Local Plan 2011-2031 Proposed Submission Draft

Thank you for your letter dated 17th October 2016, regarding the proposed Submission Local Plan consultation.

Broadly speaking, I am a supporter of the LPA's aspiration to adopt a new Local Plan to cover the twenty year period to 2031. It can only be right that at a time when the whole nation is facing an increasingly severe housing shortage, each and every Local Authority helps towards meeting that pent-up demand.

This proposed Local Plan addresses some of the deficiencies missing from the 1996 Local Plan No. 2 with Alterations. The new Local Plan will hopefully ensure a better standard of new-build, although it remains to be seen whether such an increased building programme from 2017-2031 is actually achievable. But, unquestionably, having a Local Plan in place is the single biggest key step, going forward.

However, whilst we would not wish to see any further delays, nevertheless, I consider the current Submission Draft has two serious shortcomings.

Firstly; ever since the 1986 Plan was first adopted, the North Hertfordshire District already has too much Green Belt, covering approximately 38% of the entire District. You will recall the primary purpose of the 1986 Local Plan:- Green Belt was principally designated in order to constrain expansion of Stevenage eastwards and Luton westwards. In addition, Green Belt was also established around the principal towns of Hitchin, Letchworth and Baldock. The fact that some of that original Green Belt now needs to be reviewed is primarily in order to provide housing in the most sustainable locations on the side of Baldock, Letchworth, Hitchin and Luton. Ironically, now to be located in four out of the five places most considered, back in 1986, to be highly sensitive, and where any new housing development was to be resisted.
The courageous decision to review the current Green Belt boundaries by removing approximately 750 hectares of land from the Green Belt is, as your recent reports to Full Council and Cabinet suggests, the "least worst" option, but vital if new house building, sufficient to meet Objectively Assessed Needs is to be anywhere near achieved. But, the past mistakes from 1986, now resulting in the necessity to review the current Green Belt, should not, to my mind, be compounded by the pointless "creation" of a further 4,700 hectares of new Green Belt; which would only appear to be for reasons of pure political presentation/expediency.

Historically, one of the great problems following the piecemeal creation of Green Belt by various local authorities has in the past, been its great overuse. Thoughtlessly, unscientifically and in some cases simply for NIMBY reasons, far too much land has been included in the Green Belt; only now can we really understand, in some cases, to the detriment to some of our communities.


For these reasons, I strongly object to the creation of a further 4,700 hectares of Green Belt. It is I believe, completely unnecessary, largely proposed for a location, most of which would not ever be considered sustainable to build on, would achieve none of the listed purposes at paragraph 80 of the NPPF, and would be entirely contrary to paragraph 82 of the NPPF. Furthermore, if the proposal to remove land immediately to the West of Stevenage from the existing Green Belt is implemented, countryside which will clearly in future be under some threat from new development, simply replacing 4700 hectares of alternative countryside with a quite pointless "infill" of Green Belt is absolutely not the answer.

My second area of concern about the shortcomings of the proposed Submission Draft concerns the lack of provision for self-build. Previously, the Coalition Government took firm action to support and encourage individuals and communities who want to build their own homes. Those who choose to build their own "Custom Homes" often build cheaper, greener, more affordable and more innovatively designed homes than those available on the standard/market housing. The Coalition Government had introduced its "Custom-Build Homes Programme", which was announced as part of The Laying the Foundations: a Housing Strategy for England (published in November 2011), to support and encourage more individuals and communities to build their own homes. The overall aim of the Coalition Government's programme was to double the size of the sector over a decade and make self-build housing a main-stream housing option. It remains government policy to help increase supply, promote economic growth and sustain local jobs. The Coalition's aim was to increase the number of new self-build homes from the 8% nationally of today, to 16% of the new-build total by 2022.


Nationally, interest in self-build continues to grow following the adoption of The Housing and Planning Act 2016, which included at Chapter 2, an entire new section on Self-Build and Custom- house building. In contrast, NHDC's proposed Draft Submission Local Plan is almost silent, whilst suggesting only a derisory 100 self-build homes throughout the period 2011-2031.
Whereas, even taking just the lower-end 8% nationally, this should translate into more than 1100 self-build or custom-build homes by 2031. In fact, North Herts is beautifully suited to the aspirations of local self-builders. Across the four towns and forty other smaller communities, there are widespread opportunities in and around many of our settlements for individual high-quality small-scale homes for local residents. But I'm afraid that without new intelligent policies and support from North Herts Council, many will potentially miss out on these small-scale opportunities, otherwise overlooked by the big builders in their rush to develop large urban extensions.

I hope it is not too late to correct these two deficiencies in the Proposed Submission Draft, and that the Inspector will encourage some further changes/improvements at the Inquiry stage. I would welcome the opportunity to address the Inspector during the Examination in Public. Other than that, I wish you every success, and my support for the overall thrust of establishing a much improved Local Plan as soon as possible.

