7. Healthy Communities

Support

Representation ID: 8361

Received: 20/03/2020

Respondent: Sport England - East Region

Sport England supports the content of paragraph 7.5.1 in relation to supporting the retention of existing leisure facilities and requiring appropriate levels of leisure/sports facilities to be provided in new development. This approach is consistent with paragraph 96 of the NPPF especially as it is supported by the District Council’s Indoor Sports Facility Strategy which provides a robust evidence base for supporting the retention of existing facilities and justifying developer contributions being sought through new development towards new or enhanced indoor sports facilities.

Object

Representation ID: 8362

Received: 20/03/2020

Respondent: Sport England - East Region

Section 7.5 does not provide any detailed guidance to provide clarity and transparency on the Council’s approach to securing developer contributions for indoor sports facilities. It is therefore requested that the section is amended to provide more detailed advice covering the matters identified in the comments. This will help ensure that the approach set out in the SPD is consistent with the tests in Regulation 122 of the CIL Regulations and would reduce the risk of challenge in practice.

Support

Representation ID: 8363

Received: 20/03/2020

Respondent: Sport England - East Region

Sport England supports the content of section 8.4 of the SPD in relation to requiring provision to made for outdoor sport in new development through developer contributions or on-site provision. The reference to only seeking on-site provision where this would generate a usable quantity of open space for a form of provision for which there is an identified requirement is welcomed as this should help prevent unsuitable on-site proposals being progressed.

Object

Representation ID: 8442

Received: 24/03/2020

Respondent: Barkway Parish Council

7.8.4 - The proposal for the transfer of the freehold of community buildings is clear, but the proposals for developer support of ongoing management arrangements, for example for community hubs is far too vague. As with the proposals in 8.2.4 the commitment to ongoing management should be for 10 years, or more.

Object

Representation ID: 8446

Received: 17/03/2020

Respondent: Hertfordshire Constabulary - Architectural Liaison

7.9.6 {NEW} Police services are provided through the Office of The Police and Crime Commissioner for Hertfordshire and contribute to the overall well – being of local communities. Police infrastructure comprises fixed property and technology assets; and human resources, which includes Local Community Policing, victim support, and crime reduction initiatives such as use of CCTV. These can arise either locally, or as a result of cross – boundary considerations where scale and efficiency of operation require policing facilities to be located outwith the boundaries of the local authority.

The Council will therefore require development, where required and appropriate, to contribute towards the delivery of policing infrastructure to serve new developments and mitigate against their impact upon existing police resources.


7.9.6.1 - To assist with the proper design of new communities, and in addition to the wider range of policing infrastructure, HC are able to advise on design. This is in line with Local Plan Policy D1 Sustainable Design, and applicants should demonstrate that opportunities for crime and anti-social behaviour have been designed-out. Hertfordshire Constabulary will be consulted on planning applications where it is considered that there may be an impact in terms of community safety.

Object

Representation ID: 8447

Received: 25/03/2020

Respondent: Countryside Properties (UK) Ltd

Agent: Barker Parry Town Planning

7.2.1 - Developers may be liable to contribute land as well as financial contributions. This approach is unreasonable, and should be reviewed. The developer is entirely within their right to recover relevant land value for alternative purposes associated with infrastructure that is not solely required in respect of their site.

7.10.3 - Contributions for boosting high-speed communication coverage is not supported by a policy and offers lack of clarity associated with what may be sought or the scale of the contribution.

Object

Representation ID: 8449

Received: 24/03/2020

Respondent: New Road (Ashbrook) Ltd

Agent: Miss Charlotte Bailey

7.7.4 - Why are contributions sought by NHS. No clear evidence base for the calculation of contributions referred to at 7.4.2 which are not services provided for by local government or administered by local authorities.

Object

Representation ID: 8455

Received: 24/03/2020

Respondent: Letchworth Garden City Heritage Foundation

Agent: Planning Matters

7.1.3 - Include North Herts College as key stakeholder. The LPA should also work with the applicant to determine the key additional stakeholders or produce an updated list of those who may be contacted to provide certainty and direction.

7.1.5 - It is greatly disappointing that there is no provision to require developers to contribute to training and apprenticeship programmes. This is a standard approach for many authorities, particularly in London, and this can make a significant contribution to local people. North Herts College can be the lead provider in these programmes funded by S106 contributions, but this can be supplemented by developer and contractor in house schemes. The current text places a reliance on Youth Connections, should in the future this no longer exist, an alternative mechanism should be in place.

