1 INTRODUCTION

Missing viable from the Venn diagram

I am writing on behalf of Hitchin Forum to say that we are in agreement with the aims of the draft Sustainability SPD, which has clearly been compiled with much careful thought.

Having recently visited the show homes at Hurlocke Fields, Hitchin, it is clear that the document is much needed. The internal design of the homes makes excellent use of space, and the design and specification of the properties is varied. Whilst they appear to be well-insulated, it is very disappointing that the developer has installed gas boilers rather than heat pumps. There are no solar panels and no provision for electric vehicle charging. The estate itself creates an atmosphere of sterility - there are no trees there appears to be a high proporton of hard, possibly impermeable surfaces.

Apparently the next development to be built by Cala Homes in Hitchin will include some of these features. Whilst the draft Sustainability SPD will not be statutory we hope it can be effective in encouraging more sustainable developments in future.

Will you stop wasting council taxpayers money on stupid sustainability planning.
The reason our council taxes are so high is because this council is wasting money on virtue signalling projects rather than looking after the residents needs.

National Highways welcomes the opportunity to comment on the North Herts Sustainability Supplementary Planning Document which forms part of the North Hertfordshire Local Plan 2011-2031.

National Highways has been appointed by the Secretary of State for Transport as strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN). It is our role to maintain the safe and efficient operation of the SRN
whilst acting as a delivery partner to national economic growth.

In relation to the North Herts Sustainability Supplementary Planning Document Draft, our principal interest is in safeguarding the operation of the A1 in the area.

We understand that a Sustainability Supplementary Planning Document is required to provide information as to the council's sustainability expectations for development in
North Herts and to offer good practice guidance to residents and developers when developing proposals and submitting planning applications. The document has been
prepared to support Policy SP1 (Sustainable Development in North Hertfordshire), Policy D1 (Sustainable Design) and other relevant policies in the adopted Local Plan.

The document does not incorporate any future developments, such as residential or employment, and thus no trip generation will be produced. It is noted that National Highways is consulted on regular basis in relation to any potential changes to the schemes and the potential impact on the SRN in the area.

We consider that the North Herts Sustainability Supplementary Planning Document is not expected to have any significant impacts on the operation of the SRN in the area.
It is considered that the plans set out within the document are unlikely to cause a severe impact on the operation or capacity of the SRN.

Henceforth, we have no further comments to provide and trust that the above is useful in the progression of the North Herts Sustainability Supplementary Planning
Document.

Thank you for consulting Transport for London (TfL). I can confirm that we have no comments on the draft Sustainability SPD

Thank you for the consultation on North Hertfordshire Council’s Draft Sustainability SPD. Please note the following response is made at an officer level.

We are supportive of the aims of the SPD to provide guidance on sustainable construction in North Hertfordshire, and to assist work in the planning sector to mitigate and adapt to climate change. We have no further comments.

I am writing to provide my comments on the draft Sustainability SPD, as requested through the public consultation exercise which opened on 4 January 2024 and closes on 16 February 2024.

I am a qualified actuary (with significant experience of scenario modelling), supportive of sustainable development and pleased to see that NHC has drafted an SPD covering this. I have a particular interest in planning for solar plants, so I have reviewed the draft Sustainability SPD with these developments in mind. Hence my comments are largely, but not exclusively, related to solar plant developments.

Page 5
This slide summarises and paraphrases the requirements of the National Planning Policy Framework (NPPF)
paragraphs 7 and 8; the source should be referenced.

The definition of the environment pillar should include the requirement of NPPF to make effective use of land. A
summary of the following requirements of NPPF paragraph 9 should be included (I have highlighted the key
requirements in bold): “These objectives should be delivered through the preparation and implementation of plans and the application of the policies in this Framework; they are not criteria against which every decision can or should be judged. Planning policies and decisions should play an active role in guiding development towards sustainable solutions, but in doing so should take local circumstances into account, to reflect the character, needs and opportunities of each area.”

