Appendix 1 - Publication Draft Local Plan - Analysis of Issues Arising (March 2019)

1.2 – Neighbourhood Plans

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point (see below for list Reply (including any of abbreviations) Changes to Plan)

Lack of strategic Jarvis Homes (973180) Disagree Cross reference to S2. The NPPF and draft Local Plan Minor modification to framework for support Neighbourhood planning. Given the specific wording S2 Neighbourhood Plan CALA Group Ltd used in the final NPPF 2018 (after the Council decision on 11 making due to out of (977724) July 2018 based on the draft NPPF) a minor modification If detailed local date 1994 Plan should be made to make clear that if detailed local evidence evidence justifies Albert Bygrave Centre development at a (985070) justifies development at a neighbourhood scale, on land currently designated as Green Belt, it is supported in neighbourhood scale, Park Street BCh & Bloor principle. on land currently Homes Ltd (985300) designated as Green Belt, it is supported in Rice Group (1058426) principle. Beechwood Homes (1123837) Linden Homes (1153662) Hertfordshire Land (1159945) Aldwyck Housing Group (1186030) DB Rees (Builders) Ltd (1160056) Land at the Dak (1186131) Hilton House Properties (1057476)

Owner of Land at Piggotshill Lane (1159948) Owners of Land South of Burydell Lane (1186128) 1153651 973643 Not enough Jarvis Homes (973180) Disagree The Local Plan deals with the overall need for new housing No change emphasis on and is not reliant on NPs. NPs are supported and must promoting CALA Group Ltd conform with the NPPF and in due course the draft LP. Neighbourhood Plan (977724) opportunities to Albert Bygrave Centre deliver housing (985070) Park Street BCh & Bloor Homes Ltd (985300) Rice Group (1058426) Beechwood Homes (1123837) Linden Homes (1153662) Hertfordshire Land (1159945) Owner of Land at Piggotshill Lane (1159948) Aldwyck Housing Group (1186030)

DB Rees (Builders) Ltd (1160056) Land at the Dak (1186131) Hilton House Properties (1057476) London Colney Limited (977496) Owners of Land South of Burydell Lane (1186128) 973643 115365 Policy should enable Jarvis Homes (973180) Noted Cross reference to S2. The NPPF and draft Local Plan Minor modification to Neighbourhood support Neighbourhood planning. Given the specific wording S2. Plans to deliver CALA Group Ltd used in the final NPPF 2018 (after the Council decision on 11 housing on Green (977724) July 2018 based on the draft NPPF) a minor modification If detailed local Belt should be made to make clear that if detailed local evidence evidence justifies Albert Bygrave Centre development at a (985070) justifies development at a neighbourhood scale, on land currently designated as Green Belt, it is supported in neighbourhood scale, Park Street BCh & Bloor principle. on land currently Homes Ltd (985300) designated as Green Belt, it is supported in Rice Group (1058426) principle. Beechwood Homes (1123837) Linden Homes (1153662) Hertfordshire Land (1159945)

Aldwyck Housing Group (1186030) Martin Grant Homes and Kearns Land (975683) DB Rees (Builders) Ltd (1160056) Land at The Dak (1186131) Hilton House Properties (1057476) London Colney Limited (977496) Owners of Land South of Burydell Lane (1186128) Owner of Land at Piggotshill Lane (1159948) 1153651 973643 No recognition of Martin Grant Homes and Disagree Redbourn Neighbourhood Plan has not yet undergone an No change sites allocated in the Kearns Land (975683) Examination process. The Local Plan deals with the overall Redbourn need for new housing and is not reliant on NPs. NPs are Neighbourhood Plan supported and must conform with the NPPF and in due course the draft LP. Address the need for 52064 Disagree Local Plans contain district-wide policies, whereas NPs No change avoiding contain neighbourhood level policies. Not all areas will likely unnecessary policy duplication with

Neighbourhood ‘produce ‘made’ Neighbourhood Plans. Some duplication may Plans. occur but should not prove problematic. 1.5 – Duty to Cooperate Neighbours – South West Hertfordshire

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point (see below for list Reply (including any of abbreviations) Changes to Plan) London Colney will 1182733 Noted There has been and will be ongoing joint working with No change be overdeveloped by neighbouring local authorities including the South West Herts Hertsmere’s Group. DtC considered to be met. proposals, therefore more co-operation for housing land allocation between authorities needed A failure to co- 334023 Disagree There has been and will be ongoing joint working with No change operate with neighbouring local authorities including the South West Herts neighbouring 1144419 Group. Duty to co-operate is considered to be met. councils on the Joint Strategic Plan (JSP) and the South-West Herts Group (SWHG) St Albans has Redbourn Parish Council Disagree There has been and will be ongoing joint working with No change progressed too far (759908) neighbouring local authorities including the South West Herts ahead of the Group. Duty to co-operate is considered to be met. neighbouring Leverstock Green Village authorities in the Association (1185907) Joint Strategic Plan (JSP) that prevents cross boundary

working for housing allocations. Lack of a Redbourn Parish Council Disagree There has been and will be ongoing joint working with No change timetable/plan to (759908) neighbouring local authorities including the South West Herts address concerns Group. Duty to co-operate is considered to be met. from adjoining Jarvis Homes (973180) Authorities in CALA Group Ltd particular East (977724) Hemel and Dacorum Borough Council Albert Bygrave Centre (985070) Eaton Lodge (985289) Park Street BCh & Bloor Homes Ltd (985300) Rice Group (1058426) Beechwood Homes (1123837) Linden Homes (1153662) Hertfordshire Land (1159945) Aldwyck Housing Group (1186030) Department of Health & Social Care and Bloor Homes (1156886) Longbourn Estates (977635)

Leverstock Green Village Association (1185907) 973643 973659 1144419 1186108 1159948 1153650 1153651 St Albans has not Redbourn Parish Council Disagree There has been and will be ongoing joint working with No change met the housing (759908) neighbouring local authorities including the South West Herts needs of Dacorum Group. Duty to co-operate is considered to be met. Borough Council Jarvis Homes (973180) and other CALA Group Ltd neighbouring (977724) authorities, therefore may need to Albert Bygrave Centre concede more land (985070) Eaton Lodge (985289) Park Street BCh & Bloor Homes Ltd (985300) Rice Group (1058426) Leverstock Green Village Association (1185907) Beechwood Homes (1123837)

CP Holdings (1158145) Linden Homes (1153662) Hertfordshire Land (1159945) Aldwyck Housing Group (1186030) Owners of Land South of Burydell Lane (1186128) 1186108 973643 973659 1153650 1144419 1153651 1159948 A Duty to Cooperate Martin Grant Homes and Noted There has been and will be ongoing joint working with No change document should be Kearns Land (975683) neighbouring local authorities including the South West Herts published to Group. Duty to co-operate is considered to be met. illustrate how each LPA is meeting their housing need and how any unmet needs are addressed

SADC should have Martin Grant Homes and Noted A Memorandum of Understanding has been agreed with the No change had a Statement of Kearns Land (975683) SWHG and a Statement of Common Ground. Common Ground (SCG) published M Scott Properties (1185993) ERLP 1 Sarl (1123561) Dacorum Borough Council (1186054) CWC Group (1153869) Department of Health & Social Care and Bloor Homes (1156886) Pennard Holdings Ltd (51983) London Colney Limited (977496) Longbourn Estates (977635) CEG (1158030) CP Holdings (1158145) Lack of/no evidence Martin Grant Homes and Noted There has been and will be ongoing joint working with No change of Joint Working/ Kearns Land (975683) neighbouring local authorities including the South West Herts Duty to Cooperate Group. DtC considered to be met. A Memorandum of published Harpenden Green Belt Understanding has been agreed with the SWHG and a Association (866541) Statement of Common Ground. Jarvis Homes (973180) CALA Group Ltd (977724)

Albert Bygrave Centre (985070) Eaton Lodge (985289) Park Street BCh & Bloor Homes Ltd (985300) Rice Group (1058426) Beechwood Homes (1123837) CP Holdings (1158145) Linden Homes (1153662) Hertfordshire Land (1159945) Aldwyck Housing Group (1186030) M Scott Properties (1185993) ERLP 1 Sarl (1123561) Batford Community Action Group (1185696) Colney Heath Parish Council (51891) Burhill Developments Ltd (977347) Aurora Properties Limited (1151817)

Home Builders Federation Ltd (1156936) CWC Group (1153869) Wrenbridge Land Ltd (1187023) Gladman Developments Ltd (1187201) Pennard Holdings Ltd (51983) London Colney Limited (977496) Longbourn Estates (977635) Intrasales Ltd (1157383) Leverstock Green Village Association (1185907) Owners of Land South of Burydell Lane (1186128) 1144419 973643 973659 1153650 1153651 1159948

1186108 347648 1185714 Plan fails to take into Berkhamsted Residents Disagree There has been and will be ongoing joint working with No change account the impact Action Group (BRAG) neighbouring local authorities including the South West Herts of proposed housing (1186012) Group. Duty to co-operate is considered to be met. or contribution to housing targets in 1153245 neighbouring 1186129 councils Intentions of 1185955 Disagree There has been and will be ongoing joint working with No change neighbouring neighbouring local authorities including the South West Herts authorities have had Group. Duty to co-operate is considered to be met. a big impact on plans for development within the district The Decision to Ellenbrook Area Disagree There has been and will be ongoing joint working with No change include East St Residents Association neighbouring local authorities including the South West Herts Albans Broad Committee (1185802) Group and Welwyn & Hatfield. Duty to co-operate is Location did not considered to be met. Evidence on development strategy / consider Welwyn site selection is available in full. Hatfield Borough Council Plans for development in the same area Any expansion to Berkhamsted Residents Disagree There has been and will continue to be ongoing collaboration No change Hemel Hempstead Action Group (BRAG) with Dacorum Borough Council on masterplanning the urban should be led by (1186012) extensions to Hemel Hempstead – cross reference with Dacorum Borough Policy S6.

Council with SADC collaboration SADC has met its Trustees of James Henry Disagree Already covered in the Plan. Will additionally be covered by Already covered in the Duty to Cooperate, Frank Sewell Deceased the Duty to Cooperate Statement of Compliance. Plan. Will additionally but Paragraph 1.5 (1185630) be covered by the Duty should include to Cooperate additional wording to Statement of support this Compliance. Evidence base/Plan Dacorum Borough Disagree There has been ongoing joint working with neighbouring local No change should be updated Council (1186054) authorities including the South West Herts Group. Duty to co- to show cross- operate is considered to be met. A Memorandum of boundary issues Watford Borough Council Understanding has been agreed with the SWHG and a being dealt with (1122500) Statement of Common Ground will follow. An agreement is Dacorum Borough Noted A Memorandum of Understanding has been agreed with the No change needed to agree Council (1186054) SWHG and a Statement of Common Ground will follow. housing and employment need CWC Group (1153869) between Dacorum Borough Council and SADC Duty to Cooperate Dacorum Borough Noted Support noted No change has been met and Council (1186054) any DtC issue between Dacorum Borough Council should be addressed as a soundness issue Duty to Cooperate Burhill Developments Ltd Noted There has been ongoing joint working with neighbouring local No change development need (977347) authorities including the South West Herts Group. Duty to co- assessments should consider all sources

of housing land operate is considered to be met. Evidence on development supply strategy / site selection is available in full. There is a lack of Burhill Developments Ltd Disagree There has been ongoing joint working with neighbouring local No change understanding from (977347) authorities including the South West Herts Group. Duty to co- Neighbouring operate is considered to be met. Authorities to deal with cross-boundary issues Welwyn Hatfield Aurora Properties Noted This decision was determined as a result of the evidence No change Borough Council is Limited (1151817) from the SWHG research. Whilst not part of the South West not part of the Joint Herts grouping, SADC acknowledges the existing cross- Strategic Plan for boundary relationship with Welwyn Hatfield Borough Council South-West and will be maintaining this relationship through a wider Duty Hertfordshire – to Cooperate. Why? There are sites Aurora Properties Disagree There has been ongoing joint working with neighbouring local No change Welwyn Hatfield Limited (1151817) authorities including the South West Herts Group. Duty to co- Borough Council operate is considered to be met. Evidence on development have assessed but strategy / site selection is available in full. There is no omitted from their reasonable prospect of Welwyn Hatfield providing for SADC’s plan, which provide need. 1,826 dwellings. This can be used to provide for unmet need in SADC’s plan Site allocations are St Albans Civic Society Disagree There has been ongoing joint working with neighbouring local No change only viable once the (1156974) authorities including the South West Herts Group. Duty to co- Duty to Cooperate operate is considered to be met. has been fulfilled

Concerns over duty St Albans Civic Society Disagree There has been ongoing joint working with neighbouring local No change to co-operate; there (156974) authorities including the South West Herts Group. Duty to co- is a lack of clarity operate is considered to be met. between local 52064 authorities and HCC as there are no firm policies or spatial approaches set London Colney London Colney Parish Noted Support noted No change Parish Council has Council (52477) little influence to protect existing local infrastructure from overdevelopment coming from outside the District, therefore support discussion taking place to enable Duty to Cooperate to be agreed Watford Borough Watford Borough Council Noted Support noted No change Council supports (1122500) progress on the Draft Plan and joint working between SADC and Watford Borough Council Clarification needed Watford Borough Council Disagree There has been ongoing joint working with neighbouring local No change to show types of (1122500) authorities including the South West Herts Group. Duty to co- strategic and cross operate is considered to be met. A Memorandum of boundary issues relevant to SADC

that will be Understanding has been agreed with the SWHG and a addressed through Statement of Common Ground will follow. the Joint Strategic Plan A review of the JSP Watford Borough Council Disagree There has been ongoing joint working with neighbouring local No change should take place (1122500) authorities including the South West Herts Group. Duty to co- with SWHG once operate is considered to be met. A Memorandum of strategic issues Understanding has been agreed with the SWHG and a have been identified Statement of Common Ground will follow. and progressed WHBC welcome Welwyn Hatfield Borough Noted Support noted No change acknowledgement of Council (52397) joint working between SADC & WHBC in Draft Plan, even though not part of South West Housing Market Area and Functional Economic Market Area WHBC suggest Para Welwyn Hatfield Borough Disagree Wider Duty to Cooperate relationships addressed in No change 1.5 makes clear that Council (52397) paragraph 1.5. those not part of SWHG are Duty to Cooperate neighbours and that work will commence/be agreed for a Statement of Common

Ground/Memorandu m of Understanding WHBC have placed Welwyn Hatfield Borough Noted SADC will continue to work with WHBC and other DC bodies. No change a number of holding Council (52397) objections that are hoped to be resolved with a Statement of Common Ground/Memorandu m of Understanding once SADC has completed evidence gathering SADC should record Crest Strategic Projects Noted Records of Duty to Cooperate discussions have been No change all Duty to and Bloor Homes maintained. Cooperate (DtC) (1158079) discussions and undertakings to demonstrate that DtC has been complied with 1.7 – Plan Preparation

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point (see below for list Reply (including any of abbreviations) Changes to Plan) St Albans has Redbourn Parish Council Disagree There has been and will be ongoing joint working with No change progressed too far (759908) neighbouring local authorities including the South West Herts ahead of the Group. Duty to co-operate is considered to be met. neighbouring Leverstock Green Village authorities in the Association (1185907)

Joint Strategic Plan (JSP) that prevents cross boundary working for housing allocations The Publication Aurora Properties Disagree The LP to be submitted is the Publication Draft. No change Draft of the Local Limited (1151817) Plan should be the intended Submission Local Plan, not a “Draft”. A Regulation 19 Aurora Properties Disagree The Local Plan will be carried out in accordance with the No change consultation is for Limited (1151817) requirements of the relevant legislation. the benefit of the Examination in Public. If the plan gets amended SADC should undertake a further Regulation 19 consultation before submission. SADC should not Aurora Properties Disagree Disagree that the Plan is flawed and unsound. No change repeat the same Limited (1151817) mistake as WHBC by submitting a plan that they know is manifestly flawed and not sound The plan has not 1034653 Disagree SADC has carried out the necessary consultations at both No change been designed with Regulation 18 and Regulation 19 stages.

the cooperation of local residents There is no evidence Leverstock Green Village Disagree SADC has carried out the necessary consultations at both No change to suggest that Association (1185907) Regulation 18 and Regulation 19 stages. SADC has engaged with the local community of Leverstock Green The information Martin Grant Homes and Disagree The vision of the Local Plan is based on a thriving community No change contained within the Kearns Land (975683) which includes long term sustainability. SA reports has not influenced policies in ERLP 1 Sarl (1123561) the Plan relating to Stackbourne Limited landscape, (1153646) character, infrastructure, Redbourn Parish Council balance of sites in (759908) different settlements, 1185775 broad location selection, environmental dimension of sustainable development

1.9 – Plan Evidence Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) The draft local plan Harpenden Green Belt Disagree Evidence supporting the Local Plan is available in full. No change has not been based Association (866541) on up to date evidence Martin Grant Homes and Kearns Land (975683) The Environment Agency (1147557) Aboyne Residents Association (1181214) 51 Pegasus Ltd (1186098) Department of Health & Social Care and Bloor Homes (1156886)

334023

1185714 Absence of evidence Martin Grant Homes and Disagree There has been ongoing joint working with neighbouring local No change of effective joint Kearns Land (975683) authorities including the South West Herts Group. Duty to co- working from the operate is considered to be met. A Memorandum of local plan evidence Hunston Planning Understanding has been agreed with the SWHG and a base Limited (1185622) Statement of Common Ground. Batford Community Action Group (1185696)

Helioslough Ltd (1182085) Gladman Developments Ltd (1187201) Owners of Land South of Burydell Lane (1186128) 1186131 1185714 Concerns that the Martin Grant Homes and Disagree Full and detailed justification is provided by evidence No change local plan is not Kearns Land (975683) documents. It is not necessary to justify the Plan within the based upon Plan document itself. To do so would result unnecessarily in a proportionate and 347648 longer and more complex document. justified evidence as the policies are not accompanied by supporting text There is insufficient Martin Grant Homes and Disagree Development need and site specific analysis in GB work No change evidence to support Kearns Land (975683) provide exceptional circumstances for GB release. Evidence the strategy for on development strategy / site selection is available in full. meeting the Redbourn Parish Council Council’s housing (759908) Concentrating development in larger sites that can effectively requirement Leverstock Green Village deliver infrastructure is a key part of the development predominantly at Association (1185907) strategy. these Broad Locations Owners of Land South of Burydell Lane (1186128) 1186131 Further evidence Martin Grant Homes and Disagree Evidence relating to care homes is available in full. No change required on the need Kearns Land (975683) for residential care

homes/nursing Signature Senior homes Lifestyle (1186910) SADC does not Martin Grant Homes and Disagree Evidence relating to small sites is available in full. No change provide evidence or Kearns Land (975683) justification in support of the future supply of sites of 0.5ha or less Use of outdated Aboyne Residents Disagree Evidence on retail is available in full. No change retail study data as Association (1181214) evidence for the retail policy Propose the Legal and General Disagree Such documents would support the Broad Location in the No change inclusion of (1051022) masterplanning process and would not be Local Plan Brookbanks NW evidence documents. Harpenden Local CEG (1158030) Plan Transportation Study, Transport Position Statement, Vision Document and L&G/ CEG Regulation 19 response document as part of the Council’s evidence base Difficulty in providing CEG (1158030) Disagree Any further evidence is in the form of updates and are not No change conclusive new studies. Comments can be provided on the evidence comments on the 347648 base to date in conjunction with the draft Local Plan. soundness of the plan as SADC is still compiling evidence

Concerns that the 347648 Disagree Evidence supporting the Local Plan is available in full. No change policies in the plan rely to some extent on the views of certain long standing members rather than empirical data and evidence Lack of evidence to 1153268 Disagree Development need and site specific analysis in GB work No change suggest that the provide exceptional circumstances for GB release. Evidence council has Owners of Land South of on development strategy / site selection is available in full. examined fully all Burydell Lane (1186128) Concentrating development in larger sites that can effectively other reasonable 1186131 deliver infrastructure is a key part of the development options for meeting strategy. their identified housing need. Lack of Mr Pete Hutchison Disagree Development need and site specific analysis in GB work No change consideration has (1153268) provide exceptional circumstances for GB release. Evidence been given to the on development strategy / site selection is available in full. proposed site as Concentrating development in larger sites that can effectively part of the LP’s deliver infrastructure is a key part of the development evidence on strategy. assessing sites for the release from the Green Belt. The evidence base 51 Pegasus Ltd Disagree Existing SADC and SWHG evidence studies set out a clear No change does not establish (1186098) evidence base that the LP approach is directly based on. an up-to-date objective assessment of the need for employment land,

given the new housing target. Local Plan CP Holdings (1158145) Noted The Local Plan and its appendices will be added to the Local The Local Plan and its appendices should Plan 2018 /19 Library of Documents. appendices will be be included on the added to the Local planning policy Plan 2018 /19 Library evidence base of Documents. webpages The local plan fails Owners of Land South of Disagree The NPPF and Plan evidence necessitates a significant No change to demonstrate and Burydell Lane (1186128) change in approach from previous tight Green Belt restraint. evidence an This involves a carefully considered stepped trajectory for adequate five-year 1186131 delivery of new sites that are best able to deliver to the overall supply of housing plan development strategy. There are sufficient deliverable sites for years 1-5. This is confirmed in relevant developer representations. Section 1.9 does not Redbourn Parish Council Disagree The current wording reflects the approach actually taken to No change specify which (759908) the structure of the LP. The new NPPF wording 2018 is version of the NPPF generally similar and not contradictory to the approach taken. the local plan complies with Absence of an Gladman Developments Agree IDP will be updated on an ongoing basis.IDP will be updated IDP will be updated updated Ltd (1187201) on an ongoing basis. on an ongoing basis. Infrastructure Delivery Plan Leverstock Green Village Association (1185907)

Up to date CP Holdings (1158145) Disagree Evidence is available in full and where required has been No change documents for the updated. In some cases evidence base are not contained within the document library

Paragraph 2.1 – Vision Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) The Plan vision does Stackbourne Limited Disagree The vision is based on a thriving community which includes No Change not promote long (1153646) long term sustainability. term sustainability in relation to the SA / 1153802 SEA objectives, it prioritises economic development and resource use The Plan vision Stackbourne Limited Disagree The vision is specific to the District. No Change provides no context (1153646) and is not specific to the district Theatres Trust (1179001) The Plan vision M Scott Properties Ltd. Disagree Covered by reference to a great place to live. Cross reference No Change should address (1185993) with Paragraph 2.2 and Policy L3. housing affordability Paragraph 2.2 – Strategic Policies Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) The strategic Hertfordshire County Disagree Strategic policies are based on the draft NPPF and includes No change policies should Council (837689) health. address public health and wellbeing

The plan should Historic England Disagree The current wording reflects the approach actually taken to No change make reference to (929489) the structure of the LP. The new NPPF wording 2018 is the revised NPPF generally similar and not contradictory to the approach taken. Paragraph 2.3 – Objectives Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) The objectives are Stackbourne Limited Disagree The objectives provide an appropriate structure for the No change too short and vague. (1153646) context and detail set out in the Policies later in the Plan. They provide no context/are not Theatres Trust (977496) specific to the District/fail to guide land allocations/not compatible with SA objectives Protection of existing Theatres Trust (977496) Disagree Already covered by Objectives 3, 4 and 5 No change cultural and entertainment facilities should be an objective Support objective on Historic England Noted Support noted No change conservation and (929489) enhancement of the historic environment. Support inclusion of 1185775 Noted Support noted No change affordable housing in objectives

Paragraph 2.4 – Local Policies Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Plan lacks site Historic England Disagree Cross reference with L23 and L30 – provides design No change specific policies for (929489) principles that must be applied to all development, including small sites development on small sites. Paragraph 2.6 – Plan Period Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Plan ERLP 1 Sarl (1123561) Disagree 2020 is the earliest realistically possible date of adoption of No change commencement the Plan and is therefore appropriate in the context of the new year lacks M Scott Properties draft and final NPPF. justification in (1185993) relation to historic Gladman Developments housing need / Ltd (1187201) under delivery. 2018 should be the start M Scott Properties for the Plan, not (1185993) 2020, otherwise not Andersons Group accounting for two (1146719) years of need Department of Health & Social Care and Bloor Homes (1156886)

Support the plan Andersons Group Noted Support noted No change period with regards (1146719) to the plan horizon Plan submission will Department of Health & Agree The new NPPF wording 2018 is generally similar to the 2012 No change be after the NPPF Social Care and Bloor NPPF and not therefore contradictory to the approach taken. transition date of Homes (1156886) 24th January 2019 and should therefore be prepared in the context of the new NPPF / PPG Plan evidence is not Gladman Developments Disagree Evidence is available in full and where required has been No change available in relation Ltd (1187201) updated. to full plan period Paragraph 2.7 – Plan Review Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Plan review (with Gladman Developments Disagree Review will be in accordance with the requirements of the No change clear timetable) Ltd (1187201) NPPF. should also be undertaken where housing delivery is below the annual requirement or where land supply is significantly below 5 years

Paragraph 2.8- Minerals and Waste Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Mineral Hertfordshire County Disagree HCC’s Minerals and Waste Plan forms part of the statutory Minor modification – Safeguarding Areas Council (837689) Development Plan and includes the MSA on the Policies Map HCC Mineral should be shown on Safeguarding Areas the Policies Map added to list of ‘Other GIS sources’ at 1.10 Paragraph 3.1 – Using the Policies Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) The plan fails to Crown Estate (51946) Disagree All text under the Policies is Policy. This is clear from the No change distinguish between overall plan format. policy and Historic England supporting text (929489) The policies are not Martin Grant Homes and Disagree Full and detailed justification is provided by evidence No change accompanied by Kearns Land (975683) documents. It is not necessary to justify the Plan within the supporting text, Plan document itself. To do so would result unnecessarily in a meaning the CP Holdings (1158145) longer and more complex document. necessary justification (i.e. in terms of planning law, national policy or the planning policy evidence base) of the policies is absent.