Thank you for your letter dated 17th October 2016, regarding the proposed Submission Local Plan consultation.

Broadly speaking, I am a supporter of the LPA's aspiration to adopt a new Local Plan to cover the twenty year period to 2031. It can only be right that at a time when the whole nation is facing an increasingly severe housing shortage, each and every Local Authority helps towards meeting that pent-up demand.

This proposed Local Plan addresses some of the deficiencies missing from the 1996 Local Plan No. 2 with Alterations. The new Local Plan will hopefully ensure a better standard of new-build, although it remains to be seen whether such an increased building programme from 2017-2031 is actually achievable. But, unquestionably, having a Local Plan in place is the single biggest key step, going forward.

However, whilst we would not wish to see any further delays, nevertheless, I consider the current Submission Draft has two serious shortcomings.

Firstly; ever since the 1986 Plan was first adopted, the North Hertfordshire District already has too much Green Belt, covering approximately 38% of the entire District. You will recall the primary purpose of the 1986 Local Plan:- Green Belt was principally designated in order to constrain expansion of Stevenage eastwards and Luton westwards. In addition, Green Belt was also established around the principal towns of Hitchin, Letchworth and Baldock. The fact that some of that original Green Belt now needs to be reviewed is primarily in order to provide housing in the most sustainable locations on the side of Baldock, Letchworth, Hitchin and Luton. Ironically, now to be located in four out of the five places most considered, back in 1986, to be highly sensitive, and where any new housing development was to be resisted.
The courageous decision to review the current Green Belt boundaries by removing approximately 750 hectares of land from the Green Belt is, as your recent reports to Full Council and Cabinet suggests, the "least worst" option, but vital if new house building, sufficient to meet Objectively Assessed Needs is to be anywhere near achieved. But, the past mistakes from 1986, now resulting in the necessity to review the current Green Belt, should not, to my mind, be compounded by the pointless "creation" of a further 4,700 hectares of new Green Belt; which would only appear to be for reasons of pure political presentation/expediency.

Historically, one of the great problems following the piecemeal creation of Green Belt by various local authorities has in the past, been its great overuse. Thoughtlessly, unscientifically and in some cases simply for NIMBY reasons, far too much land has been included in the Green Belt; only now can we really understand, in some cases, to the detriment to some of our communities.


For these reasons, I strongly object to the creation of a further 4,700 hectares of Green Belt. It is I believe, completely unnecessary, largely proposed for a location, most of which would not ever be considered sustainable to build on, would achieve none of the listed purposes at paragraph 80 of the NPPF, and would be entirely contrary to paragraph 82 of the NPPF. Furthermore, if the proposal to remove land immediately to the West of Stevenage from the existing Green Belt is implemented, countryside which will clearly in future be under some threat from new development, simply replacing 4700 hectares of alternative countryside with a quite pointless "infill" of Green Belt is absolutely not the answer.

My second area of concern about the shortcomings of the proposed Submission Draft concerns the lack of provision for self-build. Previously, the Coalition Government took firm action to support and encourage individuals and communities who want to build their own homes. Those who choose to build their own "Custom Homes" often build cheaper, greener, more affordable and more innovatively designed homes than those available on the standard/market housing. The Coalition Government had introduced its "Custom-Build Homes Programme", which was announced as part of The Laying the Foundations: a Housing Strategy for England (published in November 2011), to support and encourage more individuals and communities to build their own homes. The overall aim of the Coalition Government's programme was to double the size of the sector over a decade and make self-build housing a main-stream housing option. It remains government policy to help increase supply, promote economic growth and sustain local jobs. The Coalition's aim was to increase the number of new self-build homes from the 8% nationally of today, to 16% of the new-build total by 2022.


Nationally, interest in self-build continues to grow following the adoption of The Housing and Planning Act 2016, which included at Chapter 2, an entire new section on Self-Build and Custom- house building. In contrast, NHDC's proposed Draft Submission Local Plan is almost silent, whilst suggesting only a derisory 100 self-build homes throughout the period 2011-2031.
Whereas, even taking just the lower-end 8% nationally, this should translate into more than 1100 self-build or custom-build homes by 2031. In fact, North Herts is beautifully suited to the aspirations of local self-builders. Across the four towns and forty other smaller communities, there are widespread opportunities in and around many of our settlements for individual high-quality small-scale homes for local residents. But I'm afraid that without new intelligent policies and support from North Herts Council, many will potentially miss out on these small-scale opportunities, otherwise overlooked by the big builders in their rush to develop large urban extensions.

I hope it is not too late to correct these two deficiencies in the Proposed Submission Draft, and that the Inspector will encourage some further changes/improvements at the Inquiry stage. I would welcome the opportunity to address the Inspector during the Examination in Public. Other than that, I wish you every success, and my support for the overall thrust of establishing a much improved Local Plan as soon as possible.