Sustainability Draft Supplementary Planning Document

HCC comments on the North Herts Sustainability SPD consultation February 2024

General comment regarding the HGB missions: The Hertfordshire Growth Board have prepared a series of mission statements covering; World Class Economy,
Digital Access for All, Transport for Hertfordshire, Right Homes, Right Places, Healthy Places for All and Sustainable County. It would be beneficial for the SPD to
refer to the missions as relevant.
General comment regarding references to the NPPF: the SPD may need to be reviewed following the publication of the revised NPPF and NPPG.
Specific comments:
• Pg 6 The last sentence of the opening paragraph currently reads ‘managing the flood risk’. Suggest this be changed to ‘managing the risk of flooding’ or
‘managing flood risk’.

• Pg 11, Table 1 – the NPPF may now be relevant to more sections -energy use/low carbon? Also the table switches between National Planning Policy Framework and the NPPF.

• The document may benefit from referencing the National Planning Practice Guidance. There have also been recent Ministerial Statements that may be relevant – energy efficiency.

• Pg 16 the Tyndall report and the SPD make recommendations regarding ‘shipping and aviation’ however, this may not be relevant to North Herts and
so would benefit from some explanation.

• Pg23 Hertfordshire Ecology is now known as ‘Hertfordshire LEADS’. The link provided is also broken. Here is the current link: Wildlife (Ecology) |
Hertfordshire County Council

• Pg25 ‘bat boxes, bird feeders, insect hotels, insect hibernation houses’ cannot be accounted for in the BNG metric and therefore have no impact on a BNG
unit score of a site. So while they may be best practice for enhancing the biodiversity of a site generally they are not best practice for achieving high quality BNG according to the metric. Admittedly a minor point.

• Pg25 Local Nature Recovery Strategy section doesn’t mention the Local Nature Recovery Strategy and references Nature Recovery Networks which is
not a term that sees a lot of usage. I suggest changing:

‘…which includes provision for a Nature Recovery Network (NRN) states that recovering wildlife will require more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the NRN should be designed to bring a wide range of additional benefits such as:’ to '…which includes the provision of Local Nature Recovery Strategies
(LNRSs)across England. The Hertfordshire Nature Recovery Partnership will lead on the creation of Hertfordshire’s Local Nature Recovery Strategy which
will enable the delivery of more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the LNRS will be designed to bring a wide range of additional benefits such as:’

• Pg25 The bottom of the page references ‘the Local Nature Partnership’. This partnership is now defunct. The reference should be changed to the Hertfordshire Nature Recovery Partnership - Hertfordshire Nature Recovery
Partnership | Hertfordshire County Council

• Pg26 This process map is now out of date. It has now been confirmed that a Biodiversity Gain Plan needs to include confirmation of a site being legally secured and added to the national register and does not need to be submitted prior to determination of a planning application. As such, it should come after these steps in the process. I don’t have a link to a decent process map. I would avoid including a process map at all as the process is so complicated any simple map like this may just mislead those unfamiliar.

• The SPD does not define how North Herts will determine Strategic Significance areas for BNG calculations until the LNRS is in place. There is no requirement to do this but it will be of interest to developers and a clear policy
will speed up the assessment of applications. Is this listed elsewhere? If not, Hertfordshire LEADS recommend using the Hertfordshire Ecological Network Map provided by HERC. If you need support with this, one of the ecologists in the LEADS team would be happy to advise.

• Pg 44 Dry biomass ‘The most common source of dry biomass is wood ‘form’ forests’. Should this sentence read ‘from’ rather than form?

Pg 54 Air Quality
The inclusion of the paragraph stating “Children are more vulnerable to the effects of air pollution therefore play/ recreation spaces should be located such as to minimize
exposure to air pollution” is a well thought out addition focussing on more at risk individuals and whole life course health impact. As noted in HCC’s Air Quality JSNA
those living in more deprived areas, which highlights those who may have limited personal funds available, are also more at risk to air pollutants. As such it is suggested that this paragraph could be expanded to follow the evidence in this area and extend to affordable housing contribution locations on any site, care/residential homes, and health sites (e.g. position these in areas likely to receive best air quality within the development site).

