Local Plan 2011-2031 Proposed Submission Draft

The following comments relate to the Local Plan 2011-31: Proposed Submission Draft. They are not intended as detailed root and branch comment on the document as a whole. They are meant to highlight issues from perspective of 'What will this Plan do for Hitchin?'.

Section 4: Strategic Policies - The need for better background

* 'Strategic' (and cascaded) policies should be policies resting on an evidence based District framework and accorded precedence/weightings according to realities identified within that framework. A general criticism of the Plan is that the District background/framework - its depiction of the detail, variety, distinctiveness, comparative strengths and opportunities within North Hertfordshire - is generally shallow and inconsistently drawn. This weakness in background is especially marked where that framework is specifically focused in Section 13: Communities. This section, with a thorough-going evidence base, should be the starting point for policy making not, as it is, a 'tack-on' at the end.

Section 5: Economy & Town Centres - The need for realistic hierarchy

* It is clear that Hitchin provides the District's main market, retail and service centre. It qualifies within the top 300 such town centres in the country. It is also clear that, overall, the levels of user satisfaction with its role are relatively high (see the NLP Town Centre and Retail Study 2016).

* District policy should, therefore, give a much clearer strategic priority to maintaining this key role for Hitchin and thereby reducing leakage elsewhere of business from the District: to do this would be to build on success. Yet the Plan actually recommends (see Section 13.220) in the medium to longer term the diversion of business away from Hitchin within the District. Such a policy risks undermining North Hertfordshire's key retail-commercial asset and should be rejected.

* Given its success and attractiveness some additional retail/commercial development in Hitchin town centre is logical. It must not, however, be a 'big-hit' scheme (such as the whole-scale redevelopment of Churchgate and its area) as the town centre's success has long been based on incremental growth and adaptation. Keeping this in view is particularly important given the major long term pressures of on-line commerce currently affecting traditional high street provision. In this context phased refurbishment of Churchgate and the Market area (identified as key contributors to the retail health of the town centre even in their present condition) should be linked to a sequential development of additional retail space (including some additional parking) on Paynes Park.

* Given Hitchin town centre's key place within the District a specifically focused and integrated policy to support it must be developed rather than resting on the fragmented catch-all approach advocated in the draft Local Plan (eg SP4, ETC3-5; policies HT11-12 need support from a wider Hitchin framework). A Hitchin specific town centre policy should recognise the significant input to town centre business activity provided by voluntary effort over many years and commit the District Council to support (but not control) that effort much more significantly than it does at present.

* Hitchin is an important 'evening economy' hub in Hertfordshire; such a function is an additional strand of commercial strength. There is, however, no specific recognition of this 'evening economy' and how such provision needs careful management in relation to more conventional day time retail and service functions eg working to avoid 'dead' frontages in key shopping areas.

* Hitchin is not recognised as a major employment centre in the District although it is, in fact, difficult to judge its ranking from the lack of systematic analysis provided; mention (SP3) is made of 'bringing forward' employment land but there is no Hitchin provision for this aim. Hitchin has a diverse and active industrial/employment area that is well occupied despite suffering some major access problems; the solution of these problems deserves a very much higher priority (SP3; there should be a HT policy to support the town's main employment area in addition to the access question; see also Section 7: Transport).

Section 7: Transport - The need for better coordination of congestion relief and public transport

* Transport issues, beyond the very local, pose a challenge to a District Council Plan given the key responsibility of the County Council although SP6 promises to 'deliver' on sustainable transport. It is important, therefore, that the District Council develops coherent views on the transport issues within North Hertfordshire so these can be deployed effectively to influence County decision making.

* The draft notices, but not effectively enough, a number of key (judged in county terms) road congestion hotspots within Hitchin but has no decisive proposals to 'deliver' any amelioration.

* The draft Plan fails to recognise Hitchin's key role as the District's main railhead (a junction, variety of services and destinations and over 3m passengers per year making it the busiest station on the Great Northern after Kings Cross/Finsbury Park, Cambridge, Peterborough and Stevenage). The draft Plan also fails to confront the challenges of Hitchin station access (pedestrian, cyclist, bus, and car), especially from the east. Nor does it recognise the need to improve significantly linkages at the station with Hitchin's useful portfolio of bus services, including key east-west links to/from Luton and Bedford. These omissions need remedy to achieve 'delivery'.