Page 8
The penultimate paragraph refers to the “evidence” needed to comply with Local Plan policies. This is an area which I believe needs far more scrutiny by NHC and requirements need tightening up including:
• all claims made by applicants and their advisers need to be substantiated ie proven; it is simply not adequate
for claims to be taken at face value, especially not if those claims are to be taken into account by Planning
Officers in deciding whether or not to grant approval (through a delegated power) to an application or
recommend its approval to the Planning Control Committee. An example of this is the claims made by
developers with regard to the number of houses that a proposed solar plant would provide electricity for.
These have varied widely (after adjusting for the differing capacities of the developments) for different developments. Another example is the claim that a development will provide local employment. This should
be clearly specified, ie how many people and for how long, and adjusted to reflect any loss of employment.
For example, in the case of a solar plant, it is highly likely that construction work will be undertaken by experienced, established teams who operate nationally and monitoring carried out remotely (sometimes
overseas).
• where there is a conflict of interest and/or subjective views and assumptions are required, it is not appropriate
for NHC to rely on reports prepared by the applicant or parties appointed by them. In such cases, NHC
should take advice from parties appointed by them working to NHC’s (not the applicant’s) brief

Page 15
The first paragraph should be deleted. It doesn’t add anything to the SPD, it is not helpful, and it is potentially
misleading to quote a few modelling results without providing context. For example, what is the reader expected to read into the word “could” with regard to the various projected results? Presumably, the modelling work produced other results which do not show such extreme changes which “could” also be delivered.

Page 16
The information on the modelling work and recommendations of the Tyndall Centre are interesting but further information is required to give any meaning to these. For example:
 What are the current carbon dioxide emissions for North Hertfordshire?
 What are the projected emissions for North Hertfordshire?
 What actions has NHC agreed to take to reduce projected emissions for North Hertfordshire, what will be the impact of these and how much will they cost?
 Has NHC agreed to follow the recommendations of the Tyndall Centre? If so, what actions are to be taken
and what will be the cost of these actions?

I have been unable to find any information on the first three bullet points above either for North Hertfordshire or for NHC.

The words “Zero Waste” at the end of the second bullet point should be deleted.

Page 20
I support the requirement for a WLC emissions assessment to be undertaken. This would encourage developers to use more sustainable building materials and building methods and choose efficient sites for their developments. It would also have the advantage of addressing the issue of applications being made without full details of the build (including materials to be used and where they will be manufactured) being made available. The embodied carbon of a solar plant is highly dependent on the materials used for the solar plant. For example, in the UK, solar panels are usually made from crystalline PV but this has a much higher level of embodied carbon than CdTe which could be used instead. Looking at the whole life of the solar plant would require projections to be made of the carbon savings for each year that the solar plant is in operation. This would mean that account would be taken of the reduced efficiency, year on year, of PV panels, as well as the decarbonisation over time of the National Grid. Both these factors would result in reduced carbon savings year on year. Currently, developers typically quote (unsubstantiated) first year operational carbon savings which give a misleading picture of the savings over the lifetime of the development and provide no information on embodied carbon.

Page 24

I can see the attraction of setting a minimum required level of biodiversity net gain (BNG), as this is easy to apply.
However, there are two key drawbacks to this approach. Firstly, it is easy for developers and their advisers to
manipulate/overstate the results, simply by understating the current biodiversity levels for the proposed site. So even if the projected levels for future biodiversity are reasonable, the BNG will be overstated. To help to guard against this, it is essential that NHC appoints its own adviser to assess the BNG and does not rely on the work undertaken by advisers appointed by and paid by the developer. Secondly, using it in isolation is too simplistic. Looking solely at one metric, the BNG score, ignores entirely the impact on existing wildlife on the site. This could result in a tacit agreement to significant numbers of existing animals, birds and insects being killed or displaced, as long as biodiversity is “predicted” to increase overall. Surely this cannot be right? Surely, the first priority must, wherever possible, be to protect what is already there and look to enhance it through the introduction of other fauna and flora?
If this is not possible, the expected impact on existing wildlife should be spelt out.

Page 67
This slide provides very helpful clarification of NHC policy.

I would be interested to know whether NHC would be prepared to consider a policy of non-usage of Grade 1 and
Grade 2 (and possibly Grade 3a) BMV land for these purposes. I understand that some other UK Councils have
adopted such policies. We do need to move to renewable and low carbon energy production but we also need food.
Reducing food production will increase imports. By way of illustration, the UK is already a net importer of milling
grade wheat, so reducing production by taking fields out of agricultural use will increase imports, with the associated
carbon emissions. As an aside, research has shown that the modern cultivation of wheat absorbs more carbon dioxide than it releases.

