By Email
Helen George
Housing Development and Strategy Manager
East Herts Council
Pegs Lane
SG13 8EQ 21 September 2021

1. I am writing on behalf of the Bishop’s Stortford Civic Federation to comment on this document.

General comments

2. We begin with some general comments about the coverage of the document itself. It says, under Themes and Priorities that the new strategy gives the opportunity to set out the overall context and aspirations for housing in the District and the vision for the communities and the homes we want. However, the document is entirely silent on the great majority of new housing provision in East Herts and indeed the rest of England, which is the provision of new housing on market terms by volume housebuilders. So it makes no attempt either to describe the aspiration for housing in the District or to set out a vision for the communities and homes we want in respect of most housing provision.

3. Much of this is of course the product of the interaction between the planning system, particularly the District Plan adopted in 2018, and the parts of the District in which housebuilders have assembled their land banks. As we pointed out in our submissions on the District Plan before its adoption, this will lead to some perverse results. In particular, in the case of Bishop’s Stortford and its surroundings, overall housing supply far exceeds the naturally arising demand in the locality. On the other hand, housing supply in the District’s many rural settlements has been planned to fall well short of naturally arising demand.

4. The result will be to lead to those settlements becoming increasingly unsustainable places in which to live. Young people wanting to leave the family home and set up a new household will find that they are unable to stay in the community in which they grew up. Similarly, older people who want to downsize will face the same problem as the younger generation – insufficient or no provision of suitable housing they can move into in their own communities, as a deliberate consequence of the policies adopted in the current District Plan. This excludes the people most likely to support the services that help to sustain rural communities – the GP surgery, shop, school, local bus service – even the pub and the church. Eventually these villages will become mono-cultural middle-aged enclaves entirely dependent on the private car.

5. The provision of housing in the District Plan is due to be reviewed five years after its adoption ie in 2023. A new housing strategy could therefore provide an ideal opportunity to influence that review by insisting that the shortcomings in the current plan, described above, are properly addressed.

6. In the meantime, the strategy could at least make some recommendations about the minimum quality standards which all new homes should comply with to make them more sustainable for the future. We suggest that these should include a requirement for all new housing to be fitted with solar panels, separation of drinking water from potential ‘grey’ water supplies for uses such as toilet flushing, and future proofing water and space heating provision in anticipation of the phasing out of natural gas as a domestic fuel source. Domestic housing is a major source of greenhouse gases, and continued reliance on the minimum standards required by current building regulations will simply lead to retrofitting in times to come. This is far more expensive than designing in the features we are suggesting at the outset in new developments. It is open to the Council, as planning authority, to insist on these higher standards as a condition of planning permission but so far it has chosen not to.

7. Finally, in this section, we feel we should comment on the time horizon for this strategy. Housing is a long lived asset and assembling land, obtaining planning permission and building new homes is a time consuming process. If the strategy were to introduce significant policy changes then, apart from influencing the review of the District Plan, nothing at all is likely to be achieved within a five year timescale. At the very least the strategy should have the same time horizon as the District Plan, ie to 2033, with ambitions to match.

8. In practice, in spite of its title, this strategy appears to be simply a description of how the Council intends to discharge its residual responsibilities as a housing authority over the next five years. Our remaining comments therefore examine how far it fulfils this much more limited remit.

9. In this context, it would have been helpful if the document had described the statutory duties imposed on the Council and the discretionary powers it is able to exercise in helping it to discharge those statutory duties or in addition to those duties. It might then have identified problems impeding the discharge of its duties or the exercise of its powers and concluded with an action plan designed to overcome the problems identified. Because the document does not do this, we have had to infer that the main residual duty of the Council is to ensure that housing is provided for people who have been unintentionally made homeless.

Housing Needs

10. This issue is covered in the opening section of the document describing housing need. It notes that the number of households in temporary accommodation remains high due to an increase in the number of single persons with complex housing needs, but also says that the most significant increase in growth of demand is for two and four bedroomed accommodation, which seems somewhat at odds with the previous statement. However, the most significant part of the text, which is also relevant to the next section, concerns the gap between housing which people can afford, and the cost of so-called affordable housing which follows the Government’s definition of affordability being 80% of market values whether for ownership or rent.