* As noted above the draft Plan does not have any effective response to the problem of vehicular access to Hitchin's important industrial-employment area; a specific transport or Hitchin policy is needed to achieve a solution to this problem.

Section 8: Housing Strategy - The need for variation, inclusion and Green Belt reinforcement

* Hitchin has seen steady population growth over recent decades; in the period 2001-11 it took over 60% of the new dwelling permissions that were granted in all of the four towns of the District and is again the largest urban centre. The town has recently appeared several times in 'Top Ten' surveys of desirable national living locations, has a good quality retail-commercial base, excellent state primary and secondary education, and good road and railway connections. As such it is inevitable that pressure for housing development in Hitchin will continue.

* It is, however, becoming increasingly difficult to accommodate this pressure while preserving both the town's attractive mixed residential make up and its vital Green Belt buffers, especially in the east. The draft Plan understandably allows for some additional expansion (SP17, HT1-10) including one major estate development (Highover Farm) on the east side. This latter does, however, require very sensitive handling to preserve long term Hitchin's eastern Green Belt and also to allow for the effective 'stitching' of the new housing into the adjacent residential areas with some forms of access to Grovelands Avenue and Highover Way along with a carefully sited access on Stotfold Road. The scope for housing development elsewhere (including infill) is now very limited and would raise significant historic environment and Green Belt/countryside issues (SP5).


Section 12: Historic Environment - The need for better more consistent enforcement

* The policies supporting the Historic Environment (SP13, HE1-3) are to be welcomed. Hitchin's continued success as a 'historic market town' commercial hub and attractive residential centre rests heavily on high quality management of its historic character. This cannot be an 'aspic' policy if the town is to continue to adapt and thrive but it must be a constructively enforced policy. Too often in the past historic environment issues have been over-ruled by short sighted reasoning in favour of unsuitable redevelopment.

* Management of Hitchin's historic environment also requires a more intelligent and connected policy towards its urban morphology as a whole. It is deeply disappointing that modest but intrinsically interesting suburban townscapes have been damaged by over intensive or out of keeping redevelopment. There is also the point that the shape of the modern town, as defined by roadways, paths and building plot shapes and sizes, is an important legacy of the fact that the town was never formally 'enclosed' meaning many of its urban 'patterns' still show influences dating back to its very earliest origins centuries ago. It makes sense to ensure that the policies on Design are truly tuned to distinctive local circumstance (SP9, D1) and linked to the historical contexts.

* Hitchin's historic landscape also includes the surviving extent of Priory Park. Despite the insertion of a relief road in 1981 this area still has many historic features (defined as including key planted areas) and as such should be accorded a much higher level of protection, such as English Heritage Designation, in the context of its Grade I Listed Building. Additionally, there should be no possibility of any of this area being considered for residential development.

Section 13: Communities - The need for a much better encapsulation of the District

* The poor quality of this section as a foundation for policy making has been noted above. If the question is posed 'Can you recognise Hitchin?' from its entry the answer is 'no' because the coverage is thin, partial and inconsistent.

* All the District's settlements need much more careful, consistent description and analytical assessment. The District is very clearly not a 'one centre' authority suited to top-down policy making: only by understanding and responding to local characteristics and variations can policies be properly applied and, as important, gain local acceptance. There needs to be much more scope for 'bottom up' influence in achieving solutions.

* The whole Communities section requires, therefore, a tighter and more systematic treatment of historic background, retail/commercial, service, industrial and agricultural aspects so the characteristics and needs of different areas of the District can be more easily compared and prioritised. This picture should be supplemented with relevant comparative analysis of the employment, economic ranking, district function and travel-transport importance of the various settlements. A logical outcome based on this revised background would be the development of a more graded Settlement Hierarchy to inform decision making. The draft Plan is prefaced (Section 2.6) with the remark that 'North Hertfordshire is a diverse area' but the following 240 pages do far too little to give reality, in the delivery of policies, to this key observation.

