Local Plan 2011-2031 Proposed Submission Draft

Please find below my comments for the local plan consultation.

Local plan process:
1. I am afraid that I lack confidence that the council has rigorously analysed housing need in North Herts. The council's own original estimation of needed housing numbers was well below the number that is now identified and it appears that the council has simply abdicated from the requirement to assess its own housing need in favour of simply following the government guidance - until recently, when the government reduced the guidance number, but the council did not downwardly adjust its own numbers.
2. It is also evident that the council did not make any in depth assessment of the land most suitable for development. The methodology (to invite suggestions from landowners and others (including, of course, developers) coupled with the fact that there was only one such invitation, amounted to an unreflective approach to identification of land which did not make any real attempt to save green belt land and which inevitably resulted in easy/profitable sited being put forward at the expense of sites that would be more difficult to develop but have less impact on the environment. This has resulted in a number of specific problems with the sites proposed.

Site specific issues
1. A number of sites lack clear, defensible green belt boundaries. This is particularly true of the site off North Road Stevenage, where the proposed boundary goes over the middle of the hill, but is also true of the Baldock development and of the site between Graveley, Weston and Great Ashby.
2. A number of the proposed development coalesce villages with neighbouring settlement. The guidance advises against this and I understand that a recent court decision has upheld the principle of non coalescence.
3. Several of the developments are very large in relation to the settlements they are adjacent to. These will have a huge impact on these settlements, making it very difficult to achieve community cohesion in these areas. These sites are the ones adjacent to Wymondley, Baldock and Knebworth.

General issues
I am concerned that there has been no comprehensive assessment of traffic that takes into account traffic through, as well as within, North Herts. There is already significant congestion around Stevenage, Hitchin and on to the A1(M) and the increase in housing can only exacerbate this. Without a comprehensive assessment it will not be possible to consider the traffic impact and possible plans for amelioration.