7.4.2 - The Clinical Commission Group’s requirements will be reviewed regularly and thus to refer to the current edition will cause confusion at later date. The associated commentary may also not be relevant in the future.

7.4.3 - Object to the use of developer contributions to fund record digitisation. To insist upon contributions for this purpose would be contrary to the established legal requirements for payments and thus must not be pursued.

7.4.4 - Evidence of the expenditure of any health contributions should be provided to an applicant for the purposes of transparency and accountability.

7.6.1 to 4 - reference should be made to the legal validity of developer contribution requirements to ensure that requests relate appropriately to the associated
development.

7.8.4 - The Heritage Foundation would not support the freehold transfer of community buildings on its development site. This is not justified in planning policy terms and is contrary to the rules of the Foundation regarding the integrity of the Estate.

This is also not necessary to ensure the long-term use of community facilities and fails to recognise the role of other providers, such as local community groups and Community Land Trusts.

As such, we object to this requirement.

7.9.7 & 7.9.8 - It is not the role of the planning system to secure policing numbers.

7.10.2 - Should be all new major development.

Object

Representation ID: 8462

Received: 23/03/2020

Respondent: Osprey Homes Ltd

Agent: JB Planning Associates

7.41-7.4.2 - What is meant by 'largest developments'? How will existing provision be factored into the calculation?Occupiers may be already be resident within the Health Authority area, so no additional burden. Contributions should not be sought absent of direct need for new provision arising from a development.

7.4.3 - Emphasising the tests of obligations.

Object

Representation ID: 8467

Received: 01/04/2020

Respondent: Hertfordshire County Council - Environment & Infrastructure Department

7.3 - The youth section needs a paragraph referring to HCC as has been included within other sections. ‘Discussions should be undertaken at an early stage with Hertfordshire county Council to ensure that there is sufficient capacity of youth facilities to mitigate the implications of the proposed development. This includes having regard to the Hertfordshire County Council Guide to Developer Infrastructure Contributions to determine the level of contributions expected to be provided from the proposed development.’ [footnote reference URL]

7.6.3 - it would also be useful to include a reference to contributions to enhance and expand existing facilities, should this be appropriate. The reason for this is because new finds of significant archaeological material may not be sufficient on their own to warrant a new facility and may put enormous pressure on existing facilities.

7.10.2 - This paragraph ought to go further referencing Full Fibre and Gigabit Capable coverage which would be in line with new Government targets.

The heading of section 7.2 reads “Education and early childcare facilities”. Instead this should read “Education and early childcare years facilities”.

The last sentence of paragraph 7.2.1. makes reference to “…the demand for school and nursery places…”. This should read “…the demand for school and nursery early years places…”.

The last sentence of paragraph 7.2.2. reads “…be it expansion to an existing school or a new school, then serviced land will also be required.” This should have the following added and read; “…be it expansion to an existing school or a new school, then serviced land will also be required, which will be expected to adhere to Hertfordshire County Councils land specification.”

Hertfordshire Fire and Rescue Service Response

1. Hertfordshire Fire & Rescue Services (HFRS) capacity to deliver an emergency response is not unduly effected by individual developments but may be impacted by the cumulative effect of the detail within the draft NHDC Supplementary Planning Document.

2. Contributions may be sought from development schemes which have the potential to increase the demand on the Service as currently provided across the respective Council area. In those cases, HFRS may seek advice on planning obligations towards fire and rescue services via Section 106 (S106) of the Town and Country Planning Act 1990 and also ask for consideration under the Community Infrastructure Levy (CIL) where applicable.

3. HFRS would request that planners and developers continue to consult on requirements for the provision of water supplies and that the fire hydrant(s) served by the mains water supply shall be provided prior to any dwellings being occupied and to the satisfaction of the Fire & Rescue Service. Expansion within North Herts through development provides an opportunity for planning authorities to take a national lead by applying a proactive approach towards protecting the community and infrastructure through in-built fire suppression systems. HFRS would recommend greater inclusion of Automatic Water Suppression Systems (AWSS) in the built environment. Sprinklers save lives, protect property, reduce the impact of fire on the environment and support UK businesses by reducing interruption.

Object

Representation ID: 8475

Received: 25/03/2020

Respondent: Bellcross Homes and Gallagher Developments Ltd

Agent: Rapleys LLP

7.4 - The Council should set the requirement to meet CIL regs and evidence the tests are met for health contributions to be provided by ENHCCG.

7.2.2- suggested amendment - the provision and/or contributions towards the serviced land may also be required, to be determined on a case by case basis.

7.4.1 - What is 'largest development sites'?

7.4.3 - justification fails CIL reg tests.