The following comments relate to the Local Plan 2011-31: Proposed Submission Draft. They are not intended as detailed root and branch comment on the document as a whole. They are meant to highlight issues from perspective of 'What will this Plan do for Hitchin?'.

Section 4: Strategic Policies - The need for better background

* 'Strategic' (and cascaded) policies should be policies resting on an evidence based District framework and accorded precedence/weightings according to realities identified within that framework. A general criticism of the Plan is that the District background/framework - its depiction of the detail, variety, distinctiveness, comparative strengths and opportunities within North Hertfordshire - is generally shallow and inconsistently drawn. This weakness in background is especially marked where that framework is specifically focused in Section 13: Communities. This section, with a thorough-going evidence base, should be the starting point for policy making not, as it is, a 'tack-on' at the end.

Section 5: Economy & Town Centres - The need for realistic hierarchy

* It is clear that Hitchin provides the District's main market, retail and service centre. It qualifies within the top 300 such town centres in the country. It is also clear that, overall, the levels of user satisfaction with its role are relatively high (see the NLP Town Centre and Retail Study 2016).

* District policy should, therefore, give a much clearer strategic priority to maintaining this key role for Hitchin and thereby reducing leakage elsewhere of business from the District: to do this would be to build on success. Yet the Plan actually recommends (see Section 13.220) in the medium to longer term the diversion of business away from Hitchin within the District. Such a policy risks undermining North Hertfordshire's key retail-commercial asset and should be rejected.

* Given its success and attractiveness some additional retail/commercial development in Hitchin town centre is logical. It must not, however, be a 'big-hit' scheme (such as the whole-scale redevelopment of Churchgate and its area) as the town centre's success has long been based on incremental growth and adaptation. Keeping this in view is particularly important given the major long term pressures of on-line commerce currently affecting traditional high street provision. In this context phased refurbishment of Churchgate and the Market area (identified as key contributors to the retail health of the town centre even in their present condition) should be linked to a sequential development of additional retail space (including some additional parking) on Paynes Park.

* Given Hitchin town centre's key place within the District a specifically focused and integrated policy to support it must be developed rather than resting on the fragmented catch-all approach advocated in the draft Local Plan (eg SP4, ETC3-5; policies HT11-12 need support from a wider Hitchin framework). A Hitchin specific town centre policy should recognise the significant input to town centre business activity provided by voluntary effort over many years and commit the District Council to support (but not control) that effort much more significantly than it does at present.

* Hitchin is an important 'evening economy' hub in Hertfordshire; such a function is an additional strand of commercial strength. There is, however, no specific recognition of this 'evening economy' and how such provision needs careful management in relation to more conventional day time retail and service functions eg working to avoid 'dead' frontages in key shopping areas.

* Hitchin is not recognised as a major employment centre in the District although it is, in fact, difficult to judge its ranking from the lack of systematic analysis provided; mention (SP3) is made of 'bringing forward' employment land but there is no Hitchin provision for this aim. Hitchin has a diverse and active industrial/employment area that is well occupied despite suffering some major access problems; the solution of these problems deserves a very much higher priority (SP3; there should be a HT policy to support the town's main employment area in addition to the access question; see also Section 7: Transport).

Section 7: Transport - The need for better coordination of congestion relief and public transport

* Transport issues, beyond the very local, pose a challenge to a District Council Plan given the key responsibility of the County Council although SP6 promises to 'deliver' on sustainable transport. It is important, therefore, that the District Council develops coherent views on the transport issues within North Hertfordshire so these can be deployed effectively to influence County decision making.

* The draft notices, but not effectively enough, a number of key (judged in county terms) road congestion hotspots within Hitchin but has no decisive proposals to 'deliver' any amelioration.

* The draft Plan fails to recognise Hitchin's key role as the District's main railhead (a junction, variety of services and destinations and over 3m passengers per year making it the busiest station on the Great Northern after Kings Cross/Finsbury Park, Cambridge, Peterborough and Stevenage). The draft Plan also fails to confront the challenges of Hitchin station access (pedestrian, cyclist, bus, and car), especially from the east. Nor does it recognise the need to improve significantly linkages at the station with Hitchin's useful portfolio of bus services, including key east-west links to/from Luton and Bedford. These omissions need remedy to achieve 'delivery'.

