ED191A

Showing comments and forms 1 to 7 of 7

Object

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

Representation ID: 8812

Received: 23/06/2021

Respondent: Save Our Green Belt

Representation Summary:

See full text; significant oversupply of new homes, MHCLG targets are incorrect

Full text:

The position of the many people supporting the Save Our Green Belt group remains unchanged, despite the further modifications implemented and consulted upon now.

1. It is clear from these modifications that the population increase envisaged has not evolved and that the provision of New Homes will result in a significant oversupply.
2. As a consequence of incorrect MHCLG housing targets as confirmed by the Office for National Statistics (ONS), the target number of homes is at least 4 times and possibly 5 times the number actually required.
3. The decision to leave the additional 5,500 homes to the west of Stevenage safeguarded and not bring them forward in the first instance despite their close proximity to a major Town and consequent established urbanisation, has placed unnecessary pressure on many Villages, relied upon to infill in completely unsustainable locations, to support an irrelevant five year housing supply plan, which is totally unjustified.
4. In the age of the Covid pandemic, poor air quality and the growing need for climate change, there remains little justification in removing land from the protected Green Belt to build homes to support 90% of your intended development options.
5. As a consequence of the changing mood in government, society and the forgoing facts, the development of the “Villages for Growth” and those areas east of Luton are entirely incorrect and unjustified and therefore should be completely removed.
6. There are many other facts and objections raised previously by our group that remain unresolved by your modifications despite bringing those to the attention of the NHDC and the Planning Inspector previously.
We await the decision of the Inspector where it is hoped that common sense will prevail, failing which a statutory review will be requested.

Object

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

Representation ID: 8873

Received: 24/06/2021

Respondent: Landhold Capital on behalf of Southern & Regional Developments

Agent: Claremont Planning Consultancy

Representation Summary:

See Attachments - detailed comments on housing trajectory, allocated sites, five-year supply and delivery in ED191B

Full text:

See Attachments

Object

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

Representation ID: 9006

Received: 24/07/2021

Respondent: Bulger Group

Agent: ROK Planning

Representation Summary:

See Attached; Detailed commentary on OAN, 2014-based figure of 13,800 should be used

Full text:

See Attached

Attachments:

Object

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

Representation ID: 9306

Received: 23/05/2021

Respondent: NHDC Ermine Councillor

Representation Summary:

Schedule of Further Proposed Modifications to the North Hertfordshire Local Plan 2011-2031

MM010/FM039 Page 32

The phrase will be delivered is incorrect. The Inspector and NHDC do not have the power to guarantee delivery. Delivery is dependent upon economic circumstances, democracy and the desire of the landowner to develop.

MM213/FM108 Page 143

This paragraph seeks to justify a disproportionate amount of development in Barkway; reasoning that it has the largest in population terms of the three villages to the east of the A10 and south of Royston.

The population of Barkway is virtually the same as the population of Barley. In any event the size of the village is irrelevant. As Officers and the Inspector know, development is based upon other factors, sustainability, proximity to services, employment and availability of land. As the Inspector and Officers also know, Barkway has few services and yet Barley has more, yet Barley has not been categorised as a village for growth, whilst Barkway strangely has. Barley is also closer to the numerous missing services, which are located in Royston.

MM216/FM112 Page 144

The new suggestion of a contribution towards travel by sustainable modes of transport between Barley and Barkway schools it's not realistic. There is no other source of money available to provide this service; therefore it would have to use all the S106 contributions, leaving nothing for Barkway village in general. This benefit would then be shared 50-50 between Barkway and Barley, with Barkway only benefitting in part. The cost of providing this transport, effectively in-perpetuity, will far exceed any S106 money that is likely to be available (circa £500,000.00). The Parish Council has already been consulted and agreed how any S106 money could be allocated. This proposal contradicts that agreement.

MM219/FM114 Page 144

The NHDC Officer responsible for preparing the Plan, Recommended that site BK3 be removed from the ELP. He prepared a well argued report explaining why. The Inspector has decided that the Officer's report justifying the removal of BK3 is not relevant, thereby leaving BK3 within the ELP. The Inspector has not produced any report explaining why he reached his decision.

It should be remembered that the NHDC Plan Officer has lived with the evolution of this Plan over several years and has a better understanding of it than anybody else.

It cannot be acceptable to ignore the Officer's recommendation without providing a well argued reason why.

The ELP was submitted to the NHDC Cabinet 16th March 2021 and approved at that stage with BK3 included. The Cabinet were not able to understand any rationale as to why BK3 was included and not excluded. Therefore the Cabinet took their decision to approve with insufficient information. This decision and all the background arguments must render the Plan unsound and likely subject to Judicial Review.

