1.3 What is the Plan About?

Further to our letter of 13 May 2016 to Pirton Parish Council about the draft Plan, Campaign to Protect Rural England (CPRE) Hertfordshire wishes to make the following representations on the Pirton Neighbourhood Plan (PNP). As with the consultation draft, the most important of these relate to the Plan's conformity with the Development Plan (a basic condition), and the assumptions made by the Parish Council in respect of the content of emerging North Hertfordshire Local Plan.

Paragraph 1.3.7, Village Development Boundary, and Preferred Options Map.

There is no explanation or justification in the PNP for the proposed change to include site PT1 within the redefined village boundary, other than to conform with the proposed boundary shown in the emerging North Herts Local Plan (NHLP) which has not yet been submitted for independent examination. Similarly, the Preferred Options Map has little status at least until the NHLP has been examined.

The proposed south-western boundary is currently defined by the Adopted North Herts District Local Plan (NHDLP), and this still reflects local landscape character. Indeed site PT1 and the adjacent land to the north-west are part of the same landscape character area, V2, shown in the PNP's evidence base, and not within the village itself. The proposed boundary would effectively split this local character area in two for no sound reason. The separate designation of PT1 as a scheduled monument, also referred to on page 4 of the PNP, has no material bearing on this boundary change.

A statutory requirement of the PNP is to conform to the Development Plan, in this case the NHDLP, not the proposed submission NHLP, which is still at an early stage in its progress, and which can therefore be given limited weight in decision making. Consequently in our view the PNP fails this basic condition because the adopted 'Rural Areas beyond the Green Belt' policy is strategic, and still consistent with national policy as set out in the NPPF in terms of countryside protection, and the proposal to amend the village boundary conflicts with it.

CPRE Hertfordshire is concerned that the inclusion of site PT1 within the defined village boundary would threaten not just future development, but also the release of the adjacent land within the same local landscape character area and which also abuts the Chilterns AONB. Both fields are highly prominent in views from the AONB as shown in the Plan's evidence documents, and which other policies in the PNP, and paragraph 14 and footnote 9 of the National Planning Policy Framework (NPPF) seek to protect at both local and strategic levels.

CPRE Hertfordshire therefore considers that there is a risk that the PNP would fail to satisfy the 'basic condition' of compliance with the statutory Development Plan with the above elements of the Plan as currently drafted.

Policy PNP2 - Design and Character

CPRE Hertfordshire suggests that paragraph 2.6 should be amended to delete from the end of this sentence the phrase 'or provide a convincing explanation why compliance is not possible' as we consider such phrase unenforceable by the District Council.

For the above reasons CPRE Hertfordshire considers that amendments should be made to the PNP before it is submitted for examination.

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