The paragraph which states “Development design should prioritise sustainable and active travel modes to help reduce reliance on private cars (see transport section)” is
welcomed. HCC Public Health wider determinants service area advocates using a Healthy Streets Approach to promote sustainable travel mode. Referencing this and
expressing a desire for developers to present development which has taken on board a Healthy Streets approach is required. There is the potential for the SPD to go further and request all developments/ that which is over a certain size to score the streets proposed using a Healthy Streets Design Check available at: Healthy Streets | Making streets healthy places for everyone. A minimum score threshold for new streets could be proposed. In addition requiring development to contribute to the network of streets the proposed development will feed into to uplift the existing locality street score is suggested for inclusion. This is to ensure that the wider area has relevant improvements required to reduce barriers to sustainable travel in the proposal area to encourage these modes to occur both on and off the development land parcel. This approach supports the travel plan aspect of the SPD by promoting confidence that sustainable mode share is likely to be adopted widely.

HCC comments on the North Herts Sustainability SPD consultation February 2024

General comment regarding the HGB missions: The Hertfordshire Growth Board have prepared a series of mission statements covering; World Class Economy,
Digital Access for All, Transport for Hertfordshire, Right Homes, Right Places, Healthy Places for All and Sustainable County. It would be beneficial for the SPD to
refer to the missions as relevant.
General comment regarding references to the NPPF: the SPD may need to be reviewed following the publication of the revised NPPF and NPPG.
Specific comments:
• Pg 6 The last sentence of the opening paragraph currently reads ‘managing the flood risk’. Suggest this be changed to ‘managing the risk of flooding’ or
‘managing flood risk’.

• Pg 11, Table 1 – the NPPF may now be relevant to more sections -energy use/low carbon? Also the table switches between National Planning Policy Framework and the NPPF.

• The document may benefit from referencing the National Planning Practice Guidance. There have also been recent Ministerial Statements that may be relevant – energy efficiency.

• Pg 16 the Tyndall report and the SPD make recommendations regarding ‘shipping and aviation’ however, this may not be relevant to North Herts and
so would benefit from some explanation.

• Pg23 Hertfordshire Ecology is now known as ‘Hertfordshire LEADS’. The link provided is also broken. Here is the current link: Wildlife (Ecology) |
Hertfordshire County Council

• Pg25 ‘bat boxes, bird feeders, insect hotels, insect hibernation houses’ cannot be accounted for in the BNG metric and therefore have no impact on a BNG
unit score of a site. So while they may be best practice for enhancing the biodiversity of a site generally they are not best practice for achieving high quality BNG according to the metric. Admittedly a minor point.

• Pg25 Local Nature Recovery Strategy section doesn’t mention the Local Nature Recovery Strategy and references Nature Recovery Networks which is
not a term that sees a lot of usage. I suggest changing:

‘…which includes provision for a Nature Recovery Network (NRN) states that recovering wildlife will require more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the NRN should be designed to bring a wide range of additional benefits such as:’ to '…which includes the provision of Local Nature Recovery Strategies
(LNRSs)across England. The Hertfordshire Nature Recovery Partnership will lead on the creation of Hertfordshire’s Local Nature Recovery Strategy which
will enable the delivery of more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the LNRS will be designed to bring a wide range of additional benefits such as:’

• Pg25 The bottom of the page references ‘the Local Nature Partnership’. This partnership is now defunct. The reference should be changed to the Hertfordshire Nature Recovery Partnership - Hertfordshire Nature Recovery
Partnership | Hertfordshire County Council

• Pg26 This process map is now out of date. It has now been confirmed that a Biodiversity Gain Plan needs to include confirmation of a site being legally secured and added to the national register and does not need to be submitted prior to determination of a planning application. As such, it should come after these steps in the process. I don’t have a link to a decent process map. I would avoid including a process map at all as the process is so complicated any simple map like this may just mislead those unfamiliar.

• The SPD does not define how North Herts will determine Strategic Significance areas for BNG calculations until the LNRS is in place. There is no requirement to do this but it will be of interest to developers and a clear policy
will speed up the assessment of applications. Is this listed elsewhere? If not, Hertfordshire LEADS recommend using the Hertfordshire Ecological Network Map provided by HERC. If you need support with this, one of the ecologists in the LEADS team would be happy to advise.

• Pg 44 Dry biomass ‘The most common source of dry biomass is wood ‘form’ forests’. Should this sentence read ‘from’ rather than form?

