Policy NE5: New and improved public open space and biodiversity

While the intentions of this policy are welcomed, there are concerns about its detail in relation to according with the Council's evidence base for outdoor sport and meeting Government policy in the NPPF. In particular:

* The policy does not specifically support the principle of new outdoor sports facilities in suitable locations as the policy (criterion (a)) focuses on open space within new residential developments. In practice, developments will come forward for new outdoor sports facilities such as new or enhanced playing fields on the edge of urban areas or in the countryside and it is important that a positive policy approach is taken to help community sports facility needs (as identified in the Council's Playing Pitch Strategy) to be met as proposals for such facilities can sometimes conflict with other planning policies and a clear policy approach is therefore considered necessary. A positive approach to new outdoor sport/open space would also allow the policy to accord with paragraph 70 of the NPPF.
* In relation to outdoor sports facilities, it is unclear what the approach to provision in new development will be as the Council's evidence base (Playing Pitch Strategy) did not recommend standards for this type of open space provision. Furthermore, with the exception of some of the strategic allocations, it will not be justifiable or appropriate for most residential developments to make on-site outdoor sports provision. Clarity is therefore needed on the approach to outdoor sport especially as the policy advises that exceptions to criterion (a) will only be made in exceptional circumstances. For outdoor sport, in practice it will be the exception for developments to make on-site provision so it is considered that this approach is too generic for applying to all open space types. It is considered that financial contributions towards delivery of projects identified by the Council in the playing pitch strategy would be the most appropriate solution unless direct on-site provision is required as set out in master plans for the strategic allocations.
* The reference in the supporting text implies that developments of less than 200 dwellings will generally not be required to make any open space provision. This is of concern given that the majority of new residential developments will be less than 200 dwellings in scale and collectively these developments will create significant additional demand for open space including outdoor sports facilities. Unless such development makes additional provision for meeting the needs that it generates, there is a concerns that pressure will be placed on existing facilities which may not be accessible or have the capacity for meeting these needs. While it would not be appropriate for smaller developments to make on-site provision they should be required to make financial contributions as the evidence base has identified needs for new or enhanced provision to meet future needs which is not linked to the scale of residential developments. A reference to the need for all new residential developments to make provision for open space including outdoor sport is considered to be justified therefore

Allotment Provision in Baldock
In the NHDC Local Plan 2011 - 2031 it states in Paragraph 11.28 that the Council has an Allotments Action Plan (AAP), and in paragraph 11.30 that "No new allotment sites are designated in this plan. However, the Council will require appropriate contributions towards allotment provision given the demand for allotment space". The current version of the AAP does not address the demand for allotments in Baldock.
In paragraph 13.15 the population of Baldock in the 2011 Census is given as 10,280 people in 4,491 dwellings. BALGA manages the 2 largest allotment sites in Baldock for NHDC, and has currently 185 tenanted allotments, and 19 untenanted allotments. The Local Plan requires 3136 extra dwellings to be built in Baldock up to 2031. By simple mathematics Baldock currently requires 41 allotments per thousand dwellings. Hence by 2031 the 3136 new dwellings could generate a demand for some 130 extra allotments, and we have available only 19!
If the Allotment Action Plan is updated, will this be taken into account? Since the AAP is for only 5 years, is it of any help alongside The Local Plan period of 2011 to 2031? It seems unlikely if no new allotment sites are planned!
BALGA has some undeveloped allotment land at North Road site, which could provide some 15 extra plots. However, Herts County Council owns a field adjacent to the North Road allotment site, currently used as set-aside, which could provide a further 60 plots if leased to BALGA. Also Herts County Council own the land to the west of Clothall Road Allotment site, and BALGA have previously discussed with them the lease of land to add a further 30 plots. However, BALGA would need significant capital to develop these areas as allotments, as they would need to be fenced and ploughed, and supplied with water. Paragraph 11.30 suggests that CIL could be used for this, if allotment provision is included in development funding (which is not currently allowed for by NHDC in its Section 106 provision). Is it a reasonable supposition that NHDC would provide funding, and Herts County Council would be willing to lease this land to BALGA?
Can the provision of Allotments in Baldock be directly addressed in the next version of the Allotment Action Plan?

we support this policy and are satisfied that our previous comments have been incorporated

Environment Bank welcomes the opportunity to briefly respond to the Consultation for North Hertfordshire District Council's Local Plan 2011-2031 Proposed Submission Draft. We support Policies SP12: Green infrastructure, biodiversity and landscape, SP14, SP18 and SP19, along with points 4.76, 4.185, 11.38, 11.39 and 11.48, and their requirements for No Net Loss / Net Gain of biodiversity, metric assessments of biodiversity impacts and offsetting to deliver compensation.

About us:
Environment Bank is a private company working to broker biodiversity compensation agreements - offsets - for developers and landowners. We act as impartial advisers to Local Planning Authorities and are experts in biodiversity impact assessment and No Net Loss (NNL) strategies. We have partnerships and support relationships with over 25 LPAs across 15 counties - providing advice on local policies, planning guidance and strategies, together with support in implementation and individual planning cases. We have seen biodiversity No Net Loss, Net Gain and offset policies be adopted in Local Plans across the country.

Working on individual developments on behalf of developers and planning authorities we calculate the biodiversity impacts and enhancements of development proposals using approved Government metrics, determining residual biodiversity losses, if any, and proposing offset solutions. Our ecological experts then match a developer's compensation requirement with sites put forward by landowners and conservationists who undertake biodiversity enhancements on their land to generate conservation credits available as compensation. Offset schemes must be the right type of site, of the right size, in the right place, at the right time, for the right cost. Credits are sold in exchange for the creation or enhancement of habitats, generating biodiversity gain. Thereafter, legal and fiscal systems assure planning authorities that such compensation measures have been arranged independently and delivery will be overseen and guaranteed in the long-term, providing net biodiversity gain across a district.

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