Object

Representation ID: 6042

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Para 2.8 - text demonstrates that the plan fails to seek to limit population and household growth in the district to a level consistent with national planning policy , and in particular para 14 and footnote 9 of the NPPF.
Para 2.35 - This para should include the key caveat in para 47 of the NPPF, which requires constraints such as Green Belt and AONB to be taken into account in determining the scale of housing provision in the district and HMA.
Para 2.39 - The final sentence fails to state that the needs of the HMA can only be met in full if the constraints imposed by paragraphs 14 and 47 of the NPPF are ignored, resulting in significant harm to the Green Belt.
Para 2.41 and 2.42 Figures for Lutons housing capacity are out of date and this has an important bearing on the scale for new housing that North Hertfordshire should contribute to Luton's needs. Figures updated through EIP process. Specific intention in para 2.42 to meet all of the Plans proposed contribution to Luton's housing needs within the small strip of GB land immediately abutting Luton is unjustified, particularly when weighed against the harm that would be caused to the GB and the high quality landscape of the whole of this area, and the likely impact on the communities in the area and rural infrastructure.
Para 2.44 - The plan does not justify he statement that Stevenage is unable to provide adequate employment land within its own administrative area to meet the scale of need that is acceptable in the context of NPPF para 14. The evidence on capacity within Stevenage has yet to be tested through the SBC Local Plan examination which is due to commence in January. NHDC plan should not pre-judge the inspectors conclusions on this issue.
Para 2.66 - The second bullet point fails to include the important caveat in NPPF para 14 and footnote 9, which set out the context for meeting development needs and the principal constraints limiting this aspiration.