FM 190

Preston Parish Council supports this new policy to review the Plan by end of 2023 to ensure up to date information is taken into account until the end of the Plan period in 2031.

FM190 states a whole plan review will occur by the end of 2023. FM193 says a whole plan review will commence by the end of 2023. Are these referring to the same review and if so can it be made clear when the review is expected to start and end?

‘The Council will undertake a whole plan review of the Local Plan 2011-2031 by the end of 2021 at the latest….’
There is a need to review housing requirements so that there is no unnecessary development on good agricultural land.

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I write on behalf of the parish of Langley in respect of the consultation related to the plan for the West of Stevenage planned developments.

There is considerable concern in Langley about the removal of the Green Belt status for a range of reasons which have been documented in detail.

The latest concern which gives the most objection to date is the proposal written as a plan to "Safeguard" the land marked in the documentation as "Amber". This proposal does not represent safeguarding and is a complete misnomer. It is completely inappropriate to identify this particular area of land as suitable for removal from the very important protection offered by the Green Belt status.

I wish to refer the Planning Inspector's attention to several matters covered by NHDC's Main Modifications.

The significant document produced by NHDC is for me the one relating to OAN and supply of housing - ED171.

I quote from H.M. Inspector's letter of 9 July 2019:

"Para 21: In different circumstances, that might not be a shortcoming. The problem here, however, is that the land proposed for that purpose is in the Green Belt, and exceptional circumstances must be demonstrated to exist to justify its ‘release’. This is a high bar. I am concerned that, in order to overcome it, it may be necessary to show (through a comparative assessment of the kind I have described above) that the sites involved are preferable to all other potential options. I am struggling to understand how exceptional circumstances can exist if one is left wondering whether there might be preferable options elsewhere within the applicable housing market area.

Para 22: This is a point that was taken up by Natural England in its response (dated 30 November 2016) to the Proposed Submission Local Plan consultation. In section 8 of that letter, Natural England says “There hasn’t been an adequate assessment of alternatives [to the East of Luton sites]. The Sustainability Appraisal should set out alternative locations/sites considered to meet the housing need elsewhere …"

There has been no consideration of Density ever relating to OAN, nor in NHDC's general planning and developments built over the years previous to the Local Plan. Attached is a list of all the sites in the NHDC Local Plan and their size. The average density is worked out at 18.7, which is extremely low, considering that NHDC know they have a real problem with sites. NHDC Planners have instead chosen to squander land that was available to them with impunity. eg the Geoff King site in Letchworth - Blackhorse Road - low density housing on brownfield.

CPRE representatives from London and Hertfordshire Groups have met with the Planning staff at NHDC and local Councillors and residents concerned about NS1 to discuss this problem in 2020 - all ignored by the Planning staff present at the meeting.

Were NHDC to build at a higher density, in brownfield sites, places now available in empty retail areas - eg Letchworth Town Centre (many empty sites because of the effects of the pandemic) there would be no need to build on Green Belt sites at all. Certain Green Belt sites could be excluded from the Local Plan - eg the 900 houses planned for NS1. NHDC are intransigent on this and fail to see the opportunities to build at a higher density in town centres to satisfy the needs of young and old people instead of using up precious Green Belt areas. The government does see the value of building in Town Centres.

Below is correspondence between myself and my local M.P. who has appeared at the NHDC Local Plan to oppose building on Green Belt land in the countryside.

Thank you for contacting me about planning reform.

The government is aware of the benefits of increasing density in city centres, as a way to tackle the housing shortage. The Local Housing Need will be increased by 35 per cent for areas with the largest proportion of the 20 most populated cities and urban centres in England. This is one of the ways the government is working to protect greenbelt land.

Bim Afolami MP
Member of Parliament for Hitchin and Harpenden
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Peers
Sent: 21 June 2021 13:46
To: AFOLAMI, Bim
Cc: Stephen McPartland MP
Subject: Doubling the density - halve the land needed

Hi Bim

This is such an interesting read and makes perfect sense, though totally ignored by NHDC Planning staff:

Space to Build: double the density, halve the land needed - CPRE Londonhttps://www.cprelondon.org.uk/news/space-to-build-double-the-density-halve-the-land-needed/

I have in the past mentioned the very successful Goldsmith Street dwellings in Norwich to the Councillors in NHDC who liked them. The occupiers love them because they look good and have cheap eco heating.

Can you mention this to your friend Boris Johnson today and MCLG ?

Best wishes

Norgan

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There is also the problem of Land Banking. The result of this issue is that we have a problem in North Herts when the issue could be resolved by the government.

Land Banking: 10 Jun 2021: House of Commons debates - TheyWorkForYou

FM028: There has been a severe lack of engagement between NHDC and the general public/communities.

