District but in Stevenage and Luton as well, identified through their background studies, must be met in full, despite national planning policy and planning case law to the contrary. If the Plan is allowed to proceed as published by the Council, it would commit future generations to continuing development which would cause incalculable harm to the Green Belt.

I believe that the Council has not considered all reasonable alternative approaches to meeting the District's development needs, particularly when setting a Housing Target, and that this failure has contributed to an unsound Strategy. A realistic contribution to housing capacity from a greater range of sources including windfall sites, changes of use in accordance with current permitted development rights, and other measures promoting the recycling of previously developed land and property, should have been included in the Plan, and a Housing Target then determined that reflects both development needs and the nationally important constraints that exist in this part of Hertfordshire.

The proposal to move Green Belt boundaries from their current long established position solely because there is an equally or more defensible location elsewhere is contrary to national Green Belt policy. The stated reason for doing so is not an exceptional circumstance, and is not justified. The removal of Green Belt status from the land affected would be likely to cause significant harm to the Green Belt and it's overall purpose.