* As noted above the draft Plan does not have any effective response to the problem of vehicular access to Hitchin's important industrial-employment area; a specific transport or Hitchin policy is needed to achieve a solution to this problem.

Section 8: Housing Strategy - The need for variation, inclusion and Green Belt reinforcement

* Hitchin has seen steady population growth over recent decades; in the period 2001-11 it took over 60% of the new dwelling permissions that were granted in all of the four towns of the District and is again the largest urban centre. The town has recently appeared several times in 'Top Ten' surveys of desirable national living locations, has a good quality retail-commercial base, excellent state primary and secondary education, and good road and railway connections. As such it is inevitable that pressure for housing development in Hitchin will continue.

* It is, however, becoming increasingly difficult to accommodate this pressure while preserving both the town's attractive mixed residential make up and its vital Green Belt buffers, especially in the east. The draft Plan understandably allows for some additional expansion (SP17, HT1-10) including one major estate development (Highover Farm) on the east side. This latter does, however, require very sensitive handling to preserve long term Hitchin's eastern Green Belt and also to allow for the effective 'stitching' of the new housing into the adjacent residential areas with some forms of access to Grovelands Avenue and Highover Way along with a carefully sited access on Stotfold Road. The scope for housing development elsewhere (including infill) is now very limited and would raise significant historic environment and Green Belt/countryside issues (SP5).


Section 12: Historic Environment - The need for better more consistent enforcement

* The policies supporting the Historic Environment (SP13, HE1-3) are to be welcomed. Hitchin's continued success as a 'historic market town' commercial hub and attractive residential centre rests heavily on high quality management of its historic character. This cannot be an 'aspic' policy if the town is to continue to adapt and thrive but it must be a constructively enforced policy. Too often in the past historic environment issues have been over-ruled by short sighted reasoning in favour of unsuitable redevelopment.

* Management of Hitchin's historic environment also requires a more intelligent and connected policy towards its urban morphology as a whole. It is deeply disappointing that modest but intrinsically interesting suburban townscapes have been damaged by over intensive or out of keeping redevelopment. There is also the point that the shape of the modern town, as defined by roadways, paths and building plot shapes and sizes, is an important legacy of the fact that the town was never formally 'enclosed' meaning many of its urban 'patterns' still show influences dating back to its very earliest origins centuries ago. It makes sense to ensure that the policies on Design are truly tuned to distinctive local circumstance (SP9, D1) and linked to the historical contexts.

* Hitchin's historic landscape also includes the surviving extent of Priory Park. Despite the insertion of a relief road in 1981 this area still has many historic features (defined as including key planted areas) and as such should be accorded a much higher level of protection, such as English Heritage Designation, in the context of its Grade I Listed Building. Additionally, there should be no possibility of any of this area being considered for residential development.

Section 13: Communities - The need for a much better encapsulation of the District

* The poor quality of this section as a foundation for policy making has been noted above. If the question is posed 'Can you recognise Hitchin?' from its entry the answer is 'no' because the coverage is thin, partial and inconsistent.

* All the District's settlements need much more careful, consistent description and analytical assessment. The District is very clearly not a 'one centre' authority suited to top-down policy making: only by understanding and responding to local characteristics and variations can policies be properly applied and, as important, gain local acceptance. There needs to be much more scope for 'bottom up' influence in achieving solutions.

* The whole Communities section requires, therefore, a tighter and more systematic treatment of historic background, retail/commercial, service, industrial and agricultural aspects so the characteristics and needs of different areas of the District can be more easily compared and prioritised. This picture should be supplemented with relevant comparative analysis of the employment, economic ranking, district function and travel-transport importance of the various settlements. A logical outcome based on this revised background would be the development of a more graded Settlement Hierarchy to inform decision making. The draft Plan is prefaced (Section 2.6) with the remark that 'North Hertfordshire is a diverse area' but the following 240 pages do far too little to give reality, in the delivery of policies, to this key observation.

The following comments relate to the Local Plan 2011-31: Proposed Submission Draft. They are not intended as detailed root and branch comment on the document as a whole. They are meant to highlight issues from perspective of 'What will this Plan do for Hitchin?'.

Section 4: Strategic Policies - The need for better background

* 'Strategic' (and cascaded) policies should be policies resting on an evidence based District framework and accorded precedence/weightings according to realities identified within that framework. A general criticism of the Plan is that the District background/framework - its depiction of the detail, variety, distinctiveness, comparative strengths and opportunities within North Hertfordshire - is generally shallow and inconsistently drawn. This weakness in background is especially marked where that framework is specifically focused in Section 13: Communities. This section, with a thorough-going evidence base, should be the starting point for policy making not, as it is, a 'tack-on' at the end.

Section 5: Economy & Town Centres - The need for realistic hierarchy

* It is clear that Hitchin provides the District's main market, retail and service centre. It qualifies within the top 300 such town centres in the country. It is also clear that, overall, the levels of user satisfaction with its role are relatively high (see the NLP Town Centre and Retail Study 2016).

* District policy should, therefore, give a much clearer strategic priority to maintaining this key role for Hitchin and thereby reducing leakage elsewhere of business from the District: to do this would be to build on success. Yet the Plan actually recommends (see Section 13.220) in the medium to longer term the diversion of business away from Hitchin within the District. Such a policy risks undermining North Hertfordshire's key retail-commercial asset and should be rejected.

* Given its success and attractiveness some additional retail/commercial development in Hitchin town centre is logical. It must not, however, be a 'big-hit' scheme (such as the whole-scale redevelopment of Churchgate and its area) as the town centre's success has long been based on incremental growth and adaptation. Keeping this in view is particularly important given the major long term pressures of on-line commerce currently affecting traditional high street provision. In this context phased refurbishment of Churchgate and the Market area (identified as key contributors to the retail health of the town centre even in their present condition) should be linked to a sequential development of additional retail space (including some additional parking) on Paynes Park.

* Given Hitchin town centre's key place within the District a specifically focused and integrated policy to support it must be developed rather than resting on the fragmented catch-all approach advocated in the draft Local Plan (eg SP4, ETC3-5; policies HT11-12 need support from a wider Hitchin framework). A Hitchin specific town centre policy should recognise the significant input to town centre business activity provided by voluntary effort over many years and commit the District Council to support (but not control) that effort much more significantly than it does at present.

* Hitchin is an important 'evening economy' hub in Hertfordshire; such a function is an additional strand of commercial strength. There is, however, no specific recognition of this 'evening economy' and how such provision needs careful management in relation to more conventional day time retail and service functions eg working to avoid 'dead' frontages in key shopping areas.

* Hitchin is not recognised as a major employment centre in the District although it is, in fact, difficult to judge its ranking from the lack of systematic analysis provided; mention (SP3) is made of 'bringing forward' employment land but there is no Hitchin provision for this aim. Hitchin has a diverse and active industrial/employment area that is well occupied despite suffering some major access problems; the solution of these problems deserves a very much higher priority (SP3; there should be a HT policy to support the town's main employment area in addition to the access question; see also Section 7: Transport).

Section 7: Transport - The need for better coordination of congestion relief and public transport

* Transport issues, beyond the very local, pose a challenge to a District Council Plan given the key responsibility of the County Council although SP6 promises to 'deliver' on sustainable transport. It is important, therefore, that the District Council develops coherent views on the transport issues within North Hertfordshire so these can be deployed effectively to influence County decision making.

* The draft notices, but not effectively enough, a number of key (judged in county terms) road congestion hotspots within Hitchin but has no decisive proposals to 'deliver' any amelioration.

* The draft Plan fails to recognise Hitchin's key role as the District's main railhead (a junction, variety of services and destinations and over 3m passengers per year making it the busiest station on the Great Northern after Kings Cross/Finsbury Park, Cambridge, Peterborough and Stevenage). The draft Plan also fails to confront the challenges of Hitchin station access (pedestrian, cyclist, bus, and car), especially from the east. Nor does it recognise the need to improve significantly linkages at the station with Hitchin's useful portfolio of bus services, including key east-west links to/from Luton and Bedford. These omissions need remedy to achieve 'delivery'.