No clear CP Holdings (1158145) Disagree All text under the Policies is Policy. This is clear from overall No change differentiation plan format. between the policy wording and Full and detailed justification is provided by evidence explanatory links is documents. It is not necessary to justify the Plan within the confusing and may Plan document itself. To do so would result unnecessarily in not be correctly a longer and more complex document. interpreted Plan should have full Crown Estate (51946) Disagree Policy numbering is sufficient to signpost the Policies section. No change paragraph Paragraph numbering of Policies would confuse rather than numbering clarify presentation. Paragraph 3.2 – List of Policies Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Add a Strategic Rail Helioslough Ltd Disagree The Broad Location is a greater priority for use of this site. No change Freight Policy under (1182085) The main site owner has promoted the site as available and Chapter 4 deliverable for housing and confirmed policy requirements are deliverable. S1 Spatial Strategy and Settlement Hierarchy

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan)

Query meaning of 1144419 Noted The scale and density of new development will be expected No change lower category scale to be lower in the category 2 settlements than the scale and 2 density of new development in the category 1 settlements.

Need for medium Martin Grant Homes and Disagree Concentrating development in larger sites that can create No change sized sites in the Kearns Limited (975683) new communities and deliver infrastructure is a key part of category 2 villages the development strategy.

Object to approach Canton Ltd (1057961) Disagree Category 3 settlements are located in the Green Belt, the aim No change to category 3 of which is to prevent urban sprawl by keeping land settlements which permanently open; the essential characteristics of Green limits development Belts are their openness and their permanence. Don’t burden RF Sinclair and Sons Disagree The policy positively supports and does not prevent No change development (1058251) development in these settlements. through controls on main settlements St Albans School and towns (1187032) 52064 SADC should not be CPRE Hertfordshire Disagree Hemel Hempstead has a wide range of services and facilities No change putting new housing (872572) and is a main urban settlement. It is clearly a category 1 alongside expansion settlement. of Hemel Berkhamsted Residents Hempstead-oppose Action Group (1186012) Site selection is firmly based on comprehensive GB work which identified the allocated Broad Locations. inclusion HH as Lawes Agricultural Trust category 1 (1187615) Concentrating development in larger sites that can create settlement. new communities and deliver infrastructure is a key part of 1158258 the development strategy.

London Colney is a CPRE Hertfordshire Disagree London Colney has grown to the stage where it is a small No change large village and not (872572 town in terms of its overall scale, population level and number a town. There is of households. significant London Colney Parish development on the Council (52477) Housing requirement/targets are based on the standard methodology set out by the government – see S4. edge London Colney Aurora Properties within Hertsmere Limited (1151817) Site selection is firmly based on comprehensive GB work BC. Use land within which identified the allocated Broad Locations. existing settlement 1185583 boundaries before Concentrating development in larger sites that can create 1185821 greenfield site new communities and deliver infrastructure is a key part of adjacent to Shenley 347648 the development strategy. Lane.

Plan should promote Hill Residential Noted The policy and other LP policies positively supports and does No change more small and (1158064) not prevent development in these settlements. medium sized sites in category 1 settlements rather than using green belt Park Street Garden Butterfly World Project Disagree The main site owner has promoted the site as available and No change Village is not Ltd (1183965) deliverable for housing. Considerations have taken into available for housing account the existing planning permission for an alternative development and CPRE Hertfordshire use and other relevant factors. should be excluded (872572) from category 2 of (1185775) the settlement hierarchy. Criteria St Stephen Parish for judgement (from Council (51804) Green Belt Review) Hertsmere Borough ignored when Council (51934) looking at proposal. Hasn’t been put

forward with Aurora Properties cooperation from Limited (1151817) London Colney. Very limited M Scott Properties infrastructure and (1185993) services. Broad policy CPRE Hertfordshire Noted Policy S1 and other LP policies requires development to No change approach to density (872572) make efficient use of land, including by increasing density of category 2 large and height of development. In existing settlements this should villages should seek not however be to the detriment of the existing character. to influence and not just reflect existing density Opportunities exist J W Pigott and Son Disagree Site selection is firmly based on comprehensive GB work No change adjacent to (1183246) which identified the allocated Broad Locations. Redbourn and Wheathampstead 1185775 Concentrating development in larger sites that can create new communities and deliver infrastructure is a key part of the development strategy. East of St Albans Ellenbrook Area Agree Cross reference to S2 and S6. East of St Albans is a Broad No change site impact on Residents Association Location for development. Site selection is firmly based on Smallford doesn’t Committee (1185802) comprehensive GB work which identified the allocated Broad count as ‘small scale Locations. infilling’. Concentrating development in larger sites that can create new communities and deliver infrastructure is a key part of the development strategy. LP should prioritise Legal and General Agree The policy approach is for most larger scale development to No change bulk of new (1051022) be in/adjacent to the most accessible locations i.e. category 1 development settlements. towards the first tier CEG (1158030) of the settlement CP Holdings (1158145) hierarchy

Sequential approach Burhill Developments Ltd Disagree The policy does not include a sequential test but provides the No change is inflexible and (977347) broad policy approach that will be taken to the different unreasonable. categories of settlement. NPPF supports this approach. Extensions to existing villages and towns is more consistent with NPPF. How Wood and M Scott Properties Disagree They have not been overlooked. Site selection is firmly No change Bricket Wood (1185993) based on comprehensive GB work which identified the overlooked and have allocated Broad Locations. stations. Contrary to NPPF in that the Concentrating development in larger sites that can create approach does not new communities and deliver infrastructure is a key part of actively manage the development strategy. patterns of growth to make the fullest possible use of public transport. Evidence behind Anderson Group Disagree There are clear distinctions between the different categories No change categorisation of (1146719) of settlement in terms of accessibility and services/facilities. settlements not The policy notes that Hemel Hempstead is in Dacorum available and Longbourn Estates however there is planned expansion into the District. It is concerns with (977635) therefore necessary to categorise it. There is ongoing joint assessment. Not work with Dacorum in this area. possible for SADC to promote development in Dacorum.

Park Street Garden Anderson Group Disagree Site selection is firmly based on comprehensive GB work No change Village not well (1146719) which identified the allocated Broad Locations. located to facilities and services needed Department of Health & Concentrating development in larger sites that can create for residential Social Care and Bloor new communities and deliver infrastructure is a key part of development. No Homes (1156886) the development strategy. justification to D'Arblay Investments include proposal as (1187404) a Garden Village Some locations such Anderson Group Disagree Site selection is firmly based on comprehensive GB work No change as land at Boissy (1146719) which identified the allocated Broad Locations. Close are just as sustainable as Concentrating development in larger sites that can create settlements that new communities and deliver infrastructure is a key part of have been given the development strategy. category 2 status. Settlement hierarchy influenced by the strategic allocations rather than the settlement hierarchy influencing the site selection process.

Sandridge and Glinwell PLC (1187377) Disagree Sandridge and Smallford are small settlements with a very No change Smallford should be limited range of services and facilities within the Green Belt excluded from Longbourn Estates and are therefore category 3 settlements. Green Belt and long (977635) term boundaries D'Arblay Investments established around (1187404) them consistent with NPPF. Should be classified as category 2 ‘large villages’. ‘Excluded from the Crown Estate (51946) Disagree Cross reference to Policy S2 - sets out development strategy No change green belt’ which provides for expansion at all category 1 and one interpreted that any category 2 settlement. releases on the edge of these settlements would be contrary to strategy (which is the intent of the broad locations) Unnecessary to Pennard Holdings Ltd Disagree The policy positively supports and does not prevent No change describe Redbourn (51983) development in Redbourn and other settlements. as a large village. Policy is not positively worded to encourage appropriate and sustainable growth and appropriate development sites

Recommend more London Colney Limited Disagree Site selection is firmly based on comprehensive GB work No change land allocated (977496) which identified the allocated Broad Locations. around St Albans as the largest Concentrating development in larger sites that can create settlement and that new communities and deliver infrastructure is a key part of Land South of Alban the development strategy. Way is allocated for residential development ‘Broad policy Dacorum Borough Disagree Cross reference to paragraph 1.5 and Policy S6 – sets out No change approach’ column Council (1186054) engagement with Dacorum BC. should state planning of development edge of Hemel Hempstead in SADC will be with full engagement with Dacorum BC Consideration of infill Mr Antonio Barba Disagree Where not in the Green Belt, infill is positively supported in No change pockets of (1187384) the Plan, subject to design, context etc. Site selection is firmly development that based on comprehensive GB work which identified the have existing D'Arblay Investments allocated Broad Locations. infrastructure and (1187404) facilities has not Concentrating development in larger sites that can create been considered new communities and deliver infrastructure is a key part of the development strategy. Sites on brownfield D'Arblay Investments Noted Positively bringing forward brownfield sites, subject to design, No change register are close to (1187404) context etc. is part of the Plan strategy; but it is not possible public transport and to meet all need through this type of development. should be developed before release of greenbelt.

Council’s approach D'Arblay Investments Disagree Site is already located outside of the Green Belt No change to Green Belt is (1187404) inconsistent in that it regards an industrial estate (Ventura Park) to be excluded from Green Belt but not entire village (Smallford /Sandridge) ‘Development must Hertfordshire County Disagree Clarified in S1 in the broad policy approach column. No change make efficient use of Council (837689) Additionally cross reference to Policies L1 and L23. land by increasing the density and height of development’ should be clarified as development must be appropriate to the site context Emphasis should be Hertfordshire County Disagree Cross reference to Policy L18 which addresses sustainable No change on reduced travel Council (837689) transport infrastructure. demand instead of greater accessibility

Allocated Broad CP Holdings (1158145) Disagree Cross reference to Policy S2 - sets out development strategy No change locations do not which provides for expansion at all category 1 and one conform with Spatial category 2 settlement Strategy

S2 Development Strategy

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) No evidence that Ramblers Association Disagree Development need, overall Plan context and site specific No change harm to the Green (52420) analysis in GB work provide exceptional circumstances for Belt has been GB release. properly weighed Redbourn Parish Council against benefits of (759908) meeting the London Colney Limited objectively assessed (977496) need for housing – housing need is too Intrasales Ltd (1157383) highly weighted The British Horse Society (1187597) 334023 1185775 Housing need (and Harpenden Green Belt Disagree Development need, overall Plan context and site specific No change an inability to meet Association (866541) analysis in GB work provide exceptional circumstances for Government figures GB release. for housing need) St Albans & District does not constitute Footpaths Society exceptional (723340) circumstances that CPRE Hertfordshire necessitate major (872572) development in Green Belt (as set Berkhamsted Residents out in NPPF para Action Group (BRAG) 137). The evidence / (1186012)

justification available Legal and General is inadequate (1051022) Redbourn Parish Council (759908) CWC Group (1153869) Glinwell PLC (1187377) CEG (1158030) 1153802 1185523 1019306 1185714 1153651 Hemel Garden Dacorum Borough Disagree HGC is a wider and evolving concept that is better set out No change Communities should Council (1186054) and explained outside of the Local Plan. be referred to in the policy The development RF Sinclair and Sons Disagree Concentrating development in larger sites that can create No change strategy relies too (1058251) new communities and deliver infrastructure is a key part of heavily on a limited the development strategy. number of large Hill Residential strategic (1158064) allocations/is not J W Pigott and Son appropriate as it (1183246) does not include smaller sites Rice Group (1058426) ERLP 1 Sarl (1123561)

DB Rees (Builders) Ltd (1160056) Jarvis Homes 973180, Hilton House Properties (1057476) Wrenbridge Land Ltd (1187023) Trustees of G.A. Simons Family Trust (1187408) Taylor Wimpey Strategic Land (1187472) Gallagher Estates (1143916) M Scott Properties (1185993) Trustees of G.A. Simons Family Trust (1187408) Intrasales Ltd (1157383) Glinwell PLC (1187377) London Colney Limited (977496) D’Arblay Investments (1187404) Shonleigh Nominees (978420) CP Holdings (1158145)

1153650 1159948 1187384 498103 978427 52064 52552 977889 Plan fails to consider ERLP 1 Sarl (1123561) Disagree The Plan necessitates a significant change in approach from No change sites that can come previous tight Green Belt restraint. This involves a carefully forward quickly to DB Rees (Builders) Ltd considered stepped trajectory for delivery of new sites that help maintain a 5 (1160056) are best able to deliver to the overall plan development years supply of Jarvis Homes 973180 strategy. There are sufficient deliverable sites for years 1-5. deliverable housing This is confirmed in relevant developer representations. sites. Requirement Home Builders of specific Federation Ltd deliverable sites for (1156936) years 1-5 is not met. Ralph Catton Family Trust (1186119) Sandridge Parish Council (869186) Comer Group (872799) Anderson Group (1146719) Longbourn Estates (977635)

Taylor Wimpey Strategic Land (1187472) SADC Community Services and Green Spaces (1200137) 1153650 1153651 1159948 Trajectory of delivery ERLP 1 Sarl (1123561) Disagree There is no backlog under Government standard No change / development methodology approach as additional provision is already strategy DB Rees (Builders) Ltd incorporated. unsatisfactory. (1160056) Backlog of housing Jarvis Homes (973180) needs require to be addressed earlier in Home Builders the plan period Federation Ltd (1156936) Ralph Catton Family Trust (1186119) Comer Group (872799) Anderson Group (1146719) Longbourn Estates (977635) Taylor Wimpey Strategic Land (1187472) 1153650

1153651 1159948 There are small and Canton Ltd (1057961) Disagree Evidence on development strategy / site selection is available No change medium sized sites in full. that would deliver Hill Residential under 500 dwellings (1158064) which have not been Minister Court Frogmore robustly assessed as (1185980) reasonable alternatives and London Colney Parish which constitute Council (52477) ‘exceptional ERLP 1 Sarl (1123561) circumstances’ for Green Belt release Trustees of James Henry Frank Sewell Deceased (1185630) Jarvis Homes (973180) Burhill Developments Ltd (977347) Park Street BCh & Bloor Homes Ltd (985300) Home Builders Federation Ltd (1156936) M Scott Properties (1185993) Linden Wates (Bricket Wood) Limited (1186996)

Thakeham Homes (1187005) Hilton House Properties (1057476) Anderson Group (1146719) CWC Group (1153869) Department of Health & Social Care and Bloor Homes (1156886) Wrenbridge Land Ltd (1187023) Glinwell PLC (1187377) Pennard Holdings Ltd (51983) London Colney Limited (977496) Longbourn Estates (977635) Mr Keith Hadley (1153539) Intrasales Ltd (1157383) Hallam Land Management Limited (1185998)

Taylor Wimpey Strategic Land (1187472) Gallagher Estates (1143916) Castleoak Care Communities (1187716) Gorhambury Estates Company Limited (375996) 1153650 1159948 52552 978427 1186046 1019306 1158213 1153268 52064 Strategic and small (see separate schedule) Noted Site selection is firmly based on comprehensive GB work No change sites put forward which identified the allocated Broad Locations. (see separate Concentrating development in larger sites that can create schedule) new communities and deliver infrastructure is a key part of the development strategy.

The site selection CWC Group (1153869) Disagree Site selection is firmly based on comprehensive GB work and No change process/ Green Belt the key development strategy points that larger settlements assessment/ranking Harpenden Green Belt are most appropriate as locations and larger sites deliver of the broad Association (866541) greater community benefit. locations is not Helioslough Ltd justified/flawed (1182085) Burhill Developments Ltd (977347) Department of Health & Social Care and Bloor Homes (1156886) Lawes Agricultural Trust (1187615) Historic England (929489) Tarmac (1153600) London Colney Limited (977496) Taylor Wimpey Strategic Land (1187472) CPRE Hertfordshire (872572) Redbourn Parish Council (759908) Leverstock Green Village Association (1185907) CP Holdings (1158145)

1185714 789007 1055738 1185092 498103 1153539 Support approach to Crown Estate (51946) Noted Support noted No change site selection Trustees of James Henry Frank Sewell Deceased (1185630) Other Broad Hertsmere Borough Disagree Site selection is firmly based on comprehensive GB work No change Locations for Council (51934) which identified the allocated Broad Locations. development should be considered and Redbourn Parish Council referenced (759908) Leverstock Green Village Association (1185907) Tarmac (1153600) Burhill Developments Ltd (977347) Comer Group (872799) Department of Health & Social Care and Bloor Homes (1156886) London Colney Limited (977496)

Helioslough Ltd (1182085) CP Holdings (1158145) Alternative/additional Tarmac (1153600) Noted Site selection is firmly based on comprehensive GB work No change strategic sites put which identified the allocated Broad Locations. forward as Burhill Developments Ltd ‘reasonable (977347) alternatives’ Comer Group (872799) Gallagher Estates (1143916) Lawes Agricultural Trust (1187615) Department of Health & Social Care and Bloor Homes (1156886) London Colney Limited (977496) A regional approach 1185483 Disagree This approach is not something that SADC can deliver. No change to development Though such an approach might provide additional strategy is required development capacity it would not be sufficient to deal with as there is a viable the Government view of housing need at a District level. alternative development strategy - building a new garden town in North Herts/South Beds.

Should provide for a Tarmac (1153600) Disagree Site selection is firmly based on comprehensive GB work No change contingency of which identified the allocated Broad Locations.

additional strategic sites The development Martin Grant Homes and Disagree Evidence on development strategy / site selection is available No change strategy needs to be Kearns Land (975683) in full. justified by a better / up to date evidence Minister Court Frogmore base (1185980) Watford Borough Council (1122500) CWC Group (1153869) Intrasales Ltd (1157383) Leverstock Green Village Association (1185907) Historic England (929489) Gorhambury Estates Company Limited (375996) CP Holdings (1158145) 1153651 1185775 1153539

The Plan / policy Martin Grant Homes and Partly The NPPF and draft Local Plan support Neighbourhood Minor modification fails to provide Kearns Land (975683) Agree planning. The Local Plan deals with the overall need for new guidance for housing and is not reliant on NPs. NPs must make their local If detailed local Neighbourhood Aldwyck Housing Group own justification for additional housing provision (and for evidence justifies Plans that advocate (1186030) other uses); this is their intended role. Given the specific development at a additional housing wording used in the final NPPF 2018 (after the Council neighbourhood scale, Hilton House Properties on land currently (such as Redbourn (1057476) decision on 11 July 2018 based on the draft NPPF) a minor Neighbourhood modification should be made to make clear that if detailed designated as Green Plan) local evidence justifies development at a neighbourhood Belt, it is supported in scale, on land currently designated as Green Belt, it is principle. supported in principle. Plan fails to take into London Colney Parish Disagree DtC arrangements ensure this is not the case. Development No change account the Council (52477) is being coordinated across boundaries under joint working cumulative impact and liaison arrangements. It is however acknowledged that (environmental, 1182733 the whole sub region will experience significant additional Green Belt and 347648 development to accommodate population / household change infrastructure) of and growth (in accordance with Government policy - NPPF) SADC and 1153245 neighbouring 1186046 council’s housing allocations/proposals 1185955 (Hertsmere and Welwyn Hatfield) 1186129 Policy should CPRE Hertfordshire Noted This is a significant part of the Plan strategy; but it is not No change emphasise that (872572) possible to meet all need through this type of development as Brownfield should be the opportunities are limited (ref BLR). It is not possible to developed first D’Arblay Investments apply a rigid phasing policy in this respect. (1187404) 1158213 1185945 1121386

Greater emphasis Owners of Land North of Disagree Evidence on development strategy / site selection is available No change should be placed on Napsbury (1186783) in full. development around London Colney/Napsbury Estate Broad Locations Colney Heath Parish Disagree Site selection is firmly based on comprehensive GB work No change should be more Council (51891) which identified the allocated Broad Locations. The key evenly distributed development strategy points that larger settlements are most across the District London Colney Parish appropriate as locations and larger sites deliver greater Council (52477) community benefit. 498103 There is no Park Street BCh & Bloor Disagree Policies S1 and S2 set out a very clear approach No change development Homes Ltd (985300) strategy for City, towns and wider district Sustainable patterns Park Street BCh & Bloor Disagree Policies S1 and S2 out a very clear approach based on No change of development have Homes Ltd (985300) accessibility of employment and high order facilities and not been considered services by modes other than the private car. in the proposed CWC Group (1153869) development Pennard Holdings Ltd strategy (51983) Longbourn Estates (977635) Intrasales Ltd (1157383) Hill Residential (1158064)

Owners of Land North of Napsbury (1186783) Leverstock Green Village Association (1185907) 867068 1153802 1153245 1186129 SA and the Plan are Helioslough Ltd Disagree The approach taken reflects the Plan’s vision of providing a No change not considered to be (1182085) thriving community which includes long term sustainability. consistent with national policy as they don’t aim to deliver sustainable development Loss of prime 759883 Noted Site selection is firmly based on comprehensive GB work No change agricultural land which identified the allocated Broad Locations. 498103 Concentrating development in larger sites that can create 1185704 new communities and deliver infrastructure is a key part of the development strategy. Loss of higher quality agricultural land has been considered as a factor amongst others, such as Green Belt, in determining the Plan strategy.

Should include more Goodman (1153774) Disagree Specific plan provision of land is based on strategic planning No change employment factors. locations. Disagree with a sole focus on Policy S5 supports employment land provision appropriate to the Enterprise Zone the settlements. at the expense of The EZ has important functions supporting business start-ups other growth areas. and attracting UK and international investment. Look forward to Central Bedfordshire Noted A transport evidence workplan has been agreed with HCC. No change reviewing the Council (861963) The next output is expected in early 2019 from the HCC strategic transport COMET run. assessments for the Broad Locations and outcomes of the COMET modelling run to understand the potential cross- boundary transport impacts Further work needs Hertfordshire County Noted A transport evidence workplan has been agreed with HCC. No change to be carried out on Council (837689) The next output is expected in early 2019 form the HCC transport – lack of COMET run. understanding for HCC to confirm if sufficient. Would be willing to agree a MoU that sets out the work going forward and how any identified problems will be addressed. Support the Broad Minister Court Frogmore Noted Support noted No change Locations identified (1185980)

Trustees of James Henry Frank Sewell Deceased (1185630)

1182518

1184221

1185695

1185939

1186062 ‘Broad Locations’ Legal and General Disagree Local Plan wording reflects NPPF wording No change should be renamed (1051022) ‘Strategic Housing Allocations’ Support allocation of Minister Court Frogmore Noted Support noted No change PSGV for housing- (1185980) led development Support the inclusion Grand Union Noted Support noted No change of East and North Investments Ltd. Hemel Hempstead (977391) Broad Locations Support inclusion of Mr and Mrs Bill and Noted Support noted No change land at Holtsmere Valerie Barr (1157883) End Road as part of North Hemel Hempstead Broad Location

Support the inclusion Hallam Land Noted Support noted No change of North St Albans Management Limited (1185998) Concerns about loss 840795 Noted Development need, overall Plan context and site specific No change of Green Belt and analysis in GB work provide exceptional circumstances for green environment GB release. as a result of development of Site selection is firmly based on comprehensive GB work North St Albans which identified the allocated Broad Locations. Concentrating development in larger sites that can create new communities and deliver infrastructure is a key part of the development strategy. Support omission of Ver Valley Society Noted Support noted No change land north-east of (826041) Redbourn Site at North East Helioslough Ltd Disagree Site selection is firmly based on comprehensive GB work No change Redbourn should be (1182085) which identified the allocated Broad Locations. considered/included as a Broad Location Lawes Agricultural Trust Concentrating development in larger sites that can create (1187615) new communities and deliver infrastructure is a key part of the development strategy. 1181750 1185092 Concerns about loss Harpenden Green Belt Noted Site selection is firmly based on comprehensive GB work No change of / harm to Green Association (866541) which identified the allocated Broad Locations. Belt as a result of strategic 1055683 Concentrating development in larger sites that can create new communities and deliver infrastructure is a key part of developments 1185714 proposed at the development strategy. Harpenden

Disagree with 789007 Disagree Site selection is firmly based on comprehensive GB work No change inclusion of North which identified the allocated Broad Locations. East Harpenden, particularly in Concentrating development in larger sites that can create relation to impact on new communities and deliver infrastructure is a key part of infrastructure the development strategy. Disagree with Redbourn Parish Council Disagree Development need, overall Plan context and site specific inclusion of East (759908) analysis in GB work provide exceptional circumstances for and/or North Hemel GB release. Hempstead Broad Leverstock Green Village Locations, including Association (1185907) due to proximity to Berkhamsted Residents Buncefield Action Group (BRAG) (1186012) 759883 498103 334023 1184569 1158258 1185704 1034653 Plan relies too much Berkhamsted Residents Disagree Site selection is firmly based on comprehensive GB work No change on development at Action Group (BRAG) which identified the allocated Broad Locations. Hemel Hempstead (1186012) Concentrating development in larger sites that can create 1185935 new communities and deliver infrastructure is a key part of the development strategy. 1184750 977889

Concerns over Redbourn Parish Council Noted Site selection is firmly based on comprehensive GB work No change impact on Redbourn (759908) which identified the allocated Broad Locations. and surrounding area’s infrastructure, Leverstock Green Village Concentrating development in larger sites that can create including roads, Association (1185907) new communities and deliver infrastructure is a key part of the development strategy. health services, train Hertfordshire County station Council (837689) 759883 1181723 867312 1144419 1034653 1184569 Concerns over 1153741 Noted Site selection is firmly based on comprehensive GB work No change proximity to which identified the allocated Broad Locations. Redbourn and 759883 Concentrating development in larger sites that can create reduction of gap with 1181723 Hemel Hempstead new communities and deliver infrastructure is a key part of 498103 the development strategy. There will still be a very substantial green gap between Hemel and Redbourn which will be enhanced and made permanent by the Country Park. Growth at HH would Redbourn Parish Council Noted Refer to S6 and L17 No change place significant (759908) pressure on the Concentrating development in larger sites that can effectively main town, through Mr Antonio Barba deliver infrastructure is a key part of the development higher use of (1187384) strategy. infrastructure, local D'Arblay Investments (1187404)

services and Concentrating development in larger sites that can create facilities new communities and deliver infrastructure is a key part of the development strategy. This matter will be properly detailed and addressed through the masterplanning / planning application / EIA process, with appropriate consultation. Limited evidence to Redbourn Parish Council Disagree Evidence on development strategy / site selection is available support inclusion of (759908) in full. East and/or North Hemel Hempstead Leverstock Green Village sites Association (1185907) Concerns over Redbourn Parish Council Disagree Evidence on development strategy / site selection is available viability and (759908) in full. deliverability of East and North Hemel Leverstock Green Village Hempstead Association (1185907) Concerns over Gorhambury Estates Disagree Evidence on development strategy / site selection is available deliverability of East Company Limited in full. and North Hemel St (375996) Albans Disagree with Owners of Land North of Disagree Development need, overall Plan context and site specific No change inclusion of West of Napsbury (1186783) analysis in GB work provide exceptional circumstances for Chiswell Green GB release. 1187590 Concerns about loss St Stephen Parish Disagree Development need, overall Plan context and site specific No change of / harm to Green Council (51804) analysis in GB work provide exceptional circumstances for Belt as a result of GB release. development 1182697 proposed at West of 1184271 Chiswell Green 1184839

1184864 1185244 1185478 1185479 1185481 1185482 1185633 1185640 863091 871923 1156288 1182480 1187008 977889 Additional residential St Stephen Parish Disagree Development need, overall Plan context and site specific No change development in Council (51804) analysis in GB work provide exceptional circumstances for Chiswell Green is GB release. not acceptable. Will 1187590 The BL was identified in the Green Belt Review. change character of 1182697 Chiswell Green and pressure local road 1158536 infrastructure and 1184271 services, impact air pollution. No 1184839 evidence as to why this designation 1184864

included as an 1185244 exception to the green belt. 1185478 1185479 1185481 1185482 1185469 1185633 863091 1185775 1156288 1182480 1185640 1187008 Concerns with London Colney Parish Noted Evidence on development strategy / site selection is available No change inclusion of West of Council (52477) in full. London Colney, particularly impact Concentrating development in larger sites that can create on local new communities and deliver infrastructure is a key part of infrastructure the development strategy. Concerns about loss Sanders Laing Noted Site selection is firmly based on comprehensive GB work No change of / harm to Green (1183909) which identified the allocated Broad Locations. Evidence on Belt as a result of development strategy / site selection is available in full. development proposed at West of London Colney

Park Street Garden RF Sinclair and Sons Disagree The main site owner has promoted the site as available and No change Village Broad (1058251) deliverable for housing. Considerations have taken into Location should be account the existing planning permission for an alternative removed from the Department of Health & use and other relevant factors. development Social Care and Bloor strategy as there is Homes (1156886) uncertainty over its availability/delivery Helioslough Ltd for housing as it has (1182085) consent for a rail M Scott Properties freight interchange (1185993)

Butterfly World Project Ltd (1183965)

Jarvis Homes (973180)

CALA Group Ltd (977724)

Albert Bygrave Centre (985070)

Eaton Lodge (985289)

Glinwell PLC (1187377)

Trustees of G.A. Simons Family Trust (1187408)

Home Builders Federation Ltd (1156936)

Gallagher Estates (1143916)

Hallam Land Management Limited (1185998)

Park Street Baptist Church & Bloor Homes Ltd (985300)

Rice Group (1058426)

Beechwood Homes (1123837)

Intrasales Ltd (1157383)

Linden Homes (1153662)

Hertfordshire Land (1159945)

Aldwyck Housing Group (1186030)

DB Rees Builders Ltd (1160056)

Owners of Land East of Common Lane (1186108)

Owners of Land South of Burydell Lane (1186128)

Land at the Dak (1186131)

D’Arblay Investments (1187404)

973643

1153650

1153651

1159948

52064

347648

1181750

1187384

1181750

1185945

1185744

52552

977889

Not clear if cross Helioslough Ltd Disagree There has been ongoing joint working with neighbouring local No change boundary sites and (1182085) authorities including the South West Herts Group. Duty to co- consequences of operate is considered to be met. Considerations have taken SRFI not being into account the existing planning permission for an delivered have been alternative use and other relevant factors. discussed with neighbouring LAs/lack of evidence of effective joint

working on cross boundary strategic priorities Park Street Garden Helioslough Ltd Disagree The main site owner has promoted the site as available and No change Village not an (1182085) deliverable for housing. Considerations have taken into efficient use give the account the existing planning permission for an alternative rarity of a suitable use and other relevant factors. site for a SRFI and longstanding national need for SRFIs. The Plan fails to Butterfly World Project Disagree The specific provision of an ‘SRFI site’ is not a requirement No change include a Ltd (1183965) for a Local Plan replacement SRFI site No details on what Helioslough Ltd Disagree Cross reference with Policy S6 where high level Garden No change PSGV will deliver to (1182085) Village aspirations and access improvements (eg to the meet garden village Abbey Line) are set out. aspirations, or how easy accessibility to St Albans will be achieved Park Street Garden Hill Residential Disagree Development need, overall Plan context and site specific No change Village is identified (1158064) analysis in GB work provide exceptional circumstances for within an area GB release. serving a strategic D'Arblay Investments gap in the Green (1187404), Belt. This will create Trustees of G.A. Simons a ribbon of built Family Trust (1187408) development, release of this land 52552 is contrary to the

Council’s Green Belt 977889 strategy which aims to maintain existing settlement patterns No Department of Health & Disagree Evidence on development strategy / site selection is available No change justification/evidence Social Care and Bloor in full. to support inclusion Homes (1156886) of PSGV Gallagher Estates (1143916)

Gorhambury Estates Company Limited (375996) Disadvantages of Helioslough Ltd Disagree The main site owner has promoted the site as available and No change not providing the (1182085) deliverable for housing. Considerations have taken into SRFI, including loss account the existing planning permission for an alternative of new jobs, 334ha use and other relevant factors. Country Park and reduction of greenhouse gases from shifting road to rail. Plan has no Ellenbrook Area Disagree DtC arrangements ensure this is not the case. Development No change consideration of Residents Association is being coordinated across boundaries under joint working cumulative impact Committee (1185802) and liaison arrangements. It is however acknowledged that between both the whole sub region will experience significant additional current and development to accommodate population / household change proposed residential and growth (in accordance with Government policy - NPPF) developments and quarrying activity within a small area

Lack of evidence to CP Holdings (1158145) Disagree Evidence on development strategy / site selection is available No change support suitability in full. and availability of Broad Location sites Meeting the housing CP Holdings (1158145) Disagree Development need, overall Plan context and site specific No change target should be analysis in GB work provide exceptional circumstances for prioritised ahead of GB release impact on the GB S3 Metropolitan Green Belt

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) General concern at St Albans Civic Society Noted Housing requirement/targets are based on the standard No change Green Belt loss to (1156974) methodology set out by the government – see S4. development 1055683 Site selection is firmly based on comprehensive GB work which identified the allocated Broad Locations. 1158258 1184569 1121386 1144419 It is important that 1182518 Noted Cross reference to NPPF for very special circumstances for No change any development Green Belt development. within the Green Belt remains subject to the ‘very special circumstances’ test in the NPPF

Educational Ramblers Association Disagree Policy L21 /S3 / S6 set out a clear approach. Schools are a No change development in the (52420) key element of infrastructure and have been successfully Green Belt is provided and maintained in the Green belt in numerous inappropriate Harpenden Green Belt locations over many years. Association (866541) St Albans & District Footpaths Society (723340) Beechwood Homes (1123837) CPRE Hertfordshire (872572) London Colney Parish Council (52477) Aurora Properties Limited (1151817) Department for Education (1186955) Linden Wates (Bricket Wood) Limited (1186996) St Albans School (1187032) Crown Estate (51946) The British Horse Society (1187597) Hertfordshire County Council (837689)

334023 1185775 Transport related Ramblers Association Disagree Transport infrastructure is essential to sustainable No change infrastructure (52420) development, including at the Broad Locations. Policy S6 development can sets out the transport infrastructure required. damage the Green St Albans & District Belt. The statement Footpaths Society Local transport infrastructure which can demonstrate a that transport (723340) requirement for Green Belt location are not considered infrastructure within inappropriate development, as set out in para 146 of the Legal and General NPPF. the Green Belt is not (1051022) inappropriate development and Aurora Properties demonstrates ‘very Limited (1151817) special The British Horse circumstances’ is not Society (1187597) justified. CEG (1158030) 867587 The inclusion of a Canton Ltd (1057961) Disagree Based on longstanding approach to maintaining character No change Local Green Belt and identity in District and beyond. purpose in GBR evidence is not justified. Policy should 1153802 Disagree Policy S3 and the NPPF protects the large majority of the GB No change propose absolute % from development. of Green Belt to be built on which cannot be exceeded

Greater recognition 1153802 Disagree GB land is protected by Policy S3 and productive and No change should be given to sustainable farming and forestry is specifically supported. Green Belt protection of productive local sustainable farming and forestry The housing 867068 Disagree Site selection is firmly based on comprehensive GB work No change development which identified the allocated Broad Locations. proposed on Green Belt land does not conserve the natural environment, landscape or infrastructure. This directly contradicts the SA. Developments on Green Belt land should only be carried out on areas of land which already suffer from environmental degradation The policy does not London Colney Limited Disagree Policy S2 deals with this. No change reference housing (977496) development, the broad locations or 1153802 the Green Belt Review and is therefore inadequate

and in conflict with S2 Environmental Intrasales Ltd (1157383) Disagree NPPF supports approach taken, where site selection is firmly No change capacity analysis based on comprehensive GB work which identified the should drive 1153802 allocated Broad Locations. sustainable development in accordance with the NPPF The Plan should not Hill Residential Disagree NPPF supports approach taken, where site selection is firmly No change rely on 2014 Green (1158064) based on comprehensive GB work which identified the Belt Review; it allocated Broad Locations. should be updated. ERLP 1 Sarl (1123561) Stackbourne Limited (1153646) Redbourn Parish Council (759908) Department of Health & Social Care and Bloor Homes (1156886) Intrasales Ltd (1157383) Lawes Agricultural Trust (1187615) Historic England (929489) 1185714 977889

No need for a Green St Albans School Disagree Green Belt Policy is consistent with the NPPF but adds local No change Belt policy at all as (1187032) context and detail. the NPPF already covers the matter 52064 extensively There is a Colney Heath Parish Disagree NPPF supports approach taken, where site selection is firmly No change disproportionate Council (51891) based on comprehensive GB work which identified the amount of allocated Broad Locations. Sites are generally spread across development / loss 347648 the district. Sites outside the district are not included in the of Green Belt in the Plan, though acknowledged through DtC work and work on south of the District, the SWH JSP. exacerbated by Hertsmere to the south and Welwyn Hatfield to the east The policy refers to Aurora Properties Disagree The Policy refers to ‘existing settlement pattern’. No change a settlement pattern Limited (1151817) which is not described or explained. Paragraph 85 of the M Scott Properties Noted Green Belt Policy is consistent with the NPPF. No change NPPF (2012) states (1185993) that when defining boundaries local planning authorities should ‘not include land which it is unnecessary to keep permanently open’ i.e. those that make little contribution to the greenbelt

There is no Crown Estate (51946) Noted The Plan covers the time period to 2036 and the trajectory at No change safeguarded land for Appendix 2 clearly shows substantial delivery of housing post Green Belt releases 52552 2036 on land excluded from the Green Belt. or indication of need 978427 for boundaries to be altered post plan period 2036 GBR evidence does North Hertfordshire Noted Much of Blackmore End is outside the District Boundary. No change not appear to have District Council Overall development strategy has considered these issues. considered the (1185674) Site selection is firmly based on comprehensive GB work release of existing which identified the allocated Broad Locations. settlements like Intrasales Ltd (1157383) Concentrating development in larger sites that can create Blackmore End or 977889 other small scale new communities and deliver infrastructure is a key part of sub areas which the development strategy. make limited contribution to the greenbelt Green Belt should West Hertfordshire Noted No substantive evidence provided to support such an No Change be released to meet Hospitals NHS Trust approach. Cross reference L22 the health care (1183618) infrastructure needs necessary to an increasing population (potentially for a new hospital site) Remove the area of 52064 Disagree Green Belt Policy and approach for this area is consistent No change Rothamsted Park with the NPPF. designated as Town Centre from Green Belt

S4 Housing Strategy and Housing Requirement/Target

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Revised 2016-based Jarvis Homes (973180) Noted The Plan is intended to address need as defined by No change household Government through the ‘standard methodology’ projections were Comer Group (872799) published in DB Rees Builders Ltd September 2018 (1160056) and indicate lower rates of household Anderson Group growth over the plan (1146719) period which need to Glinwell PLC (1187377) be taken into account Intrasales Ltd (1157383) Simons Family Trust (1187408) Lawes Agricultural Trust (1187615) Jarvis Homes (973180) CALA Group Ltd (977724) Albert Bygrave Centre (985070) Eaton Lodge (985289) Rice Group 1058426) Beechwood Homes (1123837)

Linden Homes (1153662) Hertfordshire Land (1159945) Aldwyck Housing Group (1186030) CPRE Hertfordshire (872572) DB Rees (Builders) Ltd (1160056) Owners of Land East of Common Lane (1186108) Owners of Land South of Burydell Lane (1186128) Land at The Dak (1186131) London Colney Parish Council (52477) Trustees of James Henry Frank Sewell Deceased (1185630) Colney Heath Parish Council (51891) Hertsmere Borough Council (51934)

Burhill Developments Ltd (977347) M Scott Properties (1185993) Department of Health & Social Care and Bloor Homes (1156886) North Hertfordshire District Council (1185674) Wrenbridge Land Ltd (1187023) Dacorum Borough Council (1186054) Welwyn Hatfield Borough Council (52397) CEG (1158030) Gallagher Estates (1143916) Castleoak Care Communities (1187716) 973643 1153651 1159948 978420 978427

977889 1187384 1187404 973643 347648 1185971 1019306 1153650 1153651 1159948 Housing targets are CPRE Hertfordshire Disagree Housing targets are based on the standard methodology set No change out of proportion (872572) out by the government. with the expected rise in population London Colney Parish Providing a higher amount of housing aims to accord with the over the plan period Council (52477) Government’s ambition to address the long term housing and ought to be demand whilst taking into account the future demographic Trustees of James Henry changes at a district level. lower Frank Sewell Deceased (1185630) Colney Heath Parish Council (51891) Department of Health & Social Care and Bloor Homes (1156886) 867068 867587

1184784 1153802 1019306 1185956 1055683 1185971 347648 Housing target Intrasales Ltd (1157383) Disagree Housing targets are based on the standard methodology set No change should however be a out by the government. “minimum” with the Pennard Holdings Ltd aim to achieve (51983) above these targets Longbourn Estates as per the (977635) Government’s aspirations as set Grand Union out in the NPPF Investments Ltd (2018) (977391) Local Plan base Martin Grant Homes and Disagree 2020 is the earliest realistically possible date of adoption of No change date should align Kearns Land (975683) the Plan and is therefore appropriate in the context of the new with the start of the draft and final NPPF. plan preparation Canton Ltd (1057961) The Plan necessitates a significant change in approach from period and Jarvis Homes (973180) demonstrate 5 year previous tight Green Belt restraint. This involves a carefully supply of housing CALA Group Ltd considered stepped trajectory for delivery of new sites that (977724) are best able to deliver to the overall plan development strategy. There are sufficient deliverable sites for years 1-5. Albert Bygrave Centre This is confirmed in relevant developer representations. (985070) Eaton Lodge (985289)

Park Street BCh & Bloor Homes Ltd (985300) Rice Group (1058426) Beechwood Homes (1123837) Linden Homes (1153662) Hill Residential (1158064) Hertfordshire Land (1159945) Minister Court Frogmore (1185980) Aldwyck Housing Group (186030) DB Rees (Builders) Ltd (1160056) Owners of Land East of Common Lane (1186108) Owners of Land South of Burydell Lane (1186128) Land at The Dak (1186131) ERLP 1 Sarl (1123561)

Stackbourne Limited (1153646) Burhill Developments Ltd (977347) Aurora Properties Limited (1151817) Anderson Group (1146719) CWC Group (1153869) Department of Health & Social Care and Bloor Homes (1156886) Wrenbridge Land Ltd (1187023) Pennard Holdings Ltd (51983) London Colney Limited (977496) Longbourn Estates (977635) Home Builders Federation Ltd (1156936) Dacorum Borough Council (1186054) Lawes Agricultural Trust (1187615)

Hallam Land Management Limited (1185998) Gorhambury Estates Company Limited (375996) Gallagher Estates (1143916) CP Holdings (1158145) 1153650 1153651 973643 1159948 Concerns with using Martin Grant Homes and Disagree The Plan necessitates a significant change in approach from No change a stepped trajectory Kearns Land (975683) previous tight Green Belt restraint. This involves a carefully which has ambitious considered stepped trajectory for delivery of new sites that delivery levels in Canton Ltd (1057961) are best able to deliver to the overall plan development later years, does not RF Sinclair and Sons strategy. There are sufficient deliverable sites for years 1-5. address housing (1058251) This is confirmed in relevant developer representations. need within years 1- Housing trajectory includes the 20% buffer required by NPPF. 5 of the plan, and is Hunston Planning not balanced with an Limited (1185622) affordability buffer to Jarvis Homes (973180) enable the prospect of achieving a rolling CALA Group Ltd supply of homes. (977724) Albert Bygrave Centre (985070)

Eaton Lodge (985289) Park Street BCh & Bloor Homes Ltd (985300) Rice Group (1058426) Beechwood Homes (1123837) Linden Homes (1153662) Hill Residential (1158064) Hertfordshire Land (1159945) Minister Court Frogmore (1185980) Aldwyck Housing Group (1186030) CPRE Hertfordshire (872572) DB Rees (Builders) Ltd (1160056) Owners of Land East of Common Lane (1186108) Owners of Land South of Burydell Lane (1186128)

Land at The Dak (1186131) Legal and General (1051022) Stackbourne Limited (1153646) Trustees of James Henry Frank Sewell Deceased (1185630) Burhill Developments Ltd (977347) Aurora Properties Limited (1151817) M Scott Properties (1185993) Sandridge Parish Council (869186) Comer Group (872799) Anderson Group (1146719) Intrasales Ltd (1157383) Wrenbridge Land Ltd (1187023) Owner Pound Farm & East of Sandridge (1187227)

Pennard Holdings Ltd (51983) London Colney Limited (977496) Longbourn Estates (977635) Adrian Irving and Alban Developments Ltd (1156368) Home Builders Federation Ltd (1156936) Taylor Wimpey Strategic Land (1187472) Lawes Agricultural Trust (1187615) CEG (1158030) Crest Strategic Projects and Bloor Homes (1158079) Gorhambury Estates Company Limited (375996) Gallagher Estates (1143916) CP Holdings (1158145)

Mr and Mrs Bill and Valerie Barr (1157883) 52064 973643 1153650 1153651 1159948 1157883 1153268 Suggest that 1153802 Disagree Development need, overall Plan context and site specific No change “exceptional analysis in GB work provide exceptional circumstances for circumstances” are GB release. not expected to continue and no more than 0.5% greenbelt to be built on per 15 years Other small sites Hunston Planning Disagree The Plan necessitates a significant change in approach from No change should be included Limited (1185622) previous tight Green Belt restraint. This involves a carefully as those identified considered stepped trajectory for delivery of new sites that will not address any Fairview New Homes Ltd are best able to deliver to the overall plan development percentage of the (1185602) strategy. housing requirement St Stephen Parish because they will be Council (51804) Concentrating development in larger sites that can create built out before the new communities and deliver infrastructure is a key part of start of the Plan Anderson Group the development strategy. (1146719)

Taylor Wimpey Strategic Land (1187472) Gallagher Estates (1143916) 52064 The last SHLAA Jarvis Homes (973180) Disagree Evidence on development strategy / site selection is available No change update to include in full. any detailed site 1153268 assessment was the 2016 update, although this was only a partial update and for many sites the assessment had not been revisited since the 2009 update, The paragraph Ramblers Association Disagree Development on small sites will have to satisfy relevant Local No change beginning “Small (52420) Plan policies and the NPPF, including demonstrating very sites of half a special circumstances in the Green Belt if required. hectare or less” is St Albans & District ambiguous and Footpaths Society needs to be clarified (723340) to ensure that it will The British Horse not provide grounds Society (1187597) for piecemeal erosion of Green Belt boundaries Para 68(a) of the Jarvis Homes (973180) Disagree Housing coming forward on sites of 1 hectare has formed a No change NPPF requires 10% large part of historic supply and will continue to form at least of housing CALA Group Ltd requirements to be (977724)

met on sites of 1 Albert Bygrave Centre 10% of the housing requirement during the Plan period. This hectare or less and (985070) includes those sites set out at Appendix 5. therefore there is no sound evidence to Eaton Lodge (985289) support the position Park Street BCh & Bloor that only sites of 500 Homes Ltd (985300) homes or more should be identified Rice Group (1058426) in the Local Plan Beechwood Homes (1123837) Linden Homes (1153662) Hertfordshire Land (1159945) Aldwyck Housing Group (1186030) DB Rees (Builders) Ltd (1160056) Fairview New Homes Ltd (1185602) Owners of Land East of Common Lane (1186108) Owners of Land South of Burydell Lane (1186128) Land at The Dak (1186131)

Hertsmere Borough Council (51934) Hilton House Properties (1057476) Anderson Group (1146719) Intrasales Ltd (1157383) Owner Pound Farm & East of Sandridge (1187227) 1187590 973643 1153650 1153651 1159948 1153268 Windfall allowance is Jarvis Homes (973180) Disagree Paragraph 68 of the NPPF states the “local planning No change not justified by the authorities should support the development of windfall sites NPPF or analysis of CALA Group Ltd through their policies and decisions- giving great weight to the past trends in either (977724) benefits of using suitable sites within existing settlements for the SHLAA or AMR Albert Bygrave Centre homes.” There is no conflict with NPPF. to explain or (985070) evidence the 105 dwellings per annum Eaton Lodge (985289) Park Street BCh & Bloor Homes Ltd (985300)

Hunston Planning Limited (1185622) Rice Group (1058426) Beechwood Homes (1123837) Linden Homes (1153662) Hertfordshire Land (1159945) Minister Court Frogmore (1185980) Aldwyck Housing Group (1186030) CPRE Hertfordshire (872572) DB Rees (Builders) Ltd (1160056) Owners of Land South of Burydell Lane (1186128) Land at The Dak (1186131) Anderson Group (1146719) North Hertfordshire District Council (1185674)

London Colney Limited (977496) Home Builders Federation Ltd (1156936) Lawes Agricultural Trust (1187615) Castleoak Care Communities (1187716) Owners of Land South of Burydell Lane (1186128) 973643 1153650 1153651 1159948 1186131 There is no evidence Jarvis Homes (973180) Disagree Ongoing Council programme has recently delivered and will No change of council owned continue to deliver housing sites that would CALA Group Ltd deliver housing (977724) Albert Bygrave Centre (985070) Eaton Lodge (985289) Park Street BCh & Bloor Homes Ltd (985300) Rice Group (1058426)

Linden Homes (1153662) Hertfordshire Land (1159945) Hunston Planning Limited (1185622) Aldwyck Housing Group (1186030) DB Rees (Builders) Ltd (1160056) Owners of Land East of Common Lane (1186108) Owners of Land South of Burydell Lane (1186128) Owners of Land South of Burydell Lane (1186128) Land at The Dak (1186131) 973643 1153651 1159948 1186131 There is no evidence Jarvis Homes (973180) Disagree Conversion of offices to residential using permitted No change of sites that could be development and applications have been a significant source converted from CALA Group Ltd of housing in recent years. This will however reduce as many (977724)

employment use to Albert Bygrave Centre of the conversions have now taken place. An appropriate housing (985070) approach has been taken. Eaton Lodge (985289) Park Street BCh & Bloor Homes Ltd (985300) Rice Group (1058426) Beechwood Homes (1123837) Linden Homes (1153662) Hertfordshire Land (1159945) Aldwyck Housing Group (1186030) DB Rees (Builders) Ltd (1160056) Owners of Land East of Common Lane (1186108) Owners of Land South of Burydell Lane (1186128) Land at The Dak (1186131) 186131 1153650 1153651

1159948 The target for Retirement Housing Disagree NPPF supports both appropriate provision of care homes and No change residential care Group (1185738) flexi-care and that such provision is included in housing homes and flexi-care targets. Evidence is available in full. homes is too low, Aurora Properties should not be Limited (1151817) included within the Dacorum Borough housing target and Council (1186054) there is no indication of when they would Hallam Land be delivered. Management Limited (1185998) Castleoak Care Communities (1187716) The delivery of M Scott Properties - Disagree Evidence is available and landowner/developer teams have No change infrastructure does 1185993) confirmed deliverability of Broad Location related not reflect the infrastructure. growth of housing Anderson Group and there is no (1146719) viability evidence 1152471 demonstrating that it can be supported 789007 It should be clarified CWC Group (1153869) Noted There has been and continues to be ongoing joint working No change whether the housing with neighbouring local authorities including the South West targets have Wrenbridge Land Ltd Herts Group. Duty to co-operate is considered to be met. considered unmet (1187023) This has included consideration of potential unmet development needs Dacorum Borough development needs from neighbouring authorities and their from neighbouring Council (1186054) potential to provide for St Albans. authorities such as Dacorum or if the Lawes Agricultural Trust Council sought (1187615) assistance from

adjoining councils to Welwyn Hatfield Borough meet housing need. Council - 52397) Gorhambury Estates Company Limited (375996) Central Bedfordshire Council (861963) 1185583 Support the St Stephen Parish Noted Support noted No change inclusion of Council (51804) Residential Care Homes/ Nursing homes in policy S4 Support standard CP Holdings (1158145) Noted Support noted No change methodology of 913 dwellings per annum S5 Economic Development Strategy and Employment Land Provision

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Employment 1182733 Disagree Specific plan provision of land is based on strategic planning No change welcomed but job factors. opportunities needed elsewhere Policy S5 supports employment land provision appropriate to in the south of the the settlements, which include London Colney in the south of District and the District. Policy L16 supports a mixed use opportunity area Hertsmere for new within Colney Fields Retail Centre/Ridgeview for and existing retail/services and offices. villages

Support Grand Union Noted Support noted No change employment/provisi Investments Ltd on of jobs (977391) 51 Pegasus Ltd (1186098) 1185037 Economic Colney Heath Parish Disagree The Plan’s main role is to provide sufficient land and property No change approach should Council (51891) opportunities. It is more difficult to influence the type of job be more ‘diverse’ – that is provided as this is determined by overall economic more detail 1055738 conditions / economic development. required on type of job and salary. However the multi-site Hertfordshire Enviro-Tech Enterprise Zone is a significant opportunity in respect of the point raised. The EZ has important functions supporting business start-ups and attracting UK and international investment. Green technology is a business sector with strong growth potential to create jobs over the plan period in emerging industries. The proposed development at EHH (Central) will be required to develop enviro-tech business, and provide for a range of uses including offices, research and development, light industrial and logistics and new business park of B1 uses. The precise 1055738 Noted The EZ is clearly delineated on the Policies Map. It does not No change boundaries of the affect existing residential uses. The site at EHH (Central) will Hertfordshire be subject to masterplanning under Policy S6 ii) to establish enviro-tech the precise locations of the individual areas. enterprise zone should be clarified and safeguarded to inhibit residential development.

A clear timescale 1055738 Disagree The Plan’s main role is to provide sufficient land and property No change should be set for opportunities. It is more difficult to influence the timescale on achievement of which jobs are provided, as this is determined by overall new jobs economic conditions / economic development. The proposed employment growth will be over the timeframe of the LP namely 2020-2036. Details of 1055738 Disagree Not within planning remit No change organisations using the Enterprise Zone required Improve poor 1185704 Disagree Additional employment land is needed long term. No change quality and safety of Maylands Dacorum Borough Council are working to improve the employment area, existing, important employment area. Hemel Hempstead before building on agricultural land for further employment development. Roehyde should be Goodman (1153774) Disagree An additional Green Belt employment location is not required. No change an employment This site is not suitable for such development and is in part an broad location (with 1185775 existing waste site. University links). 347648 BRE and Rothamsted Research are established areas of employment within the Green Belt and areas designated as part of the multi-site Hertfordshire Enviro-Tech Enterprise Zone supported by the Government. They have important functions supporting business start-ups and attracting UK and international investment. Whilst it is acknowledged the importance of teaching and research undertaken by the University of Hertfordshire, it is not incorporated within the Herts Enterprise Zone.

Query deliverability London Colney Parish Disagree The location is highly accessible to the strategic road network No change of East Hemel Council (52477) and is likely to be attractive to development; particularly as an Hempstead EZ. employment land Goodman (1153774) allocation, 1185775 (demand for and accessibility from 347648 St Albans & Colney Heath & London Colney). Plan economic The Owners of Disagree The plan approach to employment is well evidenced. No change evidence base not Breakspears (973659) up-to-date St Albans SW Hertfordshire Economic Study update 51 Pegasus Ltd published February 2019. Takes into account recent (1186098) economic forecasts, the changes to the commercial property stock including that lost through PD, revisit growth scenarios Hertsmere Borough and assesses demand and supply. Council (51934) Planned jobs to meet the needs of the estimated population Watford Borough Council over period 2020-2036 and serves a strategic role for the (1122500) whole of SW Herts. Luton Borough Council (861967) Crown Estate (51946) Aurora Properties Limited (1151817) St Albans Civic Society (1156974) 498103

1019306

1185704 Plan should Hill Residential Disagree Economic ambitions/needs of Rothamsted Research alone No change support future (1158064) cannot determine Plan development strategy. prosperity of Rothamsted Land at Townsend Lane does not fall within one of the Broad Research by Locations for development within the LP 2018.There are two removing planned Broad Locations for development within Harpenden Townsend Lane to the NE and NW of the town lying approx. 1.5-2 miles from from the Green Rothamsted Institute in proximity and accessible via a range Belt for residential of active transport. development Concern about 51 Pegasus Ltd Noted The plan makes substantial new land provision for office No change shortage in supply (1186098) development. of offices, impacting rent. Policy S6 ii East Hemel requires delivery of a 17ha business Lack of allocations park for Class B1 office uses. There are two strategic office in Plan. Land locations designated on policies map at St Albans City adjacent Station and St Albans Abbey Station both subject to Article 4 Copsewood should direction. be allocated for employment and removed from the green belt. All employment 51 Pegasus Ltd Disagree There are two strategic office locations designated on policies No change sites are remote (1186098) map at St Albans City Station and St Albans Abbey Station. from the city Policy L17 supports high speed broadband and next centre. There is a St Albans Labour Party generation telecommunications. Policies L11 and BL at EHH need for a new St Group (1183933) (Central) seek improvements to active travel links and public Albans digital transport. business park.

Major employment CPRE Hertfordshire Disagree The employment provision of 55ha forms part of the EHH No change allocation at East (872572) (Central) broad location designation. Development need, Hemel Hempstead overall Plan context and site specific analysis in GB work is contrary to provide exceptional circumstances for GB release. Green Belt policy– there are no exceptional circumstances More small and 347648 Disagree Policy S5 supports employment opportunities within category No change medium one settlements of St Albans and Harpenden where there are employment sites four broad locations designated and provision for a large should be allocated employment development in EHH. Policy L16 supports a within Broad mixed use opportunity area within Colney Fields Retail Locations Centre/Ridgeview for retail/services and office in proximity to BL S6ix west of London Colney. There will be local centre employment opportunities with the Broad Locations Target of 55ha Hertfordshire Local Noted The 10,000 jobs estimate for the Plan is justified in detailed No change does not align with Enterprise Partnership evidence. This is not a rigid target. Enterprise Zone (1186903) targets. Target for The more modest LEP target was prepared for a different all 7 Zones is 8000 Dacorum Borough purpose and covers a different time period. The Hertfordshire jobs whilst Council (1186054) LEP Strategy covers the period from 2017-2030 whilst the LP proposed EHH is covers the period up to 2036. for 10,000 jobs. EHH (Central) site will also be required to provide a business park of primarily B1 offices and new logistics and mixed industrial area. Plan has London Colney Parish Disagree Policy L17 supports high speed broadband and next No change insufficient sites for Council (52477) generation telecommunications which will ensure that digital employment employment sites are desirable and attractive to those industries requiring faster broadband speeds and greater digital connectivity. The Connected Counties programme of which Hertfordshire is a partner, focuses on providing

superfast broadband infrastructure and extensions of fibre broadband coverage by 2019. Concern on impact Luton Borough Council Noted Both areas need to make provision for employment growth. No change take-up, delivery (861967) The EZ approach in Hertfordshire is designed to target and viability of different aspects of employment growth to that in Luton. It Luton strategic serves the whole of SW Herts. employment sites. The importance of the Luton/Dunstable conurbation and its economic role is acknowledged. Luton has a significant sub- regional role including due to the strategic importance of the airport and the aspirations for expansion. Commuting – it is acknowledged that the M1/M25 growth area extends through Luton into Bedfordshire. Whilst commuting patterns are increasingly diffused Luton has higher self-containment rate of workers than SADC and is not top destination for out-commuting from St Albans https://www.luton.gov.uk/Environment/Lists/LutonDocuments/ PDF/Local%20Plan/Growing%20Lutons%20economy/ECON %20013.pdf Reducing need to Luton Borough Council Disagree L18 (Transport Strategy) promotes sustainable modes and Publish SW Herts travel not been (861967) transport infrastructure. Travel Plans are required for all major Economic study on considered (growth developments which should set out measures to encourage website of home working). people to use alternative modes of travel to car. Policy S5 supports a mix of employment uses and S6ii EHH site lies adjacent to BL for housing development. Evidence takes account of the trend to no location specific working by planning for a more limited level of land for employment use. The SW Herts Employment Study update 2019 further factors in home working effects into floorspace requirements. The success of Hertfordshire Connected Counties Programme may further influence transport systems and working at home.

Some jobs in EHH Dacorum Borough Disagree This is a matter for joint working within SWH structures and No change BL should count Council (1186054) JSP preparation. Employment land provision follows the lead towards Dacorum’s set by the SEP LEP and is strategic in nature, serving SW job growth target. Herts as a whole. The Local Plan deliberately does not set a SADC area job growth target as it takes an opportunities based approach. If a specific quantitative jobs target is seen as needed / useful it should be related to the whole SWH FEMA through work on the JSP. Large scale office Dacorum Borough Disagree Office uses are that the core of long term need for No change development not Council (1186054) employment premises (as evidenced in SADC and SW Herts currently viable at studies). The allocation of (a part only) of the land at this East Hemel location for offices is a crucial part of the SWH approach to Hempstead. economic development, as there are limits on alternative Maylands as locations available (alternative housing land use pressures). existing is a different market St Albans SW Hertfordshire Economic Study update and should be published February 2019 confirms likely viability in medium prioritised. term. Important role of EZ and SWH work in supporting viability. Amount of land Lawes Agricultural Trust Disagree Rothamsted Research is an established area of employment No change required at (1187615) designated as part of the multi-site Hertfordshire Enviro-Tech Rothamsted Enterprise Zone supported by the Government. They have reducing and some important functions supporting business start-ups and should be released attracting UK and international investment. Green technology for housing is a business sector with strong growth potential to create development to jobs over the plan period. The LP supports its future growth, support the but this does not justify a separate approach to housing research activity development in the Green Belt. financially – with associated economic

development benefits WHBC Economy Welwyn Hatfield Borough Disagree There is no single approach or definitive answer to the No change study (2015) Council (52397) definition of a FEMA. SADC has taken a view, supported by indicates some of evidence, that a practical FEMA definition is SW Herts. All SADC lies within five SW Herts LPAS and HCC agree. Some cross-boundary the Welwyn relationships with Welwyn & Hatfield clearly exist and are Hatfield functional acknowledged. economic area (FEMA) due to economic linkages and significant commuting flows S6 - Broad Locations for Development Representation Point Representor Outline Recommended Reply (including notes and references) Suggested Actions Raising Point (see Reply (including any below for list of Changes to Plan) abbreviations) Reference to joint Hertsmere Disagree Cross reference to paragraph 1.5. No need to repeat here. No change working with Borough Council There has been ongoing joint working with neighbouring local neighbouring authorities (51934) authorities including the South West Herts Group. required Policy needs to ensure Legal and General Disagree Policy S6 sets out a very clear approach. Masterplanning will No change masterplanning does not (1051022) be Council-led, in collaboration with developers, residents and delay delivery taking other stakeholders. place as soon as Home Builders possible and developer Federation Ltd led masterplanning (1156936) Requirement for M Scott Properties Disagree Masterplans are required for sites of this scale to secure high No change masterplans may cause (1185993) quality development. delays, particularly

where there is multiple Home Builders There are sufficient deliverable sites for years 1-5. This is ownership Federation Ltd confirmed in relevant developer representations. (1156936) Preamble should be Crown Estate Disagree Policy S6 sets out a clear approach. This matter can be No change more flexible to allow for (51946) properly detailed through the Masterplanning / planning changes arising through application / EIA process, with appropriate consultation. public consultation/ Planning application process Support community 1185950 Noted Support noted No change involvement in masterplanning Stakeholders should 1185950 Noted Masterplanning will indeed involve a range of stakeholders, No change include those providing including these and more infrastructure, including schools, public transport and health professionals Strategic maps of the Watford Borough Noted This matter can be properly detailed through the No change sites, identifying key Council (1122500) Masterplanning / planning application / EIA process, with elements, would aid appropriate consultation. interpretation of the allocations. These could also be used to demonstrate the conceptual approach to development. Important to consider Watford Borough Noted Refer to paragraph 2.1 which outlines the overall vision of the No change how the proposed Council (1122500) Local Plan. This is also applicable to the Broad Location sites. development areas will be reinforced and This matter can be properly detailed through the enhanced as part of Masterplanning / planning application / EIA process, with Local Plan reviews appropriate consultation.

Could include a greater Watford Borough Disagree Each S6 sub-policy (i), (ii) etc. sets out an overall objective. No change explanation of the long- Council (1122500) term vision of the role of the Broad Locations Support principles of Crown Estate Noted Support noted No change policy (51946) Policy is inflexible – Crown Estate Disagree The policies provide a clear requirement which reflects the No change should refer to ‘should (51946) NPPF. The wording used aims to ensure that the requirements reflect’, not ‘must meet’ are met. Health Impact Hertfordshire Noted This matter will be properly detailed through the EIA process, No change Assessment should be County Council with appropriate consultation carried out at EIA (837689) scoping opinion stage Policy S6 i) East Hemel Hempstead (North) Broad Location Representation Point Representor Outline Recommended Reply (including notes and references) Suggested Actions Raising Point Reply (including any Changes to Plan) Strongly support the Crown Estate Noted Support noted No change policy (51946) Built development Crown Estate Disagree The Plan boundaries are appropriate and reflect site No change boundary should be (51946) constraints and the general findings of the GBR. amended to be in line with SLR plan L2

Although it is inevitable Crown Estate Noted The Nickey Line footpath / cycleway is an important landscape, No change that the development of (51946) commuting and recreational route feature. As it will need to be Broad Location S6 (i) will crossed there will inevitably be some localised adverse lead to additional impacts. There will also be considerable opportunities for vehicular crossings of the enhancement. Masterplanning will consider damage mitigation, Nickey Line which will integration and maximising opportunities within and beyond the cause some detriment, development. these will be mitigated as far as possible

Point 1 should refer to Crown Estate Disagree Already set out in overall S6. No change development being (51946) materially in accordance with the masterplan No justification for 3% Crown Estate Disagree Justification based on evidence including the Self Build No change self-build figure (51946) Register. SADC are required to have regard to this as part of Self Build and Custom Housebuilding Act 2015. Should have an Dacorum Borough Disagree HGC is a wider and evolving concept, much of it beyond SADC No change overarching Hemel Council (1186054) boundaries, that is better set out and explained outside of the Garden Communities Local Plan. Broad Location policy including reference to the charter, overall development scale, masterplanning approach, affordable housing, density, housing mix, key infrastructure, infrastructure standards and joint approach, and Strategic Sites Design Guidance

Nickey Line mitigation Friends of the Agree The Nickey Line footpath / cycleway is an important landscape, No change measures indicated by Nickey Line commuting and recreational route feature. As it will need to be the Crown Estate must (1184312) crossed there will inevitably be some localised adverse be provided. impacts. There will also be considerable opportunities for enhancement. Masterplanning will consider damage mitigation, integration and maximising opportunities within and beyond the development. Concerns over proximity Redbourn Parish Disagree The importance of this issue is acknowledged. No change to Buncefield - policies Council (759908) should include reference The Plan development proposals already take account of the to the health and safety 759883 health and safety issues associated with the Depot. The Health and Safety Executive will be consulted as part of any Development Proximity 498103 Zone Consultation Zones planning application in proximity to the Buncefield DPZ. at Buncefield Oil Storage 1144419 This matter can be properly detailed through the Depot. 1185704 Masterplanning / planning application / EIA process, with appropriate consultation. Concerns with road 1153741 Disagree Cross reference with Policies L 17 / 18. No change access, particularly from / to the M1. 498103 Infrastructure evidence (ref IDP / IDS) confirms that road access can be provided and the M1 junction improvement 1184750 proposals are appropriate solutions. This matter can be properly detailed through the Masterplanning/ planning application process, with appropriate consultation. Improvements to the M1 1153741 Disagree Cross reference Policies L 17 / 18. No change Junction 8 insufficient, an additional junction should Infrastructure evidence (ref IDP / IDS) confirms that road be considered access can be provided and the M1 junction improvement proposals are appropriate solutions. Concerns development 1184750 Disagree Infrastructure evidence (ref IDP / IDS) confirms that road No change would provide access can be provided and the M1 junction improvement proposals are appropriate solutions.

opportunity for a Junction 8A Internal road/local roads Redbourn Parish Disagree The internal road is planned as a main distributor road, so it No change would become a ‘rat-run’ Council (759908) cannot reasonably be described as a rat run. 498103 Lower housing figure 498103 Disagree Housing targets are based on evidence on local housing need No change should be applied to and standard methodology set out by the government. allow for more green spaces and community facilities Density will need to be Redbourn Parish Disagree Some sub-areas will achieve higher density. Overall the land No change higher than 40dph to Council (759908) can accommodate the dwelling numbers in the Plan (reference provide the 1,650 Annex 1) dwellings as some land 498103 in private ownership, which would not be appropriate Lack of green spaces in 498103 Disagree Cross reference Policy L22 and L26 – 28. No change plans for EHH Substantial green space provision is planned. This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation. Lack of off-street parking 498103 Disagree Cross reference Policy L20 and appendix 1. No change provision in plans for EHH There are clear standards in Plan policy. Lack of community 498103 Disagree Cross reference Policy L22 and L26 – 28. No change facilities in plans for EHH Substantial community facility provision is planned.

This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation. Further work needs to be Hertfordshire Noted These points are generally recognised. These matters can be No change carried out on County Council properly detailed through the Masterplanning process / infrastructure, including (837689) planning application / EIA processes, with statutory highways, parking, water, consultation. sewerage 498103

867312 Health and safety 498103 Noted These points are generally recognised. This matter can be No change aspects of building close properly detailed through the Masterplanning process / to M1, pylons, oil 1144419 planning application / EIA processes, with statutory pipeline, Buncefield Oil 1185704 consultation. Depot and under Luton Airport flightpath need to be considered There should be a joint 498103 Disagree This was an option considered. It has been replaced with a No change Area Action Plan for EHH collaborative joint Masterplanning process which can address with DBC 1185704 the issues more quickly in the context of the clear development requirements in the Plan and the requirements of the NPPF. Not explicitly clear what Sport England Disagree Cross reference Policy L22 and L26 – 28. No change sports facilities to be (824971) provided The policy refers to strategic and local open space and recreation space and community facilities. Any specific reference to the type of specific sports facilities would be overly prescriptive and inflexible at this stage. This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation.

No evidence base to Sport England Disagree Cross reference Policy L22 and L26 – 28. No change inform need for sports (824971) provision Baseline and further work since Regulation 19 has been undertaken to inform specific development proposals. Playing Pitch Strategy update 2019 provides baseline data. Need for additional Sport England Agree Cross reference Policy L22 and L26 – 28. No change facilities at this location (824971) where facilities already at The policy concurs stating that development will be required to capacity deliver strategic and local open space and recreation space and community facilities This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation Should include sports Sport England Disagree Cross reference Policy L22 and L26 – 28. No change facility provision in (824971) proposal points The policy states that development will be required to deliver strategic and local open space and recreation space and community facilities This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation Unclear if public open Sport England Disagree Cross reference Policy L22 and L26 – 28. No change space or recreation (824971) space refers to indoor or The policy refers to strategic and local public open space. outdoor sports provision Open space is defined under the NPPF as all space of public value, land and water which offer important opportunities for sport and recreation. It is clear that this is therefore outdoor in nature. The policy also refers to recreation space and community facilities which would capture indoor sports facilities.

This matter can be properly detailed through the Masterplanning process. Further consideration of Sport England Agree Cross reference Policy L22 and L26 – 28. No change strategic community (824971) sports facility provision is The proposed Hemel BL’s S6 i-iv (apart from S6ii as a major required across all EHH new Enviro-Tech business / employment land focused BLs location) all require delivery of strategic and local public open space. The precise location and nature of the open spaces and community sport provision will be informed by ongoing joint work with Dacorum Borough Council. As per Policy L22 the Council would support new facilities in appropriate and sustainable locations and joint use of facilities near to new housing areas to meet sustainability objectives.

This is part of the Masterplanning process. Both strategic and local Ramblers Agree This is set out in the policy and will be taken forward as part of No change public space must be Association the Masterplanning process provided (52420) St Albans & District Footpaths Society (723340) Hertfordshire County Council (837689) 1184750 Countryside access links Ramblers Agree This is set out in the policy and will be taken forward as part of No change must be provided Association the Masterplanning process (52420) St Albans & District Footpaths Society (723340), 1157340

Must provide / support Ramblers Agree This is set out in the policy and will be taken forward as part of No change the country park Association the Masterplanning process (52420) St Albans & District Footpaths Society (723340) 1184750 1185037 Hertfordshire County Council (837689) Areas of the Country 498103 Disagree Provision of an accessible well managed public country park is No change Park will be inaccessible a development requirement. to the public and has unclear management This matter can be properly detailed through the plans. Country Park is masterplanning / planning application process, with appropriate really an area for consultation. balancing ponds. Heritage environment 334023 Disagree Cross reference Policy L30 No change /assets have not been considered at EHH and Redbourn Parish This supports conservation of heritage assets appropriate to lack of criteria to protect Council (759908) their significance and seeks that development which may affect such assets is accompanied by a Heritage Statement. assets Historic England (929489) Such heritage assets form only a small proportion of the overall Broad Location, are acknowledged and will be treated Leverstock Green appropriately as part of the Masterplanning / planning Village Association application processes. (1185907) Heritage Impact Historic England Disagree Cross reference Policy L30 No change Assessment required (929489)

and policy wording This is part of the masterplanning process should reflect its findings Development, including 1184750 Agree Cross reference Policy L29 No change landscaping, should be of a high standard of This is part of the masterplanning process design Further landscape and 1184750 Noted Cross reference Policy L29 No change EIA work should be carried out This is part of the masterplanning and planning application process; including statutory consultation Sports/health/educational 1184750 Disagree Cross reference Policy 26 - 28 No change facilities must not encroach into country Open space provision is very sizeable. The detailed park land masterplanning of the open space can allow for accommodation of all these uses and for appropriate country park / habitat creation. 40dph too high 1184750 Disagree This is an appropriate minimum density to make best use of land No change and to avoid further pressure on loss of greenfield land/ Green Belt. The NPPF supports optimisation of residential density. Alternatives to the 1184750 Noted Undergrounding or diversion is unlikely to be practical or No change overhead power lines viable. However the development will be Masterplanned to should be considered avoid undesirable environmental and visual issues in the design of the new development. Important trees must be 1184750 Noted Cross reference Policy L29 No change preserved Hertfordshire Retention of important trees is a requirement of the policy. County Council (837689) Clarity needed on St Albans & District Noted Cross reference Policy L21 and Policies Map. Primary school No change whether specific Footpaths Society within the area excluded from the green belt, secondary school deliverables such as (723340) within the Green Belt.

school buildings will be The British Horse accommodated in the Society (1187597) Broad Location or Green Belt Proposed secondary 1185037 Noted School place catchment and allocations policies are not a No change school will risk Redbourn planning matter. children’s access to Roundwood Park Support setting minimum Grand Union Noted Support noted No change housing number targets Investments Ltd (977391) DBC and SADC are not 1144419 Disagree Cross reference Policy S2 / S4 No change collaborating, particularly with regard to number of 1185704 SADC and DBC are clearly working together through ongoing houses allocated to Duty To Cooperate, including the SWH JSP process. SADC and DBC Concerns that the 1144419 Disagree This is a specific policy requirement in the Plan. All No change development may not requirements set out in the Broad Location policies, including a end up providing the minimum 40% affordable housing, have been agreed as required 40% affordable deliverable by the landowners/developers. housing Cross reference with L3. Support inclusion of 985289 Noted This existing Eaton Lodge is included. No change Eaton Lodge in Broad Location Further clarity on some 985289 Noted This is the approach being taken. No change detailed aspects of the development can be provided as part of masterplanning process

The development should 1048449 Agree Cross reference Policy L18 No change be required to deliver walking and cycling Hertfordshire This approach is integral to the policy. facility improvements and County Council public transport links to (837689) promote car free access Dacorum should take 1185704 Disagree Only SADC (as LPA) can plan for land within SADC’s area, No change control of planning for unless it agrees otherwise. SADC is committed to working EHH jointly with DBC on planning for land at Hemel. HSE must be consulted Environment Noted This is an important constraint that is noted in the S6 ii policy No change on buffer Agency (1147557) and will be taken into account in Masterplanning. The level of zones/mitigations for development / land available allow for the depot and pipelines Buncefield Oil Depot and constraints to be accommodated. pipelines Buffer zones / mitigation Environment Noted This is an important constraint that is noted in the S6 ii policy No change for Buncefield Oil Depot Agency (1147557) and will be taken into account in Masterplanning. The level of and pipelines might limit development / land available allow for the depot and pipelines amount of development constraints to be accommodated. No information provided Aurora Properties Disagree The development requirements are clear and the Masterplan No change on strategy or delivery, Limited (1151817) process will provide more specific proposals in due course. just a wishlist Clarify jargon e.g. St Albans Civic Disagree Term allows for allotments or other forms of growing space – No change community food zone Society (1156974) urban farming or community gardens – to be agreed in detail through Masterplanning and planning applications No strategy for delivering St Albans Civic Disagree This is included as a specific policy requirement No change 3% self-build homes Society (1156974) Strongly support Department for Noted Support noted No change allocation and Education safeguarding of land for (1186955) schools

School building areas Department for Noted Primary school site is in the land to be taken out of GB. No change should be removed from Education Secondary school to be retained in the GB. Cross reference green belt (1186955) L21 and Policies Map. Hertfordshire County Council (837689) Policy should include Department for Noted Add reference in IDP to HCC size requirements as set out in IDP will be updated indication of school site Education response to L21 on an ongoing basis. size required (1186955) Overhead electricity Redbourn Parish Disagree The large, longstanding long distance powerlines creates a No change transmission line is not a Council (759908) clear physical line marking the edge of the Green Belt, as defensible boundary for identified by consultants in the GBR. the Green Belt. Linden Wates (Bricket Wood) Limited (1186996) Residential Redbourn Parish Noted Residential development site selection is firmly based on No change development/sports Council (759908) comprehensive GB work which identified the allocated Broad pitches/education uses Locations. will extend beyond area Leverstock Green recommended in the Village Association Concentrating development in larger sites that can create new GBR for development (1185907) communities and deliver infrastructure is a key part of the development strategy. Support principles of DBC (1186054) Disagree The sites are split in the Plan to allow for explanation of No change major development at development requirements and to indicate potential stages / East and North Hemel phases of development and housing trajectory implications, Hempstead however which differ between BLs. Masterplanning and planning these areas are being applications for all will clearly be considered in the context of planned through a each other. comprehensive masterplan and should therefore be one location. Amended text

for an overarching policy suggested. School provision should DBC (1186054) Noted Cross reference L17 No change take emerging Hemel Garden Communities Work on the education infrastructure evidence base has been masterplan and ongoing and has informed the policy requirement. emerging education guidance for Garden Communities by MHCLG guidance into account Institutional residential DBC (1186054) Disagree NPPF / PPG / Housing Delivery Test acknowledge that C2 No change (C2) units should have a institutional residential units contribute to housing provision. separate housing target and be excluded from dwelling trajectory figures Secondary school should Hertfordshire Noted Work on the education infrastructure evidence base has been Minor modification – be 10FE – can be built County Council ongoing and has informed the policy requirement. to acknowledge as 8FE with flexibility to (837689) required flexibility to expand be able to expand to 10 FE. Amend policy wording to Hertfordshire Disagree Requirement as set out in Policy L2. No change include land size County Council requirement for flexi-care (837689) Size requirements can be properly detailed through the home Masterplanning / planning application / EIA process, with appropriate consultation. Broad Locations should Harpenden Town Disagree This matter can be properly detailed through the No change use Design Codes Council (51870) Masterplanning / planning application / EIA process, with appropriate consultation. Policy should consider St Albans Deanery Noted Refer to Policy L22 which encourages opportunities for new No change social and pastoral Synod (1185929) provision of places of worship as part of development of the needs of future Local Centres in Broad Locations.

occupants and include requirements for a community facility e.g. a community hall What masterplanning St Stephen Parish Noted There has been ongoing joint working with Dacorum Borough No change collaboration has there Council (51804) Council, local communities and other stakeholders. been? Collaboration with 1181750 Noted There has been ongoing joint working with neighbouring local No change neighbouring Councils authorities including Dacorum and the South West Herts needed 1182733 Group. DtC considered to be met. Is there a need for the St Stephen Parish Noted Evidence available in full, including in HCC documents and No change amount of flexi-care Council (51804) representations. Policy L2 sets out an appropriate approach. provision required? Have infrastructure Hertsmere Noted Updated evidence regarding economic viability of development No change requirements been Borough Council has been made available on the council website. viability tested to comply (51934) with national policy Major infrastructure must Colney Heath Noted New infrastructure will be provided in association with new No change be provided up front Parish Council development. Further details can be found in IDP updates/ (51891) Masterplanning work / planning application process London Colney Parish Council (52477) Be more specific with 1181723 Disagree Cross reference with Policy L25 which sets out the energy and No change renewable energy/energy environmental performance requirements of new efficiency requirement developments. This addresses renewable energy.

Policy S6 ii) East Hemel Hempstead (Central) Broad Location

Representation Point Representor Outline Recommended Reply (including notes and references) Suggested Actions Raising Point Reply (including any Changes to Plan) Support allocation of Greater London Noted Support noted No change EHH (Central) to include Authority industrial and logistics (1157729) uses, given proximity to motorway network Support principle of Crown Estate Noted Support noted No change employment allocation (51946) Gorhambury Estates Company Limited (375996) Support inclusion of Owners of Noted Support noted No change Breakspears in the Breakspears allocation (973659) Should create a business 1184750 Noted This approach is integral to the policy. No change park with well-designed open spaces 1184750 Dacorum should take 1185704 Disagree Only SADC (as LPA) can plan for land within SADC’s area, No change control of planning for unless it agrees otherwise. SADC is committed to working EHH jointly with DBC on planning for land at Hemel. HSE must be consulted Environment Noted This is an important constraint that is noted in the S6 ii policy No change on buffer Agency (1147557) and will be taken into account in Masterplanning. The level of zones/mitigations for development / land available allow for the depot and pipelines Buncefield Oil Depot and constraints to be accommodated. pipelines

Buffer zones / mitigation Environment Noted This is an important constraint that is noted in the S6 ii policy No change for Buncefield Oil Depot Agency (1147557) and will be taken into account in Masterplanning. The level of and pipelines might limit development / land available allow for the depot and pipelines amount of development constraints to be accommodated. No information provided Aurora Properties Disagree The development requirements are clear and the Masterplan No change on strategy or delivery, Limited (1151817) process will provide more specific proposals in due course. just a wishlist Should be required to St Albans Cycle Agree Cross reference with Policy L18 and Appendix 4 which set out No change deliver walking and Campaign the Key infrastructure requirements for broad locations cycling facility (346623) including East Hemel Hempstead central. improvements to promote car free access, Hertfordshire This approach is integral to the policy. which should be County Council adequately maintained (837689) 1048449 Development needs to The British Horse Agree Refer to Appendix 4 which sets out the Key infrastructure No change be required to deliver Society (1187597) requirements for broad locations including East Hemel transport network Hempstead central. (including walking, Ramblers cycling and equestrian Association This approach is integral to the policy. links) and public (52420) transport services upgrades/improvements Need for a traffic-free The British Horse Noted Cross reference with Policy L18 and Appendix 4 which set out No change multi-use right of way for Society (1187597) the Key infrastructure requirements for broad locations including walkers, cyclists, horse- East Hemel Hempstead. riders and carriage drivers linking EHH These matters can be properly detailed through the (North) and EHH (South) masterplanning process / planning application / EIA processes, with statutory consultation.

Further work needs to be Hertfordshire Noted These points are generally recognised. These matters can be No change carried out on County Council properly detailed through the master planning process / infrastructure, including (837689) planning application / EIA processes, with statutory highways consultation. 1055738 Internal road/local roads Redbourn Parish Disagree The internal road is planned as a main distributor road, so it No change would become a ‘rat-run’ Council (759908) cannot reasonably be described as a rat run. Leverstock Green Village Association (1185907)

498103 An additional Jct 8a Redbourn Parish Disagree Cross reference Policies L 17 / 18. No change would lead to additional Council (759908) traffic movements on Infrastructure evidence (ref IDP / IDS) confirms that road access local roads, impacting on Leverstock Green can be provided and the M1 junction improvement proposals are Redbourn and the Village Association appropriate solutions. surrounding area. (1185907) Are Jct 8 improvements 1184750 Disagree Cross reference Policies L 17 / 18. No change actually required? Infrastructure evidence (ref IDP / IDS) confirms that road access can be provided and the M1 junction improvement proposals are appropriate solutions. Difficulty in integrating a Owners of Disagree Sites have been allocated in the most appropriate locations, No change gypsy and traveller site Breakspears based on evidence, as set out in L7. with the wider proposed (973659) development. Vulnerable to noise and disturbance from the adjacent commercial development.

Additional gypsy and DBC (1186054) Disagree Sites have been allocated in the most appropriate locations, No change traveller pitches in EHH based on evidence, as set out in L7. There is considerable Broad Location would 1181723 flexibility within these large Broad Locations to locate sites result in an over- 498103 sensitively. concentration in the area, exacerbating existing problems. Traveller sites should be more evenly distributed across the District Requirement 1 should Crown Estate Noted Already set out in overall S6. refer to development (51946) being materially in accordance with the masterplan. Point 2 should include Crown Estate Noted Approach taken appropriately acknowledges importance and No change that development should (51946) role of EZ. take into consideration the aims and status of the EZ, which accepts that some occupiers will not meet the EZ criteria. Modify policy to clarify that compliance with the criteria is not an absolute requirement, to provide flexibility. Enviro-Tech should be Crown Estate Noted Defined as part of Hertfordshire Enviro-Tech enterprise zone No change defined in a glossary for (51946) by Herts LEP. clarity

Range of uses in point 3 Crown Estate Disagree This matter can be properly detailed through the master No change should include ‘ancillary (51946) planning process/ planning application process and supporting’ uses Split between primarily Crown Estate Disagree Policy S6 ii) sets out a clear approach. No change B1 and mixed industrial (51946) uses is too prescriptive/inflexible. Flexibility is needed over the plan period Support provision of a Crown Estate Noted Support noted. Full and detailed justification is provided by No change variety jobs, but figure of (51946) evidence documents. It is not necessary to justify the Plan within 10,000 jobs should be the Plan document itself. To do so would result unnecessarily deleted as is only in a longer and more complex document. speculative at this stage with no evidential basis apparent Due to extensive ground Crown Estate Disagree Policy S6 ii) sets out a clear approach. This matter can be No change remodelling required (51946) properly detailed through the masterplanning process / policy should be planning application process amended to retain important trees and landscape features ‘where possible and appropriate’ Point 9 should clarify that Crown Estate Noted Cross reference with Policy L18 and Appendix 4 which set out No change the link road is needed (51946) the Key infrastructure requirements for broad locations as part of the wider including East Hemel Hempstead. transport package to support development in These matters can be properly detailed through the SADC and DBC Local masterplanning process / planning application / EIA processes, Plans, and not just for with statutory consultation. EHH (central).

Point 9 should include Crown Estate Noted Cross reference with Policy L18 and Appendix 4 which set out No change reference to upgrading (51946) the Key infrastructure requirements for broad locations the A414/Green Lane including East Hemel Hempstead. junction, or add additional point These matters can be properly detailed through the masterplanning process / planning application / EIA processes, with statutory consultation. Point 10 should be Crown Estate Noted Cross reference with Policy L18 and Appendix 4 which set out No change amended to note MMTI (51946) the Key infrastructure requirements for broad locations provision will be subject including East Hemel Hempstead. to its function and viability being MMTI is required, while acknowledging function will evolve demonstrated over time. These matters can be properly detailed through the masterplanning process / planning application / EIA processes, with statutory consultation. Support use of Crown Estate Noted Refer to policy L25 which sets out the energy and No change exceptional (51946) environmental performance requirements for new environmental developments. This addresses energy efficiency that BL must opportunities within the comply with. Appropriate alternatives that deliver similar employment area objectives may be possible, if fully justified. however it is unsound to specify particular solution such as CHP and large scale solar power as the best option may change over time Mitigation for noise/air Crown Estate Disagree Cross reference to Policy L18 which requires major No change pollution not critical for a (51946) developments to provide proposals for limiting and mitigating major employment air quality impacts. location Support principles of DBC (1186054) Disagree The sites are split in the Plan to allow for explanation of No change major development at development requirements and to indicate potential stages /

East and North Hemel phases of development and housing trajectory implications, Hempstead however which differ between BLs. Masterplannig and planning these areas are being applications for all will clearly be considered in the context of planned through a each other. comprehensive masterplan and should therefore be one location. Amended text for an overarching policy suggested. Should include a DBC (1186054) Disagree Cross reference with Policy L18 and Appendix 4 which set out No change household waste the Key infrastructure requirements for broad locations recycling centre Hertfordshire including East Hemel Hempstead. County Council (837689) These matters can be properly detailed through the master planning process / planning application / EIA processes, with statutory consultation. No fundamental Hertfordshire Noted Support noted No change ecological constraints County Council and support retentions of (837689) important trees and landscape features Concerns relating to Hertfordshire Noted These points are generally recognised. These matters can be No change impact on traffic volume County Council properly detailed through the master planning process / on minor routes to (837689) planning application / EIA processes, with statutory north/east Hemel consultation. Hempstead possibly on cycle routes, on B487 Redbourn Road, on M1 Jct 8 and on roads within Maylands. MMTI not sufficient to mitigate impacts.

Although a business Hertfordshire Noted These are supported already in the overall policy approach. No change area, provision of a County Council These matters can be properly detailed through the master certain amount of other (837689) planning process / planning application / EIA processes, with uses e.g. small retail statutory consultation. may be appropriate in order to reduce the need to travel Consultation/liaison with Hertfordshire Noted That process is supported and ongoing. These matters can be No change HCC and relevant County Council properly detailed through the master planning process / bus/coach operators (837689) planning application / EIA processes, with statutory needed on MMTI consultation. Heritage environment Gorhambury Disagree Cross reference Policy L30 No change /assets have not been Estates Company considered at EHH and Limited (375996) This supports conservation of heritage assets appropriate to lack of criteria to protect their significance and seeks that development which may affect assets Historic England such assets is accompanied by a Heritage Statement. (929489) Leverstock Green Village Association (1185907) Redbourn Parish Council (759908) 334023 Heritage Impact Historic England Disagree Cross reference Policy L30 No change Assessment required (929489) and policy wording This is part of the masterplanning process amended to reflect its findings

Impact on setting of Gorhambury Noted This matter can be properly detailed through the No change Gorhambury Estate Estates Company masterplanning / planning application / EIA process, with should be mitigated by Limited (375996) appropriate consultation. way of a landscape buffer, building height limits, light shields What masterplanning St Stephen Parish Noted There has been ongoing joint working with Dacorum Borough No change collaboration has there Council (51804) Council, local communities and other stakeholders. been? Have infrastructure Hertsmere Noted Updated evidence regarding economic viability of development No change requirements been Borough Council has been made available on the council website. viability tested to comply (51934) with national policy Collaboration with 1181750 Agree There has been ongoing joint working with neighbouring local No change neighbouring Councils authorities including the South West Herts Group. DtC needed 1182733 considered to be met. Major infrastructure must Colney Heath Noted New infrastructure will be provided in association with new No change be provided up front Parish Council development. Further details can be found in IDP updates / (51891) Masterplanning work / planning application process London Colney Parish Council (52477) Be more specific with 1181723 Disagree Cross reference to policy L25 which sets out the energy and No change renewable environmental performance requirements of new energy/energy efficiency developments. This addresses renewable energy. requirement

Policy S6 iii) East Hemel Hempstead (South) Broad Location Representation Point Representor Outline Reply Recommended Reply (including notes and Suggested Actions Raising Point references) (including any Changes to Plan) Not explicitly clear what Sport England Noted Cross reference Policy L22 and L26 – 28. No change sports facilities to be (824971) provided The policy refers to strategic and local open space and recreation space and community facilities. Any specific reference to the type of specific sports facilities would be overly prescriptive and inflexible at this stage. This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation. No evidence base to inform Sport England Disagree Cross reference Policy L22 and L26 – 28. No change need for sports provision (824971) Baseline and further work since Regulation 19 has been undertaken to inform specific development proposals. Playing Pitch Strategy update 2019 provides baseline data. Need for additional facilities Sport England Agree Cross reference Policy L22 and L26 – 28. No change at this location where (824971) facilities already at capacity The policy concurs stating that development will be required to deliver strategic and local open space and recreation space and community facilities This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation

Should include sports Sport England Disagree Cross reference Policy L22 and L26 – 28. No change facility provision in proposal (824971) points The policy states that development will be required to deliver strategic and local open space and recreation space and community facilities This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation Unclear if public open Sport England Disagree Cross reference Policy L22 and L26 – 28. No change space or recreation space (824971) refers to indoor or outdoor The policy refers to strategic and local public sports provision open space. Open space is defined under the NPPF as all space of public value, land and water which offer important opportunities for sport and recreation. It is clear that this is therefore outdoor in nature. The policy also refers to recreation space and community facilities which would capture indoor sports facilities. This matter can be properly detailed through the Masterplanning process. Consideration of Sport England Agree Cross reference Policy L22 and L26 – 28. No change extending/enhancing sports (824971) facilities in proposed The proposed Hemel BL’s S6 i-iv (apart from secondary school S6ii as a major new Enviro-Tech business / employment land focused location) all require delivery of strategic and local public open space. The precise location and nature of the open spaces and community sport provision will be informed by ongoing joint work with

Dacorum Borough Council. As per Policy L22 the Council would support new facilities in appropriate and sustainable locations and joint use of facilities near to new housing areas to meet sustainability objectives.

This is part of the Masterplanning process. Development, including 1184750 Agree Cross reference Policy L29 No change landscaping, should be of high standard design This is part of the masterplanning process Concerns with road access, 1153741 Disagree Cross reference Policies L 17 / 18. No change particularly from/to the M1. 498103 Infrastructure evidence (ref IDP / IDS) confirms that road access can be provided and the M1 1184750 junction improvement proposals are appropriate solutions. Further landscape and EIA 1184750 Noted Cross reference Policy L29 No change work should be carried out This is part of the masterplanning and planning application process; including statutory consultation Important trees must be Hertfordshire Noted Cross reference Policy L29 No change preserved County Council (837689) Retention of important trees is a requirement of the policy. 1184750 Support setting minimum Grand Union Noted Support noted No change housing targets Investments Ltd (977391) Lower housing figure 498103 Disagree Housing requirement/targets are based on the No change should be applied to allow standard methodology set out by the government – see S4.

for more green spaces and Site selection is firmly based on comprehensive community facilities GB work which identified the allocated Broad Locations. Concentrating development in larger sites that can create new communities and deliver infrastructure is a key part of the development strategy. DBC and SADC are not 1144419 Disagree Cross reference Policy S2 / S4 No change collaborating, particularly with regard to number of 1185704 There has been ongoing joint working with housing allocated to SADC neighbouring local authorities including the and DBC South West Herts Group. DtC considered to be met. Collaboration with 1181750 Noted There has been ongoing joint working with No change neighbouring Councils neighbouring local authorities including the needed 1182733 South West Herts Group. DtC considered to be met. What masterplanning St Stephen Noted There has been ongoing joint working with No change collaboration has there Parish Council Dacorum Borough Council, local communities been? (51804) and other stakeholders. Dacorum should take 1185704 Disagree Only SADC (as LPA) can plan for land within No change control of planning for EHH SADC’s area, unless it agrees otherwise. SADC is committed to working jointly with DBC on planning for land at Hemel. Is there a need for the St Stephen Noted Evidence available in full, including in HCC No change amount of flexi-care Parish Council documents and representations. Policy L2 sets provision required? (51804) out an appropriate approach. Policy should include a Hertfordshire Disagree Requirement as set out in Policy L2. No change land size requirement for County Council flexi-care home (837689) Size requirements can be properly detailed through the Masterplanning / planning

application / EIA process, with appropriate consultation. Have infrastructure Hertsmere Noted Updated evidence regarding economic viability No change requirements been viability Borough Council of development has been made available on tested to comply with (51934) the council website. national policy Major infrastructure must Colney Heath Noted New infrastructure will be provided in No change be provided up front Parish Council association with new development. Further (51891) details can be found in IDP updates / Masterplanning work / planning application London Colney process Parish Council (52477) Strongly support the policy Crown Estate Noted Support noted No change (51946) GB boundary to southern Centurion Golf Disagree Site selection is firmly based on comprehensive No Change corner of site should be Club (1160058) GB work which identified the allocated Broad moved to Locations. 1) allow flexibility in terms of future development 2) questionable what strategic GB function the triangle of land would continue to play 3) not a strong GB boundary – should be moved out to Hemel Hempstead Road/M1, and to also include Centurion Golf Club which would be justified by economic

benefits from expansion of its facilities Amend point 1 to refer to Crown Estate Disagree Already set out in overall S6. No change development being (51946) materially in accordance with the masterplan Concerns the boundary Crown Estate Disagree Some sub-areas will achieve higher density. No change defined on the Policies Map (51946) Overall the land can accommodate the dwelling is not large enough for numbers in the Plan (reference Annex 1) 2,400 homes plus associated infrastructure at 40dph. Additional land at southern tip should be included. Density will need to be Leverstock Disagree Some areas will achieve higher density. No change much higher than 40dph to Green Village Overall the land can accommodate the dwelling provide the 2,400 dwellings Association numbers in the Plan (reference Annex 1) which would not be (1185907) appropriate 40dph too high 1184750 Disagree This is an appropriate minimum density to make No change best use of land and to avoid further pressure on loss of greenfield land/ Green Belt. The NPPF supports optimisation of residential density. No justification for 3% self- Crown Estate Disagree Justification based on evidence including the No change build figure, amended (51946) Self Build Register. SADC are required to have policy wording suggested regard to this as part of Self Build and Custom Housebuilding Act 2015.