Page 68
In terms of potential for large scale energy production within Hertfordshire, the Hertfordshire Renewable and Low
Carbon Energy Technical Study referred to on this page of the SPD looked at wind turbines and biomass; it did not
consider solar PV. (Solar PV was only considered at a micro-generational level in the Study.) Page 68 should be
amended to make this clear.

Section 160 (b) of the NPPF states that local authorities should consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure their development. Is the Council intending to do this, perhaps building on and updating the Hertfordshire Renewable and Low Carbon Energy Technical Study (which was produced in 2010)?
As regards Community Consultation (or Engagement), I believe that far greater scrutiny is required here. Some
developers will, undoubtedly, engage with the community in a meaningful and constructive way. Unfortunately,
others do not and regard it as a box-ticking exercise to satisfy the Planning Officers. A developer of a solar plant will become a neighbour of the local communities for c 40 years; they should be required to be a good neighbour.

A Noise and Vibration Impact Assessment should be required rather than simply a Noise Impact Assessment. This would be used by the developer in establishing whether a site is appropriate, designing the construction and finalising proposals but it should not be relied upon by NHC which should take its own, independent advice.

Thank you for providing me with the opportunity to comment on the draft SPD. I hope my comments will be helpful and I would be pleased to provide more detail or answer any questions. I would be grateful if you could let me know the outcome of the consultation including when the Sustainability SPD is adopted.

On behalf of Bloor Homes Ltd, please consider this representation in response to the consultation on
the North Herts Council draft Sustainability SPD.

Broadly, Bloor Homes supports the SPD and welcomes the document as supporting guidance to supplement the relevant adopted Local Plan policies and National policies, and the text in the Introduction section sets the scope and status of the SPD out clearly and is supported.

Regarding how the SPD could be used and applied, for Major Residential developments we recommend that Option B Self-Assessment checklist is the most appropriate option as the applicant will have all the
necessary technical information to complete the checklist and can signpost where amongst the application documents the supporting information can be found and checked.

In Section 2 Objectives within the Carbon Footprint section on page 19, there are a couple of instances of definitive requirements where ‘should’ and ‘will require’ are used, which are not considered appropriate, given the acknowledgement in Section 1 that the SPD cannot go beyond adopted policy or impose unnecessary financial burdens on development. These requirements should be amended to use language used elsewhere in the section, such as ‘encouraged’.

Similarly, later in Section 2 under ‘Land use & wildlife’ on page 23, the phrase ‘Proposals should avoid habitat loss’ is used which is again too definitive and on many allocated sites some degree of habitat loss is unavoidable (e.g. farmland is a habitat for certain species whose loss cannot be avoided when developing a site). The phrase would be more appropriately worded as ‘seek to avoid’.

A minor point, but in the Checklist table on page 28 and again in the checklist on page 80, ‘Complimentary’ should be replaced by ‘Complementary’ in relation to the 12m habitat buffers.

Thereafter, the Technical and General Guidance presented in Section 3 is supported and provides a
useful overview.

In relation to the Checklists presented in the Appendices, and in particular at Appendix A in relation to
Major Residential Application, we have a few comments for consideration as follows.

Firstly we suggest that consideration is given to allowing schemes to achieve the higher Silver and Gold standards where a limited number of criteria are not feasible or viable on particular schemes at the discretion of officers. This is similar to the approach taken in certification schemes such as the Code for Sustainable Homes or BREEAM whereby it is not necessarily mandatory to achieve all the
requirements to achieve an overall level or grade. This suggestion is to allow for schemes where sustainability measures have been proactively provided across most criteria, but for site-specific reasons not all of them can be achieved, but the application can nonetheless achieve a higher level.

Secondly, in some instances the criteria are perhaps too vague or imprecise to provide the clarity that Applicants or Officers may require. For example, ’20% renewable energy’ does not indicate the benchmark; ‘significant proportion of reclaimed materials’ does not indicate a percentage or range. It is suggested that some of these criteria are made clearer or more precise.

We trust that this representation and the suggestions herein are useful in informing revisions to the draft
and look forward to reviewing the final version.