Pg 54 Air Quality
The inclusion of the paragraph stating “Children are more vulnerable to the effects of air pollution therefore play/ recreation spaces should be located such as to minimize
exposure to air pollution” is a well thought out addition focussing on more at risk individuals and whole life course health impact. As noted in HCC’s Air Quality JSNA
those living in more deprived areas, which highlights those who may have limited personal funds available, are also more at risk to air pollutants. As such it is suggested that this paragraph could be expanded to follow the evidence in this area and extend to affordable housing contribution locations on any site, care/residential homes, and health sites (e.g. position these in areas likely to receive best air quality within the development site).

The paragraph which states “Development design should prioritise sustainable and active travel modes to help reduce reliance on private cars (see transport section)” is
welcomed. HCC Public Health wider determinants service area advocates using a Healthy Streets Approach to promote sustainable travel mode. Referencing this and
expressing a desire for developers to present development which has taken on board a Healthy Streets approach is required. There is the potential for the SPD to go further and request all developments/ that which is over a certain size to score the streets proposed using a Healthy Streets Design Check available at: Healthy Streets | Making streets healthy places for everyone. A minimum score threshold for new streets could be proposed. In addition requiring development to contribute to the network of streets the proposed development will feed into to uplift the existing locality street score is suggested for inclusion. This is to ensure that the wider area has relevant improvements required to reduce barriers to sustainable travel in the proposal area to encourage these modes to occur both on and off the development land parcel. This approach supports the travel plan aspect of the SPD by promoting confidence that sustainable mode share is likely to be adopted widely.

HCC comments on the North Herts Sustainability SPD consultation February 2024

General comment regarding the HGB missions: The Hertfordshire Growth Board have prepared a series of mission statements covering; World Class Economy,
Digital Access for All, Transport for Hertfordshire, Right Homes, Right Places, Healthy Places for All and Sustainable County. It would be beneficial for the SPD to
refer to the missions as relevant.
General comment regarding references to the NPPF: the SPD may need to be reviewed following the publication of the revised NPPF and NPPG.
Specific comments:
• Pg 6 The last sentence of the opening paragraph currently reads ‘managing the flood risk’. Suggest this be changed to ‘managing the risk of flooding’ or
‘managing flood risk’.

• Pg 11, Table 1 – the NPPF may now be relevant to more sections -energy use/low carbon? Also the table switches between National Planning Policy Framework and the NPPF.

• The document may benefit from referencing the National Planning Practice Guidance. There have also been recent Ministerial Statements that may be relevant – energy efficiency.

• Pg 16 the Tyndall report and the SPD make recommendations regarding ‘shipping and aviation’ however, this may not be relevant to North Herts and
so would benefit from some explanation.

• Pg23 Hertfordshire Ecology is now known as ‘Hertfordshire LEADS’. The link provided is also broken. Here is the current link: Wildlife (Ecology) |
Hertfordshire County Council

• Pg25 ‘bat boxes, bird feeders, insect hotels, insect hibernation houses’ cannot be accounted for in the BNG metric and therefore have no impact on a BNG
unit score of a site. So while they may be best practice for enhancing the biodiversity of a site generally they are not best practice for achieving high quality BNG according to the metric. Admittedly a minor point.

• Pg25 Local Nature Recovery Strategy section doesn’t mention the Local Nature Recovery Strategy and references Nature Recovery Networks which is
not a term that sees a lot of usage. I suggest changing:

‘…which includes provision for a Nature Recovery Network (NRN) states that recovering wildlife will require more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the NRN should be designed to bring a wide range of additional benefits such as:’ to '…which includes the provision of Local Nature Recovery Strategies
(LNRSs)across England. The Hertfordshire Nature Recovery Partnership will lead on the creation of Hertfordshire’s Local Nature Recovery Strategy which
will enable the delivery of more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the LNRS will be designed to bring a wide range of additional benefits such as:’

• Pg25 The bottom of the page references ‘the Local Nature Partnership’. This partnership is now defunct. The reference should be changed to the Hertfordshire Nature Recovery Partnership - Hertfordshire Nature Recovery
Partnership | Hertfordshire County Council

• Pg26 This process map is now out of date. It has now been confirmed that a Biodiversity Gain Plan needs to include confirmation of a site being legally secured and added to the national register and does not need to be submitted prior to determination of a planning application. As such, it should come after these steps in the process. I don’t have a link to a decent process map. I would avoid including a process map at all as the process is so complicated any simple map like this may just mislead those unfamiliar.

