Policy SP1: Sustainable Development in North Hertfordshire

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I make this response on behalf of the Pirton Neighbourhood Plan Steering Group.
We have worked closely with the NHDC Planning Policy Team in the development of our draft Neighbourhood Plan to ensure that the Pirton Neighbourhood Plan is in general conformity with the current planning policies and also that it will be in general conformity with the strategic policies of the Proposed Local Plan. We therefore confirm that in our opinion the Proposed Local Plan has been positively prepared, is justified, effective and consistent with National Policy.
The District must plan for significant new housing development to 2031. The process of developing the Pirton Neighbourhood Plan has meant that the Pirton Community. has given considerable thought to housing development here, both in terms of numbers, and but also in terms of type and design. At the time of the Parish Plan in 2013, 36% of the community wanted no further development for the village. Now, the community will support an increase of a minimum of 17% in our housing stock over the period of the proposed Local Plan- provided it is of the type, density and design that the community consultation process of Neighbourhood Planning has identified, and provided applications for planning permission respect our policies in relation to matters such as traffic and transport safety, heritage, biodiversity, and green space. We urge the NHDC to give greater encouragement and support to Neighbourhood Planning as a tool to assist effective implementation and to set itself targets in relation to Neighbourhood Planning in policy SP1.
Traffic levels, and improvements to the infrastructure of our roads, as well as improvements to public transport, will be very important. The amount of planned housing development will make great demands on the road and public transport networks. This must be addressed as a priority if North Herts is not to grind to a halt, or the health and well-being benefits of living in a district full of beautiful countryside are not to be eroded. These are issues of considerable importance to the community of Pirton as reflected in the consultations held during the development of the Neighbourhood Plan for Pirton.

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National policy on Green Belts not adhered to. Does not meet exceptional circumstances.
The vast majority of proposed new dwelling are in current Green Belt. (60% proposed dwellings within green belt despite the fact 2/3 of district land is outside green belt).

One of the five purposes of Green Belts as stated in the National Planning policy framework is "To assist in urban regeneration by encouraging the recycling of derelict and other urban land". The NHDC Green belt review part 1 recognises this in "Assessment against Green belt principles" (paragraph 32 and table 2) However this criteria is not included in Table 5: Assessment of Existing Green Belt. The purpose of the proposed removal of Green Belt to the east of Luton (in Sector 2 EL1 EL2 & EL3) is to meet the wider needs of the Luton housing market area. The destruction of the Green Belt to allow the development of 2100 new sites will effectively result in Luton extending into rural Hertfordshire. This significant number of sites will logically have an effect on the will to and cost effectiveness of recycling derelict and other urban land in Luton. Since urban regeneration is one of the five purposes of a Green Belt I feel this factor should have been included before the report recommended the significant destruction of Green Belt to the east of Luton. I could find no evidence of this having been done in any of the documentation. The assertion in the Green Belt review that "the fifth purpose has not been considered as the other four purposes are all deemed to contribute to urban regeneration" does not really hold water when considering destroying a significant portion of green belt which is currently constraining the spread of urban Luton to the east. The stated purpose of destroying the Green Belt to allow development to the east of Luton is to address housing needs of Luton not NHDC so there should be documentation of the effects this development will have on urban regeneration in Luton.
The green belt review is flawed. Luton is not included as a historic town.
The plan is contrary to national policy to prevent urban sprawl. The plan is not in line with Luton Borough council's statements on importance of Green Belt.

For these reasons I object to the Green Belt review and therefore Policy SP5 which references it.

The creation of vast new areas of Green Belt between Hitchin/Stevenage and Luton will make it increasingly difficult to provide for any future housing need.
The current Green Belts are stopping the current urban areas from spreading. If they are allowed to do so and all the land between them is made new Green Belt then the next time there is a need to provide more housing the only option will be to (again) allow the expansion of these settlements by destroying more Green Belt.
A genuinely plan led solution may see benefit in retaining current Green Belts. This would encourage Urban regeneration (of which there is a lot of land to redevelop in Luton). Further need could be provided by expanding current settlements outside of the Green Belt or creating new settlements such as a new Garden City.

NHDC have not demonstrated the exceptional circumstances required to justify destroying the Green Belt east of Luton.
NHDC in 4.221 reference Sir Michael Heseltines "leave no stone unturned" quote as justification (point 69). The report in question relates to growth and I could find no reference to it justifying destroying Green Belt. I did however find the following quote from Sir Michael Heseltine "It does indeed seem ridiculous that we should be scrabbling around for land in the South East - even contemplating the destruction of the green belt - when such a large and strategically-located area is in such obvious need of regeneration."

The assumptions made in the Draft Sustainability appraisal seem very biased and potentially flawed. In Table 4 What would happen without the plan? to sum up most of what could happen without a local plan "national policy might protect you but we might be able to do things better with a local plan". OK - now where's the table listing what could happen with the proposed local plan? (you're village / hamlet is subsumed into a neighbouring councils town and all the buses taking pupils to school miles away are increasing traffic and CO2 emissions). That outcome is a lot more likely than half the possibilities mentioned in the report. The sustainability appraisal is one long extremely biased piece of scaremongering propaganda and a document so lacking in facts or balanced predictions has no place being included in this process. I object to policy SP1 and the sustainability report.

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