Object

Representation ID: 6076

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to SP5: Fundamental misinterpretation outlined in para 4.53 and the Green Belt Review of National policy in NPPF para 83-86. Para 83 requires exceptional circumstances to be shown to justify removal of land from GB by the redrawing of any individual GB boundary. None of the 3 categories of site liseted in SP5 paragraph (a) satisfy this national policy requirement. This applies to strategic allocations and development around towns and villages in the GB.
Furthermore the Council has used para 86 as the basis for removal of villages from the GB, as if the GReen Belt boundaries are being defined for the first time, whereas all of these villages are already washed over by permanent GB. As the plan accepts in several parts of the plan, eg "current Green Belt boundaries have been in place for 20 years". Any change needs to be justified by exceptional circumstances, which the plan makes to attempt to demonstrate.

Para 4.53 - Final sentence of 4.53 of the plan fails to meet the requirement of NPPF para 83 to set out exceptional circumstances for changing established GB boundaries. Not set out in Plan or Evidence. para does not refer to Housing and GB Background paper, and whilst this claims that exceptional circumstances exist the statement that assessed housing need is both acute and intense is patently incorrect. incorrect justification - proposals in plan unsound.

Para 4.60 - Para sets out boundaries defined following approach set out in para 85 and 86 of NPPF. Flawed interpretation as redrawing permanent GB boundaries should only take place in defined exceptional circumstances, not just because a local plan is being prepared.