• The SPD does not define how North Herts will determine Strategic Significance areas for BNG calculations until the LNRS is in place. There is no requirement to do this but it will be of interest to developers and a clear policy
will speed up the assessment of applications. Is this listed elsewhere? If not, Hertfordshire LEADS recommend using the Hertfordshire Ecological Network Map provided by HERC. If you need support with this, one of the ecologists in the LEADS team would be happy to advise.

• Pg 44 Dry biomass ‘The most common source of dry biomass is wood ‘form’ forests’. Should this sentence read ‘from’ rather than form?

Pg 54 Air Quality
The inclusion of the paragraph stating “Children are more vulnerable to the effects of air pollution therefore play/ recreation spaces should be located such as to minimize
exposure to air pollution” is a well thought out addition focussing on more at risk individuals and whole life course health impact. As noted in HCC’s Air Quality JSNA
those living in more deprived areas, which highlights those who may have limited personal funds available, are also more at risk to air pollutants. As such it is suggested that this paragraph could be expanded to follow the evidence in this area and extend to affordable housing contribution locations on any site, care/residential homes, and health sites (e.g. position these in areas likely to receive best air quality within the development site).

The paragraph which states “Development design should prioritise sustainable and active travel modes to help reduce reliance on private cars (see transport section)” is
welcomed. HCC Public Health wider determinants service area advocates using a Healthy Streets Approach to promote sustainable travel mode. Referencing this and
expressing a desire for developers to present development which has taken on board a Healthy Streets approach is required. There is the potential for the SPD to go further and request all developments/ that which is over a certain size to score the streets proposed using a Healthy Streets Design Check available at: Healthy Streets | Making streets healthy places for everyone. A minimum score threshold for new streets could be proposed. In addition requiring development to contribute to the network of streets the proposed development will feed into to uplift the existing locality street score is suggested for inclusion. This is to ensure that the wider area has relevant improvements required to reduce barriers to sustainable travel in the proposal area to encourage these modes to occur both on and off the development land parcel. This approach supports the travel plan aspect of the SPD by promoting confidence that sustainable mode share is likely to be adopted widely.

HCC comments on the North Herts Sustainability SPD consultation February 2024

General comment regarding the HGB missions: The Hertfordshire Growth Board have prepared a series of mission statements covering; World Class Economy,
Digital Access for All, Transport for Hertfordshire, Right Homes, Right Places, Healthy Places for All and Sustainable County. It would be beneficial for the SPD to
refer to the missions as relevant.
General comment regarding references to the NPPF: the SPD may need to be reviewed following the publication of the revised NPPF and NPPG.
Specific comments:
• Pg 6 The last sentence of the opening paragraph currently reads ‘managing the flood risk’. Suggest this be changed to ‘managing the risk of flooding’ or
‘managing flood risk’.

• Pg 11, Table 1 – the NPPF may now be relevant to more sections -energy use/low carbon? Also the table switches between National Planning Policy Framework and the NPPF.

• The document may benefit from referencing the National Planning Practice Guidance. There have also been recent Ministerial Statements that may be relevant – energy efficiency.

• Pg 16 the Tyndall report and the SPD make recommendations regarding ‘shipping and aviation’ however, this may not be relevant to North Herts and
so would benefit from some explanation.

• Pg23 Hertfordshire Ecology is now known as ‘Hertfordshire LEADS’. The link provided is also broken. Here is the current link: Wildlife (Ecology) |
Hertfordshire County Council

• Pg25 ‘bat boxes, bird feeders, insect hotels, insect hibernation houses’ cannot be accounted for in the BNG metric and therefore have no impact on a BNG
unit score of a site. So while they may be best practice for enhancing the biodiversity of a site generally they are not best practice for achieving high quality BNG according to the metric. Admittedly a minor point.

• Pg25 Local Nature Recovery Strategy section doesn’t mention the Local Nature Recovery Strategy and references Nature Recovery Networks which is
not a term that sees a lot of usage. I suggest changing:

‘…which includes provision for a Nature Recovery Network (NRN) states that recovering wildlife will require more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the NRN should be designed to bring a wide range of additional benefits such as:’ to '…which includes the provision of Local Nature Recovery Strategies
(LNRSs)across England. The Hertfordshire Nature Recovery Partnership will lead on the creation of Hertfordshire’s Local Nature Recovery Strategy which
will enable the delivery of more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the LNRS will be designed to bring a wide range of additional benefits such as:’

• Pg25 The bottom of the page references ‘the Local Nature Partnership’. This partnership is now defunct. The reference should be changed to the Hertfordshire Nature Recovery Partnership - Hertfordshire Nature Recovery
Partnership | Hertfordshire County Council

• Pg26 This process map is now out of date. It has now been confirmed that a Biodiversity Gain Plan needs to include confirmation of a site being legally secured and added to the national register and does not need to be submitted prior to determination of a planning application. As such, it should come after these steps in the process. I don’t have a link to a decent process map. I would avoid including a process map at all as the process is so complicated any simple map like this may just mislead those unfamiliar.

• The SPD does not define how North Herts will determine Strategic Significance areas for BNG calculations until the LNRS is in place. There is no requirement to do this but it will be of interest to developers and a clear policy
will speed up the assessment of applications. Is this listed elsewhere? If not, Hertfordshire LEADS recommend using the Hertfordshire Ecological Network Map provided by HERC. If you need support with this, one of the ecologists in the LEADS team would be happy to advise.

• Pg 44 Dry biomass ‘The most common source of dry biomass is wood ‘form’ forests’. Should this sentence read ‘from’ rather than form?

Pg 54 Air Quality
The inclusion of the paragraph stating “Children are more vulnerable to the effects of air pollution therefore play/ recreation spaces should be located such as to minimize
exposure to air pollution” is a well thought out addition focussing on more at risk individuals and whole life course health impact. As noted in HCC’s Air Quality JSNA
those living in more deprived areas, which highlights those who may have limited personal funds available, are also more at risk to air pollutants. As such it is suggested that this paragraph could be expanded to follow the evidence in this area and extend to affordable housing contribution locations on any site, care/residential homes, and health sites (e.g. position these in areas likely to receive best air quality within the development site).

The paragraph which states “Development design should prioritise sustainable and active travel modes to help reduce reliance on private cars (see transport section)” is
welcomed. HCC Public Health wider determinants service area advocates using a Healthy Streets Approach to promote sustainable travel mode. Referencing this and
expressing a desire for developers to present development which has taken on board a Healthy Streets approach is required. There is the potential for the SPD to go further and request all developments/ that which is over a certain size to score the streets proposed using a Healthy Streets Design Check available at: Healthy Streets | Making streets healthy places for everyone. A minimum score threshold for new streets could be proposed. In addition requiring development to contribute to the network of streets the proposed development will feed into to uplift the existing locality street score is suggested for inclusion. This is to ensure that the wider area has relevant improvements required to reduce barriers to sustainable travel in the proposal area to encourage these modes to occur both on and off the development land parcel. This approach supports the travel plan aspect of the SPD by promoting confidence that sustainable mode share is likely to be adopted widely.

HCC comments on the North Herts Sustainability SPD consultation February 2024

General comment regarding the HGB missions: The Hertfordshire Growth Board have prepared a series of mission statements covering; World Class Economy,
Digital Access for All, Transport for Hertfordshire, Right Homes, Right Places, Healthy Places for All and Sustainable County. It would be beneficial for the SPD to
refer to the missions as relevant.
General comment regarding references to the NPPF: the SPD may need to be reviewed following the publication of the revised NPPF and NPPG.
Specific comments:
• Pg 6 The last sentence of the opening paragraph currently reads ‘managing the flood risk’. Suggest this be changed to ‘managing the risk of flooding’ or
‘managing flood risk’.

• Pg 11, Table 1 – the NPPF may now be relevant to more sections -energy use/low carbon? Also the table switches between National Planning Policy Framework and the NPPF.

• The document may benefit from referencing the National Planning Practice Guidance. There have also been recent Ministerial Statements that may be relevant – energy efficiency.

• Pg 16 the Tyndall report and the SPD make recommendations regarding ‘shipping and aviation’ however, this may not be relevant to North Herts and
so would benefit from some explanation.

• Pg23 Hertfordshire Ecology is now known as ‘Hertfordshire LEADS’. The link provided is also broken. Here is the current link: Wildlife (Ecology) |
Hertfordshire County Council

• Pg25 ‘bat boxes, bird feeders, insect hotels, insect hibernation houses’ cannot be accounted for in the BNG metric and therefore have no impact on a BNG
unit score of a site. So while they may be best practice for enhancing the biodiversity of a site generally they are not best practice for achieving high quality BNG according to the metric. Admittedly a minor point.