Concerns development 1144419 Disagree This is a specific policy requirement in the Plan. No change may not end up providing Evidence available suggests the level of the required 40% provision is viable. affordable housing Unlikely the development 1185704 Disagree The Plan necessitates a significant change in No change will be built out in plan approach from previous tight Green Belt period due to infrastructure restraint. This involves a carefully considered require and scale of stepped trajectory for delivery of new sites that development are best able to deliver to the overall plan development strategy. There are sufficient deliverable sites for years 1-5. New infrastructure will be provided in association with new development. Further details can be found in IDP updates / master planning work / planning application process Lack of community facilities 498103 Disagree Cross reference Policy L22 and L26 – 28. No change in plans for EHH Substantial community facility provision is planned. This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation. No information provided on Aurora Disagree The development requirements are clear and No change strategy or delivery, just a Properties the Masterplan process will provide more wishlist Limited specific proposals in due course. (1151817) Strongly support allocation Department for Noted Support noted No change and safeguarding of land Education for schools (1186955)

School building areas Department for Noted Primary school site is in the land to be taken out No change should be removed from Education of GB. Cross reference L21 and Policies Map. Green Belt (1186955) Hertfordshire County Council (837689) Education uses will extend Leverstock Noted Residential development site selection is firmly No change beyond area recommended Green Village based on comprehensive GB work which in the GBR for Association identified the allocated Broad Locations. development (1185907) Concentrating development in larger sites that can create new communities and deliver infrastructure is a key part of the development strategy. School site locations Hertfordshire Noted Primary school site is in the land to be taken out No change should be identified County Council of GB. Cross reference L21 and Policies Map. (837689) This matter can be properly detailed through the master planning process/ planning application/ EIA processes, with statutory consultation. Clarity needed on whether St Albans & Noted Primary school site is in the land to be taken out No change specific deliverables such District of GB. Cross reference L21 and Policies Map. as school buildings will be Footpaths accommodated in the Society This matter can be properly detailed through Broad Location or Green (723340) the master planning process/ planning Belt application/ EIA processes, with statutory The British consultation. Horse Society (1187597) Support transport network St Albans & Noted Support noted No change improvements District Footpaths

Society (723340)

The British Horse Society (1187597)

Ramblers Association (52420) Lack of green spaces in 498103 Disagree Cross reference Policy L22 and L26 – 28. No change plans for EHH Substantial provision is planned. This matter can be properly detailed through the master planning process / planning application / EIA processes, with statutory consultation. Support sufficient assets to St Albans & Noted Support noted No change provide sustainable District management of community Footpaths facilities, open spaces and Society parklands (723340) The British Horse Society (1187597) Ramblers Association (52420) Hertfordshire County Council (837689)

Both strategic and local Ramblers Agree This is part of the masterplanning process No change public space must be Association provided (52420) St Albans & District Footpaths Society (723340) The British Horse Society (1187597) Hertfordshire County Council (837689) 1184750 Countryside access links Ramblers Agree This is part of the masterplanning process No change must be provided Association (52420) St Albans & District Footpaths Society (723340) The British Horse Society (1187597) St Albans Cycle Campaign (346623)

1157340 Sports/health/educational 1184750 Disagree Cross reference Policy L26 - 28 No change facilities must not encroach into country park land Open space provision is very sizable. The detailed master planning of the open space can allow for accommodation of all these uses and for appropriate country park / habitat creation. Must provide/support the Ramblers Agree This is a development requirement. No change country park/green buffer to Association the south east (52420) St Albans & District Footpaths Society (723340) Hertfordshire County Council (837689) 1184750 1185037 The British Horse Society (1187597) Boundary of site should Leverstock Disagree Housing requirement/targets are based on the No change comply with Green Belt Green Village standard methodology set out by the Review Association government – see S4. (1185907) Site selection is firmly based on comprehensive GB work which identified the allocated Broad Locations.

Concentrating development in larger sites that can create new communities and deliver infrastructure is a key part of the development strategy. The development should Hertfordshire Agree Cross reference Policy L18 No change be required to deliver County Council walking and cycling facility (837689) This approach is integral to the policy. improvements and public transport links to promote St Albans Cycle car free access, which Campaign should be adequately (346623) maintained 1048449 Development must respond Leverstock Noted This matter can be properly detailed through No Change to the ‘village character’ of Green Village the master planning process / planning Leverstock Green Association application / EIA processes, with statutory (1185907) consultation. Also cross reference Policy L1 and L23. Less dwellings should be Leverstock Disagree This is an appropriate minimum density / number No change proposed so that the scale Green Village of dwellings to make best use of land and to of the development Association avoid further pressure on loss of greenfield land/ complements Leverstock (1185907) Green Belt. The NPPF supports optimisation of Green residential density. Cross reference Policy S1, S2, L1 and L23. Heritage environment Historic England Disagree Cross reference Policy L30 No change /assets have not been (929489) considered at EHH and This supports conservation of heritage assets lack of criteria to protect Redbourn appropriate to their significance and seeks that assets. Impact on nearby Parish Council development which may affect such assets is listed buildings including (759908) accompanied by a Heritage Statement. Leverstock Green Village

Westwick Row and Association buildings at Gorhambury (1185907) Gorhambury Estates Company Limited (375996) 334023 1184969 Heritage Impact Historic England Disagree Cross reference Policy L30 No change Assessment required and (929489) policy wording should This is part of the masterplanning process. reflect its findings Impact on setting of Gorhambury Noted Importance of historic Gorhambury Estate No change Gorhambury Estate should Estates acknowledged. This matter can be properly be mitigated by way of a Company detailed through the masterplanning / planning landscape buffer, building Limited application / EIA process, with appropriate height limits, light shields (375996) consultation. Additional gypsy and DBC (1186054) Disagree Sites have been allocated in the most No change traveller pitches in EHH appropriate locations, based on evidence, as Broad Location would 1181723 set out in L7. There is considerable flexibility result in an over- 498103 within these large Broad Locations to locate concentration in the area, sites sensitively. exacerbating existing problems. Gypsy and Traveller sites should be more evenly distributed across the District Should be more 1-2 bed 1034653 Disagree Cross reference L1 and Appendix 6 No change dwellings

Lack of off-street parking 498103 Disagree Cross reference Policy L20 No change provision in plans for EHH There are clear standards in Plan policy. Further work needs to be Hertfordshire Noted These points are generally recognised. These No change carried out on County Council matters can be properly detailed through the infrastructure, including (837689) master planning process / planning application / highways, parking, water, EIA processes, with statutory consultation. sewerage 498103

867312 There should be a joint 498103 Disagree This was an option considered. It has been No change Area Action Plan for EHH replaced with a collaborative joint with DBC 1185704 Masterplanning process which can address the issues more quickly in the context of the clear development requirements in the Plan and the requirements of the NPPF. Policy should consider St Albans Noted Refer to Policy L22 which encourages No change social and pastoral needs Deanery Synod opportunities for new provision of places of of future occupants and (1185929) worship as part of development of the Local include requirements for a Centres in Broad Locations. community facility e.g. a community hall Policy should include West Disagree No substantive evidence provided to support No change requirement for provision of Hertfordshire such an approach. Cross reference L22. a new hospital Hospitals NHS Trust (1183618) Civic Society Design St Albans Civic Disagree This matter can be properly detailed through No change Advisory Group should be Society the Masterplanning / planning application / EIA consulted as part of any (1156974) process, with appropriate consultation. pre-planning consultation

Broad Locations should Harpenden Disagree This matter can be properly detailed through No change use Design Codes Town Council the Masterplanning / planning application / EIA (51870) process, with appropriate consultation. Support principles of major DBC (1186054) Disagree The sites are split in the Plan to allow for No change development at East and explanation of development requirements and North Hemel Hempstead to indicate potential stages / phases of however these areas are development and housing trajectory being planned through a implications, which differ between BLs. comprehensive masterplan Masterplanning and planning applications for all and should therefore be will clearly be considered in the context of each one location. Amended text other. for an overarching policy suggested. School provision should DBC (1186054) Noted Cross reference L17 No change take emerging Hemel Garden Communities Work on the education infrastructure evidence masterplan and emerging base has been ongoing and has informed the education guidance for policy requirement. Garden Communities by MHCLG guidance into account

Institutional residential (C2) DBC (1186054) Disagree NPPF / PPG / Housing Delivery Test No change units should have a acknowledge that C2 institutional residential separate housing target units contribute to housing provision. and be excluded from dwelling trajectory figures Be more specific with 1181723 Disagree Cross reference with Policy L25 which sets out No change renewable energy/energy the energy and environmental performance efficiency requirement requirements of new developments. This addresses renewable energy.

Policy S6 iv) North Hemel Hempstead Broad Location Representation Point Representor Outline Reply Recommended Reply (including notes and Suggested Actions (including Raising Point references) any Changes to Plan) Not explicitly clear what Sport England Disagree Cross reference Policy L22 and L26 – 28. No change sports facilities to be (824971) provided The policy refers to strategic and local open space and recreation space and community facilities. Any specific reference to the type of specific sports facilities would be overly prescriptive and inflexible at this stage. This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation. No evidence base to inform Sport England Noted Cross reference Policy L22 and L26 – 28. Publish updated evidence need for sports provision (824971) Baseline and further work since Regulation 19 has been undertaken to inform specific development proposals. Playing Pitch Strategy update 2019 provides baseline data. Need for additional facilities Sport England Agree Cross reference Policy L22 and L26 – 28. No change at this location where (824971) facilities already at capacity The policy concurs stating that development will be required to deliver strategic and local open space and recreation space and community facilities This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation

Should include sports Sport England Disagree Cross reference Policy L22 and L26 – 28. No change facility provision in proposal (824971) points The policy states that development will be required to deliver strategic and local open space and recreation space and community facilities This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation Unclear if public open Sport England Disagree Cross reference Policy L22 and L26 – 28. No change space or recreation space (824971) refers to indoor or outdoor The policy refers to strategic and local public sports provision open space. Open space is defined under the NPPF as all space of public value, land and water which offer important opportunities for sport and recreation. It is clear that this is therefore outdoor in nature. The policy also refers to recreation space and community facilities which would capture indoor sports facilities. This matter can be properly detailed through the Masterplanning process. Consideration of Sport England Agree Cross reference Policy L22 and L26 – 28. No change extending/enhancing sports (824971) facilities in proposed The proposed Hemel BL’s S6 i-iv (apart from secondary school S6ii as a major new Enviro-Tech business / employment land focused location) all require delivery of strategic and local public open space. The precise location and nature of the open spaces and community sport provision will be informed by ongoing joint work with

Dacorum Borough Council. As per Policy L22 the Council would support new facilities in appropriate and sustainable locations and joint use of facilities near to new housing areas to meet sustainability objectives.

This is part of the Masterplanning process. Development, including 1184750 Agree Cross reference Policy L29 No change landscaping, should be of a high standard of design This is part of the masterplanning process Welcome requirement for The Woodland Noted Support noted No change new managed woodland Trust (1185811) and encourage provision of street trees Broad Locations should use Harpenden Disagree This matter can be properly detailed through No change Design Codes Town Council the Masterplanning / planning application / EIA (51870) process, with appropriate consultation. Support setting minimum Grand Union Noted Support noted No change housing targets Investments Ltd (977391) DBC and SADC are not 1144419 Disagree Cross reference Policy S2 / S4 No change collaborating, particularly with regard to number of 1185704 SADC and DBC are clearly working together housing allocated to SADC through ongoing Duty To Cooperate, including and DBC the SWH JSP process. What masterplanning St Stephen Noted There has been ongoing joint working with No change collaboration has there Parish Council Dacorum Borough Council, local communities been? (51804) and other stakeholders.

Collaboration with 1181750 Noted There has been ongoing joint working with No change neighbouring Councils neighbouring local authorities including needed 1182733 Dacorum and the South West Herts Group. DtC considered to be met. Concerns development may 1144419 Disagree This is a specific policy requirement in the No change not end up providing the Plan. Evidence available suggests the level of required 40% affordable provision is viable. housing Unlikely the development 1185704 Disagree The Plan necessitates a significant change in No change will be built out in plan approach from previous scales of period due to infrastructure development. This involves a carefully require and scale of considered stepped trajectory for delivery of development new sites that are best able to deliver to the overall plan development strategy. There are sufficient deliverable sites for years 1-5.

New infrastructure will be provided in association with new development. Further details can be found in IDP updates / master planning work / planning application process Further work needs to be Hertfordshire Noted These points are generally recognised. These No change carried out on infrastructure, County Council matters can be properly detailed through the including highways, parking, (837689) master planning process / planning application water, sewerage / EIA processes, with statutory consultation. 498103

867312 Support transport network St Albans & Noted Support noted No change improvements District Footpaths Society (723340)

The British Horse Society (1187597)

Ramblers Association (52420)

Concerns with road access, 1153741 Disagree Cross reference with Policies L 17 / 18. No change particularly from/to the M1 498103 Infrastructure evidence (ref IDP / IDS) confirms that road access can be provided and the M1 1184750 junction improvement proposals are appropriate solutions. This matter can be properly detailed through the Masterplanning/ planning application process, with appropriate consultation. Infrastructure requirements Redbourn Disagree New infrastructure will be provided in No change and their deliverability not Parish Council association with new development. Further been fully considered by (759908) details can be found in IDP updates / master SADC or DBC planning work / planning application process Have infrastructure Hertsmere Noted Updated evidence regarding economic viability No change requirements been viability Borough Council of development has been made available on tested to comply with (51934) the council website. national policy Major infrastructure must be Colney Heath Noted New infrastructure will be provided in No change provided up front Parish Council association with new development. Further (51891) details can be found in IDP updates / Masterplanning work / planning application London Colney process Parish Council (52477)

Health and safety aspects 498103 Noted These points are generally recognised. This No change of building close to M1, matter can be properly detailed through the pylons, oil pipeline, 1144419 Masterplanning process / planning application / Buncefield Oil Depot and 1185704 EIA processes, with statutory consultation. under Luton Airport flightpath need to be considered Lower housing figure should 498103 Disagree Housing targets are based on evidence on No change be applied to allow for more local housing need and standard methodology green spaces and set out by the government. community facilities There should be a joint 498103 Disagree This was an option considered. It has been No change Area Action Plan with DBC replaced with a collaborative joint 1185704 Masterplanning process which can address the issues more quickly in the context of the clear development requirements in the Plan and the requirements of the NPPF. Dacorum should take 1185704 Disagree Only SADC (as LPA) can plan for land within No change control of planning for EHH SADC’s area, unless it agrees otherwise. SADC is committed to working jointly with DBC on planning for land at Hemel. No information provided on Aurora Disagree The development requirements are clear and No change strategy or delivery, just a Properties the Masterplan process will provide more wishlist Limited specific proposals in due course. (1151817) Strongly support allocation Department for Noted Support noted No change and safeguarding of land for Education schools (1186955) School site locations should Hertfordshire Noted Primary school site is in the land to be taken out No change be identified County Council of GB. Cross reference L21 and Policies Map. (837689)

This matter can be properly detailed through the master planning process / planning application / EIA processes, with statutory consultation. School building areas Department for Noted Primary school sites in the land to be taken out No change should be removed from Education of GB. Cross reference L21 and Policies Map. green belt (1186955) Hertfordshire County Council (837689) Policy should include Department for Noted Add reference in IDP to HCC size IDP will be updated on an indication of school site size Education requirements as set out in response to L21 ongoing basis. required (1186955) Proposed secondary school 1185037 Noted School place catchment and allocations No change will risk Redbourn children’s policies are not a planning matter. access to Roundwood Park Is there a need for the St Stephen Noted Evidence available in full, including in HCC No change amount of flexi-care Parish Council documents and representations. Policy L2 sets provision required? (51804) out an appropriate approach. Policy wording should Hertfordshire Disagree Requirement as set out in Policy L2. No change include land size County Council requirement for flexi-care (837689) Size requirements can be properly detailed home through the Masterplanning / planning application / EIA process, with appropriate consultation. Scale of growth unclear as Redbourn Noted BL will have a minimum capacity for 1,500 No change reference to 1,000 and Parish Council dwellings, with delivery of 1,000 beyond 2036. 1,500 dwellings (759908)

Cumulative growth at East Redbourn Disagree The Plan involves a carefully considered No change and North Hemel Parish Council stepped trajectory for delivery of new sites that Hempstead sites would be (759908) are best able to deliver to the overall plan challenging to deliver development strategy. Support sufficient assets to St Albans & Noted Support noted No change provide sustainable District management of community Footpaths facilities, open spaces and Society parklands (723340) The British Horse Society (1187597) Ramblers Association (52420) Hertfordshire County Council (837689) Both strategic and local Ramblers Agree This is part of the masterplanning process No change public space must be Association provided (52420) St Albans & District Footpaths Society (723340) The British Horse Society (1187597)

Hertfordshire County Council (837689) 1184750 Countryside access links Ramblers Agree This is part of the masterplanning process No change must be provided Association (52420) St Albans & District Footpaths Society (723340) The British Horse Society (1187597) St Albans Cycle Campaign (346623) 1157340 Clarity needed on whether St Albans & Noted School sites are in the land to be taken out of No change specific deliverables such District GB. Requirement is in policy text. Cross as school buildings will be Footpaths reference L21. accommodated in the Broad Society Location or Green Belt (723340) This matter can be properly detailed through the master planning process / planning The British application / EIA processes, with statutory Horse Society consultation. (1187597)

Should be required to St Albans Cycle Agree Cross reference Policy L18 No change deliver walking and cycling Campaign facility improvements and (346623) This approach is integral to the policy. public transport links to promote car free access, Hertfordshire which should be adequately County Council maintained. (837689) 1048449 Must provide/support the Ramblers Agree This is set out in the policy and will be taken No change country park Association forward as part of the Masterplanning process (52420) St Albans & District Footpaths Society (723340) Hertfordshire County Council (837689) The British Horse Society (1187597) 1184750 1185037 Important trees must be Hertfordshire Noted Cross reference Policy L29 No change preserved County Council (837689) Retention of important trees is a requirement of the policy. 1184750

Heritage environment Historic England Disagree Cross reference Policy L30 No change /assets have not been (929489) considered and lack of This supports conservation of heritage assets criteria to protect assets, Redbourn appropriate to their significance and seeks that including nearby Grade II Parish Council development which may affect such assets is Listed buildings and Aubrey (759908) accompanied by a Heritage Statement. Camp scheduled monument Leverstock Such heritage assets form only a small Green Village proportion of the overall Broad Location, are Association acknowledged and will be treated appropriately (1185907) as part of the Masterplanning / planning application processes. 334023 Heritage Impact Historic England Disagree Cross reference Policy L30 No change Assessment required and (929489) policy wording amended to This is part of the masterplanning process reflect its findings

Support principles of major Dacorum Disagree The sites are split in the Plan to allow for No change development at East and Borough Council explanation of development requirements and North Hemel Hempstead (1186054) to indicate potential stages / phases of however these areas are development and housing trajectory being planned through a implications, which differ between BLs. comprehensive masterplan Masterplannig and planning applications for all and should therefore be one will clearly be considered in the context of each location. other. School provision should Dacorum Noted Cross reference L17 No change take emerging Hemel Borough Council Garden Communities (1186054) Work on the education infrastructure evidence masterplan and emerging base has been ongoing and has informed the education guidance for policy requirement. Garden Communities by MHCLG guidance into account

Institutional residential (C2) Dacorum Disagree NPPF / PPG / Housing Delivery Test No change units should have a Borough Council acknowledge that C2 institutional residential separate housing target and (1186054) units contribute to housing provision. be excluded from dwelling trajectory figures Should include requirement Hertfordshire Disagree Cross reference to Policy L18 which requires No change relating to mitigating County Council major developments to provide proposals for adverse impacts from (837689) limiting and mitigating air quality impacts. motorway noise and air pollution 40dph too high 1184750 Disagree This is an appropriate minimum density to No change make best use of land and to avoid further pressure on loss of greenfield land/ Green Belt. The NPPF supports optimisation of residential density. Policy should consider St Albans Noted Refer to Policy L22 which encourages No change social and pastoral needs of Deanery Synod opportunities for new provision of places of future occupants and (1185929) worship as part of development of the Local include requirements for a Centres in Broad Locations. community facility e.g. a community hall Concerns over proximity to Redbourn Disagree The importance of this issue is acknowledged. No change Buncefield - policies should Parish Council include reference to the (759908) The Plan development proposals already take health and safety account of the health and safety issues Development Proximity 759883 associated with the Depot. The Health and Safety Executive will be consulted as part of Zone Consultation Zones at 498103 Buncefield Oil Storage any planning application in proximity to the Depot. 1144419 Buncefield DPZ. 1185704 This matter can be properly detailed through the Masterplanning / planning application / EIA process, with appropriate consultation.

Be more specific with 1181723 Disagree Cross reference with Policy L25 which sets out No change renewable energy/energy the energy and environmental performance efficiency requirement requirements of new developments. This addresses renewable energy. Civic Society Design St Albans Civic Disagree This matter can be properly detailed through No change Advisory Group should be Society the Masterplanning / planning application / EIA consulted as part of any (1156974) process, with appropriate consultation. pre-planning consultation Strongly support the policy Crown Estate Noted Support noted No change (51946) Point 1 should refer to Crown Estate Disagree Already set out in overall S6. No change development being (51946) materially in accordance with the masterplan No justification for 3% self- Crown Estate Disagree Justification based on evidence including the No change build figure, amended policy (51946) Self Build Register. SADC are required to wording suggested have regard to this as part of Self Build and Custom Housebuilding Act 2015. Support inclusion of land Mr and Mrs Bill Noted Support noted No change east of Holtsmere End and Valerie Barr Road (1157883) Policy S6 v) East St Albans Broad Location

Representation Point Representor Outline Reply Recommended Reply (including notes and Suggested Actions (including Raising Point references) any Changes to Plan) School building areas Department for Noted Primary school site in the land to be taken out No change should be removed from Education of GB. Secondary school to be retained in the green belt (1186955) GB. Cross reference L21 and Policies Map.

Hertfordshire County Council (837689) Primary school should be Hertfordshire Agree Minor modification – clarification “A site for and Minor modification – “A site for increased to 3FE County Council appropriate contributions towards a 3 FE” and appropriate contributions (837689) towards a 3 FE” Clarity needed on whether St Albans & Noted Both schools within the Broad Location. No change specific deliverables such District Primary school site in the land to be taken out as school buildings will be Footpaths of GB. Secondary school to be retained in the accommodated in the Broad Society GB. Cross reference L21 and Policies Map. Location or Green Belt (723340) This matter can be properly detailed through The British the master planning process / planning Horse Society application / EIA processes, with statutory (1187597) consultation. Strongly support allocation Department for Noted Support noted No change and safeguarding of land for Education schools (1186955) Policy should include Department for Noted Add reference in IDP to HCC size IDP will be updated on an indication of school site size Education requirements as set out in response to L21 ongoing basis. required (1186955) Broad Location Land should 1153245 Disagree Housing need is a greater priority for use of No change be retained for future school this site. The main site owner has promoted expansion 1186129 the site as available and deliverable for housing. Not a sustainable location 1185775 Disagree Concentrating development in larger sites that No change for a secondary school, can create new communities and deliver and instead existing schools infrastructure is a key part of the development should be expanded strategy. Both expanded and new schools are part of the strategy.

