Local Plan 2011-2031 Proposed Submission Draft

Policy SP8: Housing - (c)(ii):
The allocation of land at North Stevenage for 900 homes in Graveley Parish is supported. Croudace has been promoting an integrated strategic urban extension at North Stevenage for some years (i.e. involving land in both Stevenage Borough and North Hertfordshire District), in association with a group of land owners and house builders representing adjoining interests within Stevenage Borough. Croudace has an Option over the land included within the NS1 designation in North Hertfordshire. The strategic urban extension scheme would deliver a sustainable development that would contribute to meet the housing needs of both Authorities.

Whilst the objective is to ensure the delivery of an integrated strategic urban extension combining the land in both Stevenage Borough and North Hertfordshire District, it is relevant to note, in relation, in particular, to the timing of the delivery of the NS1 development, that the NS1 site would have its own highway access in the form of a new junction onto Graveley Road/North Road and could therefore be brought forward for development at a time to suit North Hertfordshire District Council's housing needs, without jeopardising integration with the development of the land in Stevenage Borough through the use of a combined Master Plan approach. This flexibility may be important to ensure that the housing needs of North Hertfordshire can be met in an appropriate and timely way, meeting localneeds.

Policy SP8: Housing (f):
This part of the policy is objected to. The proposals in item (f)(i) that 33% of all homes over the plan period should be Affordable Housing is not objected to. However, the aspiration beyond the 33% figure, introducing a 'target' of delivering up to 40% Affordable Housing where viable, is objected to. The policy needs to contain a single clear and unequivocal Affordable Housing target. This is important and necessary because land owners and house builders need to have certainty and clarity when negotiating land sale/acquisitions. Setting a target of 33% and then caveating it by saying actually the LPA may seek 40% if the Council judge that a particular site can stand it in viability terms will result in a lack of certainty and make land sale/acquisition needlessly complicated and indeed may well serve to frustrate certain sites being brought forward for development (i.e. where the Council considers a 40% target is appropriate but where the land owner concludes that such a high provision would result in an unacceptably low return on the land sale and may not agree to sell the land).
Further, it is also a concern that this part of the policy overlaps with policy HS2 with the mechanism of how those two policies interact being unclear. HS2 (despite poor drafting and presentation) is reasonably clear that the level of affordable housing for sites over 25 dwellings is 40%, but criterion (f)(i) of SP8 suggests that the 40% is somehow linked to a viability test.

Also, where is the evidence supporting the housing mix proposed in Item (f)(ii). Whilst the SHMA's evidence on mix of housing points towards more smaller units, the continuing impact of the bedroom tax and pressures on registered providers will make it harder to sell the affordable housing to an RP if there is an excess of larger units by comparison to what they are able to let. If the policy aspiration is that the supply of new affordable housing should be more mixed, the Council should acknowledge that this may have negative viability consequences.

Similarly, the policy and supporting text fails to set out the evidence and justification for the figure of 100 self-build plots in (f)(iii). This needs to be clarified before being included in a Development Plan policy.

Para 4.91: This paragraph is supported. This is because Croudace has been promoting an integrated strategic urban extension at North Stevenage for some years (i.e. involving land in both Stevenage Borough and North Hertfordshire District), in association with a group of land owners and house builders representing adjoining interests within Stevenage Borough. Croudace has an Option over the land included within the NS1 designation in North Hertfordshire. The combined strategic urban extension scheme would be integrated across the border between Stevenage Borough and North Herts District to ensure the seamless delivery of a sustainable urban extension that would contribute to meet the housing needs of both Authorities.

Whilst the objective is to ensure the delivery of an integrated strategic urban extension combining the land in both Stevenage Borough and North Hertfordshire District, it is relevant to note, in relation, in particular, to the timing of the delivery of the NS1 development, that the NS1 site would have its own highway access in the form of a new junction onto Graveley Road/North Road and could therefore be brought forward for development at a time to suit North Hertfordshire District Council's housing needs, without jeopardising integration with the development of the land in Stevenage Borough through the use of a combined Master Plan approach. This flexibility may be important to ensure that the housing needs of North Hertfordshire can be met in an appropriate and timely way, meeting local needs.

Policy HS2: Affordable Housing:
The Policy is objected to. This is because the policy is awkwardly worded - i.e. because it places the actual targets at the end of the policy wording, this is confusing to the reader. The affordable housing provision targets should form part of Item a(i) of the policy.

Further, in relation to Item (a)(i) it is unclear what the words "maximised having regard to the targets" mean. This could be interpreted that there may be circumstances where the Council would be seeking to require a greater provision than the target? The policy should simply set clear, fixed and unequivocal targets.

In addition, in relation to the reference to policy HS3, in Item (b)(v) of Policy HS2, it is relevant to note that Policy HS3 does not tie-up with policy SP8(f) on the mix of affordable housing types. How are frictions between Pollices SP8 and HS3 to be resolved?