• Pg25 Local Nature Recovery Strategy section doesn’t mention the Local Nature Recovery Strategy and references Nature Recovery Networks which is
not a term that sees a lot of usage. I suggest changing:

‘…which includes provision for a Nature Recovery Network (NRN) states that recovering wildlife will require more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the NRN should be designed to bring a wide range of additional benefits such as:’ to '…which includes the provision of Local Nature Recovery Strategies
(LNRSs)across England. The Hertfordshire Nature Recovery Partnership will lead on the creation of Hertfordshire’s Local Nature Recovery Strategy which
will enable the delivery of more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the LNRS will be designed to bring a wide range of additional benefits such as:’

• Pg25 The bottom of the page references ‘the Local Nature Partnership’. This partnership is now defunct. The reference should be changed to the Hertfordshire Nature Recovery Partnership - Hertfordshire Nature Recovery
Partnership | Hertfordshire County Council

• Pg26 This process map is now out of date. It has now been confirmed that a Biodiversity Gain Plan needs to include confirmation of a site being legally secured and added to the national register and does not need to be submitted prior to determination of a planning application. As such, it should come after these steps in the process. I don’t have a link to a decent process map. I would avoid including a process map at all as the process is so complicated any simple map like this may just mislead those unfamiliar.

• The SPD does not define how North Herts will determine Strategic Significance areas for BNG calculations until the LNRS is in place. There is no requirement to do this but it will be of interest to developers and a clear policy
will speed up the assessment of applications. Is this listed elsewhere? If not, Hertfordshire LEADS recommend using the Hertfordshire Ecological Network Map provided by HERC. If you need support with this, one of the ecologists in the LEADS team would be happy to advise.

• Pg 44 Dry biomass ‘The most common source of dry biomass is wood ‘form’ forests’. Should this sentence read ‘from’ rather than form?

Pg 54 Air Quality
The inclusion of the paragraph stating “Children are more vulnerable to the effects of air pollution therefore play/ recreation spaces should be located such as to minimize
exposure to air pollution” is a well thought out addition focussing on more at risk individuals and whole life course health impact. As noted in HCC’s Air Quality JSNA
those living in more deprived areas, which highlights those who may have limited personal funds available, are also more at risk to air pollutants. As such it is suggested that this paragraph could be expanded to follow the evidence in this area and extend to affordable housing contribution locations on any site, care/residential homes, and health sites (e.g. position these in areas likely to receive best air quality within the development site).

The paragraph which states “Development design should prioritise sustainable and active travel modes to help reduce reliance on private cars (see transport section)” is
welcomed. HCC Public Health wider determinants service area advocates using a Healthy Streets Approach to promote sustainable travel mode. Referencing this and
expressing a desire for developers to present development which has taken on board a Healthy Streets approach is required. There is the potential for the SPD to go further and request all developments/ that which is over a certain size to score the streets proposed using a Healthy Streets Design Check available at: Healthy Streets | Making streets healthy places for everyone. A minimum score threshold for new streets could be proposed. In addition requiring development to contribute to the network of streets the proposed development will feed into to uplift the existing locality street score is suggested for inclusion. This is to ensure that the wider area has relevant improvements required to reduce barriers to sustainable travel in the proposal area to encourage these modes to occur both on and off the development land parcel. This approach supports the travel plan aspect of the SPD by promoting confidence that sustainable mode share is likely to be adopted widely.

HCC comments on the North Herts Sustainability SPD consultation February 2024

General comment regarding the HGB missions: The Hertfordshire Growth Board have prepared a series of mission statements covering; World Class Economy,
Digital Access for All, Transport for Hertfordshire, Right Homes, Right Places, Healthy Places for All and Sustainable County. It would be beneficial for the SPD to
refer to the missions as relevant.
General comment regarding references to the NPPF: the SPD may need to be reviewed following the publication of the revised NPPF and NPPG.
Specific comments:
• Pg 6 The last sentence of the opening paragraph currently reads ‘managing the flood risk’. Suggest this be changed to ‘managing the risk of flooding’ or
‘managing flood risk’.

• Pg 11, Table 1 – the NPPF may now be relevant to more sections -energy use/low carbon? Also the table switches between National Planning Policy Framework and the NPPF.