Both strategic and local Ramblers Agree This is part of the masterplanning process. No change public space must be Association provided (52420) St Albans & District Footpaths Society (723340) The British Horse Society (1187597) 1184750 Countryside access links Ramblers Agree This is part of the masterplanning process. No change must be provided Association (52420) St Albans & District Footpaths Society (723340) The British Horse Society (1187597) St Albans Cycle Campaign (346623) 1157340

Support transport network St Albans & Noted Support noted No change improvements District Footpaths Society (723340)

The British Horse Society (1187597)

Ramblers Association (52420) 1185460

Support sufficient assets to St Albans & Noted Support noted No change provide sustainable District management of community Footpaths facilities, open spaces and Society parklands (723340) The British Horse Society (1187597) Ramblers Association (52420) Should be required to St Albans Cycle Agree Cross reference Policy L18 No change deliver walking and cycling Campaign facility improvements to (346623) This approach is integral to the policy. promote car free access, which should be adequately maintained

Hertfordshire County Council (837689) 867587 1048449 1185460 Further work needs to be Hertfordshire Noted These points are generally recognised. These No change carried out on infrastructure, County Council matters can be properly detailed through the including highways, parking, (837689) master planning process / planning application water, sewerage / EIA processes, with statutory consultation. Ellenbrook Area Residents Association Committee (1185802)

498103

867312

867587

1184378

1185460

1185775 Policy should consider St Albans Noted Refer to Policy L22 which encourages No change social and pastoral needs of Deanery Synod opportunities for new provision of places of future occupants and (1185929) worship as part of development of the Local include requirements for a Centres in Broad Locations.

community facility e.g. a community hall

Is there a need for the St Stephen Disagree Evidence available in full, including in HCC No change amount of flexi-care Parish Council documents and representations. Policy L2 sets provision required? (51804) out an appropriate approach. Policy should include land Hertfordshire Disagree Requirement as set out in Policy L2. No change size requirement for flexi- County Council care home (837689) Size requirements can be properly detailed through the Masterplanning / planning application / EIA process, with appropriate consultation. Have infrastructure Hertsmere Noted Updated evidence regarding economic viability No change requirements been viability Borough Council of development has been made available on tested to comply with (51934) the council website. national policy Major infrastructure must be Colney Heath Noted New infrastructure will be provided in No change provided up front Parish Council association with new development. Further (51891) details can be found in IDP updates / Masterplanning work / planning application London Colney process Parish Council (52477) ‘Other community 1185035 Disagree New infrastructure will be provided in No change provisions, including health association with new development. Further provisions’ is insufficient. details can be found in IDP updates / master Request amendment to planning work / planning application process. ‘including new GP, clinic and other healthcare facilities’

Broad Locations should use Harpenden Disagree This matter can be properly detailed through No change Design Codes Town Council the Masterplanning / planning application / EIA (51870) process, with appropriate consultation. 40dph too high 1184750 Disagree This is an appropriate minimum density to No change make best use of land and to avoid further pressure on loss of greenfield land/ Green Belt. The NPPF supports optimisation of residential density. Minimum capacity of 1,250 Oaklands Disagree Policy states 1,250 dwellings includes area No change dwellings to be should be College with extant permission of 348 dwellings. changed to 902 dwellings, (1185294) as 348 already being built. Wording of S6 v) 16 and 17 Oaklands Disagree The development requirements are clear and No change to be amended to include College the masterplan process will confirm specific ‘subject to discussions proposals regarding local needs and (1185294) optimal location Wording of S6 v) 10 to be Oaklands Disagree This will in practice be the case, but there is no No change amended to include location College need to set it out explicitly in the policy. of which to be agreed (1185294) through discussions between District Council, County Council and Oaklands College Excellence in design, St Albans Civic Agree Cross reference to Policies L23/25 which set No change energy efficient and water Society out requirements for achieving high quality management is required in (1156974) design and sustainable energy. There are all Broad Locations particular opportunities at East St Albans because of the role and nature of Oaklands.

Heritage environment Historic England Disagree Cross reference Policy L30 No change /assets have not been (929489) considered and lack of This supports conservation of heritage assets criteria to protect assets 1153245 appropriate to their significance and seeks that development which may affect such assets is 1186129 accompanied by a Heritage Statement. Such heritage assets form only a small proportion of the overall Broad Location, are acknowledged and will be treated appropriately as part of the Masterplanning / planning application processes. Should include requirement Hertfordshire Disagree Cross reference to Policy L18 which requires No change to design to mitigate County Council major developments to provide proposals for adverse air quality impacts, (837689) limiting and mitigating air quality impacts. as in S6 i), ii) and iii). Ellenbrook Area Residents Association Committee (1185802) 1153245 Proposed development will 1153245 Noted Housing requirement/targets are based on the No change encroach upon the Green standard methodology set out by the Belt 1186129 government – see S4. Site selection is firmly based on comprehensive GB work which identified the allocated Broad Locations. Concentrating development in larger sites that can create new communities and deliver infrastructure is a key part of the development strategy.

The Broad Location does 1153245 Disagree Watling Chase has been identified under L29. No change not take into account Development will be considered against the Watling Chase Community Watling Chase Supplementary Planning Guide Guidance. Request Beaumont Schools Sports England Disagree Playing fields is part of Broad Location as it is No change playing field is removed (824971) part of the area that will be excluded from the from Broad Location or; Green Belt to create a new, defensible long amendment made to for term boundary. playing fields to be retained or replaced with equivalent or better. No plan for wildlife 1186129 Disagree Requirement as set out in Policy L29. This is No change protection / preservation of included in evidence documents. green space areas for the whole Broad Location area Localised detailed matters can be properly detailed through the masterplanning / planning application / EIA process, with appropriate consultation. Part of the site under HCC Hertfordshire Disagree Whole area needs to be considered holistically No change ownership is physically County Council rather than on a piecemeal basis. This matter detached from the majority (1185913) can be properly detailed through the of the broad location site, Masterplanning / planning application / EIA and should not be included process, with appropriate consultation. in the master plan. Has not taken into account Ellenbrook Area Disagree There has been ongoing joint working with No change submitted Local Plan for Residents neighbouring local authorities including the Welwyn Hatfield Association South West Herts Group. DtC considered to be Committee met. (1185802) 1153245 1186129

No information provided on Aurora Disagree The development requirements are clear and No change strategy or delivery, just a Properties the Masterplan process will provide more wishlist Limited specific proposals in due course. (1151817)

867587 What masterplanning St Stephen Noted Masterplanning is at the very earliest stages. No change collaboration has there Parish Council Collaboration with residents and stakeholders been? (51804) will take place as progress is made.

Collaboration with Ellenbrook Area Agree There has been ongoing joint working with No change neighbouring Councils Residents neighbouring local authorities including the needed Association South West Herts Group. Committee (1185802) 1181750 1182733 867587 1153245 No Sequential test based Environmental Noted Cross reference to Policy L29 and No change on the Latest SFRA. Agency NPPF/NPPG. (1147557) Updated Flood Risk Assessment has been prepared and added to the website.

Policy S6 vi) North St Albans Broad Location

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan)

Countryside Ramblers Association Agree This is part of the masterplanning process No change access links must (52420) be provided St Albans & District Footpaths Society (723340) The British Horse Society (1187597) St Albans Cycle Campaign (346623) 1157340

Support transport St Albans & District Noted Support noted No change network Footpaths Society improvements (723340)

The British Horse Society (1187597)

Ramblers Association (52420)

Insufficient 840795 Disagree Traffic modelling shows no ‘showstoppers’ regarding traffic. No change infrastructure to New infrastructure will be provided in association with new 867587 cope with development. Further details can be found in IDP updates / additional traffic Masterplanning work / planning application process

Improvements to 867587 Disagree Cross reference to Policy L18 No change public transport, 1048449 This matter can be properly detailed through the footpaths and masterplanning/ planning application/ EIA process, with cycling routes need 1153802 appropriate consultation. to be specifically identified

Clarity needed on St Albans & District Noted Primary school site in the land to be taken out of GB. Cross No change whether specific Footpaths Society reference L21 and Policies Map. deliverables such (723340) This matter can be properly detailed through the master as school buildings The British Horse Society planning process / planning application / EIA processes, with will be (1187597) statutory consultation. accommodated in the Broad Location or Green Belt

School building Department for Noted Primary school site in the land to be taken out of GB. Cross No change areas should be Education (1186955) reference L21 and Policies Map. removed from Hertfordshire County green belt Council (837689)

The development St Albans Cycle Agree Cross reference Policy L18 No change should be required Campaign (346623) This approach is integral to the policy. to deliver walking Hertfordshire County and cycling facility Council (837689) improvements and

public transport 1153802 links to promote 1048449 car free access which should be adequately maintained

Further work needs Hertfordshire County Noted These points are generally recognised. These matters can No change to be carried out on Council (837689) be properly detailed through the master planning process / infrastructure, planning application / EIA processes, with statutory 498103 including consultation. highways, parking, 867312 water, sewerage 1185775 Policy should St Albans Deanery Noted Refer to Policy L22 which encourages opportunities for new No change consider social and Synod (1185929) provision of places of worship as part of development of the pastoral needs of Local Centres in Broad Locations. future occupants and include requirements for a community facility e.g. a community hall

Have infrastructure Hertsmere Borough Noted Updated evidence regarding economic viability of No change requirements been Council (51934) development has been made available on the council viability tested to website. comply with national policy

Major infrastructure Colney Heath Parish Noted New infrastructure will be provided in association with new IDP will be updated on must be provided Council (51891) development. Further details can be found in IDP updates / an ongoing basis. up front master planning work / planning application process

London Colney Parish Council (52477)

Should include 1153802 Disagree No evidence of need identified and would be contrary to No change plans for new St Network Rail strategy for stations. Albans North station

Explicitly drop Friends of Bernards Disagree Ariston is not identified for retail. Policy S6 vi) sets out No change. Ariston Site for Heath (118795) requirement for one new primary school. retail, and confirm with HCC that the two new primary schools will be located in the North St Albans Broad Location, and not the Ariston Site.

Another primary 1184862 Disagree North St Albans Broad Location will generate additional need, No change school is not as well as other growth. Concentrating development in larger 1184966 required in North sites that can create new communities and deliver St Albans, when 840795 infrastructure is a key part of the development strategy. instead an additional secondary school is required.

Will the new 840795 Noted. Primary school site in the land to be taken out of GB. Cross No change primary school be reference L21 and Policies Map. located within the Green Belt?

Strongly support Department for Noted Support noted No change allocation and Education (1186955) safeguarding of land for schools.

Policy should Department for Noted Add reference in IDP to HCC size requirements as set out in IDP will be updated on include indication Education (1186955) response to L21 an ongoing basis. of school site size required

School site Hertfordshire County Disagree Primary school site in the land to be taken out of GB. Cross No change locations should be Council (837689) reference L21 and Policies Map. identified

North St Albans BL Hallam Land Noted Requirement set out in policy text. This matter can be No change can be developed Management Limited properly detailed through the masterplanning / planning to meet open (1185998) application / EIA process, with appropriate consultation. space standards

Suggest inclusion Hallam Land Noted This matter can be properly detailed through the No change of ‘Urban Management Limited masterplanning / planning application / EIA process, with Wilderness’ (1185998) appropriate consultation. project, as an approach for new open space creation in this Broad Location

Both strategic and Ramblers Association Agree This is part of the masterplanning process. No change local public space (52420), 1184750 must be provided St Albans & District Footpaths Society (723340)

The British Horse Society (1187597)

Welcome The Woodland Trust Noted Support noted No change requirement for (1185811) new managed woodland and encourage provision of street trees

Woodland ‘Long 1185956 Noted Importance of Long Springs acknowledged. This matter can No change Springs’ bordering be properly detailed through the masterplanning / planning the site should be application / EIA process, with appropriate consultation. protected by uncultivated strip for public access

Clarity needed on St Albans & District Noted Primary school site in the land to be taken out of GB. Cross No change whether specific Footpaths Society reference L21 and Policies Map. deliverables such (723340) as school buildings The British Horse Society will be (1187597) accommodated in the Broad Location or Green Belt

Unclear from Sport England (824971) Disagree The policies map is based on ordnance survey. The base is No change policies map if St periodically updated, but the latest available has been used. 1185956 Albans Schools In order to create a long-term defensible Green Belt Woollam Playing boundary, a very small part of the existing Woollams playing Fields playing fields are included in the Broad Location. There will be fields form part of the broad location.

Should be considerable new provision in and associated with the Broad removed from Location. Broad Location.

No evidence base Sport England (824971) Disagree Cross reference Policy L22 and L26 – 28. No change to inform need for Baseline and further work since Regulation 19 has been sports provision undertaken to inform specific development proposals. Playing Pitch Strategy update 2019 provides baseline data.

Should include Sport England (824971) Disagree Cross reference Policy L22 and L26 – 28. No change sports facility provision in The policy states that development will be required to deliver proposal points strategic and local open space and recreation space and community facilities This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation

Unclear if public Sport England (824971) Disagree Cross reference Policy L22 and L26 – 28. No change open space or recreation space The policy refers to strategic and local public open space. refers to indoor or Open space is defined under the NPPF as all space of public outdoor sports value, land and water which offer important opportunities for provision sport and recreation. It is clear that this is therefore outdoor in nature. The policy also refers to recreation space and community facilities which would capture indoor sports facilities. This matter can be properly detailed through the Masterplanning process.

Need for additional Sport England (824971) Agree Cross reference Policy L22 and L26 – 28. No change facilities at this location where

facilities already at The policy concurs stating that development will be required capacity to deliver strategic and local open space and recreation space and community facilities This matter can be properly detailed through the Masterplanning process / planning application / EIA processes, with statutory consultation

Consideration of Sport England (824971) Agree Cross reference Policy L22 and L26 – 28. No change extending/enhanci ng sports facilities As per Policy L22 the Council would support new facilities in in proposed school appropriate and sustainable locations and joint use of facilities near to new housing areas to meet sustainability objectives.

This is part of the Masterplanning process. Reference should 1153802 Noted Policy 29 sets out requirements for development. This matter No change be made to linking can be properly detailed through the masterplanning / key ecological planning application / EIA process, with appropriate corridors including consultation. Heartwood, Batchwood and Beech Bottom Dyke

In support of policy 763827 Noted Support noted No change in respect of housing mix, size, type and density, infrastructure. Clearly meets requirements for Green Belt release.

1-2 bedroom 1183126 Disagree Cross reference to Policy L1 and Appendix 6 No change homes is not a Evidence points to most need being for small – medium sized sensible mix for family homes, which will be the priority. 1 bedrooms will only this site and should be a small proportion of the total. be slanted towards larger family homes

Development will 1183126 Disagree Housing trajectory at appendix 2 shows indicative delivery No change be built out too rates. This will allow creation of a sustainable community. quickly and will not create a sustainable community

40dph too high 1184750 Disagree This is an appropriate minimum density to make best use of No change land and to avoid further pressure on loss of greenfield land/ Green Belt. The NPPF supports optimisation of residential density.

Is there a need for St Stephen Parish Disagree Evidence available in full, including in HCC documents and No change the amount of flexi- Council (51804) representations. Policy L2 sets out an appropriate approach. care provision required?

Policy should Hertfordshire County Disagree Requirement as set out in Policy L2. No change include land size Council (837689) Size requirements can be properly detailed through the requirement for Masterplanning / planning application / EIA process, with flexi-care home appropriate consultation.

Broad Locations Harpenden Town Council Disagree This matter can be properly detailed through the No change should use Design (51870) Masterplanning / planning application / EIA process, with Codes appropriate consultation.

With additional 840795 Noted Cross reference to Policy L18 which requires major No change traffic there will be developments to provide proposals for limiting and mitigating a reduction in Air air quality impacts. Quality

Should include Hertfordshire County Disagree Cross reference to Policy L18 which requires major No change requirement to Council (837689) developments to provide proposals for limiting and mitigating design to mitigate air quality impacts. adverse air quality impacts, as in S6 i), ii) and iii).

Heritage Historic England Disagree Cross reference Policy L30 No change environment (929489) This supports conservation of heritage assets appropriate to /assets have not their significance and seeks that development which may been considered affect such assets is accompanied by a Heritage Statement. and lack of criteria to protect assets Such heritage assets form only a small proportion of the overall Broad Location, are acknowledged and will be treated appropriately as part of the Masterplanning / planning application processes.

Location of Townsend School Disagree Concentrating development in larger sites that can create No change planned 2FE (1186028) new communities and deliver infrastructure – including school should be schools - is a key part of the development strategy. Cross located adjacent to reference L21. Townsend School rather than within the strategic location, to create better support between primary and secondary,

and reduce traffic on New Greens Estate.

Energy efficiency 1153802 Disagree Refer to policy L25 which sets out the energy and No change should include a environmental performance requirements for new separate policy, developments. and should be the highest standard as per Policy L25

Excellence in St Albans Civic Society Noted Requirements for BL set out in Policy L25. No change design, energy (1156974) efficient and water management is required in all Broad Locations

Maybe opportunity Hertfordshire County Disagree An Environmental Impact Assessment (EIA) would be No change for mineral Council (837689) required for developments that are prescribed by the EIA extraction at this Regulations. broad location. A mineral resource assessment should be carried out.

No information Aurora Properties Disagree The development requirements are clear and the Masterplan No change provided on Limited (1151817) process will provide more specific proposals in due course. strategy or delivery, just a wishlist

What St Stephen Parish Noted Masterplanning is at the very earliest stages. Collaboration No change masterplanning Council (51804) with residents and stakeholders will take place as progress is collaboration has made. there been?

Collaboration with 1181750 Noted There has been ongoing joint working with neighbouring local No change neighbouring authorities including the South West Herts Group. 1182733 Councils needed L1- Housing Size, Type, Mix and Density Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) There are already 1182314 Disagree The LPA does not have control over how private housing is No change many privately bought/sold/occupied. owned new housing developments in St Albans which the council agreed to, which are only partially occupied Support the draft Oaklands College Noted Support noted No change plan (1185294) 1184221 The council is not 1184399 Disagree Cross reference to policy L3/4 which provide guidance on No change doing enough to approach taken to provide affordable housing. provide affordable housing and needs to reset its targets

to restore historical supply side failure Excellence in 1034653 Disagree This is an appropriate minimum density to make best use of No change design does not go land and to avoid further pressure on loss of greenfield land/ hand in hand with Green Belt. Policy L23 sets out the main design principles for high density new developments. This includes promoting sustainable and housing high quality designs. Building massed 867312 Disagree The NPPF prioritises achieving optimal housing densities and No change concentrations of appropriate mix of sizes / types. affordable units at This matter can be properly detailed through the the proposed mix masterplanning / planning application / EIA process, with of sizes, and on appropriate consultation. the scale proposed, will unbalance the structures necessary for thriving innovative- and balanced- communities The largest 867312 Noted Evidential basis for specific mix is summarised in Appendix 6 No change requirement (57%) and more detail supporting the Local Plan is available in full. is for 3 bed houses, however credible analysts recognise that larger family and ‘executive’ homes are essential to attracting investment and

entrepreneurs into an area. Concerns over 867312 Noted DtC arrangements will ensure development is coordinated No change developer and across boundaries under joint working and liaison resident disputes arrangements. over the varying standards of space This is an appropriate minimum density to make best use of and housing land and to avoid further pressure on loss of greenfield land/ density between Green Belt. The NPPF supports optimisation of residential Dacorum (30- density. 35dph) and SADC (40dph). SADC needs to recognize this explicitly and devise clear justifications and mitigations of likely consequences Concerns that the 1184750 Disagree This is an appropriate minimum density to make best use of No change minimum average land and to avoid further pressure on loss of greenfield land/ housing density of 1185704 Green Belt. The NPPF supports optimisation of residential 40dph is too high. “ density. The average and best new developments are about 25-30 houses per hectare Requests a total 1184784 Disagree Housing targets are based on evidence on local housing No change block on all future need and standard methodology set out by the government. new builds Highlight the Martin Grant Homes and Disagree Full and detailed justification is provided by evidence No change importance of Kearns Land (975683) documents. It is not necessary to justify the Plan within the

providing a Plan document itself. To do so would result unnecessarily in a housing longer and more complex document. development that is based upon There has been and will be ongoing joint working with proportionate and neighbouring local authorities including the South West Herts up-to- date Group. 2016 evidence is still highly relevant. Forthcoming draft evidence. The SW Herts study will update 2016 evidence, but will not policy should also fundamentally alter the underlying evidence supporting the mix indicate where this set out. evidence can be found. Object to the Martin Grant Homes and Disagree Evidential basis for specific mix is summarised in Appendix 6 No change proposed Kearns Land (975683) and more detail supporting the Local Plan is available in full. requirement for affordable housing size, type and mix to reflect that being provided for the market element of all development. Whatever the market, it is very unlikely that it will be so closely aligned to the social rented sector. Flats should not be Hill Residential Disagree Cross reference to policy L23 where height must be No change more than 2 (1158064) appropriate in the street scene and not negatively impact the storeys high in existing urban characteristics. category 2 areas. 1144419 That should form part of the policy

Setting the housing 1185704 Disagree This is an appropriate minimum density to make best use of No change density to 40 land and to avoid further pressure on loss of greenfield land/ dwellings per Green Belt. The NPPF supports optimisation of residential hectare is likely to density. result in a highly urbanised Policy L23 sets out the main design principles for new environment. This developments. This includes promoting sustainable and high contradicts the quality designs. statement that “All new housing will be developed at a density that is consistent with achieving high quality, sustainable design that does not compromise the distinctive character of the area in which it is situated" The developments 1185704 Disagree Site selection is firmly based on comprehensive GB work and No change should not be the most appropriate locations have already been selected. considered urban extensions (as they 40dph is an appropriate minimum density to make best use of are not) and land and to avoid further pressure on loss of greenfield land/ density should be Green Belt. The NPPF supports optimisation of residential defined as a density. maximum of 30 dph in these areas. More Green Belt should be released if necessary to cover the shortfall.

Generally support Hill Residential Noted Support noted No change L1 draft (1158064) Disagree with the CPRE Hertfordshire Disagree Development need, overall Plan context and site specific No change policy statement (872572) analysis in GB work provide exceptional circumstances for that higher density GB release. Evidence on development strategy / site development will selection is available in full. Cross reference with policy S2. be encouraged in accessible urban locations with good access to services as it is inadequate in the context of new NPPF policies. The council should maximise opportunities for regeneration and reuse of previously developed land before removing land from the Green belt for brownfield sites and underutilised land. The policy should CPRE Hertfordshire Disagree Cross reference with Policy L23 and S2. Policy L1 states new No change include a (872572) housing will be developed at a density that is consistent with requirement for achieving high quality, sustainable design that does not new sites and compromise the distinctive character of the area. regeneration, redevelopment and Cross reference with S1 in respect of Settlement Hierarchy for change of use new development, and L18 in respect of Transport Strategy. schemes to meet

specified density standards, with suitable area for higher density development accessible by public transport shown on the policies map The Policy should CPRE Hertfordshire Disagree 40dph is an appropriate minimum density to make best use of No change therefore include (872572) land and to avoid further pressure on loss of greenfield land/ minimum density Green Belt. The NPPF supports optimisation of residential requirements in the density. Policy that reflect their location and Policy L1 states new housing will be developed at a density character. In any that is consistent with achieving high quality, sustainable Broad Locations design that does not compromise the distinctive character of that are retained in the area. Policy S6 states which density is required for each the Plan there BL. should be a minimum housing density of 60 units per hectare in accordance with policy advice for newly planned large land areas, and 100 per hectare for apartments/flats in accessible urban locations near public transport interchanges.

