Use this link to view Volume 6 of the Consultation Report for the Draft Pre

Use this link to view Volume 6 of the Consultation Report for the Draft Pre
CORE STRATEGY
REPORT OF CONSULTATION
Consultation Draft Core Strategy
Volume 6
Includes:
•
•
•
•
Public consultation November to December 2010
Citizens Panel Survey January 2011
Hemel Hempstead Town Centre Workshop January 2011
Changes to the Consultation Draft Core Strategy
Timeline:
2005
2006
2007
2008
2009
2010
2011
First published: October 2011
This publication is Volume 6 of the Report of Consultation on the Core Strategy. If you
would like this information in your own language, or you would like to contact the Council
about any other issue, please call 01442 867212.
If you would like this information in another format, such as large print or audio tape, please
call 01442 228660 or for Minicom only 01442 867877.
本刋物是核心策畧諮詢報告的第六卷。你如欲獲得此資訊的中文版,或有任何其他事宜欲聯絡
地方政府,請致電01442 867212。
閣下如欲以其他形式獲得此資料,例如大字版或
帶,
01442 228660
或聾人電話01442 867877。
Report of Consultation
The Core Strategy for Dacorum Borough has been prepared taking account of
Government policy and regulation, technical evidence and consultation. Consultation
has spanned seven years, from 2005 to June 2011. This report explains the
consultation: i.e.
•
•
•
•
•
the means of publicity used;
the nature of the consultation;
the main responses elicited;
the main issues raised; and
how they have been taken into account.
It also explains how the actual consultation relates to the Council’s policy on
consultation and engagement, the Statement of Community Involvement.
The report is presented in seven volumes:
Volume 1:
Emerging Issues and Options (June 2005 - July 2006)
- Annex A contains a summary of responses from the organisations
consulted
Volume 2:
Growth at Hemel Hempstead and Other Stakeholder Consultation
(July 2006 –April 2009)
Volume 3:
Stakeholder Workshops (September 2008 – January 2009)
- Annex A contains reports on each workshop
Volume 4:
Emerging Core Strategy (May - September 2009)
- Annex A contains a summary of responses to the general public
consultation
- Annex B contains reports from the Citizens’ Panel and Gypsy and
Traveller community
Volume 5:
Writing the Core Strategy - from Working Draft to Consultation Draft
(June – September 2010)
Volume 6:
Consultation Draft Core Strategy (November 2010 – June 2011)
- Annex A contains a summary of responses to the general public
consultation and reports from the Citizens’ Panel and Town Centre
Workshop. It also includes changes made to the Draft Core
Strategy.
Volume 7:
Overview
This is Volume 6.
CONTENTS
PAGE
1.
INTRODUCTION
1
2.
PUBLICISING THE CONSULTATION DRAFT
3
3.
CONSULTATION RESPONSES
7
4.
THE MAIN ISSUES AND HOW THEY WERE TAKEN INTO
ACCOUNT
19
SUSTAINABILITY APPRAISAL
41
5.
APPENDICES
Appendix 1: Advert
45
Appendix 2: Dacorum Digest
49
Appendix 3: Organisations contacted
61
Appendix 4: Sample Notification Letters
73
Appendix 5: Comments on Sustainability Appraisal
79
Appendix 6: Cabinet Report – 26 July 2011: Core Strategy Proposed
Submission
87
Appendix 7: Minutes of Key Meetings: June – July 2011
141
1. INTRODUCTION
1.1 The Core Strategy – Draft for Consultation was agreed by Council on 29
September 2010 for consultation. The consultation period ran from 3
November to 15 December 2010.
1.2 The Consultation Draft set out the Council’s suggested planning policies. It
included:
• an overarching sustainable development strategy, which would guide
the amount and location of development;
• individual strategies for specific places;
• policies promoting economic prosperity, providing homes and
community services and looking after the environment; and
• guidance on the delivery of the strategy.
Two options for the level of housing development were proffered. The full
amount to meet locally generated needs was considered too damaging on the
countryside around the towns, particularly Hemel Hempstead, to be a serious
realistic option. The levels put forward would have met about 80% or 90% of
the estimated local housing needs (at that time). The higher level would have
required Green Belt land release.
1.3 The Council included a very simple overview of how it had reached its policy
direction in the Consultation Draft, taking account of consultation. This
overview introduced each of the policy chapters (i.e. Chapters 6, 7 and 9-30).
The example below is taken from Chapter 9.
Promoting sustainable development
How have we got to this point?
Your consultation responses have told us that you support the principle of placing
sustainable development at the heart of the Core Strategy and that you also support the
outlined approach to the distribution of development. This focuses most new
development at Hemel Hempstead. It also distinguishes between the towns, the villages
and countryside, so as to conserve the different aspects of their character.
1.4 A question (or questions) was asked at the end of each chapter – essentially
whether the approach in that chapter (for example, promoting sustainable
development) was supported. If not the commenter was asked to state
specifically what he/she disagreed with and what change(s) should be made to
rectify the disagreement. The public were also asked to state which of the
housing levels was preferred.
1
2
2. PUBLICISING THE CONSULTATION DRAFT
2.1 The Core Strategy consultation had one principal element:
•
general public consultation with individuals and organisations, including
Dacorum Partnership (the Local Strategic Partnership).
2.2 However, there was also:
•
a survey of the Citizens Panel, covering the Borough Vision and
Objectives and Housing Options; and
•
a workshop to consider more detailed issues in Hemel Hempstead Town
Centre.
Both were conducted in January 2011.
General Public Consultation
2.3 This was broadcast in a number of different ways:
•
•
•
•
•
local advertisement in the press (i.e. the Gazette, see Appendix 1)
press release and coverage in the Gazette
notices on Twitter and Facebook
notice in the Council’s in-house magazine, Grapevine
pull out supplement in Dacorum Digest distributed to every household in
the borough between 29 October and 9 November 2010 (see Appendix
2)
• direct notification of key stakeholders and representative groups – from
29 October to 1 November 2010 (see Appendices 3 and 4)
• direct notification of individuals who had previously commented or who
had requested to be notified – mail out using main database from 29
October to 1 November 2010 (see Appendix 4 for sample letter).
2.4 Direct notification altogether amounted to around 3,000 individuals and
organisations, and included those who attended the 2008 Place Workshops.
The letters included, for the last time in this form, an invitation to interested
individuals and organisations to raise any new issues.
2.5 All information was available on the Council’s website – including a link to the
consultation portal on the homepage – and from local libraries.
2.6 Town and Parish Councils received advance notice from 30 September via
email. A short presentation on the Draft Core Strategy was given at the Clerks
Liaison Meeting on 28 October and copies of the documents were given out to
attendees. Copies were posted to all Town and Parish Council Clerks whose
Clerks did not attend the meeting.
Posters advertising the consultation and
the dates of ‘Drop In’ sessions were also provided to Clerks and assistance
requested to raise the profile of the consultation locally. As a result some
3
councils included articles in their newsletters and circulars. Borough Council
Officers attended the Town and Parish Conference on 3 December and other
Town/Parish Council meetings to present information on the Core Strategy and
answer questions. Other meetings comprised meetings with Berkhamsted
Town Council on 15 November (to which representatives of Northchurch Parish
Council and the Save Your Berkhamsted Action Group were also invited),
Wigginton Parish Council on 16 November and Nettleden with Potten End
Parish Council on 9 December.
2.7 A special Neighbourhood Action Group meeting was held on 30 November
2010 to raise awareness of the consultation within those wards where there are
active Neighbourhood Forums (namely Grovehill, Woodhall Farm and Piccotts
End; Adeyfield; Highfield; Gadebridge, Warners End and Chaulden; and
Bennetts End in Hemel Hempstead, together with Watling Ward which includes
Markyate).
2.8 The Local Strategic Partnership were informed of the consultation both through
direct email notification, through an agenda item at the Board meeting on 15
September 2010 and via a presentation to the Management Group (30
November). Information was also distributed at the meeting of the Economic
Partnership Group (7 December).
2.9 Officers were available at a series of public ‘Drop In’ sessions between 22
November and 2 December 2010 to answer questions, before people needed
to submit their comments:
Hemel Hempstead
Council Chamber,
Civic Centre,
Hemel Hempstead
22 November 2-9pm
Attendance: 10
Berkhamsted
Civic Centre, High Street
23 November 2-9pm
Attendance: 80
Bovingdon
Memorial Hall,
High Street
26 November 2-9pm
Kings Langley
Small Hall, Kings Langley
Community Centre, The
Nap
1 December 2-9pm
Attendance: 10
Attendance: 5
Tring
Markyate
Silk
Mill
Community Main Hall, Village Centre,
Centre,
Cavendish Road
Silk Mill Way
2 December 2-9pm
29 November 3.30-9pm
Attendance: 20
Attendance: 15
Attendance at the sessions was light, except for Berkhamsted: estimated
attendance is given above.
2.10 The circulation of Dacorum Digest was complicated by the discovery on 29
October of typographical errors in the pull out supplement advertising the
Consultation Draft Core Strategy. The housing figures for Hemel Hempstead
(7,530 and 8,800 respectively) were mistakenly included for Bovingdon,
Markyate, Kings Langley and the Countryside. The Option 2 figure for
Berkhamsted was also incorrect. As Digest had already been printed and was
being prepared for circulation, the following action was taken:
4
•
•
•
•
•
•
The circulation was temporarily suspended (a small number of Dacorum
Digests had already been delivered to households in Berkhamsted, Kings
Langley and Nash Mills).
A correction leaflet was prepared: it was distributed with all other copies of
Digest, and put through the doors of the households who had already
received their copies (ref Appendix 2).
Councillors and Town and Parish Councils were notified by email on 29
October.
Adverts were placed in the press to highlight the correct figures.
The website and consultation portal highlighted the corrections.
A corrected version of Digest was printed after the initial circulation, and
made available for distribution at the ‘Drop In’ sessions and during the
consultation.
Citizens Panel
2.11 The Council’s consultants, ORS, conducted a survey of the Citizens Panel
during January 2011.
The members of the Panel had changed very
significantly in 2010, when ORS recruited around 500 new people to replace
those who had left the area, died or had been “poor responders”. The survey
had been delayed from November 2010 to avoid a clash with another survey.
The Citizens Panel survey focused on central issues in the Core Strategy (ref
para 2.2): it asked how the Council should balance social, economic and
environmental factors when drawing up its future planning policies (See Annex
A, Appendix 2).
Hemel Hempstead Town Centre Workshop
2.12 On 25 January 2011, a workshop was held to consider more detailed issues in
respect of Hemel Hempstead Town Centre. It looked afresh at the town centre
(excluding the Old Town zone). The major redevelopment project, called
Waterhouse Square, which had been proposed to cover a large part of the town
centre, was shelved in 2010. The Council’s developer partner, Thornfields,
went into administration during the recession and the whole scheme required
re-evaluation. The Strategic Health Authority needed very much less land to
accommodate a smaller community hospital (key services, such as Accident
and Emergency had been transferred to Watford). And there were other issues
to consider, such as the effect of the recession. The workshop was divided into
four sessions:
•
•
•
•
What sort of town centre do we have?
What sort of town centre do we want?
What strengths and opportunities do we have?
How do we make the changes we need?
Each session embraced design, economy and access/movement issues. The
discussion on a future master plan was separate from the Core Strategy.
5
However there was an overlap, and consideration of some amendments to the
spatial strategy for the town centre followed.
6
3. CONSULTATION RESPONSES
General Public Consultation
3.1 617 organisations, individuals and organisations submitted comments to the
questions asked. 2,668 comments were made (i.e. total number of answers to
the questions). Charts A and B show how the responses were distributed
across the questions. Questions relating to the Borough Vision, housing target
and Berkhamsted generated more than 100 responses each. However, some
questions generated a relatively low response: questions relating to Tring, the
large villages and the delivery chapters attracted 35 or fewer responses each.
3.2 The results of the general public consultation have been set out in a consistent
way in Annex A, Appendix 1. Under each question, the total number of
comments was recorded, together with the numbers answering ‘yes’ and
answering ‘no’. In the case of alternative housing targets, preferences were
recorded. The responses were summarised, and the reply and principal action
taken by the Council listed. This reply was provided in a summarised form,
rather than in a ‘line by line’ analysis of lots very detailed comments.
3.3 A quantitative analysis of the answers is given in Table 1, split into themes and
places. A negative response usually entailed an objection on a particular point
or points, and not to the whole section. In addition, support was sometimes
given with a relatively minor proviso (ref Annex A, Appendix 1).
Themes
3.4 The majority of organisations who commented supported the vision, aims and
themes. Landowners gave similar support, except on the level of housing and
where there were impacts on specific land interests. It was the number of
individuals commenting that normally altered the balance between support and
opposition for a particular section of the strategy.
3.5 The majority who commented supported the sections, Supporting the Economy
and Protecting the Environment; the strategic objectives; and Part C,
Implementation and Delivery: chapters on access and design in the Sustainable
Development Strategy were also well supported (Questions 2, 4-8, 12-14 and
31-33).
3.6 This meant there were more objections (than general support) for the Borough
Vision; the chapter, Promoting Sustainable Development; and the section,
Providing Homes and Community Services (Questions 1, 3, and 9-11).
3.7 The Borough Vision only received more noes from individuals. However they
did not normally oppose the vision itself, rather they opposed matters of detail
in other parts of the draft Core Strategy. Some questioned the delivery of the
vision. Landowners raising objections felt more housing was required to meet
locally generated demands.
7
Chart A
Chart B
3.8 The objections to Promoting Sustainable Development concentrated on
housing. Most individuals objected to proposed growth in the market towns,
particularly Berkhamsted. The draft Core Strategy was considered to be too
skewed towards housing to be sustainable. The biggest concern reiterated by
landowners was that there would be insufficient housing to meet natural
population growth, accommodate in-migration and/or support business growth.
A handful of individuals also felt there would be insufficient housing.
8
3.9 The above comments were repeated in response to questions on the housing
target and provision of new homes. There was clearly a range of opinion from
those supporting the housing target, Option 1 or less, to those supporting
Option 2 or higher.
•
•
•
•
Key organisations favoured Option 1 because it would protect the Green
Belt and rural area.
More individuals favoured neither option, and often felt Option 1 was too
high. They cited reasons such as overdevelopment, overcrowding, loss of
character, loss of countryside/Green Belt/greenfield land and insufficient
or inadequate infrastructure.
28% of individuals supported Option 2 for two key reasons. More
affordable housing would be provided. The option would offer a suitable
balance between building homes and protecting the environment (i.e.
building homes to meet needs, with only a modest incursion into the
Green Belt).
The majority of landowners opted for neither option, and felt that Option 2
was too low. There was insufficient evidence to support either Option 1 or
Option 2: both would deliver less housing than the nil-net migration figure
would suggest. This would be detrimental to the economic well being of
the Borough. Such low targets would reduce the provision of affordable
housing. There would be a poor relationship between the level of housing
proposed and anticipated jobs growth.
On the provision of new homes generally, organisations questioned the
uncertainty of population projections on which housing targets were based and
the different affordable housing thresholds between Hemel Hempstead and
Berkhamsted. Some individuals opposed the provision of pitches for Gypsies
and travellers. Concerns were also raised about infrastructure provision and
incursion into the Green Belt. On the other hand some individuals felt that
more affordable housing was needed. Landowners disagreed because the
housing target should be increased in line with projections of natural growth.
Almost all landowners commented about affordable housing levels. The
consensus was that a flexible approach must be taken to ensure that
development would not become unviable. There was further disagreement
about the inclusion of windfall sites in housing figures. Landowners also
questioned whether the phasing of allocated sites was desirable or necessary.
3.10 Only individuals disagreed overall with the chapter on Meeting Community
Needs. They disagreed for many different reasons, no one reason being given
more than once.
9
Table 1: Analysis of Yes/No Comments
Subject
Question
Number
Org
YES
Ind
Land
Total
Org
Ind
NO
Land
Borough Vision
Strategic Objectives
1
2
14
16
26
28
9
8
49
52
9
8
45
29
9
8
63
45
Promoting Sustainable Development
Enabling Convenient Access
Securing Quality Design
3
4
5
10
9
42
21
19
20
7
6
5
38
34
67
6
2
4
27
18
8
13
1
0
46
21
12
Strengthening Economic Prosperity
Providing for Offices, etc
Supporting Retailing and Commerce
6
7
8
9
9
5
15
13
14
6
3
2
30
25
21
1
2
5
4
6
5
2
5
3
7
13
13
10
11
15
4
1
9
8
23
23
36
11
10
1
6
11
4
4
39
33
48
24
22
11
8
25
21
15
2
51
31
Enhancing the Natural Environment
Conserving the Historic Environment
Using Resources Efficiently
12
13
14
8
10
9
21
26
14
4
4
1
33
40
24
3
1
8
13
2
8
1
0
6
17
3
22
Delivery
Infrastructure
Monitoring
31
32
33
6
6
3
2
8
6
0
1
1
8
15
10
2
4
1
6
9
3
0
2
0
8
13
4
Total
Themes
Housing Target : Option 1 – 370 units p.a.
Option 2 - 430 units p.a.
Neither
Providing Homes
Meeting Community Needs
9
10
Subject
Question
Number
Org
Ind
YES
Land
Total
Org
Ind
NO
Land
Common Local Objectives
15
8
13
4
25
4
23
3
30
Hemel Hempstead – Local Allocations
Hemel Hempstead – Strategy
16
17
1
8
11
9
3
6
14
23
9
7
28
11
5
10
42
28
Berkhamsted – Strategic Site (SS1)
Berkhamsted – Local Allocation (Hanburys)
Berkhamsted – British Film Institute
Berkhamsted – Local Allocation (Northchurch)
Berkhamsted – Strategy
18
19
20
21
22
1
1
2
0
4
6
12
65
22
11
1
0
1
1
2
8
13
68
23
17
3
3
0
8
4
267
209
109
293
223
1
2
0
1
1
271
214
109
302
228
Tring – Local Allocation
Tring – Strategy
23
24
0
3
13
8
1
0
14
11
7
7
10
12
8
3
25
22
Kings Langley – Place Strategy
25
5
10
0
15
1
3
1
5
Bovingdon – Local Allocation
Bovingdon – Place Strategy
26
27
1
4
5
7
1
1
7
12
2
0
13
9
5
3
20
12
Markyate – Strategic Site
Markyate – Place Strategy
28
29
1
1
2
3
0
0
3
4
0
2
6
3
1
2
7
7
Countryside - Place Strategy
30
6
11
0
17
4
14
0
18
Total
Places
11
3.11 Other issues raised included the following:
•
•
•
•
•
•
•
•
•
Individual organisations suggested specific reference to walking, cycling and
sports and leisure.
Individuals would like to see reference to the Green Belt in the strategic
objectives.
Landowners questioned the relationship between housing and employment
objectives, suggesting that they do not support each other.
The jobs and office floorspace targets were considered to be too high, not
clearly justified and out of balance with housing targets.
St Albans City & District Council was concerned at the amount of new retail
floorspace identified in Policy CS16 for Hemel Hempstead, because it could
have a negative impact on St Albans City Centre and Harpenden Town
Centre. They requested an impact assessment of the proposed growth on the
centres in St Albans District.
Adult Care Services (Hertfordshire County Council) was concerned that
insufficient provision is made in the plan for various services and facilities.
Individuals and key organisations were concerned that wind turbines can be
considered appropriate in the Chilterns Area of Outstanding Natural Beauty.
The Core Strategy lacked policies on the water cycle/water infrastructure.
Hertfordshire County Council (Environment) said that issues identified with
capacity at Maple Lodge Waste Water Treatment Works must be resolved.
Places
3.12 The majority who commented opposed development locations and the place
strategies, except Kings Langley and Bovingdon. The common local objectives
were opposed, although there were relatively few comments on the objectives
themselves: most individuals repeated concerns about housing growth and the
adequacy of infrastructure. Opposition to place strategies invariably related to
a potential development option or local allocation, but there were other varied,
specific points as well.
3.13 The three local allocations at Hemel Hempstead were opposed, partly for their
impact on the Green Belt and relationship with existing settlements, Piccotts
End, the Old Town, Potten End and Bourne End. Other reasons why LA1
(Marchmont Farm) was opposed covered traffic generation, potential crime,
loss of view and lack of transport connections. The proposed allocation, LA2,
attracted concerns about the effect on the quaint and tranquil feel of the Old
Town, removal of a green gateway, loss of amenity space, increased traffic and
the impact on the historic nature of the High Street. Development at West
Hemel Hempstead (LA3) was said to affect the Chilterns Area of Outstanding
Natural Beauty and local character: there were also concerns about traffic
generation, partly due to its location away from major local employment site,
and the ambitious nature of the scheme. Reasons for opposing the strategy
were varied. A key issue however was the achievement of cross-boundary cooperation with St Albans Council to deliver the East Hemel Hempstead vision.
12
3.14 Questions about Berkhamsted generated the highest response, a large part of
which was co-ordinated by a ‘Save your Berkhamsted’ group. It raised
concerns about the proposal for land at Shootersway/Egerton-Rothesay School
(Strategic Site SS1). Reasons given for objecting to this proposal included the
number of homes planned for the site, the effect on the character of the area,
the transport implications in terms of safety and added car use/traffic
congestion, the location of the development in relation to services, and
infrastructure and utilities being insufficient to support the development. The
local allocation at Hanburys, off Shootersway (LA4), which would involve Green
Belt land, was similarly opposed. Key organisations supported investment in
and expansion of the British Film Institute next to Hanburys. Many individuals
were also in support, provided there was no enabling housing development.
The majority of individuals however were concerned about the effect on the
Green Belt, and did not want the Council to offer any financial support to the
British Film Institute. Local allocation LA5 (New Road, Northchurch) attracted
the highest level of adverse comment. Organisations and most individuals were
opposed. Most opposition was in respect of the completion of a link road, which
development could help fund, rather than the local allocation. The link road
proposal was considered to be unsafe, costly and environmentally disruptive: it
would shift problems from one area to another potentially creating more traffic
in the process. New housing should only be developed if needed in its own
right. There were also concerns about the impact on the Chilterns Area of
Outstanding Beauty and the adequacy of local infrastructure. Opposition to the
Place Strategy was directly related to opposition to the local allocations.
Organisations commented that the strategy did not contain sufficient emphasis
on retaining the town’s character. They also thought that greater priority should
be given to raising the quality of existing facilities and infrastructure.
3.15 The local allocation west of Tring (LA6) was supported by the majority of
individuals, but not others because of the perceived impact on the Chilterns
Area of Outstanding Natural Beauty and the Green Belt. Landowners disagreed
because they thought LA6 should comprise more homes or because they
considered other sites to be more suitable for development. The site was
considered by some to be isolated. The Tring Place Strategy was opposed
largely because of the concern over the level and location of new development.
Some organisations, such as Tring Sports Forum, supported plans for
additional playing fields at Tring, but individuals opposed this. They said that
Tring had large areas of underutilised sporting facilities and that Green Belt
should not be used for this purpose.
3.16 The location allocation north of Chesham Road, Bovingdon (LA7) was opposed
by individuals because they felt the village could not handle any more
development. Landowners thought that an alternative local allocation would be
better. However Bovingdon Parish Council concluded that LA7 was appropriate
to meet long term needs in the village.
3.17 Few responses were received about Markyate. However a key concern was
that some felt Hicks Road (Strategic Site 2) did not need any retail or industrial
uses and that the focus of planning should be the High Street. There would be
13
impacts on parking, drainage, sewerage and school capacity, and the housing
numbers were too high. The Highways Agency expressed reservations about
the potential traffic implications arising from development in Markyate.
3.18 On closer examination, the countryside strategy itself was largely supported.
The concern related to any of the currently designated Green Belt or
countryside being used for housing. The objective of protecting the countryside
was seen to be contradicted by proposals to release Green Belt land for
housing.
Late Comments
3.19 Some comments were received late, i.e. between January and March 2011.
They were assessed to see if there were any new issues which merited a
change to the Core Strategy. The comments were excluded from the schedule
which summarises the general public consultation (at Annex A, Appendix 1).
3.20 The comments were submitted by:
1. Residents opposing new housing next to the Old Town, Hemel Hempstead
(179 comments)
Their full argument was more relevant to a larger area of land (10 hectares) that
had been included in the earlier consultation about growth at Hemel
Hempstead (reported in Volume 2). However, the smaller area (2 hectares
proposed in the Consultation Draft) was also of concern. This land slopes, is
open and is next to a conservation area.