It has also been explained to me by two NHDC Officers that the actual reason for not removing BK3, was that it would be too controversial. In that it would encourage other selected settlements to argue as to why their selected sites should not be removed.

New Issues.

Barkway has now been selected as a village for growth. The Officer and Inspector acknowledge that Barkway has limited services et cetera. Yet Barley, is acknowledged as having a far greater selection of services has not been categorised as a village for growth.

This, is not logical. The selection of Barkway as a village for growth, is clearly not based on the suitability of the village, only that there is a large piece of land potentially available. Discounting the negative consequences of this recommendation. Particularly the largest employer in the area, Newsells Park Stud.

The Office for National Statistics.

The ONS has reduced housing numbers in North Hertfordshire.

Originally housing numbers in North Herts were calculated at approximately 14,500 Plan ending 2031 (Excluding unmet needs but including a buffer of around 8% or approximately 1,160 houses).

However because of the current modifications by the ONS, these numbers are being reduced from 14,500 to around 11,500. A similar 8% buffer within this new figure of 11,500 would amount to 920 extra homes. In terms of selected sites, the ELP is much as it was, thus Increasing the buffer to approximately 37% or 3,920 homes).

This buffer is far too high.

This results in what now appears to be an unnecessary threat to some greenbelt, when there is little prospect of houses being built on much of this valuable greenbelt within the Plan period.

It would make more sense for the Inspector to include a reasonable buffer and remove land that is perhaps of marginal suitability in particular greenbelt.

The consequence of this strange way of doing things; is that some homeowners, who live close to selected sites including greenbelt are having their properties unnecessarily blighted and many suffering stress; whilst I appreciate that house prices are not a planning issue. This blight is completely unnecessary.

In addition, some tenant farmers that are renting land that is in green belt are also under the wrong impression that some of their land will be taken from them for housing. This has the effect of not only subjecting them also to unnecessarily stress but stopping them investing in their businesses because they think some or all of their land will be sold off shortly.

The obvious option, is for the selected sites to bear a realistic relationship to the ONS housing numbers.
The Inspector should include a sensible buffer of around 8% and take out specific sites that are less suitable for development.

I understand the reason for this weird way of doing things. Is that it is easier for the Inspector and for those involved to leave all the sites in.

Green Belt.

Government says time and again, that they will "continue to protect and enhance the greenbelt". Yet, it will permit NHDC to build on it.

Finally, it is disappointing that of the thousands of representations submitted by a concerned public and many organisations. Not one site has been removed from the ELP.

We have spent an enormous amount of time and emotional effort in trying to steer the Plan in a realistic direction all without success.

Pity that the public are ignored.

Full text:

Schedule of Further Proposed Modifications to the North Hertfordshire Local Plan 2011-2031

MM010/FM039 Page 32

The phrase will be delivered is incorrect. The Inspector and NHDC do not have the power to guarantee delivery. Delivery is dependent upon economic circumstances, democracy and the desire of the landowner to develop.

MM213/FM108 Page 143

This paragraph seeks to justify a disproportionate amount of development in Barkway; reasoning that it has the largest in population terms of the three villages to the east of the A10 and south of Royston.

The population of Barkway is virtually the same as the population of Barley. In any event the size of the village is irrelevant. As Officers and the Inspector know, development is based upon other factors, sustainability, proximity to services, employment and availability of land. As the Inspector and Officers also know, Barkway has few services and yet Barley has more, yet Barley has not been categorised as a village for growth, whilst Barkway strangely has. Barley is also closer to the numerous missing services, which are located in Royston.

MM216/FM112 Page 144

The new suggestion of a contribution towards travel by sustainable modes of transport between Barley and Barkway schools it's not realistic. There is no other source of money available to provide this service; therefore it would have to use all the S106 contributions, leaving nothing for Barkway village in general. This benefit would then be shared 50-50 between Barkway and Barley, with Barkway only benefitting in part. The cost of providing this transport, effectively in-perpetuity, will far exceed any S106 money that is likely to be available (circa £500,000.00). The Parish Council has already been consulted and agreed how any S106 money could be allocated. This proposal contradicts that agreement.

MM219/FM114 Page 144

The NHDC Officer responsible for preparing the Plan, Recommended that site BK3 be removed from the ELP. He prepared a well argued report explaining why. The Inspector has decided that the Officer's report justifying the removal of BK3 is not relevant, thereby leaving BK3 within the ELP. The Inspector has not produced any report explaining why he reached his decision.

It should be remembered that the NHDC Plan Officer has lived with the evolution of this Plan over several years and has a better understanding of it than anybody else.

It cannot be acceptable to ignore the Officer's recommendation without providing a well argued reason why.

The ELP was submitted to the NHDC Cabinet 16th March 2021 and approved at that stage with BK3 included. The Cabinet were not able to understand any rationale as to why BK3 was included and not excluded. Therefore the Cabinet took their decision to approve with insufficient information. This decision and all the background arguments must render the Plan unsound and likely subject to Judicial Review.