11. The document itself acknowledges that East Herts has the UK’s 9th highest level of market rates for house prices outside London. Even if the District Plan’s build out rates were to be achieved, the effect on market prices is likely to be imperceptible. The effect of the Covid pandemic seems to have increased the upward trend of prices in our area. Not only do people want to move out of London to occupy somewhere more spacious but the increased prevalence of homeworking also makes a larger home a necessity, and Bishop’s Stortford in particular is an attractive destination from that perspective. All of this makes the gap between the current definition of affordability and average incomes particularly large. Indeed, those who are on incomes well above the average still find our District too expensive to move to.

12. This is important for a much wider segment of the population than those who appear on the Council’s housing register. Key workers, such as teachers, emergency services staff and health and care staff and even less well paid occupations such as refuse collectors need to live near their place of work, but cannot afford to do so. The Council may have no statutory obligation towards these staff, but many of them will be public sector workers whose recruitment is frustrated by the high cost of housing. We would have expected a housing strategy, even within the more limited remit of this document to have addressed this issue which is fundamental to the communities we want to live in.

Housing Supply

13. The next section on housing supply in this document is perfunctory and does little more than suggest that new policy statements will be made and that further research will be needed. We suggest that this is a wholly inadequate response to a problem that will only get worse and that what is need is action, not words. Firstly, it is clear, even from the limited information provided, that S106 agreements do not deliver housing at less than market rates in sufficient numbers. Higher build out rates are not likely to change this even if developers could be persuaded to increase the rate of completions and the proportion of affordable housing included within their schemes, and anyway, ‘affordable’ properties are not really affordable, both for those who qualify for them and also for a much larger section of the population. Secondly, as implied in our general comments, it does not necessarily lead to affordable housing being built in the places where it is needed but in the places where commercial developers want to build. And there also seems to be a mismatch in property types – too many small apartments and not enough family homes with gardens.

14. We agree with the HQN consultancy’s view that the planning delivery model needs improving through “direct delivery and formal partnerships” but not that the first “challenge” is to improve overall supply when S106 agreements cannot be relied on to deliver housing at less than market rates. We do however agree with their view that the increased use of Permitted Development Rights has not been shown to deliver social or affordable market housing of the necessary quality or quantity.

15. An obvious solution, only tentatively suggested by HQN consultancy, would be for the Council to re-engage in the direct provision of housing itself. This would enable it to meet need in areas not favoured by developers, produce housing types which reflect actual need more closely and charge social rather than ‘affordable’ rents to the occupants. It was a policy widely followed in the past, but much of that housing has been removed from the social sector as a result of the ‘Right to Buy’. The residents of Bishop’s Stortford at least might think that this would a more beneficial use of the Council’s capital resources than its current plans for our town centre.

Housing Standards and Environmental Sustainability

16. We have commented in para 6 above on housing standards and environmental sustainability. Our comments are relevant to housing as a whole, not just to the areas of housing covered by this strategy. Here too we think that action would be more productive than words. We do however welcome the suggestion of planning for a Passivhaus scheme in the District.

Housing and Development of Communities

17. This theme has little to say about anything except gypsy and traveller communities but also contains two remarkable but unsubstantiated statements.

18 Firstly, it asserts that new strategic developments and renewal projects in East Herts including Harlow and Gilston Garden Town, East of Stevenage, East of Welwyn Garden City, Hertford Sele Farm, and Northgate/Old River Lane will lead to attractive and sustainable communities. All of these are at an early stage of planning and, while this may be the aspiration, there is no evidence yet that it can or will be achieved.

19. Secondly it sets out as an imperative that ‘affordable housing must promote economic growth’ Why? Affordable housing is not an economic development vehicle. Its primary purpose is to ensure that everybody is accommodated in homes of good quality, appropriate to their needs and at a cost they can afford. A well housed population is likely to be more productive and thus benefit the economy, but that is a by product, not the purpose of affordable housing.

Housing and Future Proofing

20. Please see our comments at paras 5 to 7 above.


21. It will be apparent from our comments that we do not think that this document is a housing strategy and that even from the much more limited perspective of the Council’s housing duties and powers it is a strategy with far too limited a time horizon to effect the beneficial changes which are clearly needed.

We hope you find these comments helpful.

Yours sincerely