The St Albans draft Local Plan has been published for the plan period of 16 years from 2020 -2036. The plan period is broken down into sub-periods:
- 2020 – 2025
- 2025 – 2030
- 2030 – 2036
The vision of the plan is for “a thriving community, which is a great place to live and work and has a vibrant economy”.
The Local Plan Issues and Options consultation was held on 8th January to the 21st February 2018, although there had previously been several consultations on the earlier draft Local Plan documents in 2006-2016.
The Council consulted on the publication Draft Local Plan from the 4th September to 17th October 2018. Submission of the Draft Plan to the Secretary of State is proposed for March 2019, Public Examination by Summer 2019 and the estimated date for the adoption is anticipated for Spring 2020. For an Authority with one of the oldest adopted Local Plans (if not the oldest at 1994!), we welcome the formulation of the Council Local Plan, especially in housing supply by having a continued plan approach for increased growth. However, this does not address the 2018 -2019 housing needs and previous housing shortfalls.
With regards to the provision of housing target for the period 2020 – 2036, the Council is set to provide 14,608 additional homes at an overall average of 913 homes per annum, split into three time periods to reflect rates of delivery of both the required infrastructure. The requirement target per annum from 2020 – 2025 is 565 per annum, whilst the requirement target from 2025 – 2030 is 1,075 per annum and the target from 2030 – 2036 is 1,075 per annum.
Policy S2 of the Draft Local Plan identifies a number of “Broad Locations” for development to contribute to meeting the housing, infrastructure and other development needs over the plan period. The Broad Locations and the numbers of the housing allocations are shown below.
The Broad Locations
· Policy S6 iii) – East Hemel Hempstead (South) 2,288
· Policy S6 i) – East Hemel Hempstead (North) 1,538
· Policy S6 iv) – North Hemel Hempstead 1,380
· Policy S6 ii – East Hemel Hempstead (Central) 10,000 jobs
· Policy S6 v – East St Albans 1,138
· Policy S6 vi – North of St Albans 988
· Policy S6 vii – North East Harpenden 700
· Policy S6 viii – North West Harpenden 530
· Policy S6 ix – West London Colney 380
· Policy S6 x – West of Chiswell Green 365
· Policy S6 xi – Park Street Garden Village 2,180
Summary of Key Growth Areas:
East Hemel Hempstead
The East Hemel Hempstead proposed development Masterplan for the location was led by the Council in collaboration with Dacorum Borough Council, local communities, landowners and the other stakeholders. The East Hemel Hempstead development Sites is located south of the M1 and north of the A4147. North Hemel Hempstead Broad Location will provide 1,388 dwellings, of which 40% are to be affordable housing and 3% which equates to 41 of those dwellings are to be self-build. The East Hemel Hempstead (North) Broad Location make provision of 1,538 dwellings of which 40% will be affordable housing in accordance with Policy L3 and 3% (46 of the homes) to be provided are to be self-build. The East Hemel Hempstead Central Broad Location is for the provision of a range of employment uses for 10,000 jobs: including offices, research development, light industries and logistics.
The East Hemel Hempstead (South) site is proposed to provide 2,288 dwellings of which 40% will be Affordable Housing in accordance with Policy L3. A total of 3%, which equates to 68 of the proposed development are to be self-build housing with new neighbourhood and local centres, including commercial development opportunities.
The East St. Albans Broad Location is situated north of the A1057 Hatfield Road and is to provide 1,138 dwellings (including an area with extant permission for 348 homes) of which 40% are to be affordable housing. Also, 3% of the homes (34 homes) are to be provided for self-build housing. North St. Albans Broad Location is located east of the A1081 Harpenden Road and is to provide 988 dwellings of which 40% are to be Affordable Housing. Also, 3% of the homes which equates to 29 dwellings are to be self-built housing. See Figure 3 below.
The North East Harpenden Broad Location is situated and is to provide 700 dwellings of which 40% are to be Affordable Housing and 3% (21homes) are to be self-build housing. North West Harpenden Broad Location is to provide 530 dwellings of which 40% are to be Affordable Housing and 3% which equates to 15 dwellings of the total housing to be provided are to be self-built.
West of London Colney Broad Location is situated north of the M25 and west of the B5378 and is to provide 380 dwellings of which 40% of the housing are to be Affordable, whilst 3% (11 dwellings) to be provided are to be self-built housing.
The West of Chiswell Green Broad Location is situated west of the B4630 and is to provide 365 dwellings whilst 40% are to be Affordable Housing and 3% (11 dwellings) are to be self-build housing.
Park Street Garden Village Broad Location is situated south of the A414 North Orbital Road and is to provide 2,180 dwellings, whilst 40% are to be affordable housing and 3% which equates to 65 of the dwellings to be provided are to be self-built. Two 15 pitch Gypsy and Travellers sites are also to be provided in the Garden Village.
This draft Plan has also been welcomed by the House Builders Federation (HBF) and considered the Plan to be long overdue. We see the provision of housing in the Draft Plan to be adequate in numerical terms. However, we are concerned in relation to the provision of housing for the planning period 2020 -2036, this is because, there will be a significant backlog of housing provision, since the plan to build more housing starts in 2020 and not considering the period for 2 years for 2018 – 2019. The question being asked is whether the Council’s Emerging Plan is shifting the Plan forward. This Plan is flawed by not starting the trajectory base date at 2018. Hence, this approach is not considered to be a suitably evidence-based plan.