It has also been explained to me by two NHDC Officers that the actual reason for not removing BK3, was that it would be too controversial. In that it would encourage other selected settlements to argue as to why their selected sites should not be removed.

New Issues.

Barkway has now been selected as a village for growth. The Officer and Inspector acknowledge that Barkway has limited services et cetera. Yet Barley, is acknowledged as having a far greater selection of services has not been categorised as a village for growth.

This, is not logical. The selection of Barkway as a village for growth, is clearly not based on the suitability of the village, only that there is a large piece of land potentially available. Discounting the negative consequences of this recommendation. Particularly the largest employer in the area, Newsells Park Stud.

The Office for National Statistics.

The ONS has reduced housing numbers in North Hertfordshire.

Originally housing numbers in North Herts were calculated at approximately 14,500 Plan ending 2031 (Excluding unmet needs but including a buffer of around 8% or approximately 1,160 houses).

However because of the current modifications by the ONS, these numbers are being reduced from 14,500 to around 11,500. A similar 8% buffer within this new figure of 11,500 would amount to 920 extra homes. In terms of selected sites, the ELP is much as it was, thus Increasing the buffer to approximately 37% or 3,920 homes).

This buffer is far too high.

This results in what now appears to be an unnecessary threat to some greenbelt, when there is little prospect of houses being built on much of this valuable greenbelt within the Plan period.

It would make more sense for the Inspector to include a reasonable buffer and remove land that is perhaps of marginal suitability in particular greenbelt.

The consequence of this strange way of doing things; is that some homeowners, who live close to selected sites including greenbelt are having their properties unnecessarily blighted and many suffering stress; whilst I appreciate that house prices are not a planning issue. This blight is completely unnecessary.

In addition, some tenant farmers that are renting land that is in green belt are also under the wrong impression that some of their land will be taken from them for housing. This has the effect of not only subjecting them also to unnecessarily stress but stopping them investing in their businesses because they think some or all of their land will be sold off shortly.

The obvious option, is for the selected sites to bear a realistic relationship to the ONS housing numbers.
The Inspector should include a sensible buffer of around 8% and take out specific sites that are less suitable for development.

I understand the reason for this weird way of doing things. Is that it is easier for the Inspector and for those involved to leave all the sites in.

Green Belt.

Government says time and again, that they will "continue to protect and enhance the greenbelt". Yet, it will permit NHDC to build on it.

Finally, it is disappointing that of the thousands of representations submitted by a concerned public and many organisations. Not one site has been removed from the ELP.

We have spent an enormous amount of time and emotional effort in trying to steer the Plan in a realistic direction all without success.

Pity that the public are ignored.

Object

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

Representation ID: 9641

Received: 19/06/2021

Respondent: Mr & Mrs Tom & Kate Sargent

Number of people: 2

Representation Summary:

See full representation

Full text:

We would like to make the following representations in response to the latest consultation on the further proposed main modifications to the NHDC Local Plan 2011-2031.
1. ED172 references the Green Belt review. With reference to site 328 in particular (currently within the Green Belt), a SHLAA was carried out in 2016 that established this site as having not passed its tests and unsuitable for development for heritage reasons. Furthermore, this site has recently been rejected for development on the basis of its ecological and heritage value. However, the site continues to be proposed within the Ickleford Village boundary, converting to 'White Land', even though the reasons for its unsuitability will never change. The change of designation is inconsistent with the selection process articulated within document ED172 and we request that the site is removed from the village boundary and restored to its current Green Belt status.
2. ED191A references the OAN figures for North Herts based on a 2018 assessment point. Although these figures have reduced since the previous assessment, following both Brexit and the pandemic, it is now wholly appropriate to entirely revisit the future need for housing within NHDC. As you will of course be aware, these two events have seismically changed the landscape for housing demand. Brexit has already seen large volumes of population return to their EU nation countries. The pandemic promises to fundamentally shift the relationship between people's places of residence and their place of work and is already leading to an increase in housing demand in more rural areas, far beyond Hertfordshire's boundaries. This trend will surely only continue and we therefore request that these macro trends are given due consideration when using this data to inform policy decisions.

Support

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

Representation ID: 9750

Received: 24/06/2021

Respondent: Bellcross Homes and Gallagher Developments Ltd

Agent: Rapleys LLP

Representation Summary:

See attached - support relevant conclusions of this document

Full text:

See Attached

Object

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

Representation ID: 9808

Received: 17/06/2021

Respondent: Save The Worlds First Garden City

Representation Summary:

See attached; detailed commentary on OAN, choice of variant and uplifts

Full text:

See Attached

Attachments: