Rt. Hon. James Brokenshire MP
Secretary of State for Housing
Communities and Local Government
Fry Building
2 Marsham Street
London
SW1P 4DF
19 August 2018
Dear Secretary of State
EAST HERTFORDSHIRE DISTRICT PLAN
1. I am writing on behalf of the Bishop’s Stortford Civic Federation to support the request of CPRE Hertfordshire (CPREH) that you direct East Hertfordshire District Council to submit this Plan to you for your consideration.
2. Like CPREH, we do not believe that the Inspector has taken proper account of para 14 of the National Planning Policy Framework (NPPF) applicable to this plan. This says that Local Plans should meet objectively assessed needs unless specific policies in the Framework indicate development should be restricted. It cites land designated as Green Belt as an example of a policy which would indicate that development should be restricted.
3. This Plan provides for 43% of all the proposed new housing to be developed on land which is currently designated as Green Belt. In reaching the conclusion that this is a sound outcome the Inspector appears to rely firstly on a Sustainability Appraisal which assumes that urban extensions (or urban sprawl) will always be preferable to a more dispersed pattern of settlement, because of the alleged superior provision of infrastructure and facilities. However, this was an a priori assumption made by the authors of the Plan at the start of its preparation which was then fed into the Sustainability Appraisal, and thus predetermined its conclusions. It has never been objectively tested in the Plan making process either generally across the District or in relation to individual settlements and appears not to have been questioned by the Inspector.
4. The Plan proposes that Bishop’s Stortford, the largest town in the District should be allocated 5 times as many new homes as Hertford, a town two thirds its size, and 9 times as many homes as the villages, whose combined population is greater than that of Bishop’s Stortford. She concludes (in para 62) that without release form the Green Belt, there would not be enough homes to meet the needs of people within East Herts.
5. This is patently incorrect. Evidence provided by the Civic Federation and available to the Inspector shows that the housing total included in the Plan is far in excess of that which is needed to meet the needs of people within East Herts and that its distribution makes no attempt to satisfy demand in the places in which it arises. So, housing provision in Bishop’s Stortford is far in excess of the needs of the local population and leads to loss of Green Belt. Housing provision in the villages on the other hand makes no attempt to satisfy locally arising demand, forcing people to move away and putting at risk the viability of the supporting infrastructure on which those villages depend.
6. The Inspector concludes (in para 17) that the highest level of growth can be supported in Bishop’s Stortford. The Civic Federation presented substantial evidence that in spite of absorbing some 40% of all new housing in East Herts over the last 30 years, Bishop’s Stortford has suffered a significant depletion in the infrastructure which might have been expected to support such growth – no improvements to the highway network and the loss of the district general hospital, police station, magistrates court and job centre with even the District Council reducing its presence here. There are no proposals in this Plan to remedy any of these shortcomings – particularly in the case of the highway network – and we can only assume that the Inspector has chosen to ignore our evidence.
7. The so called Objectively Assessed Housing Need (OAN) on which the inspector relies assumes an average rate of completions of 839 per annum over the Plan period (higher than that in practice because the Plan is backdated to 2011 and completions have been lower since then). This represents an increase of about 60% in the rate of completions compared with what has been achieved in East Herts over the last 25 years. The Inspector does not explain how the construction industry is going to overcome its skills shortage and aging workforce (particularly after Brexit) to generate this sustained increase in activity. Nor does she explain why the commercial house building industry would put its profit margins at risk by releasing housing on to the market more quickly.
8. Greg Clarke MP in his forward to the NPPF which applies to this Plan says
‘Yet in recent years, planning has tended to exclude, rather than include, people and communities. In part, this has been a result of targets being imposed and decisions taken, by bodies remote from them.’
9. This comment certainly applies to the OAN. How it was derived is particularly impenetrable and its distribution between the four participating authorities has been the subject of no public engagement at all. To the lay person the result appears simply to be to allocate green field sites for commercial house building in the places where developers think they can make most money. Given the industry’s capacity problems referred to above, there is every likelihood that these allocations will not lead to more completions but unnecessary blight.
10. In Paras 61 and 62 of her report the Inspector explains the considerations that have led her to agree to the Green Belt boundaries being altered to absorb 43% of all the new housing in the District. In doing so she makes no reference to para 14 of the NPPF and whether the OAN accepted by East Herts should be modified as a result of the Green Belt policy constraint.
11. At the Examination in Public the Inspector acknowledged that the exceptional circumstances test for altering Green Belt boundaries had to be considered in relation to each individual site as well as collectively. In para 65 of her report the Inspector proposes the release of Bishop’s Stortford South from the Green Belt which, with other consequential development would lead to Bishop’s Stortford being allocated some 900 extra homes. This site has previously been considered for release from the Green Belt in relation to the previous District Plan and by your predecessor, Mr Pickles, following a planning appeal in 2012. On both occasions, its Green Belt status was upheld. The Inspector in her report offers no explanation as to what exceptional circumstances have now arisen that would justify a change in its status.
12. Although the Civic Federation provided substantial written evidence about the distribution of housing in East Herts, the sustainability of the overall strategy, and the loss of Green Belt, the Inspector declined to hear any oral representations from us in the part 1 hearings of the Examination in Public on these matters. Although we were assured that the Inspector would pay careful attention to written evidence, nothing in her report suggests that she has paid any attention to our evidence at all.
13. In conclusion therefore, we would ask you to call in this Plan for you own consideration before East Herts Council consider it for adoption on 11 September. We do so because
- The OAN is greatly in excess of the needs of the people living in East Herts.
- It appears to be an externally imposed target no different in kind from that generated by the previous planning regime.
- Its distribution within East Herts makes no attempt to meet the needs of people by reflecting the pattern of settlement in the District.
- Its delivery under this Plan will lead to major releases of Green Belt Land.
- The ability of the construction industry to deliver the Plan’s target has not been demonstrated.
- The exceptional circumstances, required by the applicable NPPF to justify the release of Green Belt land for development, have not been demonstrated generally for the District.
- No exceptional circumstances have been demonstrated for the release of Bishop’s Stortford South from the Green Belt for development, since the two previous occasions on which such proposals have been rejected.
14. The Plan in its present from is therefore unsound and ought not to be left unaltered for the District Council to adopt.
Yours sincerely
JOHN RHODES
PRESIDENT