I attended, as a Parish Councillor for Graveley a "Planning Training Meeting" held by NHDC Planning staff at which there was a near riot of complaints by many of the Parish Councillors attending because of the NHDC Planning staff preferring not to listen to what Parish Council representatives wished to do - ie they did not want to adopt the Council's proposal concerning S.106 payments and stating to developers what items they wanted S.106 monies for when planning application decisions were decided upon when they knew that their communities certainly did not want Green Belt built on - because of mistakes made in the numbers. The Planning staff themselves said that their role was to help developers, not find fault with the Local Plan.

Response to the Times front page on housing building target analysis by the Campaign to Protect Rural England - MHCLG in the Media (blog.gov.uk)

The Further Main Modifications change the context for policies in the LP, and this justifies further representations which the Inspector should take account of in his final report.

In para. 2.8 of the Further Main Modifications, the North Herts population is stated as “likely to be” 7,000 fewer than assumed in the submitted LP. This figure is itself based on 2016 Office of National Statistics (ONS) population and household projections which are higher than the later 2018-based projections which were published in 2020.

Whilst the proposed text states that the Objectively Assessed Need (OAN) is 11,500 houses, reduced from the submitted LP total of 13,800 houses, this does not take account of the impacts of Covid or Brexit which have occurred since the ONS projections and which are likely to reduce housing need further. Clearly it would be wrong not to use the latest information available.

In any case, the reductions in housing need noted by the Inspector are not reflected in any diminution of the amount of Green Belt to be released for housing in the LP. This means that the allocations of present Green Belt sites are unsound in that they do not reflect the lower housing need stated in Policies SP2 and SP8.

These issues underline the need for the Inspector to draft his Report to reflect the latest information available as required by Government planning guidance.

Review

NHDC promises an early review, not later than 2023. What exactly is to be reviewed is not clear. Will it be a review of the need for a buffer? Will it be wider ranging: an adjustment of the OAN in the light of still further (highly likely) downward projections from ONS? If we don’t know, then the commitment is not robust. It is worth noting the inspector who approved Luton’s Local Plan stipulated a complete review should begin no later than 2019; it certainly did not start then and it is unclear whether any start has been made to date. The Luton inspector specifically asked for this review in order that neighbouring authorities could be updated on their commitment under ‘Duty to Cooperate’. Luton’s failure means NHDC cannot update its OAN. The trouble with such reviews is there seems to be no sanction or enforcement if they are started late or not at all. The situation passes out of the control of the inspector or any provision of public scrutiny. Therefore the issues in need of review must be made clear and those issues resolved now, in the open while the public inquiry is still in session.

Instead of the review the Luton inspector intended, we have ED224: a “statement of common ground” in which NHDC, CBDC and Luton BC have consorted with Bloor Homes and the Crown Estate to argue that, in essence, the commitment to the original OAN figures must stay untouched. Such a collaboration between bodies whose interests and functions are (or should be) entirely separate is wholly inappropriate. Planning authorities should (and be seen to) act in the public interest and should not confuse their purpose by so closely consorting on policy with landowners and developers whose motive is speculative profit. One returns to the question again: why is NHDC moving heaven and earth to keep as high an OAN as possible? We need transparency that motives are untainted, especially as the baneful effect of the “Land Industry” on the housing market is an issue of current public concern. See Bradley:

www.http://criticalplace.org.uk/2020/01/29/housing-land-speculation-in-planning-policy/

While the question remains, ED224 must be disregarded.

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HCC welcomes the opportunity to provide comment on the Schedule of Further Proposed Modifications to the North Hertfordshire Local Plan 2011-2031.

HCC wishes to make the following comments which are in chronological order, mirroring the organisation of the document itself.

• MM043/FM065 - HCC welcomes the commitment to review the plan by the end of 2023.
• MM045/FM001 - HCC welcomes the added detail included in Policy SP9.
• FM067 - HCC welcomes the specific reference to secondary education provision for the Stevenage area requiring monitoring of demand to inform the local plan review.
• MM215/FM111 and MM216/FM112 - HCC acknowledges the modification in response to the hearing sessions and welcomes the need for a sustainable travel solution between the federated schools in Barley and Barkway to support these developments.
• MM219/FM114 - HCC agrees with the updated wording.
• MM227/FM123 - HCC considers that added wording included in modifications MM224 through MM226 of ‘Contribution towards expansion of Codicote Primary School’ ought to also be included for this modification in relation to Policy CD5.
• MM286/FM145 - HCC welcomes the removal of the wording ‘1FE’ to enable effective school planning based on the most up-to-date data available.
• FM 173 (para 13.300) - The policy should reference the west of the town rather the east in terms of new school provision
• FM190 - HCC welcomes Policy IMR2 and the commitment to an early Local Pan review.

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The attached document identifies points in the text that in our view need to be clarified for soundness of the Local Plan. These points are offered as comments rather than by way of objection or approval. As required, the comments apply to the proposed changes shown in bold, red style and the immediate contexts that affect, and are affected by, the meanings of the proposed modifications.

The document is in Adobe Portable Document Format (PDF) and each comment is marked via two kinds of annotation:
• highlighting of the words referred to, unless that's an entire paragraph, and
• a 'speech bubble' to state our suggestion or query about the item.

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