Duty to co-operate
The draft Local Plan for St Albans states that it is committed to working with neighbouring Councils of Dacorum, Hertsmere, Three Rivers and Watford as part of the South Hertfordshire Housing Market Area and the agreement to produce a joint strategic plan for this area. This is a welcome development, and one only hopes that progress will be made on this plan and allows for the needed infrastructure required to meet the areas of development needs.
The previous Local Plan submitted by the Council had failed in its Duty to Co-operate since there is no evidence by the Council to demonstrate how it has rectified this matter in preparing this Local Plan. However, the only statement on Cooperation within the Council evidence base that is apparent is in the 2017 Authority Monitoring Report. The Report in Paragraph 3.6 summarised the many discussions that have taken place with neighbouring authorities and other statutory bodies. The Council have not shown whether there are any neighbouring areas that cannot meet their own needs and how the Council have worked with those areas in trying to meet these needs in spite of the stipulation in Paragraph 60 of the NPPF.
Paragraph 27 of the NPPF makes vivid what is required to show effective and on-going joint working by stating that:
“in order to demonstrate an effective and on-going joint working, strategic policymaking authorities should prepare and maintain one or more statements of common ground, documenting the cross-boundary matters being addressed and progress in cooperating to address these. These should be produced using the approach set out in national planning guidance and be made publicly available throughout the plan-making process to provide transparency”.
With regards to the Duty to Cooperate, we urge the Council to produce the necessary statements of common ground which identifies the main cross-boundary issues and the progression being made in addressing these matters before the Plan can be found sound.
The delivery of housing in broad locations where Green Belt boundaries will be amended to enable the necessary development which is the strategic focus of St Albans local Plan Policy S2 and details of broad locations are set out in Policy S6. We consider the identification of these areas a welcome development, however, it is imperative that the Council should ensure that those broad locations can deliver the rate and scale of residential development as suggested in this plan. With regards to supply, the Council should ensure that there is evidence to support the windfalls. The Council must be able to demonstrate a five-year land supply on adoption. Hence, we are concerned that even with the proposed stepped trajectory and starting the plan period at 2020, the Council will only have a 5.02 years land supply on adoption. This is a marginal position and places the Council of a consequential risk of the Plan being considered out of date on or soon after adoption. However, if the plan period commences from 2018 as is required by NPPF, the Council would have, even using the Council proposed stepped trajectory, a 4.57 years housing land supply. The stepped trajectory evidence of this Plan suggest to allocate adequate sites in the first five years of the plan and is overly reliant on delivery later in the plan period. We suggest that rather than the Council seek to manipulate the plan period and trajectory, it should have looked to plan more effectively to meet its housing needs earlier in the plan period.
The issue of availability and the deliverability of Park Street Garden Village under Policy S6xi is also a major concern. This stems from the fact that the Council do not have the necessary evidence with regards to the availability of the site for the proposed allocation as a Garden Village. There is no clear decision as to the kind of development that will take place on this site and whether there is a reasonable prospect of the site being available at the point anticipated within the Local Plan. We suggest that the plan should address this uncertainty prior to the submission of the Local Plan before it can be considered developable as stipulated in Policy S6xi.
Another issue is how the Council intends to deal with their housing shortfall since St Albans has consistently not met their housing target, is still unclear and how the methodology intends to deal with this issue and needs clarification. The Community Infrastructural Levy (CIL) also needs to be set alongside with the Plan, this seems to be absent in the current St Albans Draft Local Plan.
Housing mix and density, size, type
In terms of the housing mix under Policy LI, this seems to be quite confusing and unclear, since there are no clear numbers and or helpfully, prescription of bedroom’s size/mix but rather the Policy states that all housing development will be expected to contribute to a different housing types by directly addressing the evidence of local needs, whilst considering the existing pattern of development in the area and site-specific factors. We suggest that the council makes clear indication within this policy as to the general mix of property size based on the number of bedrooms it is seeking to deliver within the Borough. The general mix will then inform, but not dictate, the type of development that is delivered. Hence, we are of the view that Policy L1 should be amended so as to provide an indicative housing mix for development.
The Plan needs to be addressed and one way of doing this is to get the Plan out of the local councillors to the Planning Inspector, this is based on the failure of the Council to deliver on previous plans. Another issue that the Draft Local Plan did not address, is that of timing for infrastructure implementation before the proposed housing is delivered. The specifics of where the Park Street Garden village ‘Broad Location will be situated was not adequately addressed in the Plan.
In summary, St Albans emerging Local Plan seems promising in terms of the proposed housing numbers for the plan period which are to be built in “broad Locations”, of which some of the sites are in the Green Belt. In order for the Plan to be considered sound by an Inspector, the above criticism should be considered by the Council. Overall, we consider St Albans Local Plan unsound in terms of its evidence base, duty to cooperate, and cast doubts as to how it will meet its projected housing numbers.
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