2. Hertfordshire Local Access Forum
The Forum provided a standard response, the basic principles of which are
accepted and already incorporated within the framework provided by the Core
Strategy.
3. English Heritage
English Heritage supported the vision, strategic objectives and approach to
design, meeting community needs, enhancing the natural environment and
conserving the historic environment. It requested archaeological assessments
on potential development sites and expressed concern about the potential
impact of development adjoining the Old Town. It also provided other, detailed
comments. Some led to changes in the Core Strategy (see Table 1).
Table 1: Core Strategy Changes – English Heritage Comments
Ref.
CS10
Comment
Change
Landmark buildings may be tall,
but equally may be distinctive due
Define ‘landmark building’ in a
footnote.
14
Para 18.1
Berkhamsted
Berkhamsted
to design and location.
Delete reference to ‘scheduled
archaeological sites’ because they
are ancient monuments
Amend Vision to refer to the castle
being protected and enjoyed.
Seek a supportive link between
The Rex cinema and the British
Film Institute: this would justify
expansion of BFI within its own
site.
Amend to ‘areas of
archaeological significance’.
Amend vision and strategy
accordingly.
Amend strategy to refer to links
being fostered between BFI
and the town
Citizens Panel Response
3.21 494 Panel members responded (see Annex A, Appendix 2 for the full report).
68% fully supported the Vision statement, while 28% agreed in part. Reasons
for disagreement included lack of existing health, education and shopping
facilities (which should be rectified) and reference to the transformation of
Hemel Hempstead through regeneration of the town centre and Maylands
Business Park. There appeared to be no useful suggestions for improving the
Vision.
3.22 The majority felt the Objectives were important (from 66% to 96% support for
individual objectives). The highest proportion, who said an objective was
unimportant, was 14%, commenting on social inclusion.
3.23 Over 95% felt that access to open space and health facilities was important
locally.
3.24 62% supported the lower (Option 1) housing target. 22% want a higher target
(including Option 2); the remainder lower. Panel members stated how far they
agreed with particular considerations underlying the housing target: all factors
were agreed by the majority. Provision of infrastructure had 96% agreement
(with 71% strongly agreeing). Provision of affordable housing for young people
was one of the lowest supported factors – 73% agreeing (and 37% strongly
agreeing). Panel members were not directly asked whether they considered it
important to “provide for existing residents and their children.” Provision of
affordable housing was seen as a proxy for this.
3.25 As preference for the lower housing target (370 dwellings p.a.) implied a similar
building rate to historic targets, Panel support for Option 1 was perhaps to be
expected. Panel members appeared to be more swayed by concerns over the
provision (or lack) of infrastructure and desire to protect the countryside than
other factors. Preference for the lower housing target should be seen in
context. The majority of the Citizens Panel agreed with the Vision and
Objectives, and the Vision says Hemel Hempstead will meet its own locally
generated demand for new homes. Furthermore, the 2009 Citizens Panel
survey showed majorities in favour of higher place targets for Berkhamsted,
15
Tring, Kings Langley and Bovingdon (ref Volume 4, Table 1). [It should be
noted that the question of alternative housing targets for Hemel Hempstead
could not be put at that time (ref Volume 4, Chapter 1).]
Hemel Hempstead Town Centre Workshop
3.26 The Hemel Hempstead Master Plan Charette, as the workshop was called, was
facilitated by consultants, Feria Urbanism, with Inspire East and CABE (the
Commission for Architecture and the Built Environment). It is reported in Annex
A, Appendix 3. The Council considered the findings of the workshop (Cabinet,
29 March 2011), and agreed:
•
•
•
•
the scope and content of the future master plan;
the opportunities, projects and key priorities to be taken forward in each of
the relevant zones;
an amendment to the Marlowes Shopping Zone (to include the Riverside
Centre); and
a programme to complete the work by mid 2012.
3.27 Discussion on opportunities, projects and key priorities raised a number of
points relevant to the town centre local objectives, development opportunities in
the town centre character zones, Policy CS33 Hemel Hempstead Town Centre
and the town centre vision diagram. They included:
•
•
•
•
•
•
•
•
•
•
•
•
•
the concentration of shopping uses in an enlarged Marlowes Shopping
Zone
the encouragement of smaller office and retail units
the development of a civic hub
the encouragement of pedestrian movement between and around the
north and south of the Marlowes area
the improvement of east-west links to and through the centre
keeping or opening up east-west views and linking greenspace
supporting an evening economy
development of leisure/cultural attractions
enhancing the Water Gardens and making better use of them
encouraging more uses to front Waterhouse Street
alternative locations for a supermarket and/or retail anchor store
the provision of alternative bus station facilities; and
more housing.
3.28 The preparation of a town centre master plan within the framework of the Core
Strategy was ongoing at the time. The key lessons from the workshop for the
master plan were seen to be as follows:
•
•
•
to review what is deliverable,
to give more flexibility on the location of some uses,
to amend the Marlowes Shopping Zone,
16
•
•
to refresh the retail/leisure study to check on demands in town centre, and
to prepare an access/movement strategy which will provide satisfactory
east west links, public transport and circulation in the town centre.
The town centre framework in the Core Strategy was considered to be
sufficiently robust to take account of developing projects and some variation in
location of new uses, and yet give direction.
17
18
4.
THE MAIN ISSUES AND HOW THEY WERE TAKEN INTO
ACCOUNT
Process
4.1 All comments on the general public consultation were fully considered, as was
the town centre workshop (ref. para 3.26). The Council thought through a
number of questions in response to the comments raised:
(a)
Would the objection and /or suggested alternative lead to an improvement
in the plan? It was not simply a case of considering whether an alternative
was as good. A key issue was whether the Core Strategy was sound as it
was.
(b)
Was the comment supported by evidence? The Council had to think
about the technical evidence. Opinion did not necessarily change that,
though it sometimes pointed to a different emphasis or alternative.
(c)
Would the Core Strategy lead to the promotion of sustainable
development, with or without the change indicated by the commenter?
Changes were tested through sustainability appraisal and found to be
appropriate.
(d)
Was the concern being addressed already? Or would it be addressed in a
later planning document? The Core Strategy does not constitute the full
planning policy framework for Dacorum, and there were cases where
comments could be more appropriately be dealt with elsewhere, e.g.
when considering Site Allocations.
4.2 The Council considered what changes it should make to the Core Strategy
(Consultation Draft) – whether there were reasonable answers to the comments
raised and what would improve the plan. Changes were made:
•
to the policy – including objectives, place strategies, key diagram and
vision diagrams; and
•
to the background information – including text, supporting illustrations
and delivery schedules. Some changes are consequential upon
changes to policy. Often, they are factual, contextual, supporting or
explanatory.
The root of the changes was:
(a)
(b)
the consultation: and/or
one of the following – new technical evidence, Government policy, Council
thinking or other information, including the draft national planning policy
framework.
19
4.3 The Council referred the main issues to the Dacorum Partnership Board on 15
June 2011, in particular the housing options, in the light of latest evidence and
the results of consultation (see Appendix 7 for the minutes).
4.4 The Council then considered a draft consultation report, together with an
officers’ report on the issues relating to the Core Strategy (see Appendix 6):
i.e. at
•
•
•
Strategic Planning and Environment Overview and Scrutiny Committee
– 19 July 2011 (see Appendix 7 for the minutes);
Cabinet – 26 July 2011 (see Appendix 7 for the minutes);
Full Council – 28 September 2011.
4.5 Cabinet considered the issues arising from consultation, including the draft
Volume 6, Annex A, and relevant new evidence. It recommended that the
higher housing target (430 dwellings per annum), together with most of the
local allocations, be included in the Core Strategy. Subject to the inclusion of
appropriate amendments agreed with the Portfolio Holder for Planning and
Regeneration prior to Full Council, Cabinet also recommended that the Core
Strategy should be approved for publication. Full Council approved the Core
Strategy for publication on September 28. Cabinet delegated authority to the
Assistant Director, Planning, Development and Regeneration to finalise the
Report of Consultation.
Amending the Consultation Draft
4.6 Changes were made to the Consultation Draft Core Strategy. This
chapter
summarises the main changes to policy. It also covers reasons why, in some
cases, changes were not made. Tables 3 and 4 below summarise the main
policy changes, Table 3 from the consultation and Table 4 from alternative
sources.
4.7 Annex A, Appendix 1 (Volume 6) covers all changes relating to the general
public consultation, including those relating to background information. Annex
A, Appendix 4 (Volume 6) lists changes to the Core Strategy arising from
sources other than the general public consultation.
Growth Issue
4.8 The central issue was the level of growth. While this embraced business and
commercial development and employment, the majority focused on the housing
issue – whether the housing target should be higher or lower, and/or which of
the two housing options to support. The implications extended to the local
allocations – which to support – and whether alternative locations were
preferred. There were several grounds for objecting to local allocations,
including concerns about local infrastructure.
20
4.9 The Council considered new evidence, particularly an update to the
employment space study and new household forecasts, and took into account
the draft national planning policy framework and other Government statements
on housing and economic growth.
4.10 Notwithstanding the impact on the Green Belt countryside around some
settlements, the Council concluded that Housing Option 2 (target - 430
dwellings p.a.) was equitable. It catered for most needs and demand, although
not the highest levels shown in household/dwelling projections. The level
selected was higher than any annual average rate since the main growth of the
Hemel Hempstead New Town. The sustainability appraisal showed that
Housing Options 1 and 2 were, on balance, reasonable. It also looked at an
Option 3 (target – 500 dwellings p.a., which would have met the Government’s
2006-based forecast of 12,400 dwellings between 2006 and 2031). Inevitably
the higher the housing target, the greater the environmental impact that would
result. Option 1 (370 dwellings p.a.) was dropped: it did not deliver sufficient of
the homes needed to tackle existing problems and potential demand.
4.11 In reaching its conclusion, the Council was fully aware there was not a
consensus of opinion. There was a measure of support from the Dacorum
Partnership (see Appendix 7) and organisations, particularly involved in
welfare, for Option 2. Landowners tended to want more housing, while local
communities generally opposed the impact and change new housing
development would bring to their area. Change obviously needs to be managed
and impact controlled. The Council felt that Option 2 provided the right balance;
that the strategy would allow growth while generally protecting the character of
the countryside and smaller settlements; and that the change envisaged was
both beneficial and could be managed. It did not, however, welcome Green Belt
releases.
4.12 The conclusion also took note of the following factors:
•
Actual housing delivery will include some windfall (i.e. previously
unidentified housing sites, particularly in years 6-10): this means that
delivery should exceed 430 dwellings p.a. Around 11,400 dwellings are
expected between 2006 and 2031 (achieving a level approaching 460
dwelling p.a.).
•
Household projections include a significant level of in-migration: it is
debatable how much of this it is reasonable for a council in the
Metropolitan Green Belt and Chilterns Area of Outstanding Natural
Beauty to meet.
•
Since the 1950s and 1960s growth pressure has been diverted away
from the Dacorum area (and south west Hertfordshire) into other parts of
the county beyond the Metropolitan Green Belt: at no stage has regional
guidance ever required the Council to deliver a higher level within its
district, than proposed now.
21
•
The revised employment space study (2011) recommended provision
was made to deliver around 10,000 jobs (not 18,000 jobs as previously):
the Council has taken the new recommendation forward. It means that
employment and housing growth should be much better balanced, and
there is no longer a good argument that the level of housing should be
higher (than Option 2) in Dacorum to support economic growth.
4.13 The Council has expressed the view that Dacorum’s rate of housing growth
should reduce towards the end of the plan period and beyond it (i.e. to what it
was, 360 dwellings p.a., or less). A new co-operative agreement should be
reached across the sub-region within the next ten years in the interests of
sensible planning and compliance with draft Government advice: alternatively,
strategic advice will have to be given. Should further Green Belt land be
required for development in the very long term, the Council has considered that
land east of Hemel Hempstead (in St. Albans district) would be the better
option. Further extension to the west, north and south of the town would have
unacceptable impacts. The Council concluded there was no good reason to
release more land from the Green Belt within Dacorum to provide “safeguarded
land” for development after 2031.
4.14 Changes have been made to the Consultation Draft Core Strategy (Policies
CS2, CS3 and CS17 and supporting text) to:
•
set out the housing target;
This is a target to be delivered: it is neither a minimum nor a maximum.
There is leeway to exceed the target, but this is not open-ended.
•
clarify the difference between the target and housing supply (and
delivery);
•
simplify the priority between in-settlement development and local
allocations (Green Belt releases);
•
confirm that phasing will be dealt with in more depth in the Site
Allocations DPD; and
•
include a housing trajectory: this includes the Council’s expectation that
the local allocations will be released after 2021.
The experience of past local plans is that, while targets have been
delivered, greenfield releases have not always been built out in the plan
period. The delivery of the local allocations could therefore extend
beyond the plan period. It will be necessary to plan ahead and give
reasonable certainty to landowners in the light of prevailing information.
22
4.15 Changes to Policies CS14-CS16 have reflected new evidence, taking account
of past comments as well. The newer jobs and employment/retail floorspace
figures were considered sounder, but did not change policy directions or
strategy, with one important exception. The need to plan for land in St. Albans
district for business and industry was largely removed: the role of the Area
Action Plan for East Hemel Hempstead in St. Albans district has therefore
become more limited and it should be more logical for land there to retain its
current Green Belt status. Retail growth in Hemel Hempstead will reflect a
reasonable share of its catchment, and not growth at the expense of potential
town centre competitors such as St Albans or Watford.
Distribution of Housing Growth
4.16 The distribution of housing in the Consultation Draft reflected the relative
importance of Hemel Hempstead and focus of growth there, together with
economic development and proximity to a range of services in the town centre.
It also reflected the environment and character of the district, and the desire to
control development away from the main town. In large measure it followed
past settlement strategy. The settlement hierarchy in Policy CS1 was retained.
At individual places there was a closer look at the effects of population change,
land availability, infrastructure (particularly primary school thresholds),
character and local opinion. This was particularly important for the smaller
settlements, where small scale change was considered more appropriate. One
concern was to ensure a limited, local supply of housing, notwithstanding that
most housing would be accommodated in Hemel Hempstead. The comments
received did not persuade the Council that any change was required to the
basic distribution: in fact, the majority agreed.
4.17 Housing Option 2 included local allocations. They were all retained, except for
LA5 (New Road, Northchurch). LA5 had been rejected by the Council following
consultation on the Emerging Core Strategy. It had only been retained as an
option in the Consultation Draft so that the Council could ask about its potential
to support the delivery of a link road – a petition in favour of the link road had
been submitted with comments on the Emerging Core Strategy. The weight of
opinion overall favoured the removal of any link road. The highway authority
doubted its value, had concerns over its safety and confirmed it did not intend
to fund it. LA5 would have its own impacts, particularly in respect of safety on
New Road itself and visually on the Chilterns.
4.18 All local allocations retained will be detailed in the Site Allocations DPD. The
Consultation Draft included local allocations at Hemel Hempstead for the first
time. In the light of the comments, it was decided that some additional
principles or development requirements should reasonably be inserted now
(see Table 3).
4.19 The dwellings capacity figures for the strategic sites were adjusted in the light
of further consideration and information. SS1 (land adjoining Shootersway and
Durrants Lane, Berkhamsted) was reduced by 20, and SS2 (Hicks Road,
Markyate) increased by 10.
23
4.20 Following further work on housing land availability and the decisions above on
strategic sites, there were some very minor changes to the figures used in the
local place objectives (see Table 2). There was no change in the approach. The
figures are intended to be used as a yardstick against which to assess future
delivery. The total (in Table 2 below) is the total number of new dwellings,
which the Council then expected to be delivered: it should exceed the
achievement of the housing target in Policy CS17, because of the inclusion of
some, currently unidentified, windfall sites.
Table 2: Distribution of Housing – Place Strategies
Place
Number of Dwellings indicated in Each Local
Objective
Consultation Draft
Pre-submission
Draft
Change
Hemel Hempstead
- Town Centre
- East Hemel
- Rest of Town
8,800
1,800
1,000
6,000
8,800
1,800
1,000
6,000
Berkhamsted
Tring
1,200
480
1,180
480
- 20
Bovingdon
Kings Langley
Markyate
150
100
190
130
110
200
- 20
+10
+10
Countryside
400
420
+20
11,320
11,320
Total
Note: All figures are rounded and intended to be approximations.
Pitches for Gypsies and Travellers are not included in this distribution (they should be
added to enable an estimate of total new homes over the plan period).
Other Issues
4.21 Although many issues were connected with growth and the distribution of
housing, there were others.
4.22 Some comments have suggested very detailed changes, additional points or
the inclusion of other sites. They are not necessarily relevant to the overall
Core Strategy. Where they aren’t, they can more appropriately be
24
accommodated in other, subsequent policy documents, or debated in that
context.
4.23 Some of the important policy issues, particularly those resulting in changes to
the Consultation Draft, were related to:
• the objectives,
• aspects of transport,
• the accommodation of new schools,
• green infrastructure,
• environmental/infrastructure concerns; and
• specific place matters.
4.24 Social cohesiveness was accepted to be a different aspect of welfare and
community to diversity and inclusion. It was therefore included in the strategic
objectives. Changes to the common local objectives were relatively minor but
reflected legitimate points about employment and traffic congestion.
4.25 The exclusion of rural rights of way from the transport network (in Policy CS8 in
the Consultation Draft) was rectified. It was also logical that in judging design
(Policy CS12) there should be safe access for all users: that should recognise
different modes of transport and the characteristics of the user (for example,
disabled people).
4.26 The capacity of existing primary schools and the threshold for new primary
schools (in relation to new housing) have been important factors in determining
place strategies. The Council is supporting the provision of new schools in the
right places in line with Government policy: an amendment to Policy CS23 has
been made to enable new schools to be provided, where needed, in the Green
Belt.
4.27 The importance of green infrastructure (i.e. habitat and open space networks)
was raised in this and previous consultations. The ‘Green Infrastructure
Strategy’ work commissioned from Land Use Consultants enabled the Council
to update and illuminate Policy CS26. Map 3 (High Level Green Infrastructure)
was updated and wildlife corridors included in place vision diagrams. Policy
CS26 was amended to refer to habitat management zones and priorities, the
recommendations for which can be incorporated into subsequent, more
detailed guidance.
4.28 There were a number of concerns expressed about the potential impact of
development on the Chilterns Area of Outstanding Natural Beauty. However,
most local allocations are sufficiently far away for impact to be limited: in the
case of land west of Tring, it has been clarified that all housing will be outside
the AONB. While Policy CS24 protects the Chilterns scarp slope, it would have
been unreasonable to have ruled out any wind energy generation within the
AONB.
25
4.29 The importance of water management has again been acknowledged by the
Council. Concern over the capacity of Maple Lodge Sewage Treatment Works
was noted. A steering group of the key stakeholders has been overseeing the
identification of infrastructure issues and solutions. They have agreed that
Policies CS31 and CS32 provide the appropriate framework. The Council is
awaiting further advice on the timing of development and possible new
infrastructure, particularly in south Hemel Hempstead, from Thames Water
Utilities. However, these matters can be dealt with at a later date through
subsequent planning documents and the infrastructure delivery plan. Policy
CS35 links development and infrastructure, and provides appropriate control.
4.30 Changes to place strategies have generally been minor because the
Consultation Draft was the second round of general public on most aspects.
Local allocations and strategic sites have been the focus of most comments.
Most were retained (see para 4.17 above). No potential local allocations
advanced by landowners during the consultation (e.g. at Shendish, Hemel
Hempstead and at Duckhall Farm, Bovingdon) were considered preferable.
4.31 However, in Berkhamsted there have been underlying concerns about the
amount and density of development that has occurred. The urban design zones
are a broad and reasonable basis to judge future developments. Identifying the
British Film Institute as a major development area in the Green Belt should
enable limited expansion, without significant impact, and retain the use. Better
links with the town should be sought. The strategy and vision have been
amended to recognise the value of the motte and bailey castle.
4.32 At Hemel Hempstead further discussions led to some changes in the
presentation, aims and strategy for the regeneration areas, the town centre and
Action Plan area at East Hemel Hempstead. The extent of economic
development ambitions, affecting St. Albans district, have been reined back.
Both areas are subject to ongoing further work. For example Hemel Hempstead
has been the subject of an enterprise zone bid by the Local Enterprise
Partnership (albeit unsuccessful in August 2011).
4.33 The full range of issues, comments raised and Council responses is given in
Annex A, Appendix 1.
26
Table 3: Policy Changes to the Consultation Draft
(1) Arising from Consultation
Plan Reference
Change
Reason
Consultation Reference
Strategic Objectives
Amend objective 2 to refer to
social cohesiveness
To reflect the intention that the
community should be integrated,
without tension, and function well
Annex A – Q2
Policy CS2
Simplify the sequential approach
to development within and
outside designated settlements.
Refer more flexibly to priorities
within settlements. A
consequential change is
required in Policy CS7 for
accuracy, referring to
development “at” Rural Area
villages.
To retain priorities and control the
unnecessary release and use of
green field land. Also to fit with the
Council’s overall conclusions on
the housing target, its delivery and
its implications.
Annex A – Q3. Also Volume 4
(Annex A – Q5), and Annex A Q9 and Q10.
Policy CS3
Delete the last sentence.
To reflect the Council’s overall
conclusions on the housing target
and its delivery, following the
consultation. Policy CS17
adequately covers bringing sites
forward, if there is a supply
problem. The timing of local
allocations is properly covered in
27
Annex A – Q9 and Q10. Also
Q3.
Themes
Policy CS3, subject to more
detailed guidance within the Site
Allocations DPD.
Policy CS8
Add new principle – maintain
and extend the rural rights of
way network. Remove
bridleways from principle (c), as
it is not needed.
To cover an important movement
principle.
Annex A – Q4
Policy CS12
Amend criterion (a) to refer to
safe access for all users.
To ensure access is fully available,
consistent with Policy CS8 and
previous consultation documents.
Volume 4 (Annex A – Q8)
Policy CS14
Replace first paragraph to
amend and explain the new jobs
target.
To achieve a better balance
between homes and jobs, and in
particular to fit with lower overall
housing growth (the previous
forecast and recommendation
related to 17,000 new dwellings,
2006-2031). Consultants, Roger
Tym, recommend a revised target
of 10,000 additional jobs and
131,000 sq m net additional office
floorspace, 2006-2031.
Annex A – Q6 and Q7.
Volume 4 (Annex A – Q12)
Policy CS15
Replace second paragraph and
include new employment
floorspace targets.
To accord with expected demand.
Also see above.
Annex A – Q7
Policy CS16
Amend retail capacity figures to
To more accurately reflect what is
28
Annex A –Q8
reflect new evidence of demand. required in Dacorum, and thereby
alleviate concerns about impact on
town centres outside the district.
Policy CS17
Amend policy to refer to a target
of 430 dwellings per annum on
average. Delete reference to
priorities for local allocations.
Retitle as ‘New Housing’. The
selection of the housing target
requires a housing trajectory to
be inserted at Appendix 2.
To simplify the wording and refer to Annex A – Q9 and Q10
the selected target. The target itself
is based on a consideration of a
range of factors and issues,
including potential housing
demand, potential job growth,
housing need, location and
environmental implications.
Policy CS23
Insert paragraph on the
provision of new facilities in
designated Open Land and,
subject to criteria, in defined
zones in the Green Belt.
To ensure proper provision for
schooling, while protecting the
environment.
Annex A – Q16 and Q22.
Also see Volume 4 (Annex A –
Q11).
Policy CS26
Revise policy, retaining the
existing principles and
incorporating recommendations,
action and information from new
technical work (Green
Infrastructure Strategy).
To reflect new evidence and
respond to previous consultation
comments.
Volume 4 (Annex A –Q16)
Policy CS29
Insert new text to encourage
higher standards of design, to
guide the use of sustainability
statements and to provide
To balance encouragement for the
achievement of the key sustainable
design principles with the
practicalities of delivery.
29
Annex A – Q14
another degree of flexibility in
meeting the principles set out.
Policy CS30
Add reference to water
efficiency.
To extend the use of the
Carbon/Sustainability Offset Fund.
Annex A – Q14
Policy CS31
Qualify principle (a) to accept
compatible use.
