BSCF's covering letter to the EHDC Planning Policy Team outlining objections to the draft District Plan
See here for the BSCF's Full Statement of Objections
See here for EHDC's District Plan Consulation Portal
Planning Policy Team
East Herts District Council
|20 November 2016|
PRE-SUBMISSION DISTRICT PLAN 2016
I am enclosing with this letter a summary of the objections of the Bishop's Stortford Civic Federation to this plan, the full statement of our objections, and the two ministerial letters from Brandon Lewis and Gavin Barwell referred to in the full statement. I am also sending a copy of this letter and enclosures to you by email.
I understand that you will, on request, notify me of when the Council submits the plan to the Planning Inspectorate for independent examination, when the Planning Inspector publishes their recommendations, or when the Council adopts the District Plan. I should be grateful if you would notify me of all three of these events.Yours faithfully,
John Rhodes (President)
Bishop’s Stortford Civic Federation
Summary of Objections
BSCF DISTRICT PLAN OBJECTIONS SUMMARY
While the vision and objectives of the plan are largely unexceptionable, many of them are expressed at such a high level of generality that several different plans could claim to be compliant with them. We do not believe that this plan satisfies the tests of ‘soundness’ required by the NPPF.
Development Strategy, the Green Belt and the Rural area Beyond it
The Development Strategy
History of Development in East Herts
- Bishop's Stortford has had much the greatest growth of any East Herts urban settlement – a 66% increase in population since 1981 and 40% of all East Herts’ new housing. But this has been accompanied by a loss of public services and no improvements in the road network to support such growth.
- We have no reason to suppose that this plan will differ from any of its predecessors in determining that housing should come first and that supporting infrastructure, if any, can tag along later.
- Relying on the SHMA to determine rather than simply inform the level and distribution of development is mistaken.
- It merely replaces the regional plan top down centrally determined forecast with another similar one.
- It builds in a prejudice in favour of the type of development which volume commercial house builders favour rather than reflecting the future needs of local populations.
- It ignores the potential impact of Brexit on migration and the housing market in the south east.
- While the plan cannot restrict inward migration (about half the total population growth in recent years) its location and to some extent the volume are heavily influenced by plans which determine where new housing is sited.
Housing Distribution in East Herts
- Previous plans which concentrated growth on the largest urban settlements and severely restricted growth in rural communities have led to unbalanced development of the district and of Bishop's Stortford. This plan simply proposes more of the same.
- In particular neither the claimed demand for 4349 new homes in Bishop's Stortford (which is simply the result of projecting forward past inward migration) nor the arbitrary restriction on development in villages to a total of 500 new homes are justified by population forecasts of where naturally arising demand would occur. These point to less housing in Bishop's Stortford and more in the villages.
Unsustainability of Distribution Model
- The strategy is not sustainable. Villages will die unless they are allowed to grow sufficiently to enable the young and the elderly to stay in their own communities. Village populations which span the generations help to support the shop, school, post office, GP surgery, pub and rural bus services.
- The advent of broadband communications means that many workers no longer need to travel to a central location, while on line shopping is taking an increasing share of the market. Working and shopping from home will reduce traffic and pollution and allow people to spend more time with their families.
- Forcing the young and old to move to urban settlements because of lack of suitable housing will turn villages into middle class, middle aged enclaves. Family support networks, when the generations are split, impose as many demands on transport as travelling to town to work or shop.
- Endless expansion of towns is equally unsustainable. Bishop's Stortford now has many dormitory suburbs, physically separated from the historic centre and isolated from the community in every sense. They are highly car dependant and lack of growth in local employment means commuting to London, Cambridge or Stansted Airport provides the main job opportunities. Bishop's Stortford North and development of brownfield sites should mark the end of the town’s expansion if we are to retain our reputation as one of the best towns in the country in which to live.
- The proposed housing completion rates of an annual average of 745 to 2033 and of 1200 in the first five years are patently unachievable. They represent a 40% increase over the average for the last 25 years and a 125% increase for the first 5 Years. The commercial house building industry has no interest in accelerating the rate of completions. This can only be brought about by changes in procurement and/or taxation of development land values which are not in prospect.
- Zoning land for housing, on the basis of unrealistic expectations about the ability of the industry to deliver, causes blight and discredits the planning system.
The Green Belt and Rural Area Beyond it
- Ministers have made it clear repeatedly, that housing need alone is not an exceptional circumstance which would justify review and alteration of Green Belt boundaries. Yet nearly half of all the new housing is allocated to sites which are currently within the Green Belt. The proportion rises to nearly two thirds if commitments and completions are excluded.
- The rural area beyond the Green Belt area does not meet Green Belt criteria. It is not a National Park and not (yet) an open air museum. It should not be subject to policies as restrictive as those applying within the Green Belt.
Bishop's Stortford South
- We object strongly to the proposed removal of the site at Bishop's Stortford South from the Green Belt
- Bishop's Stortford South was proposed for partial development in the draft of the previous local plan. However, it was retained wholly within the Green Belt in the adopted version of the local plan and plans for a school campus on part of the site were rejected by EHDC and, following a public inquiry, by the independent inspector and the Secretary of State. It was also deemed unsuitable for development by EHDC’s own Green Belt review consultants.
- Ministers have made it clear that local communities should have their say in any Green Belt boundary review. In this case, the Neighbourhood Plan for the area makes clear the continuing opposition of the local community to development of the site.
- Proposing to develop the whole of it has no planning justification and appears to have arisen only because of the unwillingness of EHDC to make sufficient land available for housing elsewhere within the district.
- When looked at in combination with proposals in this plan for development at Gilston and Sawbridgeworth and proposals in Uttlesford’s draft plan for development to the north of us, this would create a ribbon of development from Harlow to Stansted Mountfitchet, rivalling pre-war developments along the arterial roads. The planning system is supposed to help us avoid the mistakes of the past, not compound them.
- We suggest that that the allocation to Bishop's Stortford should be reduced by 1000 dwellings, and that either the overall total of 18040 dwellings in the plan should be reduced by 1000 to a slightly more realistic number, and/or 1000 additional dwellings should be distributed among the villages.
Detailed Changes to the Plan
- Our suggestions are set out paras 63-84 of the full note of our objections.
- We wish to highlight here our concerns about secondary education in the town and policy BISH6. If the plan (including development of BSS) remains unchanged, it will create a demand for 13 FE of additional secondary school places.
- HCC have firm plans in place for a new school of only 6 FE of additional places (at BSN). They would like to provide the balance by expanding existing schools but there is no certainty that this is feasible or that the existing schools would be willing to agree to it.
- Moving the Boys High School of itself creates no extra places. An entirely new school might be needed and BSS would provide the only suitable site for it.
- If BSS remains in the Green Belt, there would be no question of the High School moving to it. If the plan remains unchanged and BSS is developed, the High School should stay on its present site. Policy BISH6 should therefore be deleted.
- The SHMA should inform, not prescribe, the volume and distribution of housing in the district and it is no more likely that this plan will deliver appropriate infrastructure to support its housing proposals than we have experienced with previous plans.
- Sacrificing Green Belt for nearly half of the planned housing total, adding more dormitory suburbs to the main urban settlements and strangling development in villages is not the most appropriate strategy for the district.
- The plan is not deliverable. The housing completion rates envisaged have never been approached in the last 25 years and will not be accelerated by identifying more land for house building.
- The plan is not consistent with national polices in the NPPF for avoiding top down directives, empowering local communities, protecting the Green Belt or sustainability.
The plan is unsound.