Site Allocations and Development Management Policies DPD: Consultation March/April 2014 Summaries of Representations and Council responses. Chapters 1-2 July 2015 SADM SADM Consultation Draft reference and Representation reference Objection Comment Support Issues Response Whole Document 01139/2/001 Many previous comments (dated 03/04/2013) on DM Policies were We have considered both the previous response and this Environment not taken through into the Consultation Draft. Support some of the response as part of this exercise. See responses to Agency policies and paragraphs, but many require further refinement to Environment Agency throughout this document. improve the strength/clarity and comply with National and Local Policies before we could support them. Sequential Test and where necessary the Exceptions Test should be carried out where site allocations are proposed in areas of flood risk as required by NPPF para 100, 101 and 102. We note sites H2 and H7 both lie partially within Flood Zone 3, which forms part of the flood plain for the Borehamwood Brook and the King George Drain Main Rivers. It's important that the Council's evidence base, the Strategic Flood Risk Assessment (dated 2008) is used as a basis for applying the sequential test. At the moment it's not clear how the sequential test has been applied to the sites and whether the Council considers that these sites would pass. We may find your site allocations unsound if the sequential test has not informed your choice of sites and forms part of the evidence base. 01210/1/001 Watford Borough Council have reviewed the SADM DPD for Noted Watford Borough Hertsmere and are supportive of the approach. Council 01275/1/001 Support whole document Noted Warren Estate Residents 1 SADM SADM Consultation Draft reference and Representation reference Objection Comment Support Issues Response 01240/1/001 Concern about integration between policies in Chapters 4, 5 and 6 on Noted. Relevant Core Strategy Key Objectives have been HCC Environmental matters of sustainable design - policies compartmentalised in such a added to the boxes at the start of each of Chapters 2-7 Resource Planning way that the interdependencies between them are not made and provide a clear direction for the policies in each apparent. Risk to achieving integrated and well-thought out design chapter. when applicants and Council are formulating and considering proposals, and raises a doubt as to whether the internal consistency and cumulative impact of these policies on the quality of design has been properly considered. Should describe relationships between these policies eg matrix table showing the correlation between SADM policies and the Core Strategy objectives. 2 SADM SADM Consultation Draft reference and Representation reference Objection Comment Support Issues Response 01187/1/001 Hertsmere committed to early partial review of Core Strategy within 3 The Core Strategy is clear that a Site Allocations and Nathaniel Lichfield years including work on objectively assessed housing needs. Should Development Management Policies DPD (SADM) will be and Partners for either do the review first, or roll Core Strategy review and SADM into prepared. One of its key purposes is to help implement the Commercial one. SADM will work towards fulfilling Core Strategy housing targets Core Strategy, including implementation of the stated Estates Group but this delivers less housing than necessary to meet full objectively housing target. The preparation of SADM enables a review assessed needs. NPPG says CLG household projections should be used of all development management policies and boundaries of - latest are 553 pa 2011 - 2021 for Hertsmere (double Core Strategy policy areas in the Local Plan (within the context provided figs). Hertsmere is aware the housing need won't be fully met by CS1. by the Core Strategy). It is therefore quite appropriate, SADM should include updated housing target. NPPF para 153 "in reasonable and, indeed, necessary to complete SADM in producing a Local Plan, any additional development plan documents accordance with the Local Development Scheme (subject to should only be used where clearly justified." There is no any updating of the timetable). The completion of SADM clear justification for SADM being completed now, and not as part of will in effect modernise the planning policy base and, the impending review. together with the existing Core Strategy, create a new Local Plan, The NPPF accepts that local plans may be reviewed as a whole or in part. It accepts there may be separate development plan documents, provided that is explained rationally. The Council is committed to a review of key elements in the Core Strategy – specifically to consider housing and employment needs further. The review of the strategic issues and commissioning of key evidence with neighbouring authorities began in late 2014 and will continue beyond the planned adoption of SADM. If objectively assessed housing needs are very substantially higher than currently planned for within the housing market, then there are serious and potentially controversial issues to be debated with the 3 SADM SADM Consultation Draft reference and Representation reference Objection Comment Support Issues Response public. It would be wrong to assume the Green Belt boundary in Hertsmere should automatically be changed (ref NPPF para 14), but solutions accommodating major development could have major consequences for the Green Belt and a number of existing communities. The Council intends to conduct such consultations sensitively and transparently with the appropriate evidence available, and without the complication of a myriad of many other issues. The Council considers that its approach to the preparation and review of its planning policies is justifiable, and reasonable. No change. 00234/2/002 Seek assurances in relation to development proposals that the Development proposals will be assessed in relation to Elstree and following will be taken into account: - impact on wildlife (especially relevant policies contained in the Core Strategy and Site Borehamwood railway banks and gardens) - building on railway banks should be Allocations and Development Management Policies DPD. Town Council realistic and not pose a significant nuisance to local residents - design Relevant policies seek to protect wildlife (CS12) protect the should be sympathetic to character of local area and street scene - occupiers of sites and the local community (CS16) and conversion of garages to residential units should be avoided - impact ensure good quality design (CS22, SADM31, Planning and of conversions from Borough owned sites eg garages should not cause Design Guide SPD). The conversion of garages to residential undue negative impact - loss of storage and parking use is in many cases not controllable due to permitted development allowances; where appropriate it may be controllable through conditions / Article 4 directions. Where development proposals involve the potential loss of garage courts it is necessary to investigate their current usage and, if possible, alternative provision should be identified. This criterion is added to the Site Specific Requirements for H1, The Director’s Arms proposed housing site. 4 SADM SADM Consultation Draft reference and Representation reference Objection Comment Support Issues Response 01350/1/003 Shire When taken with the existing Core Strategy the current document is This response has been considered along with other Consulting for much too long. Some duplication with Core Strategy eg SADM 26 = responses, including those from statutory consultees. It is Exchange Ltd two 'Development Plan' policies concerned with heritage assets. considered that the policies listed are necessary and Neither adds anything 'Hertsmere specific' over and above the NPPF. expand on national policy. The policies have been updated Policies in the District Plan should not duplicate or repeat those in the in response to feedback. NPPF and should not cover matters already dealt with in other legislation. SADM Policies 10, 12, 13, 18, & 27 are just a few examples where nothing is added to the national position and SADM9 is not a policy at all. Removing such unnecessary policies will reduce the risk of the Plan being found 'unsound'. 01242/1/001 Shire When taken with the existing Core Strategy the current document is This response has been considered along with other Consulting for much too long. Some duplication with Core Strategy eg SADM 26 two responses, including those from statutory consultees. It is Radlett 'Development Plan' policies concerned with heritage assets. Neither considered that the policies listed are necessary and Preparatory School adds anything 'Hertsmere specific' over and above the NPPF. Policies expand on national policy. The policies have been updated in the District Plan should not duplicate or repeat those in the NPPF in response to feedback. and should not cover matters already dealt with in other legislation. SADM Policies 10, 12, 13, 18, & 27 are just a few examples where nothing is added to the national position and SADM9 is not a policy at all. Removing such unnecessary policies will reduce the risk of the Plan being found 'unsound'. 5 SADM SADM Consultation Draft reference and Representation reference Objection Comment Support Issues Response 01243/1/001 Shire When taken with the existing Core Strategy the current document is This response has been considered along with other Consulting for much too long. Some duplication