MM018 - Page 39 After Paragraph 4.39 (new paragraphs)
Proposed Main Modifications
Representation ID: 7852
Respondent: Dr Andrew Wheen
See attached representations
Proposed Main Modifications
Representation ID: 7913
Respondent: Transition Town Letchworth
See representations below
Please find below Transition Town Letchworth's (TTL) Comments on the Main Modifications to the North Herts District Council Local Plan.
MM010 (page 32 Policy SP2) - The footnote states that housing allocations are not a maximum, so are they a minimum? Much of the proposed new housing is to be built on previously designated green belt land. TTL would suggest that the allocations for these 'green belt ' development housing numbers should be a maximum, and if either the demand for housing in North Herts is not as high as predicted, or future windfalls on brown field sites are greater than predicted, the opportunity should be taken to reduce the volume of housing built on green belt sites. This would help keep towns compact, sustainable and separated and leave the maximum area of land available for farming.
MM017 (page 38 SP4) / MM018 (page 39 new paragraphs) / MM037 (page 48, Para 4.89) / MM093 (Page 78, Para 5.16) - TTL recognise that existing national planning guidance requires retail space to increase with population, despite the growing evidence of a decline in people accessing traditional shops. We are also aware that retail trends have been for shops to situate themselves on out of town estates near leisure activities rather than in vacant Town Centre properties. TTL would like to see North Herts Local Plan address the issue of 'out-dated' national guidance on retail development with some innovative thinking for Letchworth. In particular, vacant units and land on the periphery of the existing town centre should be utilised for sustainable homes, which would then be located near the shops, schools and public transport. This would reduce the amount of housing required on the green belt land North of the Grange Estate. The local plan could then set aside green belt land for industrial/retail uses to meet national guidance requirements, with a high probability that this land would never need to be built upon. Overall this approach would have the potential to reduce the erosion of green belt land and place housing in a more sustainable location.
The local plan acknowledges that Letchworth residents shop in Hitchin and implies this will change if more retail units are provided in Letchworth, but in recent years Letchworth has not lacked vacant retail units. If the social factors which influence where people shop are not addressed, building more retail units in Letchworth Town Centre, which is part of the local plan, appears to have no clear rationale.
In summary, TTL perceive that the local plan has not properly considered the Town Centre options for housing and until this is done the housing allocation for the North of Grange Strategic Site should not be finalised.
MM034 (page 46 Para 4.83) - It is really important that all elements of the planning process have an appropriate public consultation. Land owners, like Letchworth Heritage Foundation, are not required to follow the high quality consultation processes required by public bodies and we would like to see NHDC take responsibility for important areas like the town Cycling and Walking Strategy.
MM035 - Why has the self-build housing allocation been reduced? TTL support self-build as it is a method for achieving affordable housing and can deliver innovative low carbon housing. NHDC should be encouraging demand for self-build sites, not just satisfying those on their existing interested parties list.
MMO61 (page 63, Policy SP15) - This plan treats Letchworth North of the Grange strategic site (900 homes) as a distinct entity, suggesting it should have its own primary school, GP surgery and local shops. The site curves round the edge of the Grange Estate and the local plan does not adequately address how to integrate the new site into the existing town, which may be more cost effective for public service provision and improve the quality of services for existing residents of the Grange Estate.
* The new site is very close to two existing primary schools (Stonehill (1 class intake) and Northfields / Grange (2 class intake)). Is provision of a new school specifically for the site the most cost effective way to provide additional school places? Will a separate school for the new development help improve social integration in Letchworth?
* Letchworth has an existing issue that its GP services are located in the 'old' town, some distance from each of its newer estates. The Grange estate, which must have over 3000 homes, has no GP surgery. Provision of a GP surgery on the existing Grange estate, which has a pharmacy, could provide a much better solution than locating a GP surgery on the Strategic Site.
* The Grange local shops could become more viable if they serve the new site, rather than building new retail space on the Strategic Site.
* The local plan should have identified that to maximise the benefit from good cycling and walking infrastructure on the North of Grange Strategic Site will require investment in a better cycling and walking infrastructure from the existing Grange Estate to key destinations in Letchworth.
MM50 - TTL are pleased to see recognition of wildlife corridors in the local plan, but what is required is more than an acknowledgement. Has a study been undertaken to check if strategic housing sites will leave gaps in wildlife corridors? If any gaps are identified will planning permission be denied unless a solution is found to preserving the wildlife corridor?
MM062 (page 63, paragraph 4.188) - Before agreeing to North of the Grange Strategic Site's inclusion in the Local Plan the road linkages should have been considered and a satisfactory solution found. The council should have modelled the road infrastructure and advised the land owner of where they wanted the road networks to link and should be confident that the road infrastructure will cope with the additional traffic. Recognising that there may be issues is not a satisfactory 'plan'.
MM125 (page 92, Policy HS2) - By failing to recognise the existing imbalance of affordable housing across North Hertfordshire towns, and then failing to address this with different affordable housing targets for each town, this local plan fails residents of all towns. The local plan will re-enforce existing inequality issues, along with behaviours that are not sustainable (e.g. shopping or sending children to school in another town).
MM145 (page 102, Para 9.6) - Councils can put carbon emissions targets into their planning policies which require performance beyond that contained in the national standards (see https://www.ukgbc.org/wp-content/uploads/2018/09/The-Policy-Playbook-Feb-2019.pdf). NHDC should recognise this and be clearer about the levels of performance they will be expecting, which should aspire to passive house standards.
MM146 (page 102, para 9.12) -TTL are pleased to see the plan tackling issues around water supply. The importance of new homes being designed to minimise water use could be re-enforced by making a clear statement in the plan that a '3 year drought will jeopardise the chalk streams which take 12 years to recover their biodiversity once they dry up'. TTL recognise that Affinity Water have a long term target of 110 litres of water use per person per day. TTL would like to see a more ambitious target - Southern Water have a target of 100 litres of water per person per day. New housing should be built to support low water use, with low water use toilets, showers and taps, water butts and grey water recycling systems. A well designed and constructed house will make it easy for residents to achieve low water use. NHDC need to refine the target to 100 litres in the local plan and make clear that house builders must install equipment that supports this.
We hope these comments can be addressed in an updated Local Plan.