BSCF letter to District Councillors outlining concerns over removal of land from the Green Belt as proposed in the draft District Plan
cc Other District Councillors
cc The Executive of East Herts District Council
cc The Leader of East Herts District Council
cc Bishop’s Stortford Town Councillors
cc Kevin Steptoe, EHDC
cc James Parker, BSTC
|7 September 2016|
DRAFT DISTRICT PLAN
Bishop’s Stortford Civic Federation is writing to you about the proposals for Bishop's Stortford set out in the draft District Plan, and in particular about the proposals to remove land to the South of Whittington Way from the Green Belt, and instead zone it for development of up to 1000 homes. It has been the settled policy of East Herts Council for the last 30 years to allocate the lion’s share of all new housing in the district (some 40% of the total) to Bishop's Stortford. From time to time, the pretext for this policy and the political leadership of the Council has changed, but the policy has always remained the same. If this draft plan is adopted by the Council in its present form, the policy of ‘Stuff it in Stortford’ will be perpetuated for another 20 years.
The development already approved for Bishop's Stortford North, together with the prospective development of Brownfield sites within the built up area provide enough new housing to meet the needs which would arise naturally from growth in the local population together with a generous allowance for inward migration, including migration from other parts of the district where development is not planned to keep pace even with local demand.
The significance of the so-called Bishop's Stortford South site as an important Green Belt asset has been examined on numerous occasions and the conclusion has been the same each time – that it performs valuable Green Belt functions and should not be developed. There is no planning justification for its development. The housing needs of the town will be more than satisfied by the other developments identified in the Plan. And now is not the time to be sacrificing good quality agricultural land quite unnecessarily.
I trust therefore that you can be relied upon to uphold the interests of the town and of your constituents when the full Council is given the opportunity to vote on the matter, by voting against the adoption of the Plan unless it is amended to keep this site within the Green Belt and undeveloped. Please would you ask for a recorded vote on this matter, so that the electorate is able to see which of our councillors has the interests of the town at heart?
In support of our concerns we would again draw your attention to the following points:
- We have been told that if the plan is not adopted, the Government may appoint an external agent to produce a plan. However, from the point of view of Bishop's Stortford it is difficult to see how an externally imposed plan could be worse than the Council’s own proposals.
- The National Planning Policy Framework (NPPF) makes clear (para 83) that Green Belt boundaries are intended to be permanent and should only be altered in exceptional circumstances through preparation or review of the Local Plan. This has been reinforced by the Planning Practice Guidance Note (PPGN) published on 6 October 2014 (paras 044 and 045) which emphasizes that Green Belt policies are a constraint which may restrict the ability of a local authority to deliver its objectively assessed housing need.
- The Council claims that housing need represents the exceptional circumstances required to review the Green Belt and that this was confirmed by a Planning Inspector during an advisory visit in early 2016. This advice has clearly been overridden by a letter from Brandon Lewis, former Housing and Planning Minister, dated 7 June 2016 and addressed to all Members of the House of Commons (copy attached). This says in very clear terms that housing need alone will not change Green Belt boundaries. While it does imply that local authorities working with local communities might possibly take a different view in some circumstances, the view of the local community has always been clear in the case of this site. Most recently, the consultation on the Neighbourhood Plan for Bishop’s Stortford All Saints, Central, South and part of Thorley, showed that one of the issues of most concern to local people was that this site should remain in the Green Belt and undeveloped (para 184.108.40.206 in the Examination Copy).
- Confirmation that the site should remain within the Green Belt and undeveloped has occurred on the following occasions:
- By the Inspector following her Examination in Public of the previous local plan in 2006.
- By East Herts Council in the adopted local plan in 2007.
- By East Herts Council in refusing planning permission for the relocation of two schools to part of the site in 2010.
- By East Herts Head of Planning and Building Control in evidence to the public inquiry into the refusal of planning permission in 2011.
- By the Inspector in his report on the appeal against East Herts Council’s decision in 2011.
- By the Secretary of State for Communities and Local Government in upholding the Inspector’s recommendation to dismiss the appeal in 2012.
- By Peter Brett Associates in their review for East Herts Council of the suitability of sites for release from the Green Belt in 2015.
- In their discussion of the Green Belt chapter of the draft District Plan, Officers claim that concerns raised about urban coalescence are groundless because strategic Green Belt sites will be retained. This is surely one such site.
- The possibility of the Boys High School being able to move to new premises on the site would not constitute the very special or exceptional circumstances that might justify withdrawing Green Belt protection and permitting development. This proposition, affecting only part of the site was tested to destruction at the public inquiry in 2011.
- Permitting the proposed development would add to the unsatisfied demand for secondary school places which this plan and Uttlesford’s would generate. Herts County Council have firm plans in place to meet only half the demand implied by the Plan (a new 6FE school at Bishop's Stortford North) and the ability of the other schools in the area to absorb the balance through expansion is highly speculative.
- From 1981 to the most recent census in 2011, the population of Bishop's Stortford, previously a similar size to Hertford, increased by 66% to 37500. It is now half as big again as Hertford whose population has increased by only 17% over the same period.
- The housing numbers in the draft District Plan imply an 11% increase in the size of the housing stock in Bishop's Stortford, more than twice the increase in any of the other towns in East Herts (apart from Buntingford which has recently been the victim of a number of opportunistic planning applications and lies outside the Green Belt).
- Rural East Herts (i.e. excluding the 5 towns) has a collective population of around 43000. Yet the draft District Plan suggests a target of only 500 new dwellings – only about a tenth of the number proposed for Bishop's Stortford. This is quite insufficient to meet the demand that would arise naturally in rural locations, and would force people to move to places such as Bishop's Stortford whether they want to or not. It would make more sense to reduce the Bishop's Stortford total by 1000 dwellings by keeping the Whittington Way site in the Green Belt and distribute them amongst the East Herts villages to enable them to grow organically rather than fossilise and lose the remaining services that they currently enjoy.
- The Plan policies for development in rural East Herts read like a carbon copy of those for the Green Belt and they have been enforced rigorously in the past. But there is no justification for this. Unlike the areas with Green Belt protection, there is no risk of coalescence of settlements or urban sprawl and the countryside will remain open. But the current and proposed policies for the rural area have a perverse outcome. The practical effect is that protection akin to that of the Green Belt is extended to cover the whole of the district and the only areas from which it is removed are those which enjoy Green Belt status at the moment. Green Belts are there to act as a constraint on development, not as something to be discarded when developers find them inconvenient. We strongly suggest the policies for development in rural East Herts need to be looked at again.
Based upon the arguments set out above, Bishop’s Stortford Civic Federation calls upon all recipients of this letter to oppose the District Plan on the grounds stated.Yours sincerely,
Rob Francis (Treasurer)
Bishop’s Stortford Civic Federation