Some development is compatible
with Flood Zones 2 and 3. The
intention is to avoid new built
development.
Annex A – Q14
Amend bullet point 4: remove
reference to balance with
housing development. Delete
bullet point 6. Amend bullet
point 10: refer to congestion and
its effects.
Local people need employment
opportunities: balance of
employment and housing is not
precisely being sought. Congestion
is a localised issue: dependence
on car use is covered by the
strategic objectives. Bullet point 6
does not guide development
decisions by itself.
Annex A –Q15
Change reference from covered
bus station to improved bus
facilities and interchange.
To reflect further work being
undertaken, noting the concern
about any impact on the Water
Gardens.
Annex A – Q17, and para
3.27/3.28, Volume 6.
Refer to a local general hospital
To reflect latest NHS thinking.
30
Annex A – Q17.
Places
Common Local
Objectives
Hemel Hempstead
Vision
(in the vision and elsewhere)
Refer to the restoration of the
Water Gardens, leisure/cultural
facilities, the evening economy
and easier movement
(especially on foot) in the town
centre (in the vision and
elsewhere)
To reflect later thinking and
feedback from the Town Centre
charette.
Paragraphs 3.26-3.28, Volume
6.
Refer to the Option 2 housing
target, amending the strategy as
a consequence.
To reflect the Councils conclusion
on the appropriate housing target.
Annex A – Q9, Q10 and Q17.
Refer to a new school and
library in the town centre.
To reflect expressed needs from
the County Council.
Annex A – Q17.
Refer to better waste
management facilities in East
Hemel.
To provide greater flexibility in the
achievement of waste facilities.
Annex A – Q17.
Town Strategy
To refer to the protection of
open space and replacement of
lost facilities.
To reflect current Government
policy and retain open space.
Annex A – Q17.
Town Centre Strategy
Refer to multiples and new
stores, rather than a precise
type of store.
To allow flexibility in the
development and delivery of the
Town Centre Master Plan.
Annex A – Q17.
Change the Marlowes Shopping
Zone, including the Riverside
To reflect what has happened.
Paragraphs 3.26-3.28, Volume
6.
Local Objectives
31
shopping development. There
are consequential amendments
to the Plough Zone.
East Hemel Hempstead
Strategy
Refer to the delivery of waste
management facilities.
To explain the options and
probable location.
Annex A – Q17.
Policy CS33
Refer to new retail store, new
homes, restoration of the Water
Gardens, better public transport
and east-west pedestrian links,
an evening economy in
Waterhouse Street, library,
primary school and, more
generally, cultural facilities.
To clarify the proposal in the light
of consultation and recent thinking.
Annex A – A17, and
paragraphs 3.26-3.28 (Volume
6).
Local Allocations
Refer to strategic landscaping
mitigating the impact of the
Marchmont Farm allocation.
To reduce the impact of the
development.
Annex A – Q16.
Delete reference to three-storey
housing adjoining the Old Town.
To reduce the impact of the
development.
Annex A – Q16.
Refer to open space/playing
fields, a two-form entry primary
school, strategic landscaping
and green infrastructure links.
Confirm no vehicular access
from Pouchen End Lane.
To explain the proposal more fully
and mitigate its impacts.
Annex A – Q16.
Berkhamsted
32
Vision
Refer to Berkhamsted Castle
To recognise its importance locally.
Table 1 (Volume 6)
Local objectives
Refer to Option 2 housing level
and delete reference to the New
Road/Springfield Road link.
To reflect the Council’s conclusion
on the housing target, local
allocations and strategic site.
Annex A – Q9, Q18, Q19, Q21
and Q22.
Strategy
Change the housing level
sought.
As above.
Refer to the protection and
enjoyment of Berkhamsted
Castle.
Table 1 (Volume 6)
To promote the use and
conservation of this historic feature.
Seek better links between the
British Film institute and the
town
To make better use of this
significant organisation, in return
for supporting the consolidation of
its operation on its site.
Table 1 (Volume 6) and Annex
A – Q20
Seek the resolution of local
highway and environmental
issues at New Road/High Street,
Northchurch through air quality
management and small scale
measures in the Urban
Transport Plan. Remove
reference to the completion of
link road.
To tackle a local issue effectively,
avoiding the cost and
environmental damage associated
with completion of the road.
Annex A – Q21
Amend dwelling capacity to 180
(affecting the housing objective
To further respond to local
concerns and create the flexibility
33
Annex A – Q18.
Strategic site
level).
for the design of the development
to fit in with neighbouring urban
design zones.
Retain Hanburys and delete
reference to land at Lock Field.
To enable a future housing
opportunity where it better fits.
There are clear reasons why Lock
Field is not supported and no need
for the link road, to which it could
have contributed.
Local objectives
Refer to Option 2 housing level,
retaining Local Allocation (LA6)
west of the town.
To reflect the Council’s conclusions Annex A – Q9, Q10 and Q23.
on the housing target.
Local allocation
Clarify there should be no
building development within the
Area of Outstanding Natural
Beauty.
To protect this landscape,
reflecting the intention of the
proposal.
Local allocations
Annex A – Q19 and Q21
Tring
Annex A – Q23
Bovingdon
Local objectives
Refer to Option 2 housing level, To reflect the Council’s conclusions Annex A – Q26 and Q27.
on the housing target.
retaining Local Allocation (LA7)
on land north of Chesham Road.
Markyate
Strategic Sites
Increase site area and dwellings
To acknowledge that a small area
34
Annex A – Q28 and Q29.
Vision Diagram
capacity by 10, affecting the
local objective. Amend the
principles to reinforce the role of
the river Ver in landscaping and
need to ensure no adverse
impact on the A5.
of additional land is available. To
recognise a potential asset in
designing the scheme and avoid
undue highway implications.
Amend site area and show site
within the inner urban design
zone.
As above, and to reflect
appropriate design considerations.
Annex A – Q28 and Q29.
Refer to local initiatives such as
design statements.
To reflect the role such initiatives
play.
Annex A – Q30.
Countryside
Strategy
Note: References to the Consultation Report all relate to Volume 6, unless explicitly stated otherwise.
35
Table 4: Policy Changes to the Consultation Draft
(2) Arising from Technical Evidence and Other Considerations
Plan Reference
Change
Reason
Key Diagram
Add Flaunden, and name Flamstead correctly.
To correct errors.
Policy CS8
Delete ‘maximum’ in relation to car parking standards.
To reflect changes in Government advice.
Policy CS10
Delete ‘identified’ from items (f) and (g).
To allow more flexibility in applying the policy.
Policy CS11
Amend criteria: refer to attractive streetscapes and
links between them, co-ordination of streetscape
design and the avoidance of large areas dominated by
car parking.
To present the policy more clearly, emphasizing
good design features and avoiding excessive
parking areas.
Policy CS12
Amend criterion (d) to accept the loss and replacement
of important trees, if the loss is justified.
To provide greater clarity on the protection of such
trees
Policy CS18
Extend the range of information that will assist
decisions on the appropriate mix of new homes.
To improve decision-making.
Policy CS19
Amend policy to:
To provide greater clarity and respond to recent
• seek a minimum percentage of affordable homes for Government advice.
‘rent’
• explain that 100% of homes on selected rural sites
may be affordable (affecting Policy CS20 also)
• simplify criteria (a) and (b) and refer to the Council’s
housing strategy and other evidence
• give greater flexibility in delivering the benefits of
affordable housing.
Themes
36
Plan Reference
Policy CS20
Change
Refer to selected small villages and rural sites (instead
of rural exception sites).
Reason
To provide greater clarity and respond to recent
Government advice.
Policy CS27
Emphasise the need to conserve heritage assets and
positively enhance conservation areas.
To ensure both protecting and a positive approach
to conservation.
Policy CS28
Amend policy to outline the Council’s strategy. Refer to
a sustainability offset fund. Link to policies CS29 and
CS30.
To reflect other policy changes and frame the policy
to enable future development and delivery.
Policy CS29
Insert reference to carbon emission reductions to Table To reflect changes to Table 11 for accuracy and
11 (which have changed) and to maximising the
achieve consistency between Policies CS28-30.
energy efficiency performance of buildings (in
accordance with Figure 16, the energy hierarchy).
Delete reference to the replacement of trees.
It is covered by Policy CS12.
Delete reference to Lifetime Homes.
To acknowledge that standards may change over
time. The principle of building adaptation is retained
in the policy.
Policy CS30
Add reference to habitat improvements and public
building stock (extending the scope of the policy).
To extend the use of the Carbon Offset Fund
(renamed Sustainability Offset Fund).
Policy CS32
Add ‘quality’ to the title.
To more accurately reflect the content of the policy.
Policy CS35
Delete last two paragraphs. Insert reference as to how
financial contributions will be used.
To reflect the changes in Government policy and the
intended introduction of a community infrastructure
levy. Detailed reference to the Infrastructure
Delivery Plan is more appropriate in the supporting
text, apart from its use to guide the expenditure of
financial contributions.
37
Plan Reference
Places
Change
Reason
Vision Diagrams
Include wildlife corridors on vision diagrams for the
settlements (with strategic wildlife corridors and key
countryside corridors on Map 3).
To reflect evidence in the Urban Nature
Conservation Study and show green infrastructure
at local and strategic level. In addition, to link with
changes to Policy CS26.
Vision
Make stronger reference to (public) transport and open
space. Refer to Spencers Park, East Hemel
Hempstead.
To provide a fuller, more rounded vision.
Local Objectives
Re-present, noting that a cemetery would serve the
whole town.
For clarity.
Delete reference to extensions on the east of the town
in St. Albans.
To reflect St. Albans District Council’s decision not
to consider this option.
Town Strategy
Amplify the strategy to better reflect the role of areas
other than the town centre and East Hemel, to
emphasise the importance of neighbourhood open
space and green infrastructure and to extend the
reference to transport.
To provide a fuller, more rounded strategy.
Town Centre Strategy
Refer to the arts centre and historic character attracting To identify an opportunity for future improvements.
new uses and investment in the Old Town.
Hemel Hempstead
Amend text of Gade, Hospital, Original Marlowes,
To ensure sufficient opportunity for future
Marlowes Shopping and Jellicoe Water Gardens Zones improvements and allow greater flexibility in
to widen the range of uses possible within each zone.
developing the town centre master plan.
In particular, delete references to office hubs: replace
with business (Hospital Zone), commercial and
38
Plan Reference
Change
business (Original Marlowes Zone) and office uses
(Marlowes Shopping Zone). Indicate Jellicoe Water
Gardens as a possible location for civic uses.
Reason
East Hemel Hempstead
Strategy
Explain the reduced scale of development, the
emphasis on regeneration and the facilities which are
most likely to require location in St Albans district.
To reflect discussions with St. Albans District
Council and their intention to restrict the impact of
development on the Green Belt in their district.
Amend the office floorspace potential.
To reflect recent technical evidence.
Extend the area of the Maylands Gateway, providing
advice on open space to be retained or replaced.
To provide guidance on the whole gateway area.
Explain what bulky B-class uses are (in the Engine
Room).
For clarity.
Policy CS34
Refer to open land providing a setting in Maylands
Gateway.
To provide consistent advice on the enlarged
Gateway area (see above).
Vision Diagrams
(Figures 19-22)
Ensure consistency of boundaries throughout.
Extend the Marlowes Shopping Zone.
Extend the Maylands Gateway area.
Amend the Area Action Plan boundary to suggest its
extent in/overlap with St. Albans district.
Amend urban design zones to reflect proposed or
actual development at Nash Mills (semi-urban) and the
Manor Estate (semi-urban/peripheral).
To reflect more recent evidence and Council
thinking, and for accuracy.
Confirm the conclusion of the local highway authority
that the highway issue at New Road/High Street,
Northchurch will be resolved through the Berkhamsted
To update the position and confirm the removal of
the New Road link from the strategy.
Berkhamsted
Strategy
39
Plan Reference
Change
Urban Transport Plan.
Reason
Vision Diagram
Amend urban design zone at Dudswell to peripheral.
To reflect the update to the Urban Design
Assessment.
Note that Tring School might be extended “up to” two
forms of entry (affecting local objectives).
To reflect this possibility more flexibly.
Note that the three General Employment Areas are to
be retained.
For clarity.
Amend housing level sought (by -20), affecting the
local objective.
To reflect more recent monitoring information and
overview of the housing distribution
Amend housing level sought (by +10), affecting the
local objective.
To reflect more recent monitoring information and
overview of the housing distribution
Refer to Three Rivers District Council’s plans to reduce
the amount of employment land in their district.
To acknowledge that Council’s intention through
their Core Strategy.
Amend housing level sought (by +20), affecting the
local objective.
To reflect more recent monitoring information and
overview of the housing distribution
Tring
Strategy
Bovingdon
Strategy
Kings Langley
Strategy
Countryside
Strategy
40
5.
SUSTAINABILITY APPRAISAL
5.1 The Consultation Draft Core Strategy was accompanied by a Sustainability
Appraisal Report (including Strategic Environmental Assessment), upon which
comments could also be made. The Sustainability Appraisal was available as a
background document on the consultation website: reference copies were also
available at local libraries and Council deposit points.
5.2 Four responses were received. Two related to heritage and environmental
issues covered in the Sustainability Appraisal Report. The other two
commented on conclusions relating to development proposals at Markyate and
East Hemel Hempstead (see Appendix 5).
5.3 Some comments raised the question of whether Core Strategy policies should
be changed – whether there was appropriate recognition of household growth,
public transport provision at new developments, the need to use resources,
such as water, efficiently, for example. The sustainability consultants’
conclusions that policy in the Consultation Draft Core Strategy adequately
covered the points already were accepted by the Council.
41
42
APPENDICES
43
44
Appendix 1: Advert
45
46
47
48
Appendix 2: Dacorum Digest
49
50
Original Digest
51
52
53
54
Correction Note
55
56
Final Corrected Version
57
58
59
60
Appendix 3: Organisations Contacted
61
62
Distribution List – Draft Core Strategy November 2010
DBC
Recipient
Councillors
Group Rooms (x2)
Assistant Director of Planning,
Development & Regeneration
Group Manager of Development
Management
Spatial Plans Team
SP LIBRARY
Development Management Team
Leaders
Development Management Case
Officers
PLANNING RECEPTION
BERK deposit point
TRING deposit point
Registry
Head of Street Care
Green Spaces Officer
Dave Pickering – Housing Enabling
Manager
Planning Solicitor
Legal Services Manager
Team Leader Conservation & Design
Environmental Resource Manager
Valuation & Estates
Team Leader Trees and Woodlands
Group Manager, Partnerships &
Citizen Insight
Document
2
1
6
1
13
2
2
1
1
63
Method of Notification
Email/Memo & CD
Memo & Doc
Memo & Doc & CD
Memo & CD
Memo & Doc
Memo & Doc
Memo only
Memo
Memo & Doc
Memo & Doc
Memo & Doc
Memo & Doc
Memo & Doc
Memo & Doc
Memo
Memo
Memo
Memo & Doc
Memo & Doc
Memo & Doc
Memo & Doc
Memo & Doc
HCC
LIB
TPC
Recipient
Communications
Document
-
SECTION TOTAL
29
Forward Planning
HBRC
Head of Landscape
-
SECTION TOTAL
0
County
HH
Adeyfield
Berkhamsted
Bovingdon
Kings Langley
Tring
Leverstock Green
Herts Local Studies
1
1
1
1
1
1
1
1
1
SECTION TOTAL
9
Nash Mills
Flamstead
Great Gaddesden
Nettleden with Potten End
Kings Langley
Northchurch
Berkhamsted
1
1
1
1
1
1
1
64
Method of Notification
Memo only
Letter & CD
Letter & CD
Letter & CD
Library Letter & Doc
Library Letter & Doc
Library Letter & Doc
Library Letter & Doc
Library Letter & Doc
Library Letter & Doc
Library Letter & Doc
Library Letter & Doc
Library Letter & Doc
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
Recipient
Aldbury
Bovingdon
Chipperfield
Flaunden
Little Gaddesden
Tring Rural
Tring Town
Wigginton
Markyate
Leverstock Gr Village Assoc
Document
1
1
1
1
1
1
1
1
1
1
SECTION TOTAL
OTHER
STATUTORY
CONSULTEES
Method of Notification
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
TPC Letter, Doc & CD
17
Adjoining Local Authorities (x16)
Natural England (Shaun Thomas)
Environment Agency
Highways
English Heritage
British Waterways
Network Rail
British Telecom
Transco
British Gas
Three Valleys Water
Thames Water
Primary Care Trust
Strategic Health Authority
-
SECTION TOTAL
65
Letter & CD
Letter & CD
Letter & CD
Letter & CD
Letter & CD
Letter & CD
Letter & CD
Letter & CD
Letter & CD
Letter & CD
Letter & CD
Letter & CD
Letter & CD
Letter & CD
Recipient
OTHER / NON
STAT
Document
County Councillors (10)
Ethnic Minority Groups (12)
Disability Groups (15)
Residents Associations (44)
Key Land Owners/Developers (x57)
LSP (Local Strategic Partnership) (14)
Estate Agents (37)
Local Pressure Groups (37)
Local Residents (No. not known-aprox
1,170)
Ward Councillors
-
SECTION TOTAL
-
-
Actual contacts
Copies required for list
TOTAL COPIES TO PRINT (allow for
extras)
1,483
55
120
66
Method of Notification
Email
Letter no docs
Letter no docs
Letter no docs
Letter no docs
Email
Letter no docs
Letter no docs
Letter no docs
Letter no docs
County Councillors
Cllr Andrew Fairburn
Cllr Lucy Foster
Cllr Michelle Lancaster
Cllr Jonathan Mote
Cllr Michael Moore
Cllr Jai Restall
Cllr Janice Speaicht
Cllr Derek Townsend
Cllr R. Wright
Cllr Richard Roberts
Ethnic Minority Groups
HEMEL ANTI RACISM COUNCIL
Dacorum Chinese Community Association
Dacorum Multicultural Association / MWA
Asian Masti
Muslim Welfare Association
Jewish Interests
DACORUM INDIAN SOCIETY
Dacorum Indian Society
Gujarati Language School / DIS
Africans Together in Dacorum
Caribbean Women's Equality & Diversity Forum
Club Italia
Muskann - Pakistani Women's Association
Dacorum Chinese School Association
Disability Groups
DISH
Hemel Hempstead Access Group
The Puffins
Alzheimer's Society (Dacorum Branch)
Dacorum Dolphin Swimming Club
Age Concern
Dacorum Talking Newspaper
Dacorum Volunteer Bureau
Heart to Herts
Mind in Dacorum
POHWER
Tring Access Committee
Hertfordshire Action on Disability
67
Residents Associations
ADEYFIELD NEIGHBOURHOOD ASSOCIATION
APSLEY COMMUNITY ASSOCIATION
Bellgate Area Residents Association
BENNETTS END NEIGHBOURHOOD ASSN
BERKHAMSTED CITIZENS' ASSOCIATION
BOURNE END VILLAGE ASSOCIATION
Briery Underwood Residents Association
CHAULDEN NEIGHBOURHOOD ASSOCIATION
Conservation Area Resident's Association
Dacorum Borough Council Leaseholder Group
Douglas Gardens Street/Block Voice
Gaddesden Row Village Voice
GADEBRIDGE COMMUNITY ASSOCIATION
Grovehill Community Centre
Grovehill West Residents Association
Hales Park Residents Association
HEATHER HILL RESIDENTS ASSOCIATION
Henry Wells Residents Association
Herons Elm Street/Block Voice
HIGHFIELD COMMUNITY CENTRE
Hunters Oak Residents Association
HYDE MEADOWS RESIDENTS ASSOCIATION
KINGS LANGLEY COMMUNITY ASSOCIATION
Leverstock Green Village Association
LONG MARSTON TENANTS ASSOCIATION
Longdean Park Residents Association
Manor Estate Residents' Association
NASH RESIDENTS ASSOCIATION
NETTLEDEN, FRITHSDEN & DISTRICT SOCIETY
NEW HORIZONS CHRISTIAN FELLOWSHIP
NORTHEND RESIDENTS ASSOCIATION
PELHAM COURT RESIDENTS ASSOCIATION
Picotts End Residents Association
R.B.R. Residents Association
Redgate Tenants Association
Rice Close Street/Block Voice
Shepherds Green Residents Association
STREET BLOCK VOICE
Street Block Voice (Farm Place)
Street Block Voice (Hazel Road)
Street Block Voice (Hilltop Corner, Berkhamsted)
Street Block Voice (Typleden Close)
Street Block Voice (Winchdells)
Tenant Participation Team
The Briars & Curtis Road Street/Block Voice
The Planets Residents Association
The Quads Residents Association
The Tudors Residents Association
68
THUMPERS RESIDENTS ASSOCIATION
Tresilian Square Residents Association
TRING COMMUNITY ASSN
Village Voice (Little Gaddesden)
WARNERS END NEIGHBOURHOOD ASSOCIATION
Westfield Road Street/Block Voice
Key Land Owners/Developers
Rectory Farm
Mr. G. Dean & Mrs C. M. Walter
Mr. D. Brightman
Mr. Steve Cook
Mr. Mark Glenister
Mr. John Greenaway
Mr. P. J. Kelly
Mr. John Normanton
Mrs. K M PLOSZCZANSKI
Mr. David Prothero
Mr. Peter Vallis
Mr. & Mrs. West
Abbot's Hill School
Mr. Neil Aitchison - AITCHISON RAFFETY
AKEMAN PROPERTY COMPANY LTD
Mr. JOHN JAMES - APLC
Mr. John Felgate - Ashley House Plc
Mr. James Finn - Barton Willmore
Mr. Mark Hendy - Barton Willmore Planning
BEECHWOOD HOMES LTD
Mr. James McConnell - Bellway Homes - North London
BIDWELLS
Mr. T O'Brien - Brian Barber Associates
Miss. Sarah Wills - Brian Barber Associates
Mr. Michael Emett - Cala Homes (South) Ltd
Mr. Rob Mason - Calderwood Property Investment Ltd
Mr. Paul Kempe - City & Provincial Properties plc
Mr. Adam Pyrke - Colliers CRE
COURTLEY CONSULTANTS LTD
Ms. Kim Webster - Crest Nicholson (Chiltern) Ltd
D W KENT & ASSOCIATES
DAVID RUSSELL ASSOCIATES
David Wilson Estates
Ms. Dianne Bowyer - DPDs Consultant Group
Mr. Neil Hall - Entec UK Ltd.
Mr. Chris Palmer - Estates and Property Services
Felden Park Farms Ltd
Mr. Andrew Wells - George Wimpey
Mr. Mike Parkhouse - George Wimpey Strategic Land
GLEESON HOMES
69
Mr. Matt Richardson - Gleeson Homes
GRIFFITHS ENVIRONMENTAL PLANNING
Mr. David Butcher - Hives Planning
Mr. MARK WHITE - HOMES & COMMUNITIES AGENCY (HCA)
Mr. Paul Cronk - Housebuilders Federation
Mr. Andrew Fido - Indigo Planning Limited
Ms. Kim Schlagel - Indigo Planning Limited
Mr. JEREMY C PETER - Jeremy Peter Associates
Ms. Liz Weaver - Levvel
MAIN ALLEN
Mr. Daniel Palman - NATHANIEL LICHFIELD & PARTNERS LTD
Nelson Bakewell
Mr. Paul Vesty - PDMS Vesty Limited
Miss. Julie Thomas - Permisson Homes Midlands
PICTON SMEATHMANS
Mr. Peter Smith - PJSA Property & Planning Consultants
Mr. Derek Proctor - Procter Farm Partnership
Mr. Alastair Pott - Renaissance Lifecare Plc
Mr. Edward Hollest - Savills
Mr. Bob Sellwood - Sellwood Planning
Mr. Steve Morton - Steve Morton Brickworks Ltd
Mr. Stephen Healey - Strutt and Parker
Mr. Nigel Agg - Taylor Wimpey Developments
Ms. Tracy-Ann Scanlan - Tetlow King Planning
Mr. Les West - The Barton Willmore Planning Partnership
THE CROWN ESTATE
Mr. Jeremy Butterworth - Tribal MJP
TWIGDEN HOMES LTD.
Mr. Richard Lewis - Vincent and Gorbing
Mr. RICHARD PARSONS - VINCENT AND GORBING
Ms. Hannah Philip - VINCENT AND GORBING
Local Strategic Partnership
COUNTRYSIDE MANAGEMENT SERVICE
Age Concern Dacorum
CHINESE SCHOOL ASSOCIATION
Hertfordshire Primary Care Trust
Churches Together
HERTS COUNTY COUNCIL
Wenta Business Services
West Herts College
LAA Children and Young People's Block
Job Centre Plus
Community Action Dacorum
Hertfordshire Constabulary
Berkhamsted Town & Parish Council
Herts County Council
70
Estate Agents
Aitchison Rafety
ASHRIDGE ESTATES
Bidwells
BRASIER HARRIS
BROWN & MERRY
CARTER JONAS
CASTLES
CESARE NASH & PARTNERS
CHESTERTON
COLE FLATT & PARTNERS
CONNELLS
CORNERSTONE
Cushman & Wakefield
DAVID DOYLE
DTZ
FISHER WILSON
Freeth Melhuish Associates Limited
HEMEL PROPERTY
KIRKBY & DIAMOND
Lambert Smith Hampton
MALCOLM JUDD & PARTNERS
MICHAEL ANTHONY
Nathaniel Lichfield & Partners
Peacock & Smith
PENDLEY COMMERCIAL
PENDLEY ESTATES
POULTER & FRANCIS
Savills (L & P) Limited
STIMPSONS COMMERCIAL
Strutt & Parker
STUPPLES & CO
Local Pressure Groups
BOXMOOR TRUST
Built Environment Advisory & Management Service
CAMBS & HERTS FWAG
Campaign for Real Ale
Campaign to Protect Rural England
CHILTERN HUNDREDS HOUSING ASSN
CHILTERNS CONSERVATION BOARD
CPRE - THE HERTFORDSHIRE SOCIETY
DACORUM COUNCIL
DACORUM CVS
FRIENDS OF TRING RESERVOIRS
GROUNDWORK HERTFORDSHIRE
GUINESS TRUST
71
HEMEL HEMPSTEAD HIGH STREET ASSN.
HERTFORDSHIRE AGRICULTURAL SOCIETY
HERTS & MIDDLESEX BADGER GROUP
Herts & Middlesex Wildlife Trust
HERTS FED.OF WOMEN'S INSTITUTES
HERTS NATURAL HISTORY SOCIETY
HIGHTOWN PRAETORIAN
INLAND WATERWAYS ASSOCIATION
KINGS LANGLEY LOCAL HISTORY & MUSEUM SOCIETY
LONDON LUTON AIRPORT OPERATIONS LTD
MARKYATE VILLAGE HALL COMMITTEE
RAMBLERS ASSOCIATION
S & W Herts WWF Group and Green Party
ST ALBANS ENTERPRISE AGENCY
ST ALBANS MUSEUMS
The Box Moor Trust
THE CHILTERN SOCIETY
THE CONSERVATION SOCIETY (HERTS)
The Inland Waterways Association
TRING CYCLING CAMPAIGN
TRING ENVIRONMENTAL FORUM
WENDOVER ARM TRUST
Woodland Trust
72
Appendix 4: Sample Notification Letters
73
74
General Notification Letter without copies of the document
Date:
Our Ref:
Contact:
E-mail:
Directline:
Fax:
1 November 2010
File 7.17
Spatial Planning
[email protected]
01442 228660
01442 228771
«tiTitle» «coInit» «coName»
«coPosition»
«coCompanyName»
«coAdd1»
«coHouseNum» «coStreet»
«coDistrict»
«toTown»
«toCounty»
«coPostCode»
Civic Centre
Hemel Hempstead
HP1 1HH
(01442) 228000 Switchboard
(01442) 228656
Minicom
DX 8804 Hemel Hempstead
Dear «tiTitle» «coName»,
CONSULTATION ON DRAFT CORE STRATEGY FOR DACORUM (REGULATION
25)
I am writing to let you know that the Council has published a Draft Core Strategy for
consultation. The consultation begins on 3rd November and ends on 15th December
2010.
What is the consultation about?
The Draft Core Strategy sets the planning framework for Dacorum for the next 20
years. It contains a vision of what the Borough should be like in 2031 and a set of
policies to help achieve this. It also contains individual strategies for the towns, large
villages and the wider countryside. These set out specific planning issues affecting
these individual areas and how any problems will be addressed. The document
translates the approach set out in the Emerging Core Strategy (summer 2009) into
detailed planning policies and also puts forward two detailed housing options for
comment.
How do I find out more?
Copies of the Core Strategy and associated documents can be purchased from the
Borough Council’s offices during normal opening hours, or downloaded free of
charge from www.dacorum.gov.uk/planning. Reference copies are also held at all
libraries within the Borough.
A summary of the Core Strategy is included as a centre-spread in the current edition
of the Council’s magazine, Dacorum Digest, which is currently being delivered to all
households within the Borough. Please note that this article does contain some
printing errors relating to the housing numbers for some towns and villages. A
correction leaflet will be delivered with your copy of Digest and is also enclosed.
75
I would particularly draw your attention to the list of ‘Drop In’ sessions that have been
arranged in late November and early December, where you can come and find out
more information.
Date
Town / Village
22 Nov Hemel Hempstead
23 Nov Berkhamsted
26 Nov Bovingdon
29 Nov Tring
1 Dec
Kings Langley
2 Dec
Markyate
Venue
Council Chamber, Civic Centre
Main Hall, Council Offices, High
Street
Memorial Hall, High Street
Silk Mill Community Centre, Silk
Mill Way
Small
Hall,
Kings
Langley
Community Centre, The Nap
Main
Hall,
Village
Centre,
Cavendish Road
Time
2-9pm
2-9pm
2-9pm
3.30-9pm
2-9pm
2-9pm
The Draft Core Strategy is accompanied by a Sustainability Appraisal Report, upon
which comments are also welcomed.
How do I comment?
We would encourage you to submit your comments via the Council’s online
consultation portal at http://consult.dacorum.gov.uk. I have enclosed a sheet that
gives a step-by-step guide on how to do this. Paper copies of the Core Strategy
questionnaire are however available on request.
The consultation runs from 3rd November to 15th December. Comments must be
received by 5.15pm on 15th December in order for them to be taken into account.
What happens next?
The Council will consider the results of this consultation before progressing to the next
stage which is called ‘Pre-submission.’ At this stage the Council will need to come to a
firm view on the strategy for the Borough, including the housing target. This version of
the Core Strategy will be published for comment before being submitted to the
Planning Inspectorate and discussed at an Examination.
If you have any questions please contact the Spatial Planning team on 01442 228660
or email [email protected]
Yours sincerely
Laura Wood
Principal Planning Officer – Spatial Planning
Strategic Planning and Regeneration
76
Organisations Notification Letter with copies of the document on CD
Date:
Our Ref:
Contact:
E-mail:
Directline:
Fax:
29 October 2010
File 7.17
Spatial Planning
[email protected]
01442 228660
01442 228771
«tiTitle» «coInit» «coName»
«coPosition»
«coCompanyName»
«coAdd1»
«coHouseNum» «coStreet»
«coDistrict»
«toTown»
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Civic Centre
Hemel Hempstead
HP1 1HH
(01442) 228000 Switchboard
(01442) 228656
Minicom
DX 8804 Hemel Hempstead
Dear «tiTitle» «coName»,
CONSULTATION ON DRAFT CORE STRATEGY FOR DACORUM (REGULATION
25)
I am writing to let you know that the Council has published a Draft Core Strategy for
consultation. The consultation begins on 3rd November and ends on 15th December
2010.
What is the consultation about?
The Draft Core Strategy sets the planning framework for Dacorum for the next 20
years. It contains a vision of what the Borough should be like in 2031 and a set of
policies to help achieve this. It also contains individual strategies for the towns, large
villages and the wider countryside. These set out specific planning issues affecting
these individual areas and how any problems will be addressed. The document
translates the approach set out in the Emerging Core Strategy (summer 2009) into
detailed planning policies and also puts forward two detailed housing options for
comment.
How do I find out more?
Copies of the Core Strategy and associated documents can be purchased from the
Borough Council’s offices during normal opening hours, or downloaded free of
charge from www.dacorum.gov.uk/planning. Reference copies are also held at all
libraries within the Borough.
A summary of the Core Strategy is included as a centre-spread in the current edition
of the Council’s magazine, Dacorum Digest, which is currently being delivered to all
households within the Borough. Please note that this article does contain some
printing errors relating to the housing numbers for some towns and villages. A
correction leaflet will be delivered with your copy of Digest and is also enclosed.
77
I would particularly draw your attention to the list of ‘Drop In’ sessions that have been
arranged in late November and early December, where you can come and find out
more information.
Date
Town / Village
22 Nov Hemel Hempstead
23 Nov Berkhamsted
26 Nov Bovingdon
29 Nov Tring
1 Dec
Kings Langley
2 Dec
Markyate
Venue
Council Chamber, Civic Centre
Main Hall, Council Offices, High
Street
Memorial Hall, High Street
Silk Mill Community Centre, Silk
Mill Way
Small
Hall,
Kings
Langley
Community Centre, The Nap
Main
Hall,
Village
Centre,
Cavendish Road
Time
2-9pm
2-9pm
2-9pm
3.30-9pm
2-9pm
2-9pm
The Draft Core Strategy is accompanied by a Sustainability Appraisal Report, upon
which comments are also welcomed.
How do I comment?
We would encourage you to submit your comments via the Council’s online
consultation portal at http://consult.dacorum.gov.uk. I have enclosed a sheet that
gives a step-by-step guide on how to do this. Paper copies of the Core Strategy
questionnaire are however available on request.
The consultation runs from 3rd November to 15th December. Comments must be
received by 5.15pm on 15th December in order for them to be taken into account.
What happens next?
The Council will consider the results of this consultation before progressing to the next
stage which is called ‘Pre-submission.’ At this stage the Council will need to come to a
firm view on the strategy for the Borough, including the housing target. This version of
the Core Strategy will be published for comment before being submitted to the
Planning Inspectorate and discussed at an Examination.
If you have any questions please contact the Spatial Planning team on 01442 228660
or email [email protected]
Yours faithfully
Laura Wood
Principal Planning Officer – Spatial Planning
Strategic Planning and Regeneration
78
Appendix 5: Comments on Sustainability
Appraisal
Key to Table:
•
Page and other references are to the:
“Dacorum Local Development Framework
Core Strategy – Consultation Draft
November 2010”
•
Response – initially provided by consultants C4S independently, and then
agreed with the Council.
79
80
Consultation Draft Core Strategy SA/SEA: Consultation Comments
Summary of Comments
How the comments have been taken on board
English Heritage
Appendix B 1.4 Cultural Heritage
The baseline information referred to in para 1.4.2 would be strengthened by reference to the Some update to the baseline in relation to the
Extensive Urban Survey reports available on the Historic Environment Record. These reports can Urban Survey has been made. Other comments
provide a helpful foundation for the place strategies and site allocations. The English Heritage data noted for future SA assessment.
on buildings at risk provides data on grade I and II* listed buildings only. This should be
supplemented by information on grade II listed buildings collected locally. Mapping historic
environment assets at a strategic scale can be difficult but we suggest that conservation areas can
readily be included in Figure 4.
Appendix F: Hemel Hempstead
Note on page F5 that the potential for housing and other developments to adversely affect known This is an issue for the more detailed Site
or undiscovered heritage assets is recognised. The appraisal of the suitability of sites should be Allocations DPD
informed by archaeological evaluation, where potential archaeological interest is identified, in
accordance with PPS5. The county archaeologist should be consulted on this and other greenfield
sites.
Note that the potential impact of site LA2 on the Old Town conservation area is identified on page Assessment updated to take this comment into
F16 in relation to ‘historic and cultural assets’. While the allocation does not extend into the open account.
countryside we feel the assessment against ‘landscape and townscape’ fails to recognise the
contribution of the unspoilt valley landscape to the quality of the interface with the Old Town.
Berkhamsted
The assessment on page F24 shows a potential negative impact for cultural heritage. It is not clear if No archaeological assessment was used. The
assessment was based on the fact that the area
appropriate archaeological assessment has been provided to inform the judgement.
falls within an “area of archaeological significance”.
Advice from County Archaeologist has already
81
been incorporated into the ‘Assessment of Local
Allocations and Strategic Sites’ (Oct 2010).
Tring
The site to the west of Tring is appraised on page F26. The proximity of the Roman road and Icknield Advice from County Archaeologist has already
Way may suggest archaeological interest. We suggest the advice of the county archaeologist should been incorporated into the ‘Assessment of Local
be sought to inform the assessment.
Allocations and Strategic Sites’ (Oct 2010).
Entec
The SA acknowledges that the eastern strategy in combination with the EHAAP, should they both
proceed, could have cumulative positive effects on the economic and social objectives through the
provision of employment, leisure and housing in close proximity, plus improvements to the
transport infrastructure and positive effects in terms of sustainability appraisal objectives. The SA
needs to have considered all options individually, for instance NE Hemel Hempstead should have
been considered as an option rather than just as part of a wider option including other sites/broad
development areas. Consideration of sites individually would pick up on issues that are specific to
the site, for instance developing further at West Hemel Hempstead may lead to more cross to travel
that would be reduced/balanced by including land to the east of Hemel Hempstead.
No change required. The SA did consider all
options separately when it was undertaken in
August 2009. The results of these assessments are
summarised in sections 5.4 – 5.6 of the SA Report.
The text in 6.3.4 (of the previous SA Report, Nov
2010), on which this comment is based, took the
assessment further to consider the how the Core
Strategy would link with the Area Action Plan.
Markyate Parish Council
Appendix E: We have noticed on maps on pages E23 and E24 that the number of houses for This is a typographic error. The 140 figure relates
to the approximate number of units that have
Markyate is shown as 140, not 190. We do not understand this discrepancy.
either been built or identified through the Council’s
housing studies. The 190 figure takes into account
the inclusion of a higher level of housing on the
Hicks Road site and is the total anticipated housing
figure for the village over the plan period. These
maps have now been removed from the SA Report.
Appendix F: 6.1.5 repeats the 140 houses figure mentioned in policy assessment E above. Again the See above regarding the housing figure.
benefits from the Hicks Road development are stretched. This acceptance of the poor public
82
transport connections and the use of cars must be followed by the acceptance for adequate Parking and access issues are considered in the
Core Strategy and associated Masterplan for the
parking, above national guidelines.
Hicks Road site. The development requirements
for the site (Proposal SS2) includes replacement
public car parking to serve the village, existing
commercial uses and new surgery as part of the
redevelopment. The precise levels of car parking
requirement will be a matter for the planning
application.
6.1.11 - This talks of preserving the Cell Park landscape – it is the Manor Farm development already Noted.
permitted, that will affect Cell Park. Even without the tall trees lining the A5, you would have to
build very high at Hicks Road to even see Cell Park.
6.1.12 - Consider that the health benefits arising from the provision of the public space at Hicks The health benefits predicted were not just based
Road have been over-emphasised. If the survey requirement for leisure use is translated into active on this factor but also took account of
leisure provision this will be far more healthy. Also, if the Doctor’s surgery is expanded into a Health improvements to walking and cycling provision.
Centre and the other services like dentist etc are provided it should not only help keep people
healthy, it will also help with reducing greenhouse gas emissions and improving air quality as there
will need to be fewer journeys to access these facilities elsewhere, almost inevitably by car. (Any
hospital is at best a two bus journey from Markyate). As commented earlier:
Noise nuisance from the commercial operations and the A5 would suggest that the noisiest
businesses be sited next to the A5, with the new Heath Centre and car parking providing a buffer for
the housing.
It should be noted that the other housing close to the A5 and the industrial area has all been
Comments noted.
developed after they were there!
Hicks Road is one of the two permitted lorry accesses to the village from the A5. The main part of
the High Street is restricted to lorries with business there. The safe passage of traffic from the A5
must be maintained or improved. Any chance of traffic backing onto the A5 because it cannot Comments noted for the Core Strategy.
progress onwards must be avoided. Pickford Road is a well used route to and from the village, and Discussions are ongoing with Hertfordshire County
Council, the Highway Authority and the developers
83
much uses Hicks Road to access or leave the A5. Any development at Hicks Road must take this with regard to access and highway safety issues.
situation on board and address the issue so that traffic congestion and conflict does not occur.
[Additional comments, not related to the SA, were made.]
Dennis Harvey
Policy CS16 – Retail development should have public transport. Does not agree that “no change is
necessary to the policy”. There has to be a way of linking any development, retail or housing, to a
provision of public transport. It is not acceptable to have a view that the Council has no jurisdiction
over mandating public transport. It is in the vision so the Council must find a way of making it
happen at the same time as the development.
Comments noted but no action required.
The County Council are the authority responsible
for bus services, together with private bus
providers. Section 10 of the Core Strategy sets out
the Council’s policy approach to access between
homes, jobs and facilities, which includes retail
facilities.
Policy CS8 requires all new development to
contribute to a well connected and accessible
transport system. This includes public transport.
The sustainability appraisal includes a statement on sustainable communities relating to
consumption and production and economy. I do not see anything in the document which ensures
that this happens. There is also a statement to protect natural resources. For a community to be
sustainable it cannot use resources faster than they are replenished. For a community to have a
sustainable economy it must not spend more than it receives for its trade. If more dwellings are
planned, there should be land allocated, within walking distance, large enough to grow sufficient
food for that dwelling, if the land with the dwelling is not sufficient.
The SA includes objectives relating to these issues
and the assessment has identified how the Core
Strategy would help (or hinder) towards the
achievement of these objectives.
The SA itself cannot ensure that the objectives are
met.
The SEA includes the requirement to consider population – I do not see anything in the document to The SA has considered how the Core Strategy
address population directly: i.e. is the absolute number of people in the borough a good or a bad would meet the needs of the predicted changes in
thing. Generally I believe that more people are a bad thing for sustainability but there is no such population.
statement to plan to keep the number of people the same or lower.
The SEA includes the requirement to consider the climate – I do not see anything in the document The SA includes objectives relating to these issues
84
to directly address this. There needs to be something to restrict the use of materials or processes
which could have an effect on the climate. The document could include a requirement that all
dwellings have at least one form of sustainable energy source (as in some European countries) and a
requirement that any businesses have a similar form of sustainable energy source. This should apply
to all council buildings.
and the assessment has identified how the Core
Strategy would help (or hinder) towards the
achievement of these objectives.
Recommendations have been provided throughout
the SA process as to how the Core Strategy can
take into account issues relating to climate. These
are reflected in the text of section 19 of the Core
Strategy.
The SEA includes the requirement to consider water: Opportunities from the Sustainability Report Comments more in relation to the Core Strategy
not written into the draft core strategy.
than the SA.
Consider overall siting of development schemes in order to minimise potential effects on water No change required. Section 19 of the Core
Strategy (Using Resources Efficiently) already
quality.
includes appropriate requirements relating to
Encourage the use of Sustainable Drainage Systems in new developments
minimising water consumption, and dealing with
issues of water supply, surface water, foul drainage
Ensure efficient use of water resources in development schemes, this includes the use of recycled
and the use of sustainable drainage systems.
water.
New developments should incorporate rainwater use.
Ensure new polluting processes are located in areas where groundwater is not vulnerable.
The issue of delivery is also covered in section 19 of
the Core Strategy and includes reference to
partnership working with the Environment Agency,
Thames Water and Veolia Water.
There is no direct statement to say how the above are going to be forced to happen.
Delivery of these policies will be supported by the
Council’s Sustainable Development Advice Note
(March 2011)
Key issues from the Sustainability Report but solutions not written into the draft core strategy:
The River Gade: overall status is bad (ecological status is moderate, chemical status is failing).
Over abstraction of water resources is an issue in the regions. The Chilterns Chalk Streams are
85
Comment more in relation to the Core Strategy
than the SA.
particularly susceptible to over abstraction.
The Environment Agency has already stated that we are running out of water in the region. This
means that our present system is not sustainable. To add more consumers or businesses into the
region is therefore going to make the situation worse. We can not create water. We are using it See above response regarding Core Strategy.
faster than it is being replenished. The limiting capacity of the existing sewage treatment works has
been identified but it can only process the sewage if it has sufficient water. There is no point in
increasing the sewage treatment capability if there is no more water.
86
Appendix 6: Cabinet Report – 26 July
2011: Core Strategy Proposed Submission
87
88
AGENDA ITEM:
Report for:
Cabinet
Date of meeting:
26 July 2011
PART:
l
If Part II, reason:
Title of report:
Contact:
Purpose of report:
Recommendations
LOCAL DEVELOPMENT CORE STRATEGY – PROPOSED
SUBMISSION
Stephen Holmes, Portfolio Holder for Strategic Planning and
Regeneration
Authors: Laura Wood – Team Leader – Strategic Planning (ext
2660) and James Doe – Assistant Director Planning
Development and Regeneration (ext 2583)
That Cabinet:
1. Consider the key issues raised by the consultation held in
late 2010 on the Draft Core Strategy and new information
and advice.
2. Recommend the Core Strategy Proposed Submission
documents to Full Council for publication and comment.
3. Support the principle of developing a Community
Infrastructure Levy (CIL).
1. To note the key issues arising from consultation on the
Draft Core Strategy (November 2010) and new evidence.
2. To recommend to Council that housing option 2,
incorporating the growth level and the local allocations set
out in paragraph 1.37 of this report, are included within the
Pre-Submission Core Strategy.
3. To delegate authority to the Portfolio Holder for Planning
and Regeneration to approve changes to the Draft Core
Strategy prior to consideration by Full Council.
4. To delegate authority to the Assistant Director (Planning,
Development and Regeneration) to finalise the Report of
Consultation and Sustainability Appraisal.
89
5. To recommend to Council that it approve the Core Strategy
for publication, seeking representations in accordance with
the Statement of Community Involvement and relevant
Regulations.
6. To recommend to Council to approve the following
procedure for considering further issues on the Core
Strategy:
(a) If significant new issues are raised in the
representations on forthcoming consultation routines,
to report to Cabinet and Council for a decision as to
whether any change to the Core Strategy is justified
(b) If there are no significant new issues, to delegate
authority to the Assistant Director (Planning,
Development and Regeneration) to
- submit the Core Strategy for examination; and
- in consultation with the Portfolio Holder to agree
any minor changes to the Core Strategy to
resolve objections and improve the clarity of
the document.
7. To request the Assistant Director (Planning, Development
and Regeneration) to prepare a Community Infrastructure
Levy charging schedule for Council approval.
[Council should note that Strategic Planning and Environment
Overview and Scrutiny Committee considered the draft Core
Strategy on 19 July 2011].
Corporate
objectives:
Implications:
Financial/
Value for Money
Risk Implications
Preparation (and delivery) of the Local Development
Framework and its component parts contributes to all the
corporate objectives. The aim is to achieve high quality,
sustainable development in the right place, at the right time
and with the right infrastructure, whilst also ensuring
recognising the need to protect green space.
The process of preparing the Core Strategy, as part of the
LDF, has financial implications. Cabinet considered the
implications of a three year budget programme when
considering the Annual Monitoring Report and progress
towards the Local Development Scheme in November 2009.
Budget provision, together with an LDF reserve, is made for
2011/12.
Having an up to date planning policy framework helps reduce
the incidence of planning appeals (and thus costs associated
with those). It will also be the most effective way of ensuring
the optimum level of developer contributions to infrastructure
and in mitigation of development impacts can be achieved.
This process will be further improved and simplified through
the adoption of a Community Infrastructure Levy (CIL)
approach.
Key risks are identified in the Local Development Scheme and
reviewed annually with the Annual Monitoring Report. They
90
Equalities
Implications
Health and Safety
Implications
Monitoring
Officer/S.151
Officer Comments
include failure of external agencies or consultants to deliver on
time, change in Government policy and team capacity. A
separate risk assessment prepared for the Core Strategy PreSubmission identifies a number of risks relating to the
examination in public process and particularly the soundness
tests with which the Core Strategy must comply. There are
also risks associated with not delivering sustainable
development i.e. in terms of not meeting local housing needs.
The issues covered by the Core Strategy include affordable
housing and homes for minority groups, accessibility of
facilities and local employment. The Sustainability Appraisal
Report that accompanies the Core Strategy considers
equalities issues. It concludes that no issues have been
identified in relation to the Core Strategy potentially
discriminating on the basis of disability, gender or ethnic
minority.
Implications are included in the planning issues covered by the
Core Strategy.
Monitoring Officer:
The request for delegated powers to officers and the Portfolio
Holder set out in the recommendation are intended to expedite
the decision making process in relation to the formation of the
Core Strategy and are in line with the relevant planning
legislation and the Council’s Constitution.
S.151 Officer
Consultees:
Background
papers:
****************************************************
The report refers to consultation undertaken at various stages.
The results of all previous consultation is summarised in the
Report of Consultation that will accompany the Pre-Submission
Core Strategy. Volume 6 is a draft report of consultation from
November 2010, including public consultation on the
Consultation Draft Core Strategy. Development Plans Task &
Finish Group has been consulted at regular intervals in the
preparation of the Core Strategy.
The Local Strategic
Partnership Board has also discussed the content of the Core
Strategy at key stages in its preparation.
Corporate
Management Team have been appraised of progress. It has
expressed support for housing option 2.
• Draft Core Strategy (November 2010)
• Draft Core Strategy Report of Consultation (especially
Volume 6).
• The draft Pre-Submission Core Strategy.
• Sustainability Appraisal report (November 2010)
• Presentation given at Members Briefing (February 2011).
• Report presented to the Local Strategic Partnership Board
on the ‘Dacorum Local Development Framework – Core
Strategy’ (June 2011).
• Assessment of Strategic Sites and Local Allocations
(October 2010)
• Assessment of Alternative Growth Locations for Hemel
91
•
•
•
•
•
•
•
•
Hempstead (May 2009)
Statement of Community Involvement (June 2006).
Draft National Planning Policy Framework (June 2011).
Draft proposals from DCLG regarding ‘Presumption in
Favour of Sustainable development’ (June 2011).
Local Development (England) Regulations (2004 as
amended)
Planning and Compulsory Purchase Act (2004 as
amended).
Draft Localism Bill.
Planning Policy Statement 12: Local Spatial Planning.
Technical studies (available from www.dacorum.gov.uk).
92
BACKGROUND
1
Introduction to the Core Strategy
1.1
The purpose of the Core Strategy is to set the planning framework for the Borough
up to 2031. Its aim is to achieve sustainable development i.e. new homes, facilities
and businesses, whilst maintaining the quality of the environment. It is an essential
tool in helping to co-ordinate new investment within the area and helping promote
economic regeneration and growth. Infrastructure provision should be aligned with
new development.
1.2
Once agreed, the Core Strategy, together with other planning documents that make
up the ‘Local Development Framework’, will replace the current Dacorum Borough
Local Plan, adopted in 2004.
1.3
The Core Strategy contains a vision of what the Borough should be like in 2031,
together with a series of objectives which set out how this vision will be realised.
Both the vision and objectives complement those set out within the Sustainable
Community Strategy (January 2008). They are followed by planning policies that
provide a framework through which the Council will judge future development
proposals. These cover the plan’s core themes of:
o Strengthening Economic Prosperity
o Providing Homes and Community Services; and
o Looking After the Environment.
1.4
In addition to this Borough-wide framework, the Core Strategy also contains
individual Place Strategies that look at the specific planning issues affecting our
towns, large villages and the wider countryside. These set out how we intend to
protect their different characters, build upon their strengths and, where possible, help
address any problems they face. These Place Strategies provide a clear planning
framework for any Neighbourhood Plans that communities may wish to draw up once
the new Localism Bill is enacted. The important issues of infrastructure provision,
delivery and monitoring are also addressed.
Where we are in the process
1.5
The Council is about to reach a critical stage in the Core Strategy development,
known as Pre-Submission. This is where the Council publishes the version of the
Core Strategy that it proposes to submit to the Planning Inspectorate and take
forward to examination.
1.6
The Pre-Submission Core Strategy must be accompanied by a Sustainability
Appraisal Report and Consultation Statement. Both of these documents have been
prepared on an iterative basis and show how the Core Strategy has developed from
a consideration of issues and options to the Pre-Submission version. The PreSubmission Core Strategy, the Sustainability Appraisal Report and the Consultation
Report are jointly referred to as the Proposed Submission documents.
1.7
Once endorsed by Full Council, the Pre-Submission Core Strategy becomes a
material planning consideration and will be published for formal comment for a 6
week period. If the Council wishes to make any significant changes to the PreSubmission version in the light of representations made during this period, it will need
to repeat the Pre-Submission consultation before submitting the document to the
Planning Inspectorate. This has significant time and resource implications.
93
1.8
The Core Strategy has been subject to a very rigorous process of evidence collection
and testing, and consultation. It is a long term plan and decisions taken now should
be robust for many years to come.
1.9
In revising the Consultation Draft and approving the Core Strategy, the Council must
take into account:
• Technical evidence
• Government and strategic policy (The East of England Plan is still relevant)
• Sustainability appraisals (including strategic environmental assessment and
Habitats Assessment)
• Consultation
• Government regulations.
New information and evidence
1.10
A number of new sources of information and evidence have arisen since Cabinet last
considered the Core Strategy in September 2010.
Results of Public Consultation
1.11
Through previous consultation over several years we have already gained a good
understanding of what local residents, organisations and businesses consider to be
the main issues facing the Borough and the different options for tackling these.
Consultation has taken different forms, some with the general public and some with
targeted groups.
Preparation of the technical evidence has also included
consultation with stakeholders to verify accuracy and support recommendations.
1.12
The most recent consultation on the Draft Core Strategy during November /
December 2010 generated over 2,600 comments from more than 600 different
groups and individuals. Additional feedback was gained from a questionnaire
circulated to the Council’s Citizens' Panel (a cross section of about 1,000 residents)
and from meetings with organisations to discuss specific issues.
1.13
Officers are currently finalising the Report of Consultation, which will provide a full
summary of the consultation comments and the Council’s response to issues raised.
It will comprise seven volumes. Previously published volumes are being edited for
ease of reading and clarity. Volume 6 relates to the current consultation and Volume
7 will provide an overview of the whole consultation process. The Report of
Consultation will need to be amended to reflect decisions made regarding the
Council’s housing target, any new information that becomes available before Full
Council, to ensure the information they contain is comprehensive and that responses
to objections are accurate, consistent and robust. Once complete, the report will be
available on the Council’s website. Copies of the current draft documents are
available in the Group Rooms.
1.14
The table in Appendix 1 provides a summary of the yes/no answers given to
questions in each section of the Core Strategy. These are broken down to
distinguish responses by the general public, organisations and landowners.
1.15
These high level results show that the approach to the environment and economy is
generally supported. The principal issues of concern centre around the housing
section and site information contained within some of the Place Strategies. A more
94
detailed summary of the nature of these concerns and the significance of issues
raised is set out in Appendix 1.
1.16
It is particularly important to note the impact of site-related campaigns when
considering responses. These have often affected responses to other sections, such
as the overall Borough Vision and objectives and the approach towards infrastructure
and delivery.
1.17
Volume 6 (Annex A, Appendix 1) of the Report of Consultation sets out the Council’s
recommended response to issues raised through the consultation and any changes
required to the Core Strategy. Additional changes are also required as a result of
new information, changes in Council and Government policy and for consistency,
clarity and accuracy. These additional changes are listed in Appendix 3. This
schedule will be included in the final Report of Consultation.
New Government advice
1.18
The Government intends to replace Planning Policy Guidance (PPGs), Planning
Policy Statements (PPSs) and other national guidance with a more succinct
document called the ‘National Planning Policy Framework’ (NPPF). A draft version of
the NPPF has been submitted to Ministers and there will be formal consultation later
this year. Whilst the approach may change following initial feedback, the current
draft takes a very pro-development stance. Key points include:
•
•
•
•
A reiteration of the importance of a plan-led system and the need for every
authority to have an up-to-date plan upon which to base planning decisions.
A move towards authorities being required not just to plan for local housing need,
but also to reflect housing demand. This would require Councils to base housing
targets on their Strategic Housing Market Assessments (SHMA) and latest
household projections (see below).
The need for planning to play an important role in delivering economic growth
and prosperity.
The retention of the 5 tests for development in the Green Belt currently in PPG2:
Green Belts.
1.19
A ‘presumption in favour of sustainable development’ will underpin the NPPF. This is
a key part of the Coalition Government’s stated intention to reform the planning
system so that it is more supportive of development. The draft presumption says that
local planning authorities should “plan positively for new development and approve all
individual proposals where possible.” It also requires Councils to “grant permission
where the plan is absent, silent, indeterminate or where relevant policies are out of
date.”
1.20
The Localism Bill is also due to be enacted later this year. This will introduce a new
tier of ‘Neighbourhood Plans’ to the development plan system.
1.21
Sufficient flexibility must be built into the Core Strategy to enable it to reflect these
(and future) changes to the planning system, whilst still providing a clear basis upon
which planning decisions can be made.
New population and household growth information
1.22
The critical benchmark that will be used by a Planning Inspector to assess the
Council’s approach to housing is the household projection information from central
95
Government (CLG). This is often referred to as the ONS projection. The most up-todate ONS figures relate to 2008. The 2008 ONS projections were published in May
2010, so were not available to inform earlier drafts of the Core Strategy. Figures
from the 2004 CLG household projections and Hertfordshire County Council’s own
internal work were used instead.
1.23
The results of these earlier projections are set out in the ‘Population: Background
Note for the Core Strategy’ (April 2009). This document is currently being revised.
We must also be aware of the latest projections from the East of England Forecasting
Model (EEFM) which captures the interdependence of the economy, economic
change and housing at a local level. Projections are also available using the
Chelmer model, but these are considered less robust. This model is based on out of
date assumptions and has been subject to criticism by experts. Officers do not
consider that the Chelmer projections to be a realistic, reasonable or sound basis on
which to base our housing target.
1.24
Results from these different household projections are shown in Appendix 2. The
ONS projections indicate that over 13,400 new households will be formed within the
Borough over the period covered by the Core Strategy (2006-2031).
Technical evidence
1.25
Additional technical information has become available, which needs to be reflected in
the Core Strategy.
1.26
The Employment Study Update (June 2011) has confirmed Officer advice that the
jobs target needs to be reduced. The new figure of 10,000 better reflects anticipated
levels of housing growth, whilst still taking account of the sub-regional role of
Maylands and the Council’s aspirations for economic regeneration. The report has
also helped clarify assumptions regarding uses in the Maylands Gateway and
confirmed that business expansion into St Albans District will not be required within
the plan period.
1.27
The Green Infrastructure Study (March 2011) and the outcomes of the Hemel
Hempstead Town Centre workshop (“charette”) held in January 2011 have also
required amendments to the content of the Core Strategy. None of these changes
have affected the main policy approach within the document.
1.28
Some technical work and information is still outstanding:
•
An update of retail capacity figures. The Council’s latest retail study (March
2009) was based on high and low housing forecasts. These retail figures were
amended by Officers for the Draft Core Strategy to better reflect actual planned
levels of housing provision. The latest retail update, being carried out as part of
work to support the Hemel Hempstead Town Centre Master Plan, will act as an
independent check on these figures.
•
Discussions with St Albans regarding cross boundary issues and the content and
scale of the East Hemel Hempstead Area Action Plan (AAP) are ongoing. At the
request of St Albans Officers, the Council has suggested draft wording regarding
the future planning framework for this area for inclusion in its Pre-Submission
Core Strategy. This includes a suggested boundary for the AAP area. A final
version of St Albans’ Pre-Submission Core Strategy is not yet available and a
planned meeting between senior Members and Officers has yet to take place. It
96
is important to ensure the two authorities take a complementary approach to this
area. Officers are trying to ensure that there is flexibility to include uses which
would serve the Maylands Business Park and Spencers Park neighbourhood
within St Albans. Examples might include a new primary school, waste
management facility, park and ride and a community sports facility. Further
amendments to our Core Strategy (especially the Hemel Hempstead Place
Strategy) may therefore be required.
•
Consideration is also being given as to whether the Outdoor Facilities Study
(October 2006) needs to be updated.
1.29
If available, this information will be reflected in the Pre-Submission Core Strategy that
is put before Full Council. However, none of the outstanding work is considered to be
critical enough to warrant delaying progression to Pre-Submission.
1.30
Since the Draft Core Strategy was written, progress has been taken to improve the
way in which the Council collects developer contributions, through the adoption of a
Supplementary Planning Document (SPD). This SPD is intended to be an interim
measure before a more comprehensive tariff-based system is introduced through
development of a Community Infrastructure Levy. Formal endorsement of the move
towards CIL will enable the Pre-Submission Core Strategy to better reflect future
approaches to collecting infrastructure contributions from new development. Whilst
CIL cannot be put in place until after the Core Strategy has been found sound by a
planning inspector, considerable work is required in the interim to draw up the
charging schedule and put the necessary processes in place to enable it to come into
effect once approved. Key advantages of CIL are:
• It will allow the Council to collect contributions towards infrastructure required as
a result of the cumulative effects of development – the ability to do this via S106
will be greatly reduced.
• It should allow the Council to raise more money towards the cost of infrastructure
than would be case if we rely solely on S106.
• It will allow the Council freedom to decide how to spend the contributions it
receives.
• Once it is in place it will be easier to administer than S106 agreements and
should save Officers time.
1.31
In particular there are new rules which limit the pooling of s106 contributions which
will not apply to CIL. Also the Council will not the able to seek s106 contributions by
way of standard charges on developments (as it currently does through its new
Developer Contributions Supplementary Planning Document) after 1st April 2014 or
from the date it adopts CIL (whichever is sooner). In this regard the SPD provides an
important stop-gap before CIL can be introduced. These legal changes underline the
importance of moving to adopting CIL as soon as possible and before the April 2014
cut off point.
Setting a housing target
1.32
The key outstanding issue that needs to be resolved before progression to PreSubmission is the housing target the Council wishes to set. The level we choose
must still follow a set of national rules, be justified by strong evidence, reflect housing
need, strengthen economic growth and be supported by adequate infrastructure.
Government statements encourage growth – in terms of both recovery from the
economic recession and the provision of housing.
97
1.33
The Government considers that financial incentives (through for example, the New
Homes Bonus) will encourage local authorities to support new housing. The
emphasis is upon accepting ‘sustainable development.’ If the Core Strategy is not
considered to have set a robust and justified housing target, then it will not be found
‘sound’ by the Planning Inspector following examination and work on developing a
new strategy will have to begin again.
1.34
The Draft Core Strategy (November 2010) sought feedback on two different housing
levels. Both cover the period from 2006-2031.
1.35
Option 1 aims to make the best use of land within defined settlements and is
sometimes referred to as ‘urban capacity.’
It equates to a target of 370
dwellings/year or an overall housing programme of about 9,800 new units.
1.36
Option 2 adds to Option 1 through the inclusion of ‘Local Allocations.’ It equates to a
target of 430 dwellings/year or an overall housing programme of about 11,300 (as at
1st April 2009). Option 2 was set at this level because it was considered to strike an
appropriate balance between social, economic and environmental objectives. It
represents a sustainable level of growth for the Borough, taking into account
infrastructure thresholds and the ability of settlements to at least maintain their
existing populations. It provides greater opportunities to provide local affordable
housing.
1.37
The local allocations include in Option 2 are:
Settlement
Hemel Hempstead
Berkhamsted
Tring
Bovingdon
1.38
LA1
LA2
LA3
LA4
LA6
LA7
Site
Marchmont Farm
Old Town
West Hemel Hempstead
Hanburys, Shootersway
Icknield Way, West of Tring
Land north of Chesham Road
Estimated capacity
300
80
up to 900
60
150
up to 60
Feedback was also sought on another local allocation at land at Lock Field, New
Road, Northchurch (LA5), but this site did not form part of Option 2 assumptions.
Consultation feedback
1.39
Of the two options put forward for consideration, the public consultation shows that
opinion is divided, but on balance there was a preference for Option 1 (see Figure 1).
This was primarily due to the opposition of local residents to any housing
development within the Green Belt. Some people considered that an even lower
target should be considered due to concerns over the capacity of local infrastructure
and the impact that new development may have upon the character of towns and
villages. The feedback from organisations, businesses and landowners who
responded to this consultation was less clear cut. Many supported Option 2, or
suggested that the Council should set an even higher target.
1.40
Many landowners and their representatives have put forward the argument that the
Council should choose a target higher than Option 2. Their arguments include
reference to the latest ONS household projections, including taking account of inmigration; the role of housing in supporting wider economic and regeneration
objectives and local housing need; the need to seek a balance between homes and
jobs and concerns that the current housing programme places too much emphasis
98
upon the delivery of lots of small sites (both identified and those expected to come
forward as windfall).
1.41
The overall number of representations received regarding this issue was relatively
low.
Figure 1
Responses to question on housing target in Draft Core Strategy Consultation
Key organisations
Individuals
Landowners
Total
Option 1
15
23
1
39
Option 2
4
13
6
23
Neither
4
36
11
51
No clear answer
1
0
2
3
116
1.42
Landowners and their representatives have suggested additional locations for
housing: these include:
• South Berkhamsted;
• Duckhall Farm (Bovingdon);
• Shendish and Nash Mills (Hemel Hempstead); and
• Dunsley Farm and land adjoining Longbridge Close, also referred to as
Waterside Way (Tring).
1.43
If a housing target above Option 2 were selected, these would be possibilities.
Officers have concluded that none of them offer superior choices to the local
allocations in Option 2, for reasons primarily set out in the published ‘Assessment of
Local Allocations and Strategic Sites’ (October 2010).
1.44
The Citizens Panel survey indicated a preference for the lower housing target, which
is more in line with recent levels of housing development. Panel members appeared
to be more swayed by concerns over the provision (or lack) of infrastructure and the
desire to protect the countryside than other factors. The preference for the lower
housing target should be seen in context.
1.45
Firstly, the majority of respondents agreed with the vision and objectives set out
within the Draft Core Strategy. The vision for Hemel Hempstead says that the town
will meet its own locally generated demand for new homes. Secondly, the 2009
Citizens Panel survey showed a majority in favour of higher place targets for
Berkhamsted, Tring, Kings Langley and Bovingdon. The results of the recent
consultation are however only one factor amongst many that must be taken into
account when determining the Core Strategy and setting the Borough’s housing
target. It will not be enough for the Borough Council to agree lower housing levels
just because of public opinion fro the consultation. A range of other sources of
information and evidence also need to be taken into account. This includes:
a) Information about future growth in population and households.
b) Evidence of housing need (through the Strategic Housing Market
Assessment, housing register etc);
c) Availability of land (as indicated through the Strategic Housing land
Availability Assessment and subsequent update reports);
d) What is happening in adjoining authorities i.e. what levels of new homes and
jobs they are planning to deliver; and
99
e) Other information and technical studies and results of independent
Sustainability Appraisal work.
1.46
1.47
These issues were discussed in the report to the June 2011 Dacorum Partnership
(Local Strategic Partnership) Board and further detailed information is set out in
Appendix 2. Key points to note include:
•
If the Council wishes to give more weight to one source of evidence / information
than another, it must have clear and logical reasons for doing so. Otherwise it
runs the risk of the Core Strategy being found ‘unsound’ by the Planning
Inspector at Examination.
•
Work on the Council’s Infrastructure Delivery Plan shows that neither of the
housing options raise any significant issues that cannot be resolved through
continued close working with infrastructure providers.
•
The Option 1 annual target would meet about 70% of the projected household
demand identified by the latest figures from the latest ONS projections and the
Option 2 target about 80%.
•
The Sustainability Appraisal Report (November 2010) indicates that no significant
sustainability issues are raised by either housing Option 1 or 2. For comparison,
the appraisal also tested a higher level of growth (Option 3), which equated to
about 12,500 dwellings (2006-2031) or 500 dwellings per year. At this level of
growth the appraisal identified that there would be a significant adverse effect
upon the local landscape. This would be much worse if 13,400 dwellings were
provided (in accordance with the latest ONS household projections). It is the view
of Officers that the original conclusions of the Sustainability Report would be
unchanged.
•
Consultation on the Core Strategy has highlighted a strong local desire to protect
the Green Belt within the Borough. It is however important to note that Green
Belt is a planning policy tool aimed at helping manage the level and type of
development in areas of high development pressure. It is not an indicator of
landscape quality. Government guidance requires Green belt boundaries to be
reviewed regularly when preparing a new local plan. The areas of greatest
landscape quality within the Borough fall within the Chilterns Area of Outstanding
Natural Beauty (AONB). Neither Option 1 nor Option 2 involve the development
of any land within the Chilterns AONB. The draft NPPF would expect the Green
Belt boundary to be reviewed only when preparing a new local plan.
•
Delivering the Option 2 housing level lends greater support to local regeneration
and employment objectives and provides a better balance between homes and
jobs. The Consultation Draft Core Strategy had a jobs target of 18,000 (based on
earlier Regional Plan housing targets) and was out of balance. This better
relationship between homes and jobs will need to be reflected in the PreSubmission Core Strategy text.
Government policy towards delivery of housing and how this is expressed in local
plans has been emerging over the past few months. This is taking on an increasingly
pro-development stance, with strong encouragements to local planning authorities to
have robust and sustainable plans in place. Government has indicated that in the
absence of such plans, the default position will be to grant planning permission for
100
developments that comply with the National Planning Policy Framework. On this
basis, it is important that the Core Strategy puts forward a level of growth that is
based on meeting housing needs – which from the available evidence is high – whilst
seeking to protect the high environmental quality of the Borough.
1.48
In the light of the above evidence and information, Members are recommended to
include housing Option 2 in the Pre-Submission Core Strategy. Housing Option 2
equates to approximately 11,385 dwellings and includes Proposals LA1-4, LA6 and
LA7. The Option 2 target of 430 dwellings per year is an indication and because of
Government rules on windfall sites will probably be exceeded slightly. The target is
not however open-ended, a point which should be made in the Core Strategy.
The role of Local Allocations
1.49
Local allocations are relatively modest extensions to some of our towns and large
villages. They will help maintain existing populations, meet local housing needs and
local infrastructure. They are focused upon meeting specific local needs and the
future vision for that particular place. They have been chosen following detailed site
assessments, which looked at issues such as accessibility, the capacity of local
infrastructure, the impact on the Green Belt and compatibility with sustainability
objectives. The choice of sites also reflects the results of previous public
consultation. Several of the proposed sites were considered by the Inspector at the
last Local Plan Inquiry.
1.50
If selected, local allocations would be defined in a separate planning document, the
Site Allocations Development Plan Document (DPD), which forma part of the Local
Development Framework. Matters such as design, layout and potential benefits
worked through with the local community when the Site Allocations DPD is produced.
1.51
Local allocations provide some flexibility in the housing land supply. Whilst Hemel
Hempstead will be the focus for growth due to the regeneration agenda, local
allocations would help ensure that further opportunities for new housing are also
provided elsewhere in the Borough. Their development would be carefully phased,
and until required they would be managed as countryside (i.e. as Green Belt or Rural
Area). Policies in the Core Strategy would control this.
1.52
Our land supply information currently indicates that local allocations are only required
under housing option 2, though even under Option 1 policies CS2 and CS3 (which
relate to the selection and management of development sites) would provide
flexibility.
1.53
A two stage approach will be taken to the definition of local allocations:
(a)
Local Allocations defined within the Core Strategy
1.54
This is the approach set out in the Draft Core Strategy (November 2011). Local
allocations are shown as symbols on the relevant vision diagrams in the place
strategies. This sets a long-term framework for the scale and location of new
development. It provides clarity for both the public and landowners and will also help
with longer term infrastructure planning. It also provides clarity that other land that
has been under pressure for release from the Green Belt will remain in the Green
Belt e.g. those sites listed in paragraph 1.42.
101
1.55
Textual changes are required to the Core Strategy, to reflect changes required as a
result of the last consultation, take account of new information and for general
editorial reasons.
(b)
Detail and phasing of Local Allocations set out in the Site Allocations DPD
1.56
The precise boundary of the Local Allocations will be defined in the Site Allocations
Development Plan Document (DPD), together with their detailed planning
requirements. It is at this stage that necessary changes to the Green Belt boundary
will be made.
1.57
In order to deliver homes in a sustainable manner, the priority is to development
previously developed land and urban sites as far as possible. Some Green Belt land
will be needed as part of the 20 year supply of land in the remainder of the Plan
period, but it is important that this land comes forward only when needed. A
mechanism for phased release is important not only for this reason but to ensure the
appropriate phasing of new infrastructure. Existing text in Policy CS3 referring to the
potential early release of Green Belt allocations can be removed in response to
concerns expressed through the public consultation. In this way, Policy in the Core
Strategy will be adjusted to ensure there is a sound mechanism for the release of the
Local Allocations when they are needed. In addition, the Site Allocations DPD will
contain a more detailed policy that sets out detailed phasing.
1.58
The approach as drafted in the Core Strategy would allow the Council and local
community to add local allocations if they so wished (through a Neighbourhood Plan
and/or Site Allocations document) and it was justified. This approach will ensure the
plan is sufficiently flexible to reflect changes in both local circumstances and national
planning policies. The inclusion of local allocations in the Core Strategy would accord
with Government advice that key decisions should be taken within the Core Strategy.
1.59
If further local allocations were to be required at Hemel Hempstead, evidence points
towards land to the north east of Hemel Hempstead, which is currently within St
Albans district. Any plans for development in this area will not be possible without
the agreement of, and joint working with, St Albans Council.
Next steps
1.60
Changes need to be made to the Consultation Draft Core Strategy (November 2010)
as a result of consultation, new evidence, emerging Government guidance and for
general editorial reasons. Cabinet is asked to approve changes arising from the
Report of Consultation (Volume 6) and other changes currently listed in a separate
schedule (Appendix 3). There will be consequential changes to the current Local
Plan’s Proposals Map.
1.61
The main consultation responses have been discussed with the Council’s
sustainability consultants. They have confirmed verbally that the changes suggested
by Officers to the Core Strategy are not expected to give rise to any significant
sustainability implications. The Sustainability Appraisal Report (November 2010) will
be updated following Cabinet and be available in final form for consideration by Full
Council.
1.62
In order for these changes to be made in the available timescales, it is recommended
that the Planning and Regeneration Portfolio Holder is given delegated authority to
agree the final version of the Pre-Submission Core Strategy that is put before Full
102
Council.
It is also recommended that the Assistant Director for Planning,
Development and Regeneration is given delegated responsibility to make necessary
changes to the Consultation Report and Sustainability Appraisal Report for the same
reasons. Subject to these changes Officers recommend that the Core Strategy be
approved and published.
1.63
All three Proposed Submission documents will be available for consideration at Full
Council. Drafts of the documents are available in the Group Rooms.
1.64
Provided it is endorsed by Full Council, the Core Strategy will be published for
comment for 6 weeks from mid October. Arrangements for this representations stage
are governed by the Planning Inspectorate (PINS) and national regulations.
1.65
PINS prescribes how we must word the form that accompanies the Proposed
Submission documents and in order to be considered, representations must relate to
issues of soundness. Late comments cannot be accepted at Pre-Submission stage.
Although paper forms will be available, use of the Council’s online consultation portal
will be encouraged.
1.66
Due to the formal nature of the Proposed Submission stage it is not proposed to hold
any public consultation events, such as drop-in sessions or staffed exhibitions. This
accords with consultation arrangements set out in the Council’s adopted Statement of
Community Involvement (SCI). Further advice and information regarding both
strategy and process will of course be provided to individuals and organisations as
appropriate.
1.67
It is recommended that Cabinet agrees the next stages in the process that will allow
us to proceed effectively towards Examination. The first step is to draw up a Report
of Representations. This will summarise the comments raised with regard to the PreSubmission Core Strategy. If significant new objections are raised, these will be
reported to Cabinet and Full Council. If no significant new issues are raised, Cabinet
/ Full Council are asked to delegate authority to the Assistant Director (Planning,
Development and Regeneration) to submit the Core Strategy for examination and, in
consultation with the Planning and Regeneration Portfolio Holder, agree minor
changes to the Core Strategy to resolve objections and improve clarity. At this stage,
the prospect of significant new issues should be low. It is normal to allow this degree
of flexibility to enable smooth running of the examination process.
1.68
If the Inspector considers that no immediate soundness issues arise he/she will
proceed to Examination. Following receipt of the Inspector’s Report Cabinet and Full
Council will consider its findings. It is hoped that the final Core Strategy can be
adopted by the Council in late 2012 or early 2013.
103
104
Appendix 1
Consultation Draft Core Strategy – summary of consultation responses
Note:
The following is an extract from chapter 3 of draft Volume 6 of the Report of
Consultation.
General Public Consultation
3.1
617 organisations, individuals and organisations submitted comments to the
questions asked. 2,668 comments were made (i.e. total number of answers to the
questions). Charts A and B show how the responses were distributed across the questions.
Questions relating to the Borough Vision, housing target and Berkhamsted generated more
than 100 responses each. However, some questions generated a relatively low response:
questions relating to Tring, the large villages and the delivery chapters attracted 35 or fewer
responses each.
DRAFT
3.2
The results of the general public consultation have been set out in a consistent way
in Annex A, Appendix 1. Under each question, the total number of comments was recorded,
together with the numbers answering ‘yes’ and answering ‘no’. In the case of alternative
housing targets, preferences were recorded. The responses were summarised, and the reply
and principal action [to be] taken by the Council listed. This reply was provided in a
summarised form, rather than in a ‘line by line’ analysis of lots very detailed comments.
3.3
A quantitative analysis of the answers is given in Table 1, split into themes and
places. A negative response usually entailed an objection on a particular point or points,
and not to the whole section. In addition, support was sometimes given with a relatively
minor proviso (ref Annex A, Appendix 1).
Themes
3.4
The majority of organisations who commented supported the vision, aims and
themes. Landowners gave similar support, except on the level of housing and where there
were impacts on specific land interests. It was the number of individuals commenting that
normally altered the balance between support and opposition for a particular section of the
strategy.
3.5
The majority who commented supported the sections, Supporting the Economy and
Protecting the Environment; the strategic objectives; and Part C, Implementation and
Delivery: chapters on access and design in the Sustainable Development Strategy were also
well supported (Questions 2, 4-8, 12-14 and 31-33).
3.6
This meant there were more objections (than general support) for the Borough
Vision; the chapter, Promoting Sustainable Development; and the section, Providing Homes
and Community Services (Questions 1, 3, and 9-11).
3.7
The Borough Vision only received more ‘no’s from individuals. However they did not
normally oppose the vision itself, rather they opposed matters of detail which appeared
elsewhere in the draft Core Strategy. Some questioned the delivery of the vision.
105
Landowners raising objections felt more housing was required to meet locally generated
demands.
DRAFT
106
Chart A
DRAFT
Chart B
107
3.8
The objections to Promoting Sustainable Development concentrated on housing.
Most individuals objected to proposed growth in the market towns, particularly Berkhamsted.
The draft Core Strategy was considered to be too skewed towards housing to be
sustainable. The biggest concern reiterated by landowners was that there would be
insufficient housing to meet natural population growth, accommodate in-migration and/or
support business growth. A handful of individuals also felt there would be insufficient
housing.
3.9
The above comments were repeated in response to questions on the housing target
and provision of new homes. There was clearly a range of opinion from those supporting the
housing target, Option 1 or less, to those supporting Option 2 or higher.
•
•
•
•
Key organisations favoured Option 1 because it would protect the Green Belt
and rural area.
More individuals favoured neither option, and often felt Option 1 was too
high. They cited reasons such as overdevelopment, overcrowding, loss of
character, loss of countryside/Green Belt/greenfield land and insufficient or
inadequate infrastructure.
28% of Individuals supported Option 2 for two key reasons. More affordable
housing would be provided. The option would offer a suitable balance between
building homes and protecting the environment (i.e. building homes to meet
needs, with only a modest incursion into the Green Belt).
The majority of landowners opted for neither option, and felt that Option 2
was too low. There was insufficient evidence to support either Option 1 or
Option 2: both would deliver less housing than the nil-net migration figure would
suggest. This would be detrimental to the economic well being of the Borough.
Such low targets would reduce the provision of affordable housing. There would
be a poor relationship between the level of housing proposed and anticipated
jobs growth.
DRAFT
On the provision of new homes generally, organisations questioned the uncertainty of
population projections on which housing targets were based and the different affordable
housing thresholds between Hemel Hempstead and Berkhamsted. Some individuals
opposed the provision of pitches for Gypsies and travellers. Concerns were also raised
about infrastructure provision and incursion into the Green Belt. On the other hand some
individuals felt that more affordable housing was needed. Landowners disagreed because
the housing target should be increased in line with projections of natural growth. Almost all
landowners commented about affordable housing levels. The consensus was that a flexible
approach must be taken to ensure that development would not become unviable. There was
further disagreement about the inclusion of windfall sites in housing figures. Landowners
also questioned whether the phasing of allocated sites was desirable or necessary.
4.10 Only individuals disagreed overall with the chapter on Meeting Community Needs.
They disagreed for many different reasons, no one reason being given more than once.
108
Table 1: Analysis of Yes/No Comments
Question
Number
YES
Org
Ind
Land
Total
NO
Org
Ind
Land
Total
Borough Vision
Strategic Objectives
1
2
14
16
26
28
9
8
49
52
9
8
45
29
9
8
63
45
Promoting Sustainable Development
Enabling Convenient Access
Securing Quality Design
3
4
5
10
9
42
21
19
20
7
6
5
38
34
67
6
2
4
27
18
8
13
1
0
46
21
12
Strengthening Economic Prosperity
Providing for Offices, etc
Supporting Retailing and Commerce
6
7
8
9
9
5
15
13
14
6
3
2
30
25
21
1
2
5
4
6
5
2
5
3
7
13
13
10
11
15
4
1
9
8
23
23
36
11
10
1
6
11
4
4
39
33
48
24
22
11
8
25
21
15
2
51
31
Enhancing the Natural Environment
Conserving the Historic Environment
Using Resources Efficiently
12
13
14
8
10
9
21
26
14
4
4
1
33
40
24
3
1
8
13
2
8
1
0
6
17
3
22
Delivery
Infrastructure
Monitoring
31
32
33
6
6
3
2
8
6
0
1
1
8
15
10
2
4
1
6
9
3
0
2
0
8
13
4
Subject
Themes
Housing Target : Option 1 – 370 units p.a.
Option 2 - 430 units p.a.
Neither
Providing Homes
Meeting Community Needs
9
109
Subject
Question
Number
YES
Org
Ind
Land
Total
NO
Org
Ind
Land
Total
Common Local Objectives
15
8
13
4
25
4
23
3
30
Hemel Hempstead – Local Allocations
Hemel Hempstead – Strategy
16
17
1
8
11
9
3
6
14
23
9
7
28
11
5
10
42
28
Berkhamsted – Strategic Site (SS1)
Berkhamsted – Local Allocation (Hanburys)
Berkhamsted – British Film Institute
Berkhamsted – Local Allocation (Northchurch)
Berkhamsted – Strategy
18
19
20
21
22
1
1
2
0
4
6
12
65
22
11
1
0
1
1
2
8
13
68
23
17
3
3
0
8
4
267
209
109
293
223
1
2
0
1
1
271
214
109
302
228
Tring – Local Allocation
Tring – Strategy
23
24
0
3
13
8
1
0
14
11
7
7
10
12
8
3
25
22
Kings Langley – Place Strategy
25
5
10
0
15
1
3
1
5
Bovingdon – Local Allocation
Bovingdon – Place Strategy
26
27
1
4
5
7
1
1
7
12
2
0
13
9
5
3
20
12
Markyate – Strategic Site
Markyate – Place Strategy
28
29
1
1
2
3
0
0
3
4
0
2
6
3
1
2
7
7
Countryside - Place Strategy
30
6
11
0
17
4
14
0
18
Places
110
3.11
Other issues raised included the following:
•
•
•
•
•
•
•
•
Individuals would like to see reference to the Green Belt in the strategic
objectives.
Landowners questioned the relationship between housing and
employment objectives, suggesting that they do not support each other.
The jobs and office floorspace targets were considered to be too high,
not clearly justified and out of balance with housing targets.
St Albans City & District Council was concerned at the amount of new
retail floorspace identified in Policy CS16 for Hemel Hempstead,
because it could have a negative impact on St Albans City Centre and
Harpenden Town Centre. They requested an impact assessment of the
proposed growth on the centres in St Albans District.
Adult Care Services (Hertfordshire County Council) was concerned that
insufficient provision is made in the plan for various services and
facilities.
Individuals and key organisations were concerned that wind turbines
can be considered appropriate in the Chilterns Area of Outstanding
Natural Beauty.
The Core Strategy lacked policies on the water cycle/water
infrastructure.
Hertfordshire County Council (Environment) said that issues identified
with capacity at Maple Lodge Waste Water Treatment Works must be
resolved.
Places
3.12 The majority who commented opposed development locations and the place
strategies, except Kings Langley and Bovingdon. The common local objectives were
opposed, although there were relatively few comments on the objectives themselves:
most individuals repeated concerns about housing growth and the adequacy of
infrastructure. Opposition to place strategies invariably related to a potential
development option or local allocation, but there were other varied, specific points as
well.
3.13 The three local allocations at Hemel Hempstead were opposed, partly for
their impact on the Green Belt and relationship with existing settlements, Piccotts
End, the Old Town, Potten End and Bourne End. Other reasons why LA1
(Marchmont Farm) was opposed covered traffic generation, potential crime, loss of
view and lack of transport connections. The proposed allocation, LA2, attracted
concerns about the effect on the quaint and tranquil feel of the Old Town, removal of
a green gateway, loss of amenity space, increased traffic and the impact on the
historic nature of the High Street. Development at West Hemel Hempstead (LA3)
was said to affect the Chilterns Area of Outstanding Natural Beauty and local
character: there were also concerns about traffic generation, partly due to its location
away from major local employment site, and the ambitious nature of the scheme.
Reasons for opposing the strategy were varied. A key issue however was the
achievement of cross-boundary co-operation with St Albans Council to deliver the
East Hemel Hempstead vision.
3.14 Questions about Berkhamsted generated the highest response, a large part
of which was co-ordinated by a ‘Save our Berkhamsted’ campaign and stemmed
111
from specific concerns about the proposal for land at Shootersway/Egerton-Rothesay
School (Strategic Site SS1). Reasons given for objecting to this proposal included the
number of homes planned for the site, the effect on the character of the area, the
transport implications in terms of safety and added car use/traffic congestion, the
location of the development in relation to services, and infrastructure and utilities
being insufficient to support the development. The local allocation at Hanburys, off
Shootersway (LA4), which would involve Green Belt land, was similarly opposed. Key
organisations supported investment in and expansion of the British Film Institute next
to Hanburys. Many individuals were also in support, provided there was no enabling
housing development. The majority of individuals however were concerned about the
effect on the Green Belt, and did not want the Council to offer any financial support to
the British Film Institute. Local allocation LA5 (New Road, Northchurch) attracted the
highest level of adverse comment. Organisations and most individuals were
opposed. Most opposition was in respect of the completion of a link road, which
development could help fund, rather than the local allocation. The link road proposal
was considered to be unsafe, costly and environmentally disruptive: it would shift
problems from one area to another potentially creating more traffic in the process.
New housing should only be developed if needed in its own right. There were also
concerns about the impact on the Chilterns Area of Outstanding Beauty and the
adequacy of local infrastructure. Opposition to the Place Strategy was directly related
to opposition to the local allocations. Organisations commented that the strategy did
not contain sufficient emphasis on retaining the town’s character. They also thought
that greater priority should be given to raising the quality of existing facilities and
infrastructure.
3.15 The local allocation west of Tring (LA6) was supported by the majority of
individuals, but not others because of the perceived impact on the Chilterns Area of
Outstanding Natural Beauty and the Green Belt. Landowners disagreed because
they thought LA6 should comprise more homes or because they considered other
sites to be more suitable for development. The site was considered by some to be
isolated. The Tring Place Strategy was opposed largely because of the concern over
the level and location of new development. Some organisations, such as Tring
Sports Forum, supported plans for additional playing fields at Tring, but individuals
opposed this. They said that Tring had large areas of underutilised sporting facilities
and that Green Belt should not be used for this purpose.
3.16 The location allocation north of Chesham Road, Bovingdon (LA7) was
opposed by individuals because they felt the village could not handle any more
development. Landowners thought that an alternative local allocation would be
better. However Bovingdon Parish Council concluded that LA7 was appropriate to
meet long term needs in the village.
3.17 Few responses were received about Markyate. However a key concern was
that some felt Hicks Road (Strategic Site 2) did not need any retail or industrial uses
and that the focus of planning should be the High Street. There would be impacts on
parking, drainage, sewerage and school capacity, and the housing numbers were too
high. The Highways Agency expressed reservations about the potential traffic
implications arising from development in Markyate.
3.18 On further examination, the countryside strategy itself was largely supported.
The concern related to any of the currently designated Green Belt or countryside
being used for housing. The objective of protecting the countryside was seen to be
contradicted by proposals to release Green Belt land for housing.
112
Late Comments
3.19 Some comments were received late, i.e. between January and March 2011.
They were assessed to see if there were any new issues which merited a change to
the Core Strategy. The comments were excluded from the schedule which
summarises the general public consultation (at Annex A, Appendix 1).
3.20
The comments were submitted by:
5.
Residents opposing new housing next to the Old Town, Hemel Hempstead
(179 comments)
Their full argument was more relevant to a larger area of land (10 hectares)
that had been included in the earlier consultation about growth at Hemel
Hempstead (reported in Volume 2). However, the smaller area (2 hectares
proposed in the Consultation Draft) was also of concern. This land slopes, is
open, though little used, and is next to a conservation area.
6.
Hertfordshire Local Access Forum
The Forum provided a standard response, the basic principles of which are
accepted and already incorporated within the framework provided by the Core
Strategy.
7.
English Heritage
English Heritage supported the vision, strategic objectives and approach to
design, meeting community needs, enhancing the natural environment and
conserving the historic environment. It requested archaeological assessments
on potential development sites and expressed concern about the potential
impact of development adjoining the Old Town. It also provided other,
detailed comments. Some led to changes in the Core Strategy (see Table 1).
Table 1: Core Strategy Changes – English Heritage Comments
Ref.
Comment
Change
CS10
Landmark buildings may be tall,
but equally may be distinctive
due to design and location.
Para 18.1
Delete reference to ‘scheduled
archaeological sites’ because
they are ancient monuments
Berkhamsted Amend Vision to refer to the
castle being protected and
enjoyed.
Berkhamsted Seek a supportive link between
The Rex cinema and the British
Film Institute: this would justify
expansion of BFI within its own
site.
113
Define ‘landmark building’ in
a footnote.
Amend
to
‘areas
of
archaeological significance’.
Amend vision and strategy
accordingly.
Amend strategy to refer to
links being fostered between
BFI and the town
114
Appendix 2
Issues to consider when setting a housing target
a) Information about future growth in population and households
The critical benchmark that will be used by a Planning Inspector to assess the
Council’s housing target is the household projection information from central
Government (CLG). This is often referred to as the ONS projection. The most up-todate ONS figures relate to 2008. The 2008 ONS projections were published in May
2010, so not available to inform earlier drafts of the Core Strategy. Figures from the
2004 CLG household projections and Hertfordshire County Council’s own internal
work were used instead. The results of these earlier projections are set out in the
‘Population: Background Note for the Core Strategy’ (April 2009). This document is
currently being revised. We must also be aware of the latest projections from the
East of England Forecasting Model (EEFM) which captures the interdependence of
the economy, economic change and housing at a local level. Projections are also
available using the Chelmer model, but these are considered less robust: these
model runs are based on out of date assumptions and have been subject to criticism
by experts. Results from these different household projections are shown in Figure
1.
Figure 1 - Results of Different Household Projections (2006-2031)
CLG
EEFM 2010
Chelmer std
Chelmer znm
2006
58,112
58,881
58,831
58,799
2009
59,743
59,673
59,993
60,313
2011
60,966
60,752
60,768
61,322
2016
63,413
63,837
62,603
63,826
Notes: ONS projections are those published by CLG.
HCC do not produce dwelling projections.
115
2021
66,064
66,856
64,439
66,329
2026
69,122
69,728
65,611
68,262
2031 2006-2031
13,457
71,569
13,453
72,334
7,953
66,784
11,395
70,194
Newer projections from the Chelmer model were received after this report was first
drafted. These projections suggest the following increase in households (20062031):
• Standard (baseline) projection:
11,828
• Zero net migration projection:
14,215.
b) Evidence of housing need
There are over 5,600 people currently on the Council’s housing waiting list. Whilst
this may include an element of ‘double counting’ caused by people expressing an
interest in different types of homes, it indicates a very high level of local housing
need. Adjoining authorities also have high levels of need. It is estimated that Option
1 would provide about 2,700 new affordable homes between 2006-2031. This figure
would rise to about 3,300 under Option 2.
c) Availability of land
The Council’s Strategic Housing Land Availability Assessment, and recent updates
provided through Housing Land Availability papers, give a picture of potential housing
sites within the Borough. This technical work indicates that there are sites within the
boundaries of existing towns and large villages to accommodate approximately 9,670
new homes (2006-2031). This figure is constrained by both policy assumptions about
density, parking provision etc and local land supply. About 1,200 of these homes
have already been built (as at 1st April 2009). The Council would not be able to justify
setting a housing target that was lower than what it can reasonably expect to be built
over the plan period. The technical work also shows that there is land available to
develop an even higher number of homes than suggested in Option 2, should the
Council decide to release further greenfield sites or reallocate more employment land
to housing.
d) What is happening in adjoining authorities
116
In the past an under-provision of new homes in one part of the County was
compensated for by higher rates of development elsewhere within Hertfordshire.
Whilst not all authorities have agreed their housing targets, it is becoming clear that
this redistribution of dwelling provision is no longer taking place and that all of the
authorities that adjoin Dacorum are likely to provide fewer new homes than they are
predicted to need in the future. As Figure 3 indicates, Stevenage Borough Council’s
Core Strategy proposed a significant level of housing growth, which would have
provided an additional pool of new homes within Hertfordshire. This Core Strategy
has however recently been found ‘unsound’ by a Planning Inspector following the
examination in public. This decision was largely due to the fact that the majority of
housing provision assumed within Stevenage’s plan would need to be
accommodated within the adjoining district, who no longer supported the proposals.
The planned level of new homes will therefore not be provided and Stevenage will
have to begin work on an amended Core Strategy with a considerably lower housing
figure. Aylesbury Vale’s Core Strategy had proposed a similarly high level of housing
provision, but the Council has withdrawn its plans following recent announcements
regarding the removal of regional housing targets. It is important to note that none of
the other authorities listed in the table have yet been through the formal examination
process.
Figure 3
Planned levels of housing provision compared to latest Government
household projections
Local Authority
Dacorum Borough Council
Three Rivers
St Albans
Watford
Chiltern
Stevenage
Aylesbury Vale
Luton / Central Bedfordshire
Level of under/over-provision of new homes
-4,413 (Option 1)
-2,913 (Option 2)
-8,490
-10,566
-4,325
-4,357
+13,694 (found unsound)
Not known
+6,571
Notes:
• Information is based on 2008 CLG/ONS household projections.
• Figures relate to the 25 year period between 2008 and 2033, broken down to provide
an average annual figure
• To translate household growth figures into actual dwelling requirements an additional
1.96% has been added to reflect recent vacancy rates and allow for natural
movement in the housing market.
• Figures relate to housing targets contained in most recent published version of each
authority’s Core Strategy.
(c) Other information and evidence
The following table shows the level of new funding that is estimated would be
released by the two housing options. This money could be used to support
infrastructure and community facilities, or to increase the amount of affordable
housing provided within the Borough.
Option 1
Money for infrastructure:
117
Option 2
(a) Developer contributions
£53.8 million
£66.2million
(b) New Homes Bonus
£7.0 million
£8.6 million
Note: Estimated figures based on information available in October 2010.
118
Annex 3
Schedule of Proposed Changes to Core Strategy not arising as a result of public consultation.
Notes:
• This schedule will need to be updated to reflect decisions on the Council’s housing target and the approach to Local
Allocations
• Changes arising as a direct result of consultation responses are included in Volume 6 of the Draft Report of
Consultation.
REFERENCE
CHANGE
GENERAL AMENDMENTS
• Delete “how we have got to this point” text.
• Delete questions
• Update all document references as appropriate
• Update references to groups / organisations where these have changed
• Update text referring to Draft Core Strategy with references to Pre-Submission document.
CONTENTS
1.
Introduction to the
Update introduction
Consultation
2.
Summary of the Strategy
Update summary of
strategy.
DRAFT
Key diagram
119
Replace ‘Flaunden’
label with ‘Flamstead’
REASON
For general updating and
clarity and to reflect move
from Draft Core Strategy
to Pre-Submission stage.
To reflect move to presubmission stage.
To reflect changes made
to theme chapters
particularly regarding the
housing target, jobs target
and references to
employment floorspace
and developer
contributions..
To correct mapping error.
PART A - CONTEXT
3.
Introduction
Figure 1
Update diagram
To reflect imminent
introduction of
Neighbourhood Plan tier.
Figure 2
Update
Para 3.3
Reference to East
Hemel Hempstead
Area Action Plan
boundary.
Para 3.4
Refer to neighbourhood
plans.
To reflect progression to
pre-submission stage.
Amend if decision on
location of boundary in St
Albans area has been
taken by St Albans
Council.
The Government has
stated that neighbourhood
plans will become part of
the planning system.
If more recent data is
available.
To reflect changes to
Hemel Hempstead Place
Strategy.
DRAFT
4.
Borough Portrait
5.
Challenges
Challenge 3
6.
7.
8.
Borough Vision
Strategic Objectives
Other Plans
Figure 7
Figure 7
120
Update factual
information
Delete reference to
Performing Arts Venue
and refer more
generally to improved
social and leisure
facilities.
Add reference to the
RSS and include
footnote to explain its
future status.
For clarity in the light of
recent High Court
judgements.
Para 8.2
Add reference to other
relevant docs including:
• Dacorum
Delivery
Programme
• Local Enterprise
Partnerships
• Local
Investment Plan
Add reference to the
fact that the SCS is
under review but core
objectives will remain.
DRAFT
PART B – THE STRATEGY
The Sustainable
9.
Promoting sustainable
Development
development
Strategy
The distribution of
development
The location and management
of development
The Towns and Large Villages
The Countryside
For completeness.
For clarity.
Para 9.5
Update reference to
Sustainability Advice
Note
To reflect latest available
information.
Policies CS2 and
CS3 and paras 9.13
– 9.16
Update / add to text
explaining the
approach towards the
selection and
management of
housing sites and the
treatment of local
allocations.
If required for clarity and to
reflect Council decisions
on housing target and
local allocations.
Para 9.34
Simplify definition of the
term ‘affordable’ by
deleting reference to
To ensure consistency
regarding terminology
throughout the plan. The
121
10.
Enabling convenient access
between homes, jobs and
facilities
Policy CS8
11.
Securing quality design
Monitoring indicator
for Policies CS10-12
different housing
categories.
Delete word ‘maximum’
in clause (f) with regard
to car parking
standards.
Amend monitoring
indicators to refer to
sustainability statement
assessments rather
than Buildings for Life
Assessments.
Define ‘landmark
building’ in a footnote.
DRAFT
Policy CS10
Delete “identified from
items (f) and (g)
Para 11.2 and
Figures 11 and 13
Minor changes
Paras 11.12-11.14
Minor changes
Policy CS11
122
Amend criteria to refer
housing section will
include the full definition.
To reflect changes to
PPG13 and ensure policy
remains accurate if the
existing approach is
amended through the
Development
Management DPD or
other guidance.
To update/amend
references to new
guidance and
methodologies.
To respond to advice from
English Heritage landmark buildings are not
necessarily defined by
their height, but by their
distinctiveness due to
design and location.
In the light of advice from
Development
Management
Re-presentation following
discussion with
Development
Management
For clarity and to futureproof the document
Re-presentation and
Policy CS12
Policy CS13
Monitoring indicator
for Policy CS13
Strengthening
Economic Prosperity
12.
to positive streetscapes
and links, co-ordination
of streetscape design
and avoidance of large
areas dominated by car
parking
Minor amendments to
criteria
Minor amendments.
Amend monitoring
indicators to refer to
sustainability statement
assessments rather
than Buildings for Life
Assessments.
Replace paragraph with
new information.
DRAFT
Creating jobs and full
employment
Para 12.2
Para 12.3
123
Insert new paragraph to
explain that the
forecast growth in jobs
numbers is an
estimate.
additional criterion
following discussion with
Development
Management
For clarity following
discussion with
Development
Management
For clarity and accuracy
To update/amend
references to new
guidance and
methodologies.
To reflect new advice from
Roger Tym & Partners in
the Dacorum Employment
Land Update 2011
To reflect advice from
Roger Tym & Partners in
the Dacorum Employment
Land Update 2011. The
Council cannot physically
create jobs through
planning policy, so it is
more appropriate for to
refer to a jobs growth
estimate rather than a true
target. This figure will
then be accompanied by
policies that should enable
Para 12.4
Remove ‘relatively high’
in reference to jobs
forecast.
Para 12.6
Replace reference to
the ‘Hemel 2020 vision’
with reference to the
‘Council’s regeneration
plans’.
DRAFT
Para 12.7
Remove ‘high jobs
target and...’ from 3rd
sentence.
Update technical
figures.
A low carbon economy
The Maylands Business Park
Supporting tourism
Economic Development
Policy CS14
124
Replace jobs growth
target of 18,000 from
2006-2031 with jobs
growth estimate of
10,000. Include
statement that sufficient
land will be allocated to
accommodate this.
jobs growth to occur at the
planned level.
To reflect the significant
decrease in the jobs
forecast in the Dacorum
Employment Land Update
from the previous forecast
of 18,000 jobs.
In anticipation of the
Council’s plans to merge
the Hemel 2020 projects
into the broader Dacorum
Development Programme
(DDP). This is the new
document that outlines the
Council’s regeneration
plans.
This reflects the fact that
the updated jobs target is
lower than the previous
target.
To reflect latest study
information.
To reflect advice in the
Dacorum Employment
Land Update 2011 (Roger
Tym & Partners).
13.
Providing for offices, industry,
storage and distribution
Offices
Monitoring of Policy
CS14
Remove 2nd indicator
Delivery of approach
to Strengthening
Economic Prosperity
Amend last delivery
mechanism to make
more general.
Para 13.5
Change office jobs
forecast from 12,400 to
7,000 and update
source accordingly.
Remove reference to
amount of office
floorspace that will be
provided in the
Maylands Gateway.
Change wording to
state that Masterplan
will identify the most
appropriate location for
offices in Hemel
Hempstead Town
Centre, rather than
identify an office
quarter.
Change wording in last
sentence to remove
reference to office
quarter.
Remove last sentence.
Para 13.7
DRAFT
Para 13.8
Para 13.8
Para 13.9
Industry, storage and
distribution
Para 13.3
125
Revise job and
floorspace forecast
To reflect likely
inaccuracies of information
and its limited usefulness.
To allow for flexibility with
use of LDOs.
To reflect advice in the
Dacorum Employment
Land Update 2011 (Roger
Tym & Partners).
To allow for flexibility in
the East Hemel
Hempstead AAP.
Allow for flexibility. The
Town Centre Masterplan
will establish whether a
single location or multiple
locations for offices will be
identified.
The principle is already
covered by Policy CS15.
To reflect advice in the
Dacorum Employment
figures.
Offices, Research, Industry,
Storage and Distribution
Policy CS 15
Delivery
mechanisms
14.
Providing Homes
and Community
Services
15.
Revise floorspace
targets for additional
office and industry,
storage and distribution
floorspace.
Remove reference to
Hertfordshire Forward
and Hertfordshire
Works.
Replace Hemel 2020
Vision with reference to
Dacorum Development
Programme (DDP).
DRAFT
Supporting retailing and
commerce
The retail hierarchy
Shopping areas
Out of centre retail
development
Providing homes
Policy CS16
Review retail capacity
figures in the light of
new information.
General
Update references to
housing options and
make other
126
Land Update 2011 (Roger
Tym & Partners).
To reflect advice in the
Dacorum Employment
Land Update 2011 (Roger
Tym & Partners).
These organisations have
or will shortly be
subsumed by the Local
Enterprise Partnership.
In anticipation of the
Council’s plans to
supersede the Hemel
2020 vision through the
Dacorum Development
Programme.
The results of the latest
retail study update are due
in August 2011.
Depending on the
outcome of this work the
figures in the table within
Policy CS16 may need to
be amended. The policy
thrust will not be
amended.
To reflect decisions on the
housing target. These
changes will need to be
consequential changes.
Housing programme
General
Update to refer to the
latest and forthcoming
technical work.
Paras 15.10-15.23
Amend text in the light
of decisions on the
housing target; the
approach to local
allocations and latest
household growth
projections. The text
should also clarify that
the housing target
should not be
interpreted as an open
ended figure.
Update text.
DRAFT
Policy CS17
Table 7
Housing mix
Paras. 15.24-15.26,
Table 9 and Policy
CS18.
127
Update housing
programme and ensure
the base date of
information is clearly
stated. .
Update reference to the
SHMA in the light of the
future work on a local
needs housing survey
and rolling forward the
applied throughout the
housing chapter and in
other relevant sections of
the plan.
To reflect progress on the
evidence base.
To reflect decisions
regarding the housing
target and any local
allocations and latest
household projection
information.
To reflect decisions
regarding the housing
target and any local
allocations.
For clarity and to reflect
decisions regarding
housing targets and any
decisions regarding
capacity of Strategic Sites.
Following discussion with
Group Manager Strategic
Housing and the content
of the forthcoming
Affordable Housing
New paragraph
Affordable housing
Policy CS19 and
supporting text
Council’s Housing
Strategy and deletion of
Table 9 relating to
projected size mix of
new homes.
Insert new paragraph to
refer explicitly to the
accommodation needs
of the elderly.
Amend policy to update
reference to the SHMA
in the light of the future
work on a local housing
needs survey and in
rolling forward the
Council’s Housing
Strategy, to reflect
changes in the
definition of affordable
housing at national
level and to reorder the
priority of criteria (a)(d). The policy
approach will remain
unchanged.
Amend policy to refer to
selected small villages
and to clarify the policy
relates to affordable
homes.
DRAFT
Policy CS20
16.
Travelling communities
Meeting community needs
128
Supplementary Planning
Document and Local
Housing Needs Survey.
To ensure the plan
acknowledges the needs
of the ageing population
and reflects the latest
advice from Herts County
Council.
To respond to advice from
the Group Manager
Strategic Housing and
Development
Management. These
changes are required to
reflect amendments to
PPS3 relating to
affordable rent category,
to improve presentation
and clarity of policies, to
strengthen requirements,
to cross reference to the
Planning Obligations SPD
and to simplify reference
to social and affordable
rent.
Delivering community services
and facilities
Delivering leisure and cultural
facilities
Looking after the
Environment
17.
Para 16.23
Delete specific
reference to a
performing arts venue.
Para 17. 5 and 17.6
Editing and reference
to commons.
Additional information
to better reflect the
scarp and dip slope
topography in
Dacorum.
Editing and reference
to key
recommendations in
‘Dacorum’s Green
Infrastructure Plan’.
Include additional
information and present
the high level green
infrastructure network
as a diagram like Map
2.
Reword to reflect the
recommendations of
‘Dacorum’s Green
Infrastructure Plan.
Enhancing the natural
environment
Protecting and Improving the
Landscape
Map 2
DRAFT
Green Infrastructure
Paras 17.9 – 17.13
Map 3
Policy CS26
Biodiversity and Geological
Paras 17.14 and
129
Editing and to
To reflect changes to the
Hemel Hempstead Place
Strategy.
The editing in this chapter
also helps to link
landscape, green
infrastructure and
biodiversity together.
For clarity and to respond
to changes resulting from
‘Dacorum’s Green
Infrastructure Plan’. See
below.
To take account of new
evidence - Dacorum’s
Green Infrastructure Plan
– and ensure consistency
of approach.
For clarity and to ensure
18.
Conservation
17.15
recognise that
geological sites may be
added to the list.
Conserving the historic
environment
Para 1.8.1
Delete reference to
‘scheduled
archaeological sites’
and amend to ‘areas of
archaeological
significance.
Include reference to
landscape.
Express the social and
environmental benefits
and the significance of
historic heritage more
positively.
DRAFT
Paras 18.2-18.5
Emphasise the
importance of high
quality building design
and maintenance.
Include reference to the
heritage at risk review
and how the Council
takes positive action to
protect vulnerable
heritage assets.
Policy CS7
130
Emphasise the need to
conserve heritage
consistency of approach.
Advice from the Herts
Biological Records Centre
indicates this is currently
under investigation.
To respond to advice from
English Heritage and the
Council’s Conservation
Officer.
To respond to advise from
the Council’s Conservation
Officer.
19.
Using resources efficiently
Para 19.11
Para 19.34
assets and the positive
contribution of new
development.
Add additional text to
explain the broad
principles behind the
energy hierarchy in
Figure 16.
Insert additional
wording to reflect how
waste water and
sewerage network
upgrades will be
progressed with
adjoining authorities
and stakeholders.
Amend and update
requirements within
Table relating to the
level of carbon
emission reductions in
different areas of the
borough and for
different scales of
development.
DRAFT
Renewable energy
Table 11
131
For clarity.
To give the most up-todate position regarding
discussions with the Water
Cycle Study Steering
Group regarding crossboundary working.
The approach set out in
Table 11 in the Draft Core
Strategy has been tested
and refined following
development of the
Council’s online carbon
monitoring system (CPlan). The revised
requirements follow the
same principles as set out
in the original table but
have been amended for
the following reasons:
• To refer to the
2010 rather than
2006 Buildings
Regulations as the
benchmark figure;
•
DRAFT
Sustainable design and
construction
Policy CS28
132
Delete first two
paragraphs of policy
and replace with
requirement that new
development will be
expected to (a) deliver
carbon emission
reductions as set out in
table 11; and (b)
maximise the energy
efficiency performance
Potential changes
to Code for
Sustainable
Homes;
• To reflect current
Local Plan
definitions relating
to what constitutes
large and small
scale development;
• To make
requirements for
small scale
development less
onerous and to
focus efforts to
achieve carbon
emission
reductions on
larger scale
developments to
reflect viability
considerations.
To simplify and clarify the
policy and reflect changes
made to Table 11.
Policy CS29
of the building fabric in
accordance with the
energy hierarchy set
out in Figure 16.
Amend criteria (g) to
delete reference to the
replacement of trees
lost through
development.
Insert reference to role
of Sustainability
Statements
Delete reference to
Lifetime Homes
DRAFT
Policy CS30
Place Strategies
20.
Sustainable resource
management
Introduction
Policy CS32
End of Section
133
Criteria duplicates
requirements of Policy
CS12.
For clarity and to link with
online Sustainability
Statement requirements.
The principle of building
adaptations is already
included in the policy and
Lifetime Homes are part of
the sustainability
statements, although the
specific standards may
change over time.
To add greater flexibility to
the policy and reflect
emerging national policy
on biodiversity off-setting.
Add reference to the
off-set funding being
used for broader
habitat improvements
in criteria (c) and to
water improvements.
Revise title of policy to
refer to its broader
scope.
Add word ‘Quality’ to
end of policy.
For clarity regarding its
content.
Insert new text to refer
to neighbourhood plans
To ensure that these types
of plan, which may be
21.
Hemel Hempstead
Context
Visions
Local Objectives
and village/parish
plans.
Update.
Update and make
stronger reference to
open space and public
transport. Take
account of further work
on the town centre and
Maylands, including the
Town Centre Charette.
Re-present.
Adjust dwelling targets
for East Hemel
Hempstead by 100 (up)
and the town centre by
100 (down).
Update. Make
stronger reference to
open space and
transport, and areas
outside the town centre
and Maylands.
Take account of further
work on the town
centre, including the
Town Centre Charette.
Take account of further
work on Maylands,
including the
discussions with St
Albans Council.
DRAFT
Delivering the
Vision: Town
Delivering the
Vision: Town Centre
Delivering the
Vision: East Hemel
Policy CS33
134
Take account of further
prepared, are seen in the
context of place strategies.
For accuracy and clarity,
and to reflect the Council’s
latest thinking.
For clarity.
To reflect latest
assumptions for dwelling
capacity.
For accuracy and clarity.
For accuracy and clarity,
and to reflect the Council’s
latest thinking.
For accuracy and clarity,
and to reflect the Council’s
latest thinking. The need
for land in St Albans
district for development
has significantly reduced.
For accuracy and clarity,
Policy CS34
work on the town
centre, including the
Town Centre Charette.
Refer to new homes,
an evening economy
along Waterhouse
Street, better east west
links and restoration of
the Water Gardens.
Take account of further
work on Maylands,
including discussions
with St Albans Council.
Simplify the list of
business partners and
refer to transport
providers.
Take account of further
work on the town
centre and Maylands,
including the Town
Centre Charette.
Adjust boundaries to
ensure consistency
throughout. Extend the
Marlowes Shopping
Zone. Extend the
Maylands Gateway
area. Amend the
suggested boundary of
the Action Area.
Amend to accord with
conclusions on green
infrastructure (section
DRAFT
Monitoring
Figures
135
and to reflect the Council’s
latest thinking.
For accuracy and clarity,
and to reflect the Council’s
latest thinking.
Update for accuracy.
For accuracy, clarity and
consistency, and to reflect
more recent evidence and
Council thinking.
22.
Berkhamsted
Vision and Strategy
text
Para 22.11
23.
24.
25.
26.
27.
17). Update built vision
diagram to reflect
new/proposed
developments at Nash
Mills and the Manor
Estate.
Amend Vision to refer
to the castle being
protected and enjoyed.
Likewise insert a new
paragraph in the
strategy.
Amend strategy to refer
to links being fostered
between British Film
Institute and the town
To respond to advice from
English Heritage.
DRAFT
Tring
Kings Langley
Bovingdon
Markyate
Countryside
Proposal SS2
Para 9.34
136
Amend site area and
housing capacity to
take account of the
availability of two
additional parcels of
land adjoining the site
that could reasonably
be included within the
proposal/master plan.
Link the definition of
affordable housing to
Policy CS19: Affordable
To respond to separate
representations from an
adjoining landowner
whose land abuts the
proposal site.
Following discussions with
the Development
Management team.
For consistency.
Housing.
PART C – IMPLEMENTATION AND DELIVERY
28. Delivery
Partnership working
Key projects
Flexibility and contingency
29.
Infrastructure requirements
Para 29.3
Amend to clarify that
the IDP is the result of
technical work, rather
than being the technical
work itself.
Editorial amendments.
Add sentence stating
that most strategic and
local infrastructure
requirements are set
out in IDP. Also, add in
sentence to
acknowledge role of
neighbourhood plans
with regards to
infrastructure
requirements.
Add sentence to
acknowledge that
contributions will be
used to mitigate the
impacts of
development.
Replace ‘tariff or other
measures’ with CIL.
Remove reference to
DRAFT
Paras 29.4-5
Para 29.6
Developer contributions
Para 29.7
Para 29.8
137
For clarity.
For clarity.
For clarity and to update
the chapter in light of
emerging government
guidance re
neighbourhood planning.
Clarify that contributions
are not sought to remedy
existing deficits.
Clarify the Council’s
approach to collecting
developer contributions in
pooled contributions
and clarify how CIL and
S106 will be used.
Para 29.9-10
Para 29.11
Replace paragraphs
with one which refers to
CIL rather than the
Planning Obligations
SPD.
Amend to introduce
flexibility about how the
Council will respond
where viability is a
concern.
DRAFT
Policy CS35
30.
PART D – APPENDICES
Monitoring
138
Remove last two
paragraphs, but include
reference to the use of
financial contributions.
light of the Coalition
governments’
announcements regarding
their intentions for CIL and
S106.
Allow for flexibility re. the
Planning Obligations SPD
and confirm commitment
to CIL.
Partly because the amount
of CIL payable will not be
variable, and partly to
introduce flexibility into the
Council’s approach to
dealing with viability.
Most of the last two
paragraphs are more
suitable for background
text, where the sentiments
are already expressed,
rather than policy. The
last sentence is no longer
necessary given the
government’s clarification
of the CIL regulations. It is
however important to
indicate that the use of
financial contributions will
be guided by the
Infrastructure Delivery
Plan.
Appendix 1
Appendix 2
Housing trajectory
Insert once decision on
housing target is made
Appendix 3
Delivery
mechanisms
Appendix 4
Glossary
Update as a
consequence of
changes to the main
document.
Include new terms as
appropriate
DRAFT
139
Trajectory information is
required at the PreSubmission stage.
For consistency and
completeness.
Updating and clarity.
140
Appendix 7: Minutes of Key Meetings:
June – July 2011
•
Dacorum Partnership Board – 15 June 2011 (Extract only)
•
Strategic Planning and Environment Overview and Scrutiny
Committee – 19 July 2011
•
Cabinet – 26 July 2011 (Extract only)
141
142
Subject:
Date:
Location:
Dacorum Partnership Meeting
15 June 2010
Bulbourne Room, Civic Centre
Attendees:
Cllr Andrew Williams, Leader - DBC (Chairman)
Cllr David Andrews, Hertfordshire County Council
John Allan, Tring Town Council
Heather Allen, Volunteer Centre Dacorum
Atifa Ali-Khan, Age Concern
David Bogle, Hightown Praetorian & Churches Housing Association
James Doe, Assistant Director (Planning, Development and Regeneration) –
DBC
Mohamed Fawzi, Dacorum Children’s Trust Partnership
Trevor Fernandez, GP Commissioners
Cllr Neil Harden, Portfolio Holder for Residents and Regulatory Services
Emma Norrington, Groundwork
John Quill, Management Group
Brian Worrell, Cultural Forum Sport
John Wood, Hertfordshire County Council
Laura Wood, Strategic Planning and Regeneration Team Leader
Brian Worrell, Cultural Forum
Peter Wright, PCT
Time: 9.30 am
Others:
Nicky Flynn, LSP Development Officer
David Gill, Group Manager (Partnerships & Citizen Insight) – DBC (Partnership
Support)
Natalie Webb, Stronger Communities Policy Officer - DBC
Pat Duff , Member Support Officer – DBC (Minutes)
The meeting started at 9.35 am
143
1.
APOLOGIES FOR ABSENCE AND INTRODUCTION OF NEW
REPRESENTATIVES
Apologies for absence were given on behalf of Fatima Ikram, Communities Together; Daniel
Zammit, Chief Executive DBC; Gill Worgen, West Herts College; Mark Mitchell, Community
Action Dacorum; Dr Richard Garlick, PCT; Anne Andrews, Dacorum Children’s Trust
Partnership; and Chief Inspector Mike Pryce, Herts Police.
Councillor Williams welcomed new members to the meeting and asked everybody to
introduce themselves.
2.
MINUTES – 8 DECEMBER 2010
The minutes from the meeting held on 9 March 2011 were noted and agreed.
3.
4.
MATTERS ARISING
3.1
Hertfordshire County Council – The paper on key Transport Policy decisions
had been circulated.
3.2
Localism – This was being dealt with under AOB.
3.3
Local Development Framework – Laura Wood and James Doe to cover this
under item 4 of the agenda. James Doe advised that the powers of the
Planning Inspector would fall through the Localism Act when passed. The
Inspector had combined authority.
LOCAL DEVELOPMENT FRAMEWORK CORE STRATEGY
James Doe advised that DBC was looking to report to Council on the preferred option for
development with the borough. The report to the Dacorum Partnership dealt with the issues
going before Cabinet on 26 July and input from the Partnership. In legal terms the Local
Development Framework (LDF) was the Council’s document. In order for the document to
be a locally owned one, it would be helpful to have the endorsement of the Dacorum
Partnership.
The key issues were housing and the release of land for housing. Two growth options had
been consulted on:
Option 1 – Urban capacity option equating to a target of 370 dwellings per year/about 10k
new dwellings by 2031.
Option 2 – 430 units per year/about 11,300 dwellings by 2031. This would need the release
of Green Belt land.
The consultation showed a split of opinion with a preference for Option 1. It would not be
sustainable for the Council to accept a lower option than Option 1.
The report shows how DBC has had to balance views put forward from residents and others,
with technical information around issues such as housing need and land availability.
Concern was expressed about the use of the countryside and Green Belt land and
infrastructure needed to support growth.
144
Paragraph 4.8 of the report details the latest household projections from the Office of
National Statistics (ONS. This shows a projected need for 13,400 new households within
the borough by 2031. Option 2 was at the lower end of the projections. The report also
detais how other authorities arere setting housing targets I the context of these household
growth figures. The table on page 7 of the report showed that DBC was 3k below the
projections but other authorities were very adrift of those projections for their areas.
