Agenda item

Consultation on Modifications to the Site Allocations Development Plan Document (DPD)

Minutes:

Councillor Guest requested to address the Committee regarding this matter.

 

The Chair agreed.

 

Councillor Guest made the following address:

 

Leader, Cabinet, this document raises questions.

 

It states on P3-4 of the report that advice from key stakeholders such as the Local Education Authority and the Highway Authority should be sought where appropriate. Feedback on the Borough Council’s Infrastructure Delivery Plan has also been significant in developing a clear understanding of infrastructure needs. Will the road infrastructure in and accessing LA3 and the Site Allocations be able to cope with the traffic generated? Is there a commitment from the County Council that a new primary school at LA3 will happen?

 

The level and broad location of new development including the principle of releasing the six Local Allocations from the Green Belt has already been established through the Core Strategy. That is why I spoke and voted against the Core Strategy. It would mean the release of LA3, and I am opposed in principle to releasing this high quality Green Belt for building.  One of the most important aspects of the Site Allocations is the inclusion of policies to deliver the six Local Allocations, including 900 homes at LA3. I have been opposed to building on this land since 1996 and couldn’t support policies to deliver the development of it.

 

The Local Allocations will be managed as countryside until they are required for development. Can an assurance be given that they will remain countryside until all the brownfield sites have been exhausted?

 

The Green Belt has always been a constraint to be taken into account when deciding how far a council can go towards meeting its objectively assessed housing need. However the NPPF does allow for new Green Belt boundaries to be drawn when a council reviews its strategic plan. If the Green Belt is a constraint when meeting objectively assessed need, why propose the release of it? Could falling short of meeting housing need because of Green Belt constraints have been successfully defended to the Inspector at Examination? If it could, can the need to develop the Local Allocations be revisited in the Early Partial Review process?

 

Since the publication of the Pre-Submission Site Allocations Document there has been a re-run of the Hemel Hempstead Transport model. The Infrastructure Delivery Plan of June 2015 has an update to the 2014 report to ensure that infrastructure issues raised though the Pre-Submission consultation are discussed and addressed by service providers.

 

Updates of transport modelling and the addressing of infrastructure issues raised by consultation are welcome. However who commissioned these studies and who conducted them?

 

It is welcome that liaison with infrastructure providers has continued through the preparation of an update to the Council’s Infrastructure Delivery Plan, including meetings with the old PCT, West Herts. Hospitals Trust, Highways England, Thames Water and Children, Schools and Families at Herts. County Council.  Now that PCTs have gone, are the meetings continuing but with Herts. Valleys CCG and NHS England?

 

Infrastructure providers have confirmed that there are no infrastructure “showstoppers” that would prevent the delivery of development subject to the timely delivery of infrastructure. Does the Infrastructure Delivery Plan detail when infrastructure will be delivered to show that it is timely for the new development?

The only outstanding infrastructure issue is with the Environment Agency regarding waste water and sewerage capacity. The comments from the Environment Agency may be late, they may refer to the overall quantum of development rather than specific sites, Thames Water may support the Council’s approach as set out in the Site Allocations Document, the Environment Agency and Thames Water may be involved in work on a County-wide basis and it may be available to inform the early partial review of the Core Strategy. However can it be guaranteed that waste water and sewerage capacity will be adequate for each of the Local Allocations like LA3 when it is developed. If it isn’t you don’t need me to tell you what we’ll all be in!

 

For the submission, Habitat Regulations Assessments can be included at the Council’s discretion. Will they be for LA3, currently home to butterflies, bats and badgers? Will evidence of impact of development at this site on the river Bulbourne be submitted?

 

In the Core Strategy it is envisaged that the Local Allocations will be developed from 2021 onwards. However planning applications will be received and determined before then, and construction and works may take place before the release date to enable occupation of the new homes by 2021. What would be the status of the land at this point? Would it be Green Belt or not?

 

The Core Strategy, Site Allocations DPD, Infrastructure Delivery Plan and CIL all ensure that appropriate health infrastructure is provided. That includes improved GP cover as a result of LA3. However the Parkwood Drive surgery at Warners End doesn’t want to set up a branch surgery at LA3 and room for expansion on the current site is very limited. How is the NHS planning to provide GP cover?

 

In the light of recent ministerial announcements is there still the same need for the level of Gypsy and Traveller provision across the Borough as originally envisaged?

 

Answers to these questions will help to clarify what is needed now and whether there will be the infrastructure to support it.

 

James Doe responded that he would try to respond to the questions raised sequentially.