Policy HS4: Supported, Sheltered and Older Persons Housing:
The second part of the policy is objected to. This is because it requires the provision, on sites of 100 units or more, of an element of accommodation under Class C3 and, on strategic sites, an element of accommodation of Class C2. It is inappropriate to 'require' such provision without there being a proven local demand for such accommodation in the immediate locality, coupled to named providers of such accommodation who are prepared to acquire land for these purposes from the land owner and/or house builder developing the site. Further, an in particular, it is not the role of a Local Plan or a Local Planning Authority to force a land owner and /or house builder to sell part of their site to a provider of Class C2 and C3 accommodation.

If there is a proven local need for such accommodation and an appropriate provider were to approach a land owner and/or house builder to acquire part of a larger site this is a matter purely for the parties concerned and must be commercially driven.

Policy HS5:
The policy is objected to. This is because the imposition of an arbitrary and onerous 50% requirement in Item a) of the policy is inappropriate. The Council must be able to demonstrate a specific need for a 50% provision in its evidence-base before it seeks to impose this requirement on all major developments. Further the word 'major' is not defined and needs clarification - i.e. what constitutes a major site? In addition, the Council needs to demonstrate how it has taken the viability implications of this policy on developers into account, alongside other policies.

Policy SP16: Site NS1 - North of Stevenage:
Paragraphs 4.195 to 4.201:

The policy and paragraphs are supported. This is because Croudace recognises the potential of land at North Stevenage, in both Stevenage Borough and North Hertfordshire District as being suitable and sustainable to deliver a comprehensive and integrated strategic urban extension which could contribute to meeting the housing needs of both authorities.

Croudace has been promoting this approach at North Stevenage for some years (i.e. involving land in both Stevenage Borough and North Hertfordshire District), in association with a group of land owners and house builders representing adjoining interests within Stevenage Borough. Croudace has an Option over the land included within the NS1 designation in North Hertfordshire. The combined strategic urban extension scheme could be integrated through the use of a Master Plan covering the land located in both Stevenage Borough and North Herts District to ensure the seamless delivery of a sustainable urban extension that would contribute to meet the housing needs of both authorities.

Croudace will be submitting supporting technical evidence with these representations (which will include masterplanning, highways and access, drainage and landscaping) (i.e. sent by email due to document sizes) to confirm that there are no technical constraints that would prevent the allocation and early development of the NS1 site.

Further, whilst the objective is to ensure the seamless delivery of an integrated strategic urban extension combining the land in both Stevenage Borough and North Hertfordshire District, it is relevant to note, in relation, in particular, to the timing of the delivery of the NS1 development, that the NS1 site would have its own highway access in the form of a new junction onto Graveley Road/North Road and could therefore be brought forward for development at a time to suit North Hertfordshire District Council's housing needs, without jeopardising integration with the development of the land in Stevenage Borough through the use of a combined Master Plan approach. This flexibility may be important to ensure that the housing needs of North Hertfordshire can be met in an appropriate and timely way, meeting local needs.

In relation to Items (a) and (b) of the policy, Croudace is liaising with the promoters of the adjoining land within Stevenage Borough and is working towards an illustrative Master Plan which will be submitted with the planning application for the NS1 site. The Master Plan will illustrate how the land in both Authority areas will be developed in an integrated way. The Master Plan does not need to go through any separate external process of approval such as Development Brief, prior to the submission of a planning application, as it will fall to the applicant to demonstrate, as part of the planning application process, how the two areas of land in the separate administrative areas will be delivered as an integrated design solution.

That does not, of course, rule-out informal discussions between the land owners and house builders in both areas and both Local Planning Authorities, to ensure an appropriate approach and provision of infrastructure such as roads, drainage, open spaces, education provision, local shops and facilities, greenways, footpaths, etc. Croudace would welcome such discussions.

In relation to Item (e) of the policy, whilst Croudace does not object in principle to the identification of a small number of self-build plots as part of the development, it would want to first see the evidence for the need for such land to be set aside, and agree with the Council how long such plots should be kept available if the up-take of the plots proves to be limited. Also, how are the plots to be integrated into a wider design solution. A solution where such houses are built to noticeably different designs and styles may be visually incongruous.

In relation to Item (f) of the policy, Croudace would be prepared, following the adoption of the Local Plan, to enter into discussions with the Local Planning Authority and the land owner in respect of an advance structural planting scheme in order to establish a strong defensible landscape along the northern boundary of the site.

In relation to Item (e) of the policy, whilst Croudace does not object in principle to the identification of a small number of self-build plots as part of the development, it would want to see the evidence of need for such land to be provided, and agree with the Council how long such plots should be kept available if the up-take of the plots proves to be limited. Also, how are the plots to be integrated into a wider design solution. A solution where such houses are built to noticeably different designs and styles may be visually incongruous.