Proposed Main Modifications

We object to the lack of a main modification in relation to criterion b. of this policy, to allocate large swathes of new Green Belt land. Whilst we welcome the creation of some new, compensatory, Green Belt, we are concerned by the large scale of what has been proposed and the lack of justification for such a large designation of new Green Belt land.
Green Belt boundaries are required to have permanence in the long term (NPPF, para.83), and must be capable of enduring beyond the plan period. The Borough Council does not believe that this longer term future has been considered fully and would argue that some of the land being designated as Green Belt may be required in the future to meet increased housing needs. It is not clear that needs beyond the plan period have been calculated or considered in making these proposals. SBC would question how the view has been arrived at that the West of Stevenage safeguarded land provides sufficient capacity to accommodate future growth beyond the plan period, including taking into account the needs of SBC.
Designating such a large swathe of land as new Green Belt within NHDC, would significantly limit the opportunities for NHDC to help in terms of meeting any future needs under the Duty to Co-operate.

We object to the modification proposed to criterion e. of this policy. Please refer to our more detailed comments in relation to Policy T2 for further details of our objection.

Support modification MM030 that specifically requires strategies produced by neighbouring local authorities to be taken into account, including the Stevenage Mobility Strategy. The promotion of active and sustainable travel is a key part of the emerging Stevenage Borough Local Plan (SBLP) and this amendment will help to ensure consistency when dealing with sites adjacent to the boundary and ensure the infrastructure can accommodate with the planned growth.

We support the fact that the amendments proposed to Policy SP16 go some way towards resolving our objections in relation to infrastructure. The addition of references to sustainable travel, medical infrastructure, retail facilities, more detailed educational requirements and sensitive design related to heritage assets are welcomed.

However, the modifications have still been worded to enable the developers of site NS1 to rely on infrastructure being provided on an entirely separate adjoining allocation in Stevenage Borough. The policies within the Stevenage Borough Local Plan only require the developers of the adjoining site (Policy HO3) to provided infrastructure sufficient to support the Stevenage site (800 homes). This will not be sufficient to serve the NHDC site (900 homes) as well. All other site specific policies within the NHDC Local Plan make specific requirements for retail, education and other infrastructure to be provided on-site. Policy SP16 should follow the same approach.

In terms of primary school provision, this is now even more crucial as Hertfordshire County Council (in responding to the now-submitted planning application for HO3) have advised they require two entirely separate primary schools for the Stevenage and North Herts sites, not one larger school. As such, a 'site-wide' approach would clearly not be appropriate or sound.

We would propose the Modifications are amended, as follows, to reflect these comments. A site-wide solution integrating with the adjoining Stevenage development is appropriate and welcomed for access and sustainable travel, but education, retail and other social infrastructure should be provided on the NHDC site in accordance with the evidence of need used to inform the Local Plan and in line with other site specific policies within the plan - a consistent approach should be taken. This is not a joint allocation with the Stevenage site.

As written, the NHLP is unsound in relation to this issue as it may result in a shortfall of infrastructure to meet the needs resulting from NS1.

We would also maintain our position in relation to consideration of the design principles of Stevenage being included as a requirement of this policy, as has been included in Policy SP15 relating to Letchworth design principles (criterion a. i.) and suggest a new criterion should be added to this policy, as per the below track changes version.

.....

b. Integration with adjoining development in Stevenage Borough including site-wide solutions for access and sustainable travel to include:
ii. Travel provision designed having regard to the Stevenage Mobility Strategy and including:
* Effective links into the existing pedestrian and cycle, public transport and road networks; and
* an upgraded junction at the intersection of Graveley Road / North Road.
c. 2FE of primary-age education provision;
d. Neighbourhood-level retail facilities subject to an up-to-date assessment of local demand and supply;
e. Other medical and social infrastructure, as necessary, in accordance with an up-to-date assessment of need;
.....
i. Stevenage design principles should be considered and reflected in any development scheme.

Support amendment to include reference to the Stevenage Mobility Strategy and its hierarchy.
Whilst the detail added in relation to the level of primary school provision required is welcomed, the text proposed in the second line of this paragraph requires amendment in line with HCC's updated advice (on the planning application for the adjoining Stevenage site) that the two sites should have separate schools of 2FE and not one larger co-located school. This is also in line with our comments on MM068.
Support the addition of further detail in relation to GP provision on this site.
Support the addition of further detail in relation to retail needs. However, the replacement of the word 'could' with the word 'should' in the first line of this paragraph would be more reflective of the evidence base that demonstrates a definite need for this A-class floorspace to be provided. We would request the second sentence of this paragraph 'Equally it is recognised....' is removed. Sites cannot rely on infrastructure that is 'proposed' on other sites to come forward in order to mitigate its impact.

Support the expanded reference to heritage assets and the need for sensitive design and layout, particularly specific reference to those within the Borough.

Support proposed amendments to Policy GA2 to specify that 4ha of land will be provided on this site for educational provision, to provide 2FE primary and 4FE secondary school provision. This will ensure sufficient primary and secondary school capacity exists to serve the development and alleviate pressure arising from other developments in this area.
Support the addition of reference to medical and other social infrastructure and supporting text to explain these requirements.
Support proposed addition of criterion d. i. and ii., which reflects the need to take into account the Stevenage Mobility Strategy and the need to promote active and sustainable travel particularly.

Support proposed additional text relating to GP surgeries to clarify the level of provision evidenced to be required across all 3 sites in this area.

Support the proposed addition of text to reflect the amendments made to Policy SP18.

Support all additional text relating to access and integration of the site, and particularly reference to both the Stevenage Mobility Strategy and consultation with Stevenage Borough Council.