 

With regards to a review of the local allocations and whether it is appropriate to release this site before every greenfield site has been exhausted, the simple answer is no, however the gradual exhaustion of brownfield resource within Dacorum has led to a need for us to identify some sites that are in the green belt for development. Dacorum’s record on brownfield sites is exemplary as we have been delivering over 95% of our new housing on brownfield sites for many years, but that is a finite resource and has to end. He further added that they have to show through the local planning process show a steady and adequate supply of land to be built on and some of that resource will be brownfield but inevitably we will need to bring in some greenfield and green belt sites into that equation to make sure we have a robust housing land supply. He went on to add that the risk to the Council if we don’t make that supply available that we as a Council could be prone to speculative applications elsewhere in the green belt, where a developer might argue that we don’t have a sufficient supply. So we are trying to take a balanced approach with brownfield sites and some greenfield sites as well.

 

In terms of can this be revisited in the early partial review, the advice would have to be no, the reason being that when the local plan examination was held in October 2013, the inspector made it very clear in his report that he was concerned at the amount of housing that Dacorum actually allocated within its plan and gave us the option of doing an early partial review with a view to re-examining the housing numbers. All the evidence so far points to more land being needed for development, so on the current housing land supply information we have, I would advise against revisiting any of the six local allocations, through the early partial review. Work is being done on housing market intelligence and a meeting is to be held with Portfolio Holders next Monday to discuss the preliminary findings and we will be in a position to advise Cabinet what the new position will be for the early partial review in due course.

 

With regards to transport modelling work has been carried out for the Core Strategy as a whole and the Borough Council has commissioned that from County Council through its traffic management and forecasting models and that has shown that the network with some selected improvements, does have capacity to accommodate the additional development that we are proposing for developers to undertake through the local allocations. There will be some further transport modelling undertaken at the time of the planning application, as a planning application of this nature will require a transport assessment and the details of these improvement will be arranged through that transport assessment process.

 

With regards to health improvement, meetings are continuing with the Herts Valley Clinical Commissioning Group. In terms of provision for GP cover, that is still under discussion with the CCG. The main thing we are doing as a Council for this at present is to make the land available, through the development, for a facility. The current view of Parkwood Drive Surgery is that they wouldn’t be prepared to set up a satellite surgery in that location, but talks are still underway with them and the CCG regarding that provision. As a Local Authority we have to make the land available and the NHS have to provide the facility.

 

In terms of the Infrastructure Delivery Plan, this has been ongoing for some years now and the first purpose of it is to simply assess the amount of infrastructure that we need across the Borough. With regards to when this is phased in, this document is to make sure we are getting the right delivery of infrastructure through the successive developments of the various sites. So the Infrastructure Development Plan works hand in hand with the Core Strategy and the Site Allocations document to make sure we have a clear provision at the appropriate time. With regards to Highways and Educational provision, those are to be secured through a Section 106 agreement and not through CIL. As to the County Council’s commitment, they are engaged within this process and the primary pull on the development resources will be to deliver the two form entry primary school on this site.

 

The report does state that the Environment Agency’s reports were late, but had earlier indicated that here was capacity within the system. He went on to assure the committee that at planning application stage, the correct provision of drainage will be addressed, as has been done at Spencer’s Park.

 

In terms of the Habitat Regulations and the river Bulbourne, all sites have been subject to continual environmental appraisal, and more detailed investigations will be carried out at the planning application stage.

With regards to the questions around timing, the Plan states that the green belt sites, the Local Allocations, are not to be delivered from 2021 onwards, however the implication of that is that developers will need to organise planning applications earlier, to ensure that we get the occupations from 2021. That is critical for our supply of housing, to make sure those properties are ready by 2021.

 

In response to the question as to when the site comes out of the green belt, that is essentially when this document is adopted, which we expect to be at some point next year, once it has been through examination and assuming that that is a successful process, that will remove the site from the green belt and pave the way for the planning application to be submitted.

 

James Does finished by advising that the report builds on the site allocation document which went through public consultation last year, which resulted in a number of changes. However they had also sought legal advice and advised the committee that they will need to re-consult on the significant changes to the plan, a lot revolve around the position at Tring, where we have had to seek further advice following the legal position regarding the position of cemeteries and traveller sites within the green belt, so the biggest change to report is a slight re-drawing of the green belt boundary, to take both the cemetery and the traveller site out of the LA5 designation within the urban area. This is a fairly minor change on the map but might raise some significant issues. Our legal advisor has suggested we go to consultation with that to keep the process robust.    

 

Councillor Sutton added that there would be a six week further consultation, which would mean that the final report would be submitted in early 2016.

 

Councillor Williams commented that he had thought this report was due to go to Council in September and enquired as to whether this was now not the case.

 

Steve Baker advised there would be the consultation period, it would then go to Council and then to the Inspector.

 

The committee agreed the recommendations of the report.

Supporting documents: