NHDC Draft Local Plan
Introduction: Last month I wrote about the development sites allocated to Knebworth in the Local Plan. This month I will look at the broader context. Development sites are allocated very rarely. The last time this happened in North Herts was in 1992. Once the current Draft Local Plan is approved the pattern of development in North Herts will be set for a generation.
Much of the draft plan is available on the NHDC website, but minor changes are still being made, so it is not possible to give any links here. Please check the website itself, and social media for the latest updates.
Implications of Local Plan for Knebworth: There are several sites proposed for Knebworth, see map, one in the centre of the village and the rest for removal from the Green Belt, with dwelling estimates (area based rule of thumb, not developer proposal) totalling 791, as follows:
|SHLAA Ref||Address||Site Type||Refined dwelling estimate|
|52||Land at Deards End||Green Belt||227|
|335||Land rear of Redwood, Deards End Lane||Green Belt||14|
|53||Land at Gypsy Lane||Green Belt||229|
|55||Land North of Old Lane||Green Belt||63|
|336||Land east of Old Lane||Green Belt||44|
|57||Land south of Swangley’s Lane||Green Belt||100|
|58||Land north of Watton Road||Green Belt||100|
|KB/m01||Chas Lowe, London Road||PDL within village boundary||14|
Why is this consultation different:
Some of you are probably suffering from ‘consultation fatigue’. NHDC have consulted repeatedly on aspects of the local plan, which is not surprising since it was supposed to be ready by 2011. The most recent consultation, on the so-called Preferred Options was in December 2014 and generated about eight and a half thousand responses from around the District, including a several hundred from Knebworth.
This consultation is different because the responses will be examined by the Planning Inspector and will feed into the public enquiry where the Local Plan will finally be adopted (or not). NHDC will simply collate the responses and pass them to the Inspector. Responses may be electronic or on paper, but not by telephone or in person.
Note that, if you submitted comments in response to previous consultations on the plan and believe that the updated plan does not fully address your concerns, you should submit your comments so that they will be received by the Planning Inspector.
Soundness of Local Plan:
The Planning Inspector will examine the Draft Local Plan to determine whether it is ‘sound’. A plan is sound if it is ‘Positively prepared, Justified, Effective and Consistent with national policy.’
This requires that the plan provides for enough houses, business premises, infrastructure and community facilities. It also requires that the plan is sustainable, in the sense that it does not cause irreversible damage to the environment or the well-being of future generations. Although developers are expected, in principle, to pay for infrastructure, there is a requirement that the plan defines what infrastructure is needed. NHDC take the view that no account may be taken of ‘Brexit’ because it is too early to estimate its effects on housing numbers.
The plan is justified only if it is based on compelling evidence and that evidence is presented alongside the plan itself. The submitted draft must be the best of all possible choices. Other choices for the plan, such as the suggestion that has been made for a ‘New Garden City’, must be demonstrated to be inferior to the choices in the plan.
The plan is effective if it can be implemented within the available timescale (before 2031). If the plan does not mesh with those of neighbouring authorities, or the infrastructure required to support it cannot be built, the plan will fail the effectiveness test. The draft submission plan calls for around 1,100 house completions a year to be delivered for the latter of the plan period. This is considerably more than North Herts has previously achieved.
Consistent with national policy
The plan must be consistent with national policy. A policy that many local residents have commented on is the need to avoid changing Green Belt boundaries, except under exceptional circumstances. Available sustainable brownfield sites in the District are limited and the vast bulk of land allocated for proposed housing is on sites which are currently in the Green Belt. There are many polices in the NPPF (and the associated Planning Practice Guidance website): I suggest that residents consider whether or not the Plan is consistent with the whole of the NPPF, and not just the paragraph relating to the Green Belt.
The NHDC Cabinet is scheduled to meet on 26th September to approve the current version of the plan to go forward to consultation. It will then become the ‘draft submission plan’. If it is approved, the officers will prepare the material for consultation, and set up the consultation software on the NHDC website. Readers will be pleased to hear that new, improved software is being used this time, so the frustrations which the experienced trying to make representations on the Preferred Options draft should be a thing of the past.
If all goes according to plan the consultation period will run from the 19th October to the 30th November. Again, this period will run over the Christmas holidays, and potentially means that some residents will have a very short window in which to read the documents and make their submissions.
Following the end of the consultation period, the submissions will be categorised by NHDC and submitted together with the Draft Plan and all other supporting material to the Planning Inspector in the first part of 2017.