Local Plan 2011-2031 Proposed Submission Draft

Representation (Objecting)

The policy designation of the rural settlement of Blackmore End / Gustard Wood is considered unjustified and inconsistent with other relevant policies of the Plan and the wider context. The part of the settlement that falls within North Herts settlement is considered correctly classified as a Category B Village (Policy SP2 Settlement Hierarchy 'infilling development which does not extend the built core of the village will be allowed').

However the settlement part will sit within the newly proposed, extended, Green Belt area and should therefore be washed over by Green Belt, as set out at NPPF paragraph 86. The proper scope for development is considered therefore to be 'limited infilling in villages' in the Green Belt under NPPF paragraph 89 (Bullet 5), in conjunction with NPPF paragraph 86.

The policy proposed also creates cross boundary issues, which have not been raised directly with St Albans City and District Council. The settlement designation is inconsistent with the longstanding designation as a 'Green Belt Settlement' of the part (just under half of the same village) within St Albans City and District in the adopted St Albans City and District Local Plan Review 1994. It is also inconsistent with the (same) approach taken in the emerging St Albans Strategic / Detailed Local Plans.
References: Para 4.15 et al / Policy Nos SP2, SP5 / Policies Map Sheet 1 Side B

Supporting points:

* The settlement has previously been dealt with under rural development restraint policies that are consistent in terms of a limitation to infill development only. The new policy should align completely with the NPPF. Exclusion of the part of the settlement that falls within North Herts from the Green Belt appears unjustified as it is very small and sits within an overall area that is presented as requiring full Green Belt protection. It appears the settlement is still acknowledged as unsuitable for significant development. It follows that it should therefore be washed over by Green Belt, as the NPPF envisages.

* The policy designation is inconsistent with the treatment of other villages in Category B (Old Knebworth) in the Plan. This appears to be justified on the basis of the relative physical age and character of development and a view that a more historic village makes a greater contribution to the Green Belt than a more recent suburban area. This appears to miss the importance of the whole range of NPPF Green Belt purposes and the need to deal effectively with likely future development pressures. Both settlements appear to demonstrate a broadly equal contribution to openness of the Green Belt in that current development is low density / dispersed and should remain so (the core purpose of the national GB policy).