Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

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Comment

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

FM 016

Representation ID: 8741

Received: 22/06/2021

Respondent: Transition Town Letchworth

Representation Summary:

If this modification is about showing where the age profile of North Herts population diverges from Hertfordshire it fails to do this by not identifying the age group where the district has above average population representation, it only identifies below average representation in the 15-29 age grouping.

Full text:

If this modification is about showing where the age profile of North Herts population diverges from Hertfordshire it fails to do this by not identifying the age group where the district has above average population representation, it only identifies below average representation in the 15-29 age grouping.

Comment

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

FM 017

Representation ID: 8742

Received: 22/06/2021

Respondent: Transition Town Letchworth

Representation Summary:

This paragraph has been adjusted to give the population prediction for next ten years based on now outdated 2016 predictions. However, the plan, and housing numbers are for 20 years so it would be helpful to also identify the total population growth over the 20 years period by indicating the growth that has occurred up to 2021. Given that population growth predictions have been reviewed downwards in both ONS 2016 and 2018 population projections is it accurate to say there is ‘considerable’ pressure on housing, ‘moderate’ might be a better description.

Full text:

This paragraph has been adjusted to give the population prediction for next ten years based on now outdated 2016 predictions. However, the plan, and housing numbers are for 20 years so it would be helpful to also identify the total population growth over the 20 years period by indicating the growth that has occurred up to 2021. Given that population growth predictions have been reviewed downwards in both ONS 2016 and 2018 population projections is it accurate to say there is ‘considerable’ pressure on housing, ‘moderate’ might be a better description.

Comment

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

FM 018

Representation ID: 8743

Received: 22/06/2021

Respondent: Transition Town Letchworth

Representation Summary:

For balance it would be helpful to add the life expectancy figure for women in the most deprived areas of North Herts.

Full text:

For balance it would be helpful to add the life expectancy figure for women in the most deprived areas of North Herts.

Comment

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

FM 020

Representation ID: 8744

Received: 22/06/2021

Respondent: Transition Town Letchworth

Representation Summary:

For balance it would be helpful to add the life expectancy figure for women in the most deprived areas of North Herts.

Full text:

For balance it would be helpful to add the life expectancy figure for women in the most deprived areas of North Herts.

Object

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

FM 028

Representation ID: 8746

Received: 22/06/2021

Respondent: Transition Town Letchworth

Representation Summary:

The OAN of 11,500 was subject to considerable challenge during the hearing sessions. 2018 ONS housing projections suggest an OAN of at most 8,800. With the heavy reliance on green belt land that underlies this plan, over-provision of housing has a huge environmental cost and TTL would like to see North Herts make a case for a lower OAN based on the need to protect the green belt and in respect of the ONS 2018 population projections.

Full text:

The OAN of 11,500 was subject to considerable challenge during the hearing sessions. 2018 ONS housing projections suggest an OAN of at most 8,800. With the heavy reliance on green belt land that underlies this plan, over-provision of housing has a huge environmental cost and TTL would like to see North Herts make a case for a lower OAN based on the need to protect the green belt and in respect of the ONS 2018 population projections.

Comment

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

FM 030

Representation ID: 8747

Received: 22/06/2021

Respondent: Transition Town Letchworth

Representation Summary:

TTL would expect NHDC to acknowledge and focus on developing housing in places that can sustainably access the growing Cambridge employment area.

Full text:

TTL would expect NHDC to acknowledge and focus on developing housing in places that can sustainably access the growing Cambridge employment area.

Comment

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

FM 035

Representation ID: 8748

Received: 22/06/2021

Respondent: Transition Town Letchworth

Representation Summary:

The phrase “have regard to this strategy” appears to refer to LTP3 as adopted in 2011. Because the Hertfordshire Transport vision to 2050 was not produced by 2016, but is now close to publication, it would in our view be sound to adopt its vision and strategy for the Local Plan 2011-2031.
Should the deleted wording of this paragraph be replaced by a brief explanation of how LTP4 and the various local plans across the county, including this local plan will be reconciled to provide a consistent solution for transport, housing and employment?

Full text:

The phrase “have regard to this strategy” appears to refer to LTP3 as adopted in 2011. Because the Hertfordshire Transport vision to 2050 was not produced by 2016, but is now close to publication, it would in our view be sound to adopt its vision and strategy for the Local Plan 2011-2031.
Should the deleted wording of this paragraph be replaced by a brief explanation of how LTP4 and the various local plans across the county, including this local plan will be reconciled to provide a consistent solution for transport, housing and employment?

Comment

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

FM 038

Representation ID: 8749

Received: 22/06/2021

Respondent: Transition Town Letchworth

Representation Summary:

The final bullet point says “good quality”, what does this mean in terms that can be put into practice and verified by measurement? TTL would like these words replaced with “zero carbon” which would align with ambitions in the NHDC Climate Strategy.

Full text:

The final bullet point says “good quality”, what does this mean in terms that can be put into practice and verified by measurement? TTL would like these words replaced with “zero carbon” which would align with ambitions in the NHDC Climate Strategy.

Object

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

MM 017 / FM 050

Representation ID: 8751

Received: 22/06/2021

Respondent: Transition Town Letchworth

Representation Summary:

At the hearings concerns were raised that the modelling and data which informed the retail space allocations in the draft local plan were considered out-of-date. TTL’s expectation is that land allocated for retail could be reassigned for housing, reducing the need to build on green belt land. It is not clear why NHDC did not take the opportunity offered by the hearing to suggest a reduced allocation of land for retail.
Now we are emerging from Covid-19, it is becoming clear which retail modes of operation have changed. It seems to us unsound to exclude that reality from the Plan.

Full text:

At the hearings concerns were raised that the modelling and data which informed the retail space allocations in the draft local plan were considered out-of-date, shopping behaviours have radically changed. TTL’s expectation is that land allocated for retail could be reassigned for housing, reducing the need to build on green belt land. It is not clear why NHDC did not take the opportunity offered by the hearing to suggest a reduced allocation of land for retail.
Now that we appear to be emerging from the main Covid-19, it is becoming clear which outlets have survived, which have not and which retail modes of operation have changed substantially. It seems to us unsound to exclude that reality from the Plan.

Object

Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

MM 019 / FM 052

Representation ID: 8753

Received: 22/06/2021

Respondent: Transition Town Letchworth

Representation Summary:

Twelve months after adoption of this plan seems late to review the outdated Town Centre strategies. If a review could take place prior to adoption of this plan, it seems likely that a number of brown field sites could be reallocated to housing, allowing green belt land to be removed from the plan.

The proposed change causes a contradiction between “Town centre strategies have been produced” and “Work on these town centre strategies will commence…”. In view of drastic changes noted above for FM50, could this be clarified by proposing that revised strategies be produced now for this Local Plan?

Full text:

Twelve months into the adoption of this plan seems too late to review the outdated Town Centre strategies (which were published between 2004 and 2008). If a review could take place prior to adoption of this plan, it seems likely that a number of brown field sites could be reallocated to housing, allowing green belt land to be removed from the plan.

The proposed change causes a contradiction between “Town centre strategies have been produced” and “Work on these town centre strategies will commence…”. In view of drastic changes noted above for FM50, could this be clarified by proposing that revised strategies be produced now for this Local Plan?

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