We write on behalf of our client, the Vistry Group (‘VG’), in respect of the consultation running on North District Hertfordshire Council’s (‘NHDC’) Draft Sustainability Supplementary Planning Document – December 2023 (‘the SPD’).
VG have a strong track record of delivering scheme which maximise opportunities for highly energy efficient fabric and renewable energy measures.

The Government is already proposing to introduce very high levels of energy efficiency via the Future Homes Standards 2025. To meet this standard, not only
will all new homes be delivered with a very energy efficient fabric but also with extensive renewable energy technologies. This standard will be applied to all new
homes and will meet the vision of Sustainability SPD, without the need for additional standards to be set by the Council.

If the Sustainability SPD does propose additional measures that exceed the Future Homes Standards/Building Regulations these must be expressed as an aspiration and not a requirement and must allow for viability considerations.

The SPD aims to provide detailed guidance to support the application of Policy SP1 (Sustainable Development in North Hertfordshire), Policy D1 (Sustainable Design) and other relevant policies in the adopted Local Plan. However, VG have concerns that the Draft SPD lacks sufficient detail, clarity and/or justification to provide the intended level of guidance for developers on the approach that will be taken by the Local Planning Authority (‘the LPA’) to sustainability matters. These areas of concern are outlined below, and VG would welcome clarity from the LPA on these matters in subsequent iterations of the SPD, namely in relation to major residential development.

Section 2 Objectives
Generally speaking, Section 2 of the SPD has a notable amount of text which is very similar to text already in the Local Plan. In some cases, the wording is identical, but
it is less effective in the SPD than in the Local Plan where it is supporting policy text sitting directly under corresponding policies. This section of the SPD therefore does not appear to add specificity, clarity or further objectives beyond the information already provided within the Local Plan and should either be streamlined or omitted
entirely.

Section 3 Technical and General Guidance
Within this Section of the SPD, the language used throughout needs to be clearer as to what is a recommendation, and what is a requirement.
In the same vein, this section does not take the opportunity to provide more clarity on matters within the Local Plan and/or validation checklist which are imprecise.
For example:

- Page 41 states that Applicant’s ‘should’ submit a sustainability statement outlining details of on-site low carbon and renewable energy generation systems. No reference is made to this being proportionate to scale of
development, what level of information is required and whether some applicant’s/development proposals, say householders, would not be expected to provide such a statement.
- Page 47 provides clear and effective guidance as to when Transport Assessments (‘TAs’) will be required, but Page 53 seems to indicate that all developments require a ‘Detailed Demolition and Construction Management Plan’ and ‘detailed Travel Plan’ to be in place prior to
development. This is not in line with the LPA validation checklist, or our experience of standard conditions imposed in North Herts for smaller scales of development. A similar level of clarity and specificity as used for TAs
should be provided to outline when/why these documents would be required.
- Page 53 reiterates that the threshold for whether major developments require an air quality assessment are those proposals which ‘lead to significantly increased car parking / traffic movements’ in line with the Local
Plan. This is an unfortunately imprecise threshold in the Plan, and the SPD fails to utilise the opportunity to provide more specific and standardised criteria for what would be considered significantly increased traffic movements.

- Pages 54-55 provides very specific waste guidance which in places goes beyond what can reasonably be secured as part of major residential development, such as providing segregated internal kitchen bins for waste
and recycling as occupiers would be free to amend an internal kitchen layout to their own specification.

Overall, this section should be carefully reviewed to seek to ensure that each element is effectively worded to avoid the current variance in levels of specificity
and useability.

Checklists
The checklists scattered throughout the document, including at Pages 28, 50 and 64 are unclear in their purpose. The tables are not clearly titled and do not have
supporting text to explain the application or implications of the ‘bronze’, ‘silver’ and ‘gold’ classifications in the main body of the document. For this reason, it may be more efficient to only contain these in the Appendices and simply make appropriate cross-references for continuity purposes.

However, even within the appendices, the purpose of the checklists is unclear. As a ‘checklist’ a minimum expectation would be to set out what development is
expected to meet what level of the checklist and why. Whilst split into different application types, as prepared, the document generates more questions than it
answers, for example:

- Is the bronze level a minimum expectation, if so what would be the implications of not meeting every checklist point?
- Do the checklists effectively act as validation checklists for sustainability matters?
- Would a development meeting the gold criteria be considered to be delivering sustainability benefits over and above the minimum and therefore be attributed as a planning benefit weighing in favour of the proposal? This at least seems to be the case for ‘site wide energy
generation’ as stated on page 78.
- Further, does the weighting system essentially create a framework to be used for the tilted balance exercise?
- Would an allocation site meeting all Bronze criteria and delivering an uplift on its housing allocation numbers be considered less favourably than a development proposal with a lower number of dwellings meeting all of the
Gold criteria?