Stevenage had always planned for growth.
Atifa Ali-Khan asked what thinking had gone into ‘homes for life’ and what percentage would
be adapted or accessible homes.
Laura Wood advised that there was a policy in the existing plan that covered the issues of
‘lifetime homes’ and this is linked to the Code for Sustainable Homes standards. Accessible
homes are part of this standard. 10% – 15% are expected to be to lifetime homes standards
at present. The majority of new homes would be accessible. There was a sliding scale with
the Code for Sustainable Homes as to when those standards would come in, but DBC is
moving towards a greater proportion of homes being more accessible.
James Doe said that if the Council made green field contributions, it would be easier to get
developers comply with stricter standards on housing development. The Council could also
identify particular requirements for a particular development.
Atifa Ali-Khan asked if this was an aspiration.
Laura Wood said that the ageing population issue had been picked up and DBC was
meeting with HCC to ask for additional advice. Once received this would be more explicitly
covered in the document.
David Bogle did not agree that people should stay in their homes for all their lives and was
not sure lifetime home targets were a good idea. It was being debated as to whether older
people should move to more suitable accommodation.
Brian Worrell asked if land planning included the issue of removing the first tranches of
Government owned land in Hemel Hempstead.
James Doe said that Hemel Hempstead was at the forefront. A lot of the land was held by
the Homes and Communities Agency. Some had been identified where developers would
not have to pay for the land at the start, but when the units had been sold to help make
development more viable. These sites had been included in the numbers.
David Bogle said this was an important decision for the Council, especially for Hemel
Hempstead. The town had been lacking investment over the last decades and needed to
see investment coming in and must send out a signal that the borough was in favour of
growth and jobs. If the Council chose the option 1 number, it would not be sending out a
positive message. Maximum possible investment was needed for the benefit of the town.
The link between housing, jobs and the economy was clear. Option 1 sends out a message
to allow the town to keep declining investment.
Option 2 sends a message that says we want Hemel Hempstead to be a vital economy.
There should be more housing and the Green Belt should not be sacrosanct. This was
about the vision for Dacorum and, particularly, for Hemel Hempstead. The Council was
putting in the structure to enable that growth to be supported. The LSP should grasp this
nettle.
145
John Wood said the east of Hemel Hempstead near St Albans was important regarding the
infrastructure of Hemel Hempstead. It would be useful to know what the situation was
regarding that.
James Doe advised that this was an ongoing conversation. St Albans was continuing with
its own plans which did not allocate land in that area. As the land at North East Hemel
Hempstead is in St Albans district, any development there would count against their housing
targets, not Dacorum’s.
John Wood said that the infrastructure needed to meet the housing levels locally and would
be material and important to Hemel Hempstead.
Councillor Williams said this was under review with the change in administration. Land
adjacent to the M1 had little effect on St Albans. Agreed that further discussion was required
with ST Albans about this.
John Allan said that Town Councils were in favour of Option 1. He could see that Option 2
was ideal for Hemel Hempstead but Option 1 was ideal for smaller settlements who saw
their boundaries as important factors.
Councillor Williams said he did not think Option 2 would be supported by the people of
Hemel Hempstead. From residents’ points of view he thought Option 1 would be favoured
by all residents. There was little difference between Options 1 and 2 for smaller parishes.
The difference in Opton 2 was primarily with Berkhamsted, Tring and Hemel Hempstead.
Laura Wood confirmed that for Hemel Hempstead, Tring,Berkhamsted and Bovingdon
there was a difference. For Kings Langley and Markyate it was the same, as well as for the
countryside. Bovingdon Parish Council had supported the local Green Belt release there,
provided certain requirements are met
Trevor Fernandez asked if the figure was for the projected increase in population and asked
when infrastructure would be looked at.
James Doe said that an infrastructure study had been developed in parallel with work on the
Core Strategy. The Council had to deliver an Infrastructure Delivery Plan to the Planning
Inspector to support the level of growth aimed for.
Trevor Fernandez asked if the public had a say in that.
Laura Wood said feedback on projected needs had been received from key infrastructure
providers. Any issues raised were picked up with HCC (education etc.). The Infrastructure
Delivery Plan itself has not been subject to consultation. The Community Infrastructure Levy
(CIL), which includes an infrastructure list to inform a charging schedule will be consulted
upon once prepared
Peter Wright of the PCT advised that he had been consulted on the infrastructure study.
They could establish how many more GPs were required. This was with their Estates
Department at the moment. When there was any change of commissioning arrangements,
the formula (number of people = services provided) would stay the same (nationally decided
by the NHS).
David Bogle said the population was forecast to grow which would lead to overcrowding if
more new homes were not built. The growth in population would happen anyway, regardless
of housing numbers.
146
Councillor Williams said that 13k homes projected as needed was just what was required by
growth in Dacorum, without people coming in from outside.
Peter Wright asked how the previous Regional Plan figures were challenged.
Laura Wood said the figure in the regional plan was about 17k for the same time period
(2006-2031), taking development St Albans into account. DBC’s response was based
around the assumed capacity within existing settlements.
Councillor Williams said that the decision was around Option 1 or Option 2 which would both
provide a degree of under supply compared to the latest household growth projections.
However the Council must strike a balance between expected housing need and and other
factors. The Council wanted to provide a robust strategy to take to the Inquiry.
Peter Wright expressed support for Option 2 as good quality housing was required.
Trevor Fernandez also supported Option 2 and said that with an ageing population there
would be an increasing demand for small units.
Councillor Williams said funding would be an ongoing challenge to deliver affordable
housing.
Members were asked to send feedback to James Doe.
ACTION: ALL
A report on the Council’s Core Strategy would go to Cabinet on 26 July who would make a
recommendation to be considered at Council on 28 September. There would be
consultation (covered by the Planning Inspectorate process) for 6 weeks from about mid
October to the end of November (dates to be confirmed).
Brian Worrell said there were a lot of unused sites in the business district of Hemel
Hempstead and asked if any of those sites would be available for house building or would
Green Belt have to be used.
Councillor Williams said that part of the strategy was to create an extra 10k jobs and to
strengthen the business community.
David Bogle advised that the Heart of Maylands plan did include some residential.
Laura Wood said there was a need to provide both homes and jobs.
Brian Worrell said that empty commercial sites attracted vandals. Culture could make a
statement about what sort of society we were. It was very important to residents that there
was a Green Belt. There was a danger that, if the Green Belt was built on, neighbouring
towns would be joined up. Maximum use should be made of the land we have.
Councillor Williams said this was always being looked at. The Council would try to deliver
these houses within the existing settlement boundaries as far as it could.
Extract ends at the end of Item 4
147
148
149
150
151
152
153
154
155
MINUTES
CABINET
26 JULY 2011
Present:
Members:
Councillors:
Brian Ayling
Neil Harden
Margaret Griffiths
Stephen Holmes
Julie Laws
Nick Tiley
Andrew
(Chairman)
Officers:
Williams
Sally Marshall
Louise Miller
David Austin
Steven Baker
James Doe
Shane Flynn
Janice Milsom
Ben Hosier
Rita McGinlay
Julie Still
Chris Taylor
Linda Dargue
Pat Duff
Jim Guiton
Alison King
Matt Rawdon
Leida Smith
Laura Wood
Portfolio Holder for Service and Performance
Improvement
Portfolio Holder for Residents and Regulatory
Services
Portfolio Holder for Housing
Portfolio Holder for Planning and Regeneration
Portfolio Holder for Environmental Services
and Sustainability
Portfolio Holder for Finance and Resources
Leader of the Council
Corporate Director (Finance and Governance)
Corporate Director (Performance,
Improvement
and Transformation)
Assistant Director (Neighbourhood Delivery)
Assistant Director (Legal Democratic and Regulatory)
Assistant Director (Planning, Development and
Regeneration)
Assistant Director (Finance and Resources
Assistant Director (Strategy & Transformation)
(Community & Organisation)
Group Manager (Commissioning, Procurement and
Compliance)
Group Manager (Regulatory Services)
Group Manager (Resident Services)
Group
Manager
(Strategic
Planning
and
Regeneration)
Insurance & Risk Manager
Member Support Officer
CCTV Manager
Environmental Health Office
Human Resources Team Leader
Communications Officer
Team Leader (Strategic Planning)
Councillors Douris, N Hollinghurst, D Rance and Reay also attended.
The meeting began at 7.30 pm.
156
CA/066/11
MINUTES
The minutes of the meeting held on 28 June 2011 were agreed by the members present and
signed by the Chairman.
CA/067/11
APOLOGIES FOR ABSENCE
There were no apologies for absence.
CA/068/11
DECLARATIONS OF INTEREST
Councillor A Williams declared a personal interest in agenda item 18, Maylands Business
Centre Governance Arrangements. Councillor Williams has a tenancy on the site.
CA/069/11
1.
PUBLIC PARTICIPATION
The following people each made a statement regarding agenda item 15 – Local
Development Core Strategy – Proposed Submission (Minute CA/072/11):
Mrs J Caulfield
Mr J Heginbotham
Mr J Leith
Ms C Reece
Mr P McCann
Mr G Partridge
Mr M Nidd.
2.
Mr M Nidd made a statement regarding agenda item 16 – Dacorum Development
Programme 2011 – 2014 (Minute CA/081/11).
CA/070/11
REFERRALS TO CABINET
Strategic Planning and Environment Overview and Scrutiny Committee – 19 July 2011
OS/118/11 – Local Development Framework Core Strategy – Proposed Submission
Decision
That the referral be considered with item 15 on the agenda (minute CA/072/11).
CA/071/11
CABINET FOUR MONTH WORK PROGRAMME
Decision
That the Cabinet Four-Month Work Programme be noted, subject to the following
amendment:
13 September 2011
Medium Term Financial Strategy – additional report.
157
CA/072/11
LOCAL
DEVELOPMENT
SUBMISSION
CORE
STRATEGY
–
PROPOSED
Decision
8.
That the key issues arising from consultation on the Draft Core Strategy (November
2010) and new evidence be noted.
9.
That Council be recommended to approve that housing option 2, incorporating the
growth level and the local allocations set out in paragraph 1.37 of the report, are
included within the Pre-Submission Core Strategy.
10.
That authority be delegated to the Portfolio Holder for Planning and Regeneration to
approve changes to the Draft Core Strategy prior to consideration by Full Council.
11.
That authority be delegated to the Assistant Director (Planning, Development and
Regeneration) to finalise the Report of Consultation and Sustainability Appraisal.
12.
That Council be recommended to approve the Core Strategy for publication, seeking
representations in accordance with the Statement of Community Involvement and
relevant Regulations.
13.
That Council be recommended to approve the following procedure for considering
further issues on the Core Strategy:
14.
(c)
If significant new issues are raised in the representations on forthcoming
consultation routines, to report to Cabinet and Council for a decision as to
whether any change to the Core Strategy is justified
(d)
If there are no significant new issues, to delegate authority to the Assistant
Director (Planning, Development and Regeneration), in consultation with the
Portfolio Holder for Planning and Regeneration, to
submit the Core Strategy for examination;
and
in consultation with the Portfolio Holder to agree any minor changes to
the Core Strategy to resolve objections and improve the clarity of the
document.
That the Assistant Director (Planning, Development and Regeneration) be requested
to prepare a Community Infrastructure Levy charging schedule for Council approval.
[Council should note that Strategic Planning and Environment Overview and Scrutiny
Committee considered the draft Core Strategy on 19 July 2011].
Reason for Decision
To recommend the Core Strategy Proposed Submission documents to Full Council for
publication and comment after having considered the key issues raised by the consultation
158
held in late 2010 and to enable a Community Infrastructure Levy charging schedule to be
prepared for consideration by Council.
Implications
The process of preparing the Core Strategy, as part of the LDF, has financial implications.
Cabinet considered the implications of a three year budget programme when considering
the Annual Monitoring Report and progress towards the Local Development Scheme in
November 2009. Budget provision, together with an LDF reserve, is made for 2011/12.
Having an up to date planning policy framework helps reduce the incidence of planning
appeals (and thus costs associated with those). It will also be the most effective way of
ensuring the optimum level of developer contributions to infrastructure and in mitigation of
development impacts can be achieved. This process will be further improved and simplified
through the adoption of a Community Infrastructure Levy (CIL) approach.
Risk Implications
Key risks are identified in the Local Development Scheme and reviewed annually with the
Annual Monitoring Report. They include failure of external agencies or consultants to deliver
on time, change in Government policy and team capacity. A separate risk assessment
prepared for the Core Strategy Pre-Submission identifies a number of risks relating to the
examination in public process and particularly the soundness tests with which the Core
Strategy must comply. There are also risks associated with not delivering sustainable
development i.e. in terms of not meeting local housing needs.
Corporate Objectives
Preparation (and delivery) of the Local Development Framework and its component parts
contributes to all the corporate objectives. The aim is to achieve high quality, sustainable
development in the right place, at the right time and with the right infrastructure, whilst also
ensuring recognising the need to protect green space.
Advice
Mrs J Caulfield made the following statement:
Mrs Caulfield expressed concern about building on Cherry Bounce when there were more
appropriate places. Cherry Bounce had always been known as common land. Gypsy
horses had been tethered there – when did all this change? The fields were used daily,
children play there and dogs were walked there.
Gadebridge Park was one of the best features of the town and was available to all. The
Water Gardens were sad and the shopping precinct was bad, do not spoil the parkland area.
There was a lot of wildlife in that area and it would be sad to lose this wonderful part of the
town.
Mr J Heginbotham made the following statement:
I am an agent for a landowner, but I am not a planning expert and I am not here to promote
that site. Instead, my much more personal reason for being here is that the only way my two
children will be able to afford their own homes is if there is an adequate future housing
supply.
159
Why choose Option 1 (9,800 units) when we are going to need 13,400? This is not nearly
enough and as a plan this is not sufficiently robust. The Planning Inspector will say that is
unsound, especially as paragraph 1.18 of the report says that the Government is now
indicating a very pro-development stance.
Option 3 or higher may be a bridge too far. Paragraph 1.36 of the report says that Option 2
was a good sustainable compromise. I agree, last week’s Overview and Scrutiny Committee
did and I believe the Planning Inspector will too.
Option 2 does involve some limited Green Belt development, but bearing in mind the history
of Hemel Hempstead, attempts to prevent further growth of the town for the next 20 years
would be unsustainable.
Sensible and sympathetic development of Green Belt sites can be achieved with proper
screening and landscaping. Option 2 would only mean the development of 0.4% of the
Green Belt in Dacorum.
It is clear that Option 2 is appropriate, so please adopt it.
Mr J Leith and C Reece made the following statement:
We are objecting to building on land at Cherry Bounce and the reasons had been noted
under late comments in the report. We have over 250 petitioners against building on this
space. We only became aware of the building proposal in the final stages of the consultation
process. The community was not aware of the draft Core Strategy.
In 2007 we joined with Dacorum Borough Council against the East of England Plan and the
figure was reduced to 11,000. DBC was against any building on Cherry Bounce or other
Green Belt land and that conflicts with paragraph 1.49 of the report. There appears to have
been a U turn and the Council now appears to be in favour of Green Belt release.
It seems a foregone conclusion that Cherry Bounce will have houses built on it at some
stage. The Council was previously against that. Councillor Holmes stated that the political
will within the Council to build on Green Belt was nearly zero. Brown field sites should be
used. Why include this in the first phase of consultation and why are possible regional sites
not included?
We need to keep all the green spaces we have within the urban community, once it has
gone, we cannot turn back the clock. The MP is against this development. No further
consultation is required. By opting for Option 2 DBC is saying yes to development on the
land. We appeal to the Council not to let it go any further. The Council is capable of putting
together a clear strategy so that both residents and the Council could be assured that Hemel
Hempstead will continue to be a pleasing green space to live.
Mr P McCann of Banner Homes Limited made the following statement:
I wrote to Cabinet members last week about LA5, New Road, Northchurch that has a
potential for providing 50 houses. This site is recommended for housing and we are
concerned that it is not being given a chance to be considered.
With regard to paragraph 1.38 of the report, it was not consulted on in the draft Core
Strategy 2010 on its own merits but due to the potential of the site’s development for funding
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a Link Road. Paragraph 3.14 of the report stated that most opposition was in respect of the
Link Road. Table 1 in the report showed that the number of ‘Yes’s’ against the site was the
second highest of all the places referred to.
If the site had been consulted on without the Link Road, it may have received less negative
responses. We are still prepared to make contributions towards the Link Road if the site is
allocated but, if there is no public support for it, we would equally be happy to see it dropped.
Delivery of the site is in no way dependent on the Link Road. We have commissioned for
the first time a landscape survey that shows it can be developed at the density proposed (50
dwellings) without having a significant landscape impact.
We would ask you to include LA5 in the table of sites as set out in paragraph 3.7 of the
report to be included in the Core Strategy. There is an ongoing need for affordable housing
in Northchurch for which this site is best placed to provide.
Mr G Partridge, Chairman of Save Your Berkhamsted Residents Association, made the
following statement:
Our Association represents a very large number of local residents who have signed our
petition about the Emerging Core Strategy issues. As you know there were hundreds of
Berkhamsted residents who have made their comments known by way of the consultation
process as laid down by the Council.
We have concerns that those responses from the residents of Berkhamsted, as requested,
have gone unheeded because the Council appears to be basing its preferred option on
housing numbers as a result of speculative developers’ plans rather than basing it on the
needs of the residents.
As a result of this what assurances can the Council give that the consultation has engaged
the public and that their input has been taken into account?
It is our view that there has been no consideration taken about the character of Berkhamsted
as a historic market town being enhanced. Any housing numbers in excess of Option 1 have
been arrived at purely to take into account the requirements from speculative builders and
developers.
There will be a considerable loss of green belt land if housing numbers greater than Option 1
are to be recommended. Option 1 appeared to be the preferred option for housing numbers
up to the time that developers, such as Grand Union Investments, suggested much higher
numbers than Option 2.
We therefore conclude that the consultation is flawed because the Council is acting out of
fear from speculative developers. The Council is not taking its decision based on the
consultation process.
Mr M D Nidd made the following statement:
In respect of the draft document, I draw councillors’ attention to two paragraphs in the report:
Paragraph 1.39 reads ‘Of the two options put forward for consideration, the public
consultation shows that opinion is divided, but on balance there was a preference for Option
1. This was primarily due to the opposition of local residents to any housing development
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within the Green Belt. Some people considered that an even lower target should be
considered due to concerns over the capacity of local infrastructure and the impact that new
development may have upon the character of towns and villages.’
That ‘on balance’ comment substantially understates the community response to the
consultation – the table at 1.41 of the report shows that responses from all sources in favour
of Option 1 were double those in favour of Option 2. With the Government’s ‘Localism’
agenda in mind, approving a Core Strategy that did not reflect that community response
would be one of those ‘most courageous decisions’ from ‘Yes, Minister’ and one which could
lay DBC open to a request for judicial review.
In paragraph 1.46 of the report, the document states that ‘It is, however, important to note
that Green Belt is a planning policy tool aimed at helping manage the level and type of
development in areas of high development pressure. It is not an indicator of landscape
quality.’ That statement only partially summarises the purpose of Green Belt. Among its
purposes unstated here are the prevention of urban sprawl, the prevention of coalescence of
communities, and the protection of the quality of the surrounding landscape, whatever the
nature of the Green Belt site itself.
This paragraph also states that ‘On this basis, it is important that the Core Strategy puts
forward a level of growth that is based on meeting housing needs.’ It is important to
recognise the difference between proven housing needs and the apparent effect on need of
some artificial ‘jobs target’, on which no local authority is in any position to deliver. In this
context Dacorum already has, according to the last copy of the Estates Gazette I read, over
a third of a million square feet of unused office accommodation, some of which could now
much more easily be converted into dwellings.
The Portfolio Holder for Planning and Regeneration thanked everybody for their comments.
It was valuable to have input at this stage.
Regarding LA5, the Council did not consider this site was required to meet its housing
needs. There were concerns about the impact on the Area of Outstanding Natural Beauty
and the Chiltern Conservation Board continued to object to this site. There was little support
for the Link Road in the consultation and there was no need to have the development for the
Link Road.
Regarding Cherry Bounce, this was a difficult example of a small area of Green Belt and the
overall map of the area had to be looked at. There was strong support from the Inspector at
the last inspection for this area and, therefore, the Council felt that to protect this area it
needed to highlight it and remove it from the Green Belt. The Council can then place it in as
a longer term solution. If the Inspector chose to remove it from the Green belt, it could be
built on immediately. If the Council removes it, the land can be protected in the longer term.
The Council was bringing forward a policy to bring forward Green Belt on a slower basis.
Regarding the positive comments about Option 2, the growth factor varies and the Council
needed to look at how it could get to those figures.
There was no artificial jobs target but there was a need of jobs for our children. Those sites
that have been looked at in the Green Belt equated to 0.4% of the Green Belt, 0.2% of
Dacorum). This was low. The Council has looked at how to attach developments alongside
existing towns. The Portfolio Holder was proud of the Council’s non-housing amenity space
and had no plans to remove Gadebridge Park from the amenity space.
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The Assistant Director (Planning, Development and Regeneration) said that the Plan was
being angled to ensure a steady and manageable supply of land starting with urban sites,
Green Belt and brown field. Green Belt did not refer to parks and open spaces.
Brown field opportunities and opportunities available from redundant commercial floor space
had been addressed thoroughly. Opportunities were being made to convert some areas of
commercial land to help meet the housing supply. The Council was seeking to balance
housing supply with employment needs of the Borough to 2031.
The Portfolio Holder for Planning and Regeneration then introduced the report. Since the
abolition of the East of England Regional Authority the housing need requirement had
reduced to 11,385. The strategy runs from 2006 – 2031 and would include 2,000 units that
had already been built. Current estimates outweighed this figure. The strategy could not
contain windfall sites for first five years. There was a higher national statistical requirement
but the Council’s figure would meet the need. Other neighbouring authorities had various
housing figures. If figures were found to be unsound, the strategies would have to be
rewritten.
Dacorum Borough Council wanted to maintain the Green Belt. The Option 2 figure was a
much reduced figure. The Green Belt put forward in the strategy would only be used if
required later on in the plan. The next stages were set out on page 33 of the report.
The Portfolio Holder for Environmental Services and Sustainability said she had sympathy
with Ashlyns’ wish to improve the school. The site was consulted on in 2009 and was not
supported by residents at that stage and was dropped at that point. The Portfolio Holder
hoped that Ashlyns School would ask for a second opinion when this plan went to the
Inspector but did believe the allocation to Berkhamsted as it stood was more than adequate
from the housing numbers point of view.
The Portfolio Holder for Finance and Resources, as a resident of Berkhamsted, agreed with
the Portfolio Holder for Environmental Services and Sustainability. The Portfolio Holder had
sympathy for Ashlyns but they had to choose whatever method they decided upon to
promote their cause.
The Portfolio Holder for Planning and Regeneration said that he would be happy to forward
comments to Banner Homes in response to their letter.
The Leader of the Council said that the Council had always sought to reduce development
and was minded to support Option 2. 11,000 was a maximum number and was not likely to
be changed at the examination inquiry. The Council needed to have a robust and definable
line against increased numbers of housing and 9,000 could not be sustained. The Leader of
the Council was happy to support Option 2, although was reluctant that Green Belt may be
required unless other opportunities came forward before then.
The Leader of the Council moved that recommendation 6 (b) should include a reference to
consultation with the Portfolio Holder for Planning and Regeneration.
This was agreed.
Options and Why Options Rejected
Option 1 – aimed to make the best use of land within defined settlements and equated to
9,800 new units.
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This option was rejected as it was not thought to be sustainable and could be challenged.
Option 2 – added to Option 1 through the inclusion of ‘Local Allocations’ and equated to
11,300 units. This was the preferred option.
Consultation
The report refers to consultation undertaken at various stages. The results of all previous
consultation is summarised in the Report of Consultation that will accompany the PreSubmission Core Strategy. Volume 6 is a draft report of consultation from November 2010,
including public consultation on the Consultation Draft Core Strategy. Development Plans
Task & Finish Group has been consulted at regular intervals in the preparation of the Core
Strategy. The Local Strategic Partnership Board has also discussed the content of the Core
Strategy at key stages in its preparation. Corporate Management Team have been
appraised of progress. It has expressed support for housing option 2.
Voting
None.
Extract ends at the end of this Item
164
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