* As noted above the draft Plan does not have any effective response to the problem of vehicular access to Hitchin's important industrial-employment area; a specific transport or Hitchin policy is needed to achieve a solution to this problem.

Section 8: Housing Strategy - The need for variation, inclusion and Green Belt reinforcement

* Hitchin has seen steady population growth over recent decades; in the period 2001-11 it took over 60% of the new dwelling permissions that were granted in all of the four towns of the District and is again the largest urban centre. The town has recently appeared several times in 'Top Ten' surveys of desirable national living locations, has a good quality retail-commercial base, excellent state primary and secondary education, and good road and railway connections. As such it is inevitable that pressure for housing development in Hitchin will continue.

* It is, however, becoming increasingly difficult to accommodate this pressure while preserving both the town's attractive mixed residential make up and its vital Green Belt buffers, especially in the east. The draft Plan understandably allows for some additional expansion (SP17, HT1-10) including one major estate development (Highover Farm) on the east side. This latter does, however, require very sensitive handling to preserve long term Hitchin's eastern Green Belt and also to allow for the effective 'stitching' of the new housing into the adjacent residential areas with some forms of access to Grovelands Avenue and Highover Way along with a carefully sited access on Stotfold Road. The scope for housing development elsewhere (including infill) is now very limited and would raise significant historic environment and Green Belt/countryside issues (SP5).


Section 12: Historic Environment - The need for better more consistent enforcement

* The policies supporting the Historic Environment (SP13, HE1-3) are to be welcomed. Hitchin's continued success as a 'historic market town' commercial hub and attractive residential centre rests heavily on high quality management of its historic character. This cannot be an 'aspic' policy if the town is to continue to adapt and thrive but it must be a constructively enforced policy. Too often in the past historic environment issues have been over-ruled by short sighted reasoning in favour of unsuitable redevelopment.

* Management of Hitchin's historic environment also requires a more intelligent and connected policy towards its urban morphology as a whole. It is deeply disappointing that modest but intrinsically interesting suburban townscapes have been damaged by over intensive or out of keeping redevelopment. There is also the point that the shape of the modern town, as defined by roadways, paths and building plot shapes and sizes, is an important legacy of the fact that the town was never formally 'enclosed' meaning many of its urban 'patterns' still show influences dating back to its very earliest origins centuries ago. It makes sense to ensure that the policies on Design are truly tuned to distinctive local circumstance (SP9, D1) and linked to the historical contexts.

* Hitchin's historic landscape also includes the surviving extent of Priory Park. Despite the insertion of a relief road in 1981 this area still has many historic features (defined as including key planted areas) and as such should be accorded a much higher level of protection, such as English Heritage Designation, in the context of its Grade I Listed Building. Additionally, there should be no possibility of any of this area being considered for residential development.

Section 13: Communities - The need for a much better encapsulation of the District

* The poor quality of this section as a foundation for policy making has been noted above. If the question is posed 'Can you recognise Hitchin?' from its entry the answer is 'no' because the coverage is thin, partial and inconsistent.

* All the District's settlements need much more careful, consistent description and analytical assessment. The District is very clearly not a 'one centre' authority suited to top-down policy making: only by understanding and responding to local characteristics and variations can policies be properly applied and, as important, gain local acceptance. There needs to be much more scope for 'bottom up' influence in achieving solutions.

* The whole Communities section requires, therefore, a tighter and more systematic treatment of historic background, retail/commercial, service, industrial and agricultural aspects so the characteristics and needs of different areas of the District can be more easily compared and prioritised. This picture should be supplemented with relevant comparative analysis of the employment, economic ranking, district function and travel-transport importance of the various settlements. A logical outcome based on this revised background would be the development of a more graded Settlement Hierarchy to inform decision making. The draft Plan is prefaced (Section 2.6) with the remark that 'North Hertfordshire is a diverse area' but the following 240 pages do far too little to give reality, in the delivery of policies, to this key observation.