- Is low carbon and renewable energy generation of the greatest importance, as indicated by page 78, over say waste or air quality or ecology?

The checklists themselves, along with Section 2 of the SPD more generally, focus entirely on environmental sustainability, with the exception of open space
provision. This raises the additional question as to how the different elements of sustainability will be balanced overall such as delivering a socially sustainable level
of housing and infrastructure versus greater environmental provision and this is outlined in more detail below.

Balance of Matters

The SPD acknowledges that sustainability refers to meeting the needs of the present without compromising the ability of future generations to meet their needs, taking into account social, environmental and economic needs.

Unarguably, one of the greatest barriers to social sustainability is access to sufficient housing products to meet community needs. The Ministerial Statement
by the Secretary of State for DLUHC on 19 December 2023 recognised this by explicitly noting that “The opening chapters of the NPPF have been updated to provide clarity on a core purpose of the planning system: planning for homes and other development that our communities need”.

This provides clear policy direction that housing must be delivered to maintain socially sustainable communities. The necessity to balance this critical need against
environmental matters has also been recognised by Central Government. The ‘Planning - Local Energy Efficiency Standards Update’ Ministerial Statement
published on 13 December 2023 noted that the Government want to strike the best balance between making progress on improving the efficiency and performance of homes whilst still wanting to ensure housing is built in sufficient numbers. It set out the strongly worded expectation that:

“the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. The proliferation of multiple, local standards by local authority area can add further costs to building new homes by adding complexity
and undermining economies of scale. Any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do
not have a well-reasoned and robustly costed rationale.”

The SPD itself recognises that it cannot add unnecessary financial burdens on development. However, there is no mechanism in the production of the document to assess this; it is not viability tested or subject to the same examination process as the Local Plan. It is very probable that the requirements of the SPD will place greater financial burden upon new development. For example, there is now a much greater emphasis than in the Local Plan on low carbon and renewable energy generation on site and specific requirements for a Whole Life Carbon Assessment for all major developments with a minimum of 10% site construction waste being recycled. These are requirements which goes significantly above building
regulation requirements and will be challenging for developers to achieve without financial burden which would impact on development viability.

Further, the concern is that throughout the SPD, greater weight/emphasis is given to environmental sustainability matters over social and economic sustainability
aspects. This raises the questions as to whether the expectation of major development will be to meet all of the Gold level of environmental sustainability if any uplift in housing is to be supported. As noted, this goes against national policy direction which wants to see the correct balance with housing delivery and efficient use of land.

For example, Paragraph 129a) of the NPPF outlines that:

“Area-based character assessments, design guides and codes and masterplans can be used to help ensure that land is used efficiently while also creating beautiful and sustainable places. Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is especially important that planning policies and decisions avoid homes being built at low densities, and ensure that developments make optimal use of the potential of each site. In these circumstances:

a) plans should contain policies to optimise the use of land in their area and meet as much of the identified need for housing as possible. This will be tested robustly at examination, and should include the use of minimum density standards for city and town centres and other locations that are well served by public transport. These standards should seek a significant uplift in the average
density of residential development within these areas, unless it can be shown that there are strong reasons why this would be inappropriate;”

In North Herts, significant housing sites in the District are subject to such a Masterplan process which means there is already a mechanism to help balance efficient use of land against creating beautiful and sustainable places. It is not clear what role the SPD’s checklists and varying thresholds will play in the preparation of future Masterplans and the level of housing which will be supported over environmental targets.

This is particularly relevant considering that in the North Herts, the majority of the significant housing sites are Green Belt releases and therefore making the optimum
use of released land, balanced against design, character and sustainability considerations (as ensured by the Masterplan process) is of significant value and importance, given the exceptional housing need which was used to justify such boundary amendments. Further, recent national policy changes mean that it is unlikely that future such land will be released for housing, providing a limited opportunity to deliver on this need.

It is also more important than ever to make efficient use of allocated housing sites in North Herts given latest data and assessment work has indicated that NHDC do
not currently have a five-year housing land supply. This could leave the District open to lower quality speculative development in the near future.

Making efficient use of land also means more sustainable building practices due to the efficiencies that can be achieved in construction activities (embodies carbon)
rather than a reliance on a great number of smaller sites to deliver infrastructure needs which inevitably will result in less effective construction method/programmes.

Summary
Overall, VG are concerned that the lack of absolute clarity within the SPD will mean that local requirements will be applied in an ineffective and onerous manner which
will place significant cost burden on future developments.

We trust that the matters outlined above will be adequately addressed in the subsequent versions of the emerging SPD and we would be grateful if you could ensure that we are consulted on future stages of the document.

Attachment

This letter is a response to the consultation on the North Hertfordshire District Council Sustainability Supplementary Planning Document dated November 2023.

The Green Heat Coop is based in Royston and is a non-profit, community-based company focused on the transition away from fossil-fuels to high efficiency, low carbon, high comfort home heating systems. As such, the Coop wholeheartedly supports the aims of the draft SPD.

The Coop also recognises that the SPD cannot introduce new planning policies or add unnecessary financial burdens on development, and that the Ministerial Statement made in the House of Lords on 13th December 2023 unfortunately limits the scope of local authorities yet further in this regard. We would like to draw your attention to the response and interpretation of the Ministerial Statement prepared by LETI (the Low Energy Transformation Initiative CIC), which is available here. That said, the Coop would support, wherever possible, the encouragement of more ambitious efforts to reduce carbon dependency in new and existing homes. We note that buildings constructed under today’s Building Regulations will need to be retrofit to meet the net zero carbon targets laid out by central government (2050 target) and North Herts DC (2040 target).

We support the use of the checklists to encourage developers towards the Gold standards and we encourage North Hertfordshire DC to set the Gold standards at an ambitious level. We are pleased to see that the Gold standard for energy efficiency is the Passivhaus / LETI standard (or equivalent) and that the Gold standard for On-site Low Carbon and Renewable Energy is set at 50% or more reliance on renewable energy in the draft SPD. We believe the Gold standard could reasonably be set at an even higher level (perhaps up to 67%) to encourage the use of heat pumps and solar panels in new construction.

In addition, further guidance and support for householders who wish to retrofit their homes with, for example, more efficient insulation or renewable energy provision, would be welcome – whether within the SPD or beyond it. The Green Heat Coop has applied for funding to expand our capacity to assist householders in retrofit activity, and is exploring how we can work with the Hertfordshire Climate Change and Sustainability Partnership (HCCSP) and others to do more in this area. We would be delighted to discuss this with North Herts DC in due course. Our contact details are as above.

Attachment

HCC comments on the North Herts Sustainability SPD consultation February 2024

General comment regarding the HGB missions: The Hertfordshire Growth Board have prepared a series of mission statements covering; World Class Economy,
Digital Access for All, Transport for Hertfordshire, Right Homes, Right Places, Healthy Places for All and Sustainable County. It would be beneficial for the SPD to
refer to the missions as relevant.
General comment regarding references to the NPPF: the SPD may need to be reviewed following the publication of the revised NPPF and NPPG.
Specific comments:
• Pg 6 The last sentence of the opening paragraph currently reads ‘managing the flood risk’. Suggest this be changed to ‘managing the risk of flooding’ or
‘managing flood risk’.

• Pg 11, Table 1 – the NPPF may now be relevant to more sections -energy use/low carbon? Also the table switches between National Planning Policy Framework and the NPPF.

• The document may benefit from referencing the National Planning Practice Guidance. There have also been recent Ministerial Statements that may be relevant – energy efficiency.

• Pg 16 the Tyndall report and the SPD make recommendations regarding ‘shipping and aviation’ however, this may not be relevant to North Herts and
so would benefit from some explanation.

• Pg23 Hertfordshire Ecology is now known as ‘Hertfordshire LEADS’. The link provided is also broken. Here is the current link: Wildlife (Ecology) |
Hertfordshire County Council

• Pg25 ‘bat boxes, bird feeders, insect hotels, insect hibernation houses’ cannot be accounted for in the BNG metric and therefore have no impact on a BNG
unit score of a site. So while they may be best practice for enhancing the biodiversity of a site generally they are not best practice for achieving high quality BNG according to the metric. Admittedly a minor point.

