Local Plan 2011-2031 Proposed Submission Draft

Object

Representation ID: 2039

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Para 1.6 - the final sentence lacks and important comma before the phrase "or specific policies in thiss framework indicate development should be restricted" as set out in the NPPF and omits the vitally important cross-reference to Footnote 9 in the NPPF, which sets out the principal constraints that justify limiting housing targets.

Para 1.7 - Bullet 2 in this paragraph omits the key caveat in paragraph 47 of the NPPF which the Council is required to take into account in determining the scale of housing provision in the district and HMA

Object

Representation ID: 6042

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Para 2.8 - text demonstrates that the plan fails to seek to limit population and household growth in the district to a level consistent with national planning policy , and in particular para 14 and footnote 9 of the NPPF.
Para 2.35 - This para should include the key caveat in para 47 of the NPPF, which requires constraints such as Green Belt and AONB to be taken into account in determining the scale of housing provision in the district and HMA.
Para 2.39 - The final sentence fails to state that the needs of the HMA can only be met in full if the constraints imposed by paragraphs 14 and 47 of the NPPF are ignored, resulting in significant harm to the Green Belt.
Para 2.41 and 2.42 Figures for Lutons housing capacity are out of date and this has an important bearing on the scale for new housing that North Hertfordshire should contribute to Luton's needs. Figures updated through EIP process. Specific intention in para 2.42 to meet all of the Plans proposed contribution to Luton's housing needs within the small strip of GB land immediately abutting Luton is unjustified, particularly when weighed against the harm that would be caused to the GB and the high quality landscape of the whole of this area, and the likely impact on the communities in the area and rural infrastructure.
Para 2.44 - The plan does not justify he statement that Stevenage is unable to provide adequate employment land within its own administrative area to meet the scale of need that is acceptable in the context of NPPF para 14. The evidence on capacity within Stevenage has yet to be tested through the SBC Local Plan examination which is due to commence in January. NHDC plan should not pre-judge the inspectors conclusions on this issue.
Para 2.66 - The second bullet point fails to include the important caveat in NPPF para 14 and footnote 9, which set out the context for meeting development needs and the principal constraints limiting this aspiration.

Object

Representation ID: 6049

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to SP2 - (part 2) Villages currently washed over should not be included in the policy, boundaries are established, no exceptional circumstances. Para 86 relates to newly created Green Belt.

- (part 3) plan should not give unlimited support to any infill development. Built core should be identified in relation to category B villages.

Object

Representation ID: 6075

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to removal of 19.6ha of GB land for employment site, principally on matters of principle. The proposed allocation is unsound - object to how council has addressed issue of exceptional circumstances. Proposal is misinterpretation, outlined in para 4.53 of the plan and the Council's Green Belt Review 2016, of national Planning Policy as set out in para 83-86. Para 83 specifically requires exceptional circumstances to be shown to justify removal of land from the Green Belt by redrawing of any GB boundary. None of the proposals for development of sites currently within the GReen Belt , including the proposed Baldock employment area, satisfy this national policy requirement. No justification provided for this major employment site despite being the largest such site that the council proposes to remove from the Green Belt.

CPRE considers that this proposal, in combination with the adjacent strategic housing proposal (BA1) would have a significant adverse impact on the purposes of the Green Belt that have not been adequately addressed by either the local plan or the council's Green Belt Review.

Object

Representation ID: 6076

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to SP5: Fundamental misinterpretation outlined in para 4.53 and the Green Belt Review of National policy in NPPF para 83-86. Para 83 requires exceptional circumstances to be shown to justify removal of land from GB by the redrawing of any individual GB boundary. None of the 3 categories of site liseted in SP5 paragraph (a) satisfy this national policy requirement. This applies to strategic allocations and development around towns and villages in the GB.
Furthermore the Council has used para 86 as the basis for removal of villages from the GB, as if the GReen Belt boundaries are being defined for the first time, whereas all of these villages are already washed over by permanent GB. As the plan accepts in several parts of the plan, eg "current Green Belt boundaries have been in place for 20 years". Any change needs to be justified by exceptional circumstances, which the plan makes to attempt to demonstrate.

Para 4.53 - Final sentence of 4.53 of the plan fails to meet the requirement of NPPF para 83 to set out exceptional circumstances for changing established GB boundaries. Not set out in Plan or Evidence. para does not refer to Housing and GB Background paper, and whilst this claims that exceptional circumstances exist the statement that assessed housing need is both acute and intense is patently incorrect. incorrect justification - proposals in plan unsound.

Para 4.60 - Para sets out boundaries defined following approach set out in para 85 and 86 of NPPF. Flawed interpretation as redrawing permanent GB boundaries should only take place in defined exceptional circumstances, not just because a local plan is being prepared.

Object

Representation ID: 6079

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to part (a) and (b) - not justified by sound evidence, not justified that luton need should be met in the district, no exception circumstances, criticisms in relation to para 4.53, not NPPF compliant - meet objectively assessed need "unless policies in the NPPF say that development should be restricted. more detailed and sophisticated analysis needed - no justification or explanation for "acute" need.
part (c) - see para 4.60 comments flawed interpretation of NPPF, only redrawing permanent GB boundaries in exceptional circumstances.

part d and para 4.95? - only 20% on PDL, greater capacity from previously developed land, reduce the need for housing development in the GReen Belt and contribute to meeting a lower and more sustainable housing target.

part eii and para 4.104-4.105 - removal of land w of Stevenage for development after 2026 is unsound because it is unjustified and inconsistent with national policy, No exceptional circumstances demonstrated,

Object

Representation ID: 6080

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to BA1 (and supporting text): No exceptional circumstances, misinterpretation of NPPF policy, significant adverse impact on GB purposes not adequately addressed in plan or evidence.

Object

Representation ID: 6081

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to LG1 (and supporting text): No exceptional circumstances, misinterpretation of NPPF policy, significant adverse impact on GB purposes not adequately addressed in plan or evidence.

Object

Representation ID: 6082

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to NS1 (and supporting text): No exceptional circumstances, misinterpretation of NPPF policy, significant adverse impact on GB purposes not adequately addressed in plan or evidence, no consideration of opposition to land in Stevenage and local landscape impacts.

Object

Representation ID: 6083

Received: 23/11/2016

Respondent: CPRE Hertfordshire

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Object to SP17 (and supporting text): No exceptional circumstances, misinterpretation of NPPF policy, significant adverse impact on GB purposes not adequately addressed in plan or evidence.