Local Plan 2011-2031 Proposed Submission Draft

The LEP generally supports the designations of all 6 Strategic housing sites but considers that small scale employment related activities should be considered for the at least some of the sites, particularly the larger allocations SP14 and SP19; it should also promote the development of sustainable transport modes to serve such development.

Amount of housing to be delivered

The LEP is generally supportive of this policy but would welcome the exploration of the potential to deliver housing growth in excess of the OAN figure than currently proposed, to allow the potential to meet housing needs not capable of being met elsewhere and/or to add flexibility through a higher level of overplanning (say 10%)

Helping to meet the growth needs of Luton outside of its boundaries

The LEP questions whether the level of development that the plan seeks to accommodate within North Herts to meet Luton's growth incapable of being met within the town's boundaries (c 2,100 of the 11,000 homes required) is sufficient or whether the level of growth should be set higher (subject to environmental constraints)

Composition and mix of new housing development

The LEP supports this policy. The identification of 6 substantial Strategic Housing Sites will in the LEP's view be at a scale to allow for the delivery of relatively sustainable environments with residential development combining with a mix of other uses

Proposed safeguarding of land west of Stevenage for development post 2026 (subject to the review of the plan)

The LEP considers that it is a failing of the plan not to bring forward within the plan period the land within North Herts forming part of the west of Stevenage development site, and that to promote safeguarding for development post 2026 (and then subject to the review of the plan) may give rise to haphazard, piecemeal and potentially unsustainable development, with the potential for the North Herts land to be rendered unviable if the Stevenage land is developed in isolation (or alternatively the potential for the Stevenage land to be rendered unviable until - and if - the North Herts land comes forward)

It is the LEP's view that both landholdings need to be brought forward in tandem as part of a single overarching masterplan. Herts LEP would be willing to work with both districts and other appropriate parties to co-ordinate development as a single entity, with an overarching masterplan covering land both in North Herts and Stevenage.

Planning for a new settlement

The LEP supports the principle of this policy but considers that (a) the search needs to commence as soon as the local plan is adopted (if not immediately) and that this should be made clear in the local plan and (b) that the search could be conducted with appropriate adjoining authorities to widen the area of search, given that there can be no certainty that a suitable location can be identified within the district and with the possibility that other locations beyond the district may prove to be more appropriate

Responding to accelerated housing delivery rates

The LEP recognises the challenges the district faces in meeting much accelerated housing delivery rates from 2021 onwards but is concerned that no mechanisms to support such delivery (and the infrastructure required to support it) are identified within the local plan. Mechanisms such as infrastructure delivery partnerships, local housing companies and modern methods of housing construction should all be identified within policy SP8 (with other initiatives as appropriate) to signpost actions that will need to happen to turn these aspirations into reality

Whilst being generally supportive of policy SP3, and welcoming the new employment designations, the LEP has the following concerns:

- there is neither reference to the East of England Forecasting Model's estimate of the number of jobs created as a consequence of growth to 2031 nor an estimate of employment floorspace expected to be created and therefore anticipated floorspace densities, making it impossible to make any sort of judgement over whether sufficient additional employment land is being designated in the plan

- whilst the plan seeks to promote such higher order activities including research and development, policy SP3 contains no specific measures to promote such activities, which could be achieved through imposing a minimum proportion of B1(b) (research and development activities, restricting uses entirely to B1(b) activities or limits on the level of non B1 uses for one or more of the new employment sites

- the rollout of the new employment designations will be greatly assisted by partnerships of appropriate private and public interests to work collaboratively together to promote their delivery, and policy SP3 needs to be explicit about the need for such arrangements to be put into place

- there is a failure to identify the need for employment related activities as part of the mix of uses on appropriate strategic housing sites; the LEP considers that at minimum there should be such a designation for either or both the North of Baldock and East of Luton strategic housing sites

- the absence of any new employment sites in Hitchin and only one small additional site in Letchworth means that there will be limited new employment opportunities in the district's two largest towns, and this should be addressed in the plan

- No specific policy to identify new employment activities within suitable smaller settlements within the district.