• Pg25 Local Nature Recovery Strategy section doesn’t mention the Local Nature Recovery Strategy and references Nature Recovery Networks which is
not a term that sees a lot of usage. I suggest changing:

‘…which includes provision for a Nature Recovery Network (NRN) states that recovering wildlife will require more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the NRN should be designed to bring a wide range of additional benefits such as:’ to '…which includes the provision of Local Nature Recovery Strategies
(LNRSs)across England. The Hertfordshire Nature Recovery Partnership will lead on the creation of Hertfordshire’s Local Nature Recovery Strategy which
will enable the delivery of more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the LNRS will be designed to bring a wide range of additional benefits such as:’

• Pg25 The bottom of the page references ‘the Local Nature Partnership’. This partnership is now defunct. The reference should be changed to the Hertfordshire Nature Recovery Partnership - Hertfordshire Nature Recovery
Partnership | Hertfordshire County Council

• Pg26 This process map is now out of date. It has now been confirmed that a Biodiversity Gain Plan needs to include confirmation of a site being legally secured and added to the national register and does not need to be submitted prior to determination of a planning application. As such, it should come after these steps in the process. I don’t have a link to a decent process map. I would avoid including a process map at all as the process is so complicated any simple map like this may just mislead those unfamiliar.

• The SPD does not define how North Herts will determine Strategic Significance areas for BNG calculations until the LNRS is in place. There is no requirement to do this but it will be of interest to developers and a clear policy
will speed up the assessment of applications. Is this listed elsewhere? If not, Hertfordshire LEADS recommend using the Hertfordshire Ecological Network Map provided by HERC. If you need support with this, one of the ecologists in the LEADS team would be happy to advise.

• Pg 44 Dry biomass ‘The most common source of dry biomass is wood ‘form’ forests’. Should this sentence read ‘from’ rather than form?

Pg 54 Air Quality
The inclusion of the paragraph stating “Children are more vulnerable to the effects of air pollution therefore play/ recreation spaces should be located such as to minimize
exposure to air pollution” is a well thought out addition focussing on more at risk individuals and whole life course health impact. As noted in HCC’s Air Quality JSNA
those living in more deprived areas, which highlights those who may have limited personal funds available, are also more at risk to air pollutants. As such it is suggested that this paragraph could be expanded to follow the evidence in this area and extend to affordable housing contribution locations on any site, care/residential homes, and health sites (e.g. position these in areas likely to receive best air quality within the development site).

The paragraph which states “Development design should prioritise sustainable and active travel modes to help reduce reliance on private cars (see transport section)” is
welcomed. HCC Public Health wider determinants service area advocates using a Healthy Streets Approach to promote sustainable travel mode. Referencing this and
expressing a desire for developers to present development which has taken on board a Healthy Streets approach is required. There is the potential for the SPD to go further and request all developments/ that which is over a certain size to score the streets proposed using a Healthy Streets Design Check available at: Healthy Streets | Making streets healthy places for everyone. A minimum score threshold for new streets could be proposed. In addition requiring development to contribute to the network of streets the proposed development will feed into to uplift the existing locality street score is suggested for inclusion. This is to ensure that the wider area has relevant improvements required to reduce barriers to sustainable travel in the proposal area to encourage these modes to occur both on and off the development land parcel. This approach supports the travel plan aspect of the SPD by promoting confidence that sustainable mode share is likely to be adopted widely.

Attachment

Attachment

HCC comments on the North Herts Sustainability SPD consultation February 2024

General comment regarding the HGB missions: The Hertfordshire Growth Board have prepared a series of mission statements covering; World Class Economy,
Digital Access for All, Transport for Hertfordshire, Right Homes, Right Places, Healthy Places for All and Sustainable County. It would be beneficial for the SPD to
refer to the missions as relevant.
General comment regarding references to the NPPF: the SPD may need to be reviewed following the publication of the revised NPPF and NPPG.
Specific comments:
• Pg 6 The last sentence of the opening paragraph currently reads ‘managing the flood risk’. Suggest this be changed to ‘managing the risk of flooding’ or
‘managing flood risk’.