• The document may benefit from referencing the National Planning Practice Guidance. There have also been recent Ministerial Statements that may be relevant – energy efficiency.

• Pg 16 the Tyndall report and the SPD make recommendations regarding ‘shipping and aviation’ however, this may not be relevant to North Herts and
so would benefit from some explanation.

• Pg23 Hertfordshire Ecology is now known as ‘Hertfordshire LEADS’. The link provided is also broken. Here is the current link: Wildlife (Ecology) |
Hertfordshire County Council

• Pg25 ‘bat boxes, bird feeders, insect hotels, insect hibernation houses’ cannot be accounted for in the BNG metric and therefore have no impact on a BNG
unit score of a site. So while they may be best practice for enhancing the biodiversity of a site generally they are not best practice for achieving high quality BNG according to the metric. Admittedly a minor point.

• Pg25 Local Nature Recovery Strategy section doesn’t mention the Local Nature Recovery Strategy and references Nature Recovery Networks which is
not a term that sees a lot of usage. I suggest changing:

‘…which includes provision for a Nature Recovery Network (NRN) states that recovering wildlife will require more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the NRN should be designed to bring a wide range of additional benefits such as:’ to '…which includes the provision of Local Nature Recovery Strategies
(LNRSs)across England. The Hertfordshire Nature Recovery Partnership will lead on the creation of Hertfordshire’s Local Nature Recovery Strategy which
will enable the delivery of more habitat, in better condition and in bigger patches that are more closely connected. As well as helping wildlife thrive, the LNRS will be designed to bring a wide range of additional benefits such as:’

• Pg25 The bottom of the page references ‘the Local Nature Partnership’. This partnership is now defunct. The reference should be changed to the Hertfordshire Nature Recovery Partnership - Hertfordshire Nature Recovery
Partnership | Hertfordshire County Council

• Pg26 This process map is now out of date. It has now been confirmed that a Biodiversity Gain Plan needs to include confirmation of a site being legally secured and added to the national register and does not need to be submitted prior to determination of a planning application. As such, it should come after these steps in the process. I don’t have a link to a decent process map. I would avoid including a process map at all as the process is so complicated any simple map like this may just mislead those unfamiliar.

• The SPD does not define how North Herts will determine Strategic Significance areas for BNG calculations until the LNRS is in place. There is no requirement to do this but it will be of interest to developers and a clear policy
will speed up the assessment of applications. Is this listed elsewhere? If not, Hertfordshire LEADS recommend using the Hertfordshire Ecological Network Map provided by HERC. If you need support with this, one of the ecologists in the LEADS team would be happy to advise.

• Pg 44 Dry biomass ‘The most common source of dry biomass is wood ‘form’ forests’. Should this sentence read ‘from’ rather than form?

Pg 54 Air Quality
The inclusion of the paragraph stating “Children are more vulnerable to the effects of air pollution therefore play/ recreation spaces should be located such as to minimize
exposure to air pollution” is a well thought out addition focussing on more at risk individuals and whole life course health impact. As noted in HCC’s Air Quality JSNA
those living in more deprived areas, which highlights those who may have limited personal funds available, are also more at risk to air pollutants. As such it is suggested that this paragraph could be expanded to follow the evidence in this area and extend to affordable housing contribution locations on any site, care/residential homes, and health sites (e.g. position these in areas likely to receive best air quality within the development site).

The paragraph which states “Development design should prioritise sustainable and active travel modes to help reduce reliance on private cars (see transport section)” is
welcomed. HCC Public Health wider determinants service area advocates using a Healthy Streets Approach to promote sustainable travel mode. Referencing this and
expressing a desire for developers to present development which has taken on board a Healthy Streets approach is required. There is the potential for the SPD to go further and request all developments/ that which is over a certain size to score the streets proposed using a Healthy Streets Design Check available at: Healthy Streets | Making streets healthy places for everyone. A minimum score threshold for new streets could be proposed. In addition requiring development to contribute to the network of streets the proposed development will feed into to uplift the existing locality street score is suggested for inclusion. This is to ensure that the wider area has relevant improvements required to reduce barriers to sustainable travel in the proposal area to encourage these modes to occur both on and off the development land parcel. This approach supports the travel plan aspect of the SPD by promoting confidence that sustainable mode share is likely to be adopted widely.