• Pg 11, Table 1 – the NPPF may now be relevant to more sections -energy use/low carbon? Also the table switches between National Planning Policy Framework and the NPPF.

• The document may benefit from referencing the National Planning Practice Guidance. There have also been recent Ministerial Statements that may be relevant – energy efficiency.

• Pg 16 the Tyndall report and the SPD make recommendations regarding ‘shipping and aviation’ however, this may not be relevant to North Herts and
so would benefit from some explanation.

• Pg23 Hertfordshire Ecology is now known as ‘Hertfordshire LEADS’. The link provided is also broken. Here is the current link: Wildlife (Ecology) |
Hertfordshire County Council

• Pg25 ‘bat boxes, bird feeders, insect hotels, insect hibernation houses’ cannot be accounted for in the BNG metric and therefore have no impact on a BNG
unit score of a site. So while they may be best practice for enhancing the biodiversity of a site generally they are not best practice for achieving high quality BNG according to the metric. Admittedly a minor point.

• Pg25 Local Nature Recovery Strategy section doesn’t mention the Local Nature Recovery Strategy and references Nature Recovery Networks which is
not a term that sees a lot of usage. I suggest changing:

‘…which includes provision for a Nature Recovery Network (NRN) states that recovering wildlife will require more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the NRN should be designed to bring a wide range of additional benefits such as:’ to '…which includes the provision of Local Nature Recovery Strategies
(LNRSs)across England. The Hertfordshire Nature Recovery Partnership will lead on the creation of Hertfordshire’s Local Nature Recovery Strategy which
will enable the delivery of more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the LNRS will be designed to bring a wide range of additional benefits such as:’

• Pg25 The bottom of the page references ‘the Local Nature Partnership’. This partnership is now defunct. The reference should be changed to the Hertfordshire Nature Recovery Partnership - Hertfordshire Nature Recovery
Partnership | Hertfordshire County Council

• Pg26 This process map is now out of date. It has now been confirmed that a Biodiversity Gain Plan needs to include confirmation of a site being legally secured and added to the national register and does not need to be submitted prior to determination of a planning application. As such, it should come after these steps in the process. I don’t have a link to a decent process map. I would avoid including a process map at all as the process is so complicated any simple map like this may just mislead those unfamiliar.

• The SPD does not define how North Herts will determine Strategic Significance areas for BNG calculations until the LNRS is in place. There is no requirement to do this but it will be of interest to developers and a clear policy
will speed up the assessment of applications. Is this listed elsewhere? If not, Hertfordshire LEADS recommend using the Hertfordshire Ecological Network Map provided by HERC. If you need support with this, one of the ecologists in the LEADS team would be happy to advise.

• Pg 44 Dry biomass ‘The most common source of dry biomass is wood ‘form’ forests’. Should this sentence read ‘from’ rather than form?

Pg 54 Air Quality
The inclusion of the paragraph stating “Children are more vulnerable to the effects of air pollution therefore play/ recreation spaces should be located such as to minimize
exposure to air pollution” is a well thought out addition focussing on more at risk individuals and whole life course health impact. As noted in HCC’s Air Quality JSNA
those living in more deprived areas, which highlights those who may have limited personal funds available, are also more at risk to air pollutants. As such it is suggested that this paragraph could be expanded to follow the evidence in this area and extend to affordable housing contribution locations on any site, care/residential homes, and health sites (e.g. position these in areas likely to receive best air quality within the development site).

The paragraph which states “Development design should prioritise sustainable and active travel modes to help reduce reliance on private cars (see transport section)” is
welcomed. HCC Public Health wider determinants service area advocates using a Healthy Streets Approach to promote sustainable travel mode. Referencing this and
expressing a desire for developers to present development which has taken on board a Healthy Streets approach is required. There is the potential for the SPD to go further and request all developments/ that which is over a certain size to score the streets proposed using a Healthy Streets Design Check available at: Healthy Streets | Making streets healthy places for everyone. A minimum score threshold for new streets could be proposed. In addition requiring development to contribute to the network of streets the proposed development will feed into to uplift the existing locality street score is suggested for inclusion. This is to ensure that the wider area has relevant improvements required to reduce barriers to sustainable travel in the proposal area to encourage these modes to occur both on and off the development land parcel. This approach supports the travel plan aspect of the SPD by promoting confidence that sustainable mode share is likely to be adopted widely.