It is unclear which Jarvis Homes (973180) Disagree L1 states which criterion refers to all housing developments No change parts of the policy and broad locations. Cross reference to Policy S6 which sets relate to Broad out the criterion for each broad locations, along with Appendix Locations and 6. which relate to other development The policy Jarvis Homes (973180) Disagree Policy L1 states new housing will be developed at a density No change. encourages higher that is consistent with achieving high quality, sustainable density design that does not compromise the distinctive character of development but the area. Policy S6 states which density is required for each does not state BL. what density would be appropriate and where, this is required by paragraph 123 of the NPPF 2018 and should be included within the policy. The strategic local Aboyne Residents Evidential basis is summarised in Appendix 6 and more detail No change plan needs to Association (1181214) supporting the Local Plan is available in full address the strong unsubsidised market in larger properties Would like to see 1185971 Disagree Site selection is firmly based on comprehensive GB work No change the plan encourage which identified the allocated Broad Locations. creative implementations of higher rise flat 40dph is an appropriate minimum density to make best use of based land and to avoid further pressure on loss of greenfield land/ accommodation in

order to minimise Green Belt. The NPPF supports optimisation of residential the consumption of density. green belt land. Disagree with the 1185971 Disagree Good design is a requirement set out by the NPPF Paragraph No change prioritisation of 127 and L23 integrating the look and feel of buildings with any adjacent existing buildings over the consumption of the Green Belt Support the 347648 Noted Support noted No change housing mix proposed Local factors must Legal and General Noted Evidential basis is summarised in Appendix 6 and more detail No change be taken into (1051022) supporting the Local Plan is available in full account in tailoring an appropriate CEG (1158030) housing mix for Hallam Land each individual site Management Limited (refers to Broad (1185998) Locations) Agrees that the mix Legal and General Noted Support noted No change should be based (1051022) on robust evidence and should be informed by the District-wide assessment of housing need

Clarification is Legal and General Noted Evidential basis is summarised in Appendix 6 and more detail No change sought on whether (1051022) supporting the Local Plan is available in full. the precise housing mix CEG (1158030) required should vary between the strategic housing allocations to reflect local patterns of demand Support the Trustees of James Henry Noted Support noted No change strategy taken to Frank Sewell Deceased extrapolate from (1185630) the evidence taken from the Housing vision study which focused on the particular circumstances of the St Albans District Support L1 Trustees of James Henry Noted Support noted No change Frank Sewell Deceased (1185630) Wheathampstead Parish Council (51941) Policy wording is St Stephen Parish Disagree The NPPF prioritises achieving optimal housing densities and No change not clear and Council (51804) appropriate mix of sizes / types. This will apply to any urban disturbing “higher development / expansion. This is a reasonable approach and density other policies such as L23 and the specific context will development, determine what an appropriate height in individual including buildings circumstances is.

of greater height than existing, will be encouraged.’ Encouraging St Stephen Parish Disagree Refer to policy S1 which indicates that higher density and No change buildings of greater Council (51804) height will be encouraged, particularly in most accessible parts height than existing of urban settlements. No reason in principle that higher is not will significantly ‘acceptable’, depending on context. impact the local character of areas such as Chiswell Green and Park Street Garden Village, falling outside the acceptable standard Support the Colney Heath Parish Noted Support noted No change proposal to build Council (51891) small/medium family homes to allow both trading up and down freeing up properties for more suitable occupation Renewable energy Colney Heath Parish Agree Cross reference to Policy L25 which sets out the energy No change targets for Council (51891) standards for new developments. Larger Broad locations will developments be expected to deliver renewable/ low- carbon energy supply. should be increased and enforced ,with more specific aims

for creating carbon neutral areas

The plan should Colney Heath Parish Noted Cross reference to Policy L25 which sets out the energy No change encourage energy Council (51891) standards for new developments. efficient buildings and the This matter can be properly detailed through the incorporation of masterplanning/ planning application/ EIA process, with energy efficient appropriate consultation. solutions such as solar and wind power at an early planning stage and working with the BRE as appropriate Policy L1 is too Aurora Properties Disagree L1 directly addresses requirements. No change vague and Limited (1151817) contains no strategy (with the exception of a requirement for housing in the broad locations to achieve a minimum net average density of 40dph)

Concerned with the St Albans Civic Society Noted The NPPF prioritises achieving optimal housing densities and No change statement (1156974) appropriate mix of sizes / types. “developed at a density that is Cross reference with Policy L23 and S2. Policy L1 states new consistent with housing will be developed at a density that is consistent with achieving high achieving high quality, sustainable design that does not quality sustainable compromise the distinctive character of the area. design” and its future impact on local character for areas Suggest further Wheathampstead Parish Disagree L1 already sets out support for opportunities for downsizers. No change consideration for Council (51941) Cross reference to policy L3/4 which provide guidance on our downsizing, mix of approach taken to provide affordable housing. dwelling, first time purchasers, or Appendix 6 also provides more information on housing mix those of lower with regards to affordable and subsidised home ownership. means The key to a London Colney Parish Noted Small / medium sized family homes is a key focus of the No change thriving local Council (52477) policy. housing market is to build small / medium family homes. Building this type of property will enable people who currently live in flats to trade up to the next stage of family accommodation, freeing up smaller properties for

several of the other groups on the list. The policy could Watford Borough Council Disagree Evidential basis is summarised in Appendix 6 and more detail No change provide clearer (1122500) supporting the Local Plan is available in full. L1 sets out guidance about the taking into account evidence of local need, existing pattern of approach to development in the area and site-specific factors. housing mix and type to demonstrate flexibility. For example, will the housing mix policy be applied uniformly or will this be flexible reflecting the location of a proposal? The policy is Anderson Group Noted/ Evidential basis is summarised in Appendix 6 and more detail No change unclear as it does (1146719) Disagree supporting the Local Plan is available in full. L1 sets out not provide specific taking into account evidence of local need, existing pattern of guidance on the development in the area and site-specific factors. mix of housing to be provided in The fine details of this matter can be properly detailed developments through the Masterplanning/ planning application/ EIA process, with appropriate consultation.

Just under 30% of Anderson Group Disagree Site selection is firmly based on comprehensive GB work No change all housing (1146719) which identified the allocated Broad Locations. identified within the plan is to be an urban extension of Cross reference with S6 i), ii) and iii) Hemel Hempstead, limiting the choice for St Albans residents to find housing in the district. Concerns that the Gladman Developments Disagree Evidential basis is summarised in Appendix 6 and more detail No change policy could be Ltd (1187201) supporting the Local Plan is available in full. used to refuse developments on Cross reference to Policies S6, L3 and L23 which provide an ad hoc basis guidance on the requirements for new developments. without reference to evidence of housing need The policy provides Gladman Developments Disagree Cross reference to Policies S6, L3 and L23 which provide No change a significant Ltd (1187201) guidance on the requirements for new developments. degree of uncertainty in Home Builders terms of how it is Federation Ltd applied in the (1156936) decision making The policy should Gladman Developments Noted Evidential basis is summarised in Appendix 6 and more detail No change be amended to Ltd (1187201) supporting the Local Plan is available in full. L1 is clear in refer to the latest setting requirements. SHMA to ensure consistent and responsive decision making

with a fair degree of predictability Support L1’s aim of Crown Estate (51946) Noted Support noted No change achieving a mix of housing types in Adrian Irving and Alban new developments Developments Ltd which reflects (1156368) evidence of local need Contesting the Crown Estate (51946) Disagree Evidential basis is summarised in Appendix 6 and more detail No change evidential basis for supporting the Local Plan is available in full. the policy objective of having the same mix of dwelling sizes for all tenures Figures in Crown Estate (51946) Disagree There has been and will be ongoing joint working with No change Appendix 6 are neighbouring local authorities including the South West Herts based on the Group. 2016 evidence is still highly relevant. Forthcoming draft SADC 2013 SHMA SW Herts study will update 2016 evidence, but will not which is both out of fundamentally alter the underlying evidence supporting the mix date and assumed set out. that St Albans is a self-contained Housing Market Area. This is due to be superseded by a new joint South West Herts SHMA in late 2018

The policy should Crown Estate (51946) Disagree There has been and will be ongoing joint working with No change not include the 5th neighbouring local authorities including the South West Herts paragraph which Group. 2016 evidence is still highly relevant. Forthcoming draft refers to a single SW Herts study will update 2016 evidence, but will not housing mix for all fundamentally alter the underlying evidence supporting the mix tenures. set out. Additionally, Appendix 6 should reflect the tenure specific mix contained in the Savills Report (attached by TCE) Welcome the Adrian Irving and Alban Noted Support noted No change flexibility element Developments Ltd of the policy (1156368) Gladman Developments Ltd (1187201) Home Builders Federation Ltd (1156936) Crest Strategic Projects and Bloor Homes (1158079) Policy L1 is too Aurora Properties Disagree Policy L1 sets out a clear approach. Detailed matters can be No change vague Limited (1151817) properly detailed through the Masterplanning/ planning application/ EIA process, with appropriate consultation. 1144419 The policy and Adrian Irving and Alban Disagree Appendix 6 refers to the existing SHMA evidence, both SADC No change Appendix 6 should Developments Ltd and SWH. refer to 2016 (1156368) SHMA forms the

most recent Crest Strategic Projects evidence on and Bloor Homes housing mix (1158079) The policy must Home Builders Noted This is set out in Appendix 6. No change provide an Federation Ltd indication on the (1156936) general property size mix they are Dacorum Borough seeking to achieve Council (1186054) (based on number Hallam Land of bedrooms) and Management Limited how this will be (1185998) assessed. This general mix should inform, not dictate, the type of development that is delivered Supports Hertfordshire County Noted Support noted No change paragraph 6 which Council (837689) encourages the provision of higher density development in accessible urban locations with good access to services as it can encourage the use of sustainable modes of transport In addition, the CEG (1158030) Disagree Full and detailed justification is provided by evidence No change formatting and documents. It is not necessary to justify the Plan within the

wording should be Plan document itself. To do so would result unnecessarily in a amended to longer and more complex document. distinguish between the formal policy and the reasoned justification for the policy. Support the Crest Strategic Projects Noted Support noted No change objective of policy and Bloor Homes L1 as it proposes (1158079) all new housing developments to contribute to a mix of different housing types Welcome the Crest Strategic Projects Noted Support noted No change aspect of and Bloor Homes encouraging the (1158079) provision of first time buyers (1-2 bed) flats, first family homes (2-3 bed houses) and opportunities for downsizers The evidence of Hallam Land Note Explicitly acknowledged in Appendix 6. No change housing mix could Management Limited be different at the (1185998) end of the plan period compared to that which exists from 2015 and

underpins the policy. The policy must allow for consideration of changes in circumstances Concerns that no Hallam Land Disagree Full and detailed justification is provided by evidence No change account will have Management Limited documents. It is not necessary to justify the Plan within the been taken of (1185998) Plan document itself. To do so would result unnecessarily in a changes to the longer and more complex document. stock profile on account of houses built between 2011 and 2020 Each planning Hallam Land Noted L1 and Appendix 6 are clear as to what is required. Detailed No change permission granted Management Limited matters can be properly detailed through the Masterplanning / on Broad Location (1185998) planning application/ EIA process, with appropriate sites will need to consultation. incorporate measures that allows a flexible approach to determining what is the appropriate housing mix at different points in that build programme The density of any Hallam Land Agree This is an appropriate approach to minimum density to make No change individual proposal Management Limited best use of land and to avoid further pressure on loss of must reflect the (1185998) greenfield land/ Green Belt. Policy L23 sets out the main principles of achieving high

quality design principles for new developments. This includes development, promoting sustainable and high quality designs. sustainable design and respect an area’s character L2 – Provision of Older Persons Housing and Special Needs Housing Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) There is a lack of Martin Grant Homes and Disagree Evidence available in full, including in HCC documents and No change evidence to justify Kearns Land Limited representations. the requirements (975683) set for bedspaces within the older Hallam Land persons and Management Limited special needs (1185998) housing sector Uncertain where Martin Grant Homes and Noted Policy S6, L2 and L8 addresses this matter. No change the remainder of Kearns Land Limited the bedspace (975683) accommodation for older people is expected to be located There is no Retirement Housing Noted This is included in evidence documents, including in HCC No change definition of ‘flexi- Group (1185738) documents and representations. care’ besides it being within class C3

Flexi-care should Retirement Housing Disagree Policy L2, L3, L4 and S6 sets out an appropriate approach, No change not be classified as Group (1185738) including provision of C2. C3. Certain forms of specialist McCarthy & Stone housing for older Retirement Lifestyles Ltd people such as (1186072) Extra Care/ Assisted Living may by virtue of care provided fall within Class C2 There is a Retirement Housing Agree Flexi Care homes fall under use class C3, therefore, this will Minor modification confusion within Group (1185738) be amended in policy S4 (typo) the definition of Swap ‘C2’ and ‘C3’ in flexi-care as policy paragraph 2 of policy S4 S4 denotes that flexi-care homes and similar use class C2 can fall under one category Target for the Retirement Housing Disagree Evidence available in full, including in HCC documents and No change delivery of Group (1185738) representations. Policy L2 sets out an appropriate approach. specialist accommodation for older people should be recalculated using the Housing for Later Life multiplier

Council has not McCarthy & Stone Disagree Evidence available in full, including in HCC documents and No change considered the Retirement Lifestyles Ltd representations. Policy L2 sets out an appropriate approach. economic viability (1186072) Updated evidence regarding economic viability of of development to development has been made available on the council inform the targets website. set out within the Local Plan The policy is based McCarthy & Stone Disagree Updated evidence regarding economic viability of No change on outdated Retirement Lifestyles Ltd development has been made available on the council evidence (Three (1186072) website. Dragon’s viability research). Contravenes criteria in NPPF. Needs to be a McCarthy & Stone Disagree Policy L2 and L3 sets out a clear approach. Each scheme No change better distinction Retirement Lifestyles Ltd will be considered on its own merits. between C2 and (1186072) C3 Extra Care accommodation to allow each scheme to be considered on its own circumstances. Alternatively, the policy commentary or guidance must provide sufficient flexibility to all for consideration of the specific circumstances for each scheme.

Should be a McCarthy & Stone Agree Refer to policy L23 and L25 which sets out energy, No change presumption in Retirement Lifestyles Ltd environmental performance, design and layout standards for favour of (1186072) new developments. This will also be applicable for specialist sustainable housing on sites. housing, in particular specialist housing which is being proposed on suitable sites The plan currently Stackbourne Limited Noted Policy S6, L2 and L3 sets out a clear approach. No change relies on its (1153646) strategic developments to deliver a proportion of care or flexi-care accommodation A risk of older Stackbourne Limited Disagree Policy S6, L2, L3 and L8 set out a clear approach for older No change persons and (1153646) persons and special needs housing. The requirements are special needs expected to be met by developers. housing being made an after- thought as the economic benefits attached to them are much lower. ‘Smallford Works’ site put forward to meet this need. Supports policy Trustees of James Henry Noted Support noted No change Frank Sewell Deceased (1185630)

Harpenden Town Council (51870) St Albans Civic Society (1156974) Gladman Developments Ltd (1187201) Crest Strategic Projects and Bloor Homes (1158079) C2, C3 and special Aurora Properties Disagree Policy L2 sets out a clear approach. Evidence available in No change needs housing Limited (1151817) full, including in HCC documents and representations. numbers are too generic A lack of strategy Aurora Properties Disagree Policy S6, L2 and L8 set out a clear approach for older No change for how L2 housing Limited (1151817) persons and special needs housing. The requirements are provision will be expected to be met by developers. achieved with Castleoak Care regards to Communities (1187716) allocations No evidence to Signature Senior Disagree Policy L2 sets out a clear approach. Evidence available in No change support or explain Lifestyle (1186910) full, including in HCC documents and representations. the approach to the provision of care accommodation Provided detailed Hertfordshire Country Noted SADC acknowledges the information provided No change information relating Council (837689) to bedspace numbers

Local Plan should Crest Strategic Projects Disagree Policy L2 and L3 sets out an appropriate approach. No change include a criteria and Bloor Homes which enables (1158079) exemptions to be made to the provision of affordable home ownership where specialist accommodation is secured. C2 component of Hallam Land Disagree The plan sets out an appropriate approach. This has been No change the policy should Management Limited reinforced by the government’s approach in the updated be additional to the (1185998) NPPF and PPG. Plan’s housing requirement Plan should clarify Hallam Land Disagree L2 and L3 sets out a clear approach. No change that the affordable Management Limited housing provision (1185998) required for older persons accommodation is part of the 40% requirement and not in addition Supports the Castleoak Care Noted Support noted No change inclusion of a Communities (1187716) minimum requirement for C2 care accommodation

Concerned with the Castleoak Care Disagree Policy S6, L2, L3 and L8 set out a clear approach for older No change approach taken in Communities (1187716) persons and special needs housing. The requirements are ensuring that expected to be met by developers. sufficient specialist housing and accommodation for older persons can be delivered The minimum Castleoak Care Disagree Policy S6, L2 and L8 set out a clear approach for older No change bedspace Communities (1187716) persons and special needs housing. Evidence available in requirements for full, including in HCC documents and representations. both C2 and C3 is inadequate as it doesn’t reflect the 2016 SHMA requirements Emphasis on Wheathampstead Parish Noted Policy S6, L2 and L8 set out a clear approach for older No change mental / physical Council (51941) persons and special needs housing. Refer to policy L23 and capacity important L25 which sets out design and layout standards for new to aims of being a developments. This will also be applicable for specialist dementia friendly housing on sites. community L3 – Provision of and Financial Contributions towards Affordable Housing Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Changes Point Point Reply (including any Changes to Plan) There is already 1182314 Disagree The LPA does not have control over how private housing is No change existing privately bought/sold/occupied. owned housing which is partially occupied and can be used to meet

affordable housing targets for local people The policy fails to 1184399 Disagree Policy L3 sets out an appropriate approach. There are No change provide significant sufficient deliverable sites for years 1-5. This is confirmed short-term in relevant developer representations. improvements in affordable housing Social housing St Albans Labour Party Disagree Evidential basis for specific mix is summarised in Appendix 6 No change numbers are too (1183933) and more detail supporting the Local Plan is available in full. low 1184399 It is not necessary to justify the Plan within the Plan document itself. To do so would result unnecessarily in a longer and more complex document. The Council must 1184399 Noted Not within planning remit No change make a use of the lifting of the borrowing cap to ensure enough social housing would be built Development not 1034653 Disagree Evidential basis for specific mix is summarised in Appendix 6 No change consistent with and more detail supporting the Local Plan is available in full. national policy as only 36% of houses will be 1-2 bedroom in an area which has a high proportion of 3-4 bedroom houses

Term ‘affordable 867068 Disagree The terminology used reflects NPPF wording and is No change housing’ a misused consistent with national policy. term for ‘subsidised housing’ Plan should 867068 Disagree Housing Mix is set out in Policy L1 and Appendix 6. Evidential No change concentrate on basis for specific mix is summarised in Appendix 6 and more smaller affordable detail supporting the Local Plan is available in full. dwellings to buy Percentage of 867068 Disagree Cross reference Appendix 6 which sets out justification for No change Affordable Housing the requirement. type 3) (Subsidised Home ownership types) should be raised from 40% to preferably more than 50% Concerns over loss 867587 Disagree Policy L3 sets out an appropriate approach. Affordable No change of affordable housing can be secured through Planning Obligations at housing from the application stage. 40% target due to properties being set above the market rent Mix of affordable St Albans Labour Party Disagree Evidential basis for specific mix is summarised in Appendix 6 No change housing types does (1183933) and more detail supporting the Local Plan is available in full. not reflect the evidence base and must be adjusted to do so

Minimum target St Albans Labour Party Disagree This mix not appropriate due to viability, deliverability and No change should be raised to (1183933) community balance / cohesion 75% affordable homes on sites of 10 dwellings or more to reflect the demands 80% social and 1184750 Disagree The plans does not seek 80% affordable rent in BLs. Policy No change affordable housing S6 and L3 sets out a clear approach. is far too high Policy should be Martin Grant Homes and Disagree Policy L3 sets out a clear approach. This matter can be No change reworded to make Kearns Land (975683) properly detailed through the Masterplanning / planning clear affordable application process. housing should be secured via an affordable housing scheme to be agreed with the Council, as part of a reserved matters or full application Lack of evidence to Martin Grant Homes and Disagree Evidential basis for specific mix is summarised in Appendix 6 No change justify 40% Kearns Land (975683) and more detail supporting the Local Plan is available in full. affordable housing requirement It is not necessary to justify the Plan within the Plan document itself. To do so would result unnecessarily in a longer and more complex document. The 40% minimum Martin Grant Homes and Noted Required by Policy L3. No change requirement should Kearns Land -975683 be secured from major schemes

The term ‘socially Martin Grant Homes and Disagree Refers to schemes of 100 dwellings or more. Will be No change desirable Kearns Land (975683) agreed with the identified provider as part of Masterplanning geographic spread’ / planning application / obligation stages. is too ambiguous Jarvis Homes (973180) for applicants and decision makers Concerns over 1144419 Disagree Not within planning remit No change shared ownership schemes and the risk of increasing maintenance charges and rent for owners. Highlight the need for the council to address this and find ways to manage/prevent this. Support 40% Hill Residential Noted Support noted No change requirement for (1158064) affordable housing Trustees of James Henry Frank Sewell Deceased (1185630) Colney Heath Parish Council (51891) St Albans Civic Society (1156974) Settle (1187516)

Crest Strategic Projects and Bloor Homes (1158079) 347648 There is a need for Hill Residential Noted Updated evidence regarding economic viability of No change an up to date (1158064) development has been made available on the council whole plan viability website. assessment M Scott Properties (1185993) Home Builders Federation Ltd (1156936) Policy is not clear Jarvis Homes (973180) Disagree Policy L3 sets out a clear approach. No change about when affordable housing will be sought and what the relevant thresholds are The approach to Jarvis Homes (973180) Disagree Policy L3 sets out a clear approach. Para 63 of the NPPF is No change vacant buildings defined in footnote. credit is not in line with NPPF More information Jarvis Homes (973180) Disagree Policy L3 sets out a clear approach No change should be provided on how the affordable housing sum may vary or should be calculated

Suggested mix of CEG (1158030) Disagree Evidential basis for specific mix is summarised in Appendix 6 No change affordable housing and more detail supporting the Local Plan is available in full. type is not 1185775 conducive to addressing the fundamental affordability problems within the district. A significantly 1185775 Disagree Policy L3 sets out appropriate affordable housing No change higher proportion requirements. Evidential basis for specific mix is summarised of properties in Appendix 6 and more detail supporting the Local Plan is should be social available in full. rented than 30% The policies 1185775 Noted Policy L1 which supports opportunities for downsizing. No change relating to Older Persons Housing should also include promotion of housing suitable for downsizing, which may well be able to be provided at market value Uncertain how the Colney Heath Parish Noted All Broad Locations must meet a minimum of 40% No change affordable housing Council (51891) affordable housing. The distribution will be agreed through will be distributed the process of Masterplanning with local communities, across individual London Colney Parish landowners and other stakeholders. sites in Broad Council (52477) Locations 347648 The minimum 40% Colney Heath Parish Noted All Broad Locations must meet a minimum of 40% No change affordable housing Council (51891) affordable housing. The distribution will be agreed through

contribution should 347648 the process of Masterplanning with local communities, be evenly landowners and other stakeholders. distributed throughout individual sites and Broad Locations Developers must Colney Heath Parish Agree All requirements set out in the Broad Location policies, No change deliver the Council (51891) including a minimum 40% affordable housing, have been affordable housing agreed as deliverable by the landowners/developers. proportion and not 347648 be able to avoid this responsibility Must be a range of London Colney Parish Noted Policy L3 sets out a clear approach No change unit types and Council (52477) sizes similar to private tenure for Colney Heath Parish social and Council (51891) affordable rented 347648 housing Generally support Legal and General Noted Support noted No change policy (1051022) Inconsistency Legal and General Disagree Policy L3 sets out appropriate approach based on local No change between Local (1051022) evidence Plan and NPPF. There is no Trustees of James Henry requirement for Frank Sewell Deceased- financial (1185630) contributions for RF Sinclair and Sons schemes of 9 or (1058251) fewer homes. This should be removed Aurora Properties or corrected. Limited (1151817)

Gladman Developments Ltd (1187201) Home Builders Federation Ltd (1156936) 52064 Complex policy Legal and General Disagree Policy L3 sets out a clear approach No change wording used (1051022) relating to default mechanism Council’s full Legal and General Noted Updated evidence regarding economic viability of No change evidence base (1051022) development has been made available on the council relating to viability website. should be published prior to the submission of the emerging plan Support affordable Trustees of James Henry Noted Support noted No change housing split of Frank Sewell Deceased 60% to 40% (1185630) Would like to know St Stephen Parish Noted Policy L3 provides details on the overall affordable housing No change percentage cost for Council (51804) percentage requirements. ‘Cost’ will depend on individual schemes with 9 or site circumstances. fewer homes Affordable homes Aurora Properties Noted Required by Policy L3 for affordable rent No change should be 20% Limited (1151817) below market rents Discounted market Aurora Properties Disagree Policy L3 sets out appropriate affordable housing No change sales should be Limited (1151817) requirements responding to government definitions in NPPF

20% below local market value Insufficient specific Aurora Properties Disagree Starter homes supported by Policy L3 No change provision for Limited (1151817) Starter Homes which have the Gladman Developments greatest demand in Ltd (1187201) SADC Policy wording is M Scott Properties Disagree Refer to policy L3 ‘Affordable Housing Provisions’ and No change not clear on the (1185993) ‘financial contributions’ section. approach to be taken on sites for between 10-50 dwellings Absence of a M Scott Properties Noted Updated evidence regarding economic viability of No change detailed viability (1185993) development has been made available on the council study for each website. Further evidence may be made available in due Broad Location course. Viability/deliverability have been agreed for all Broad Locations by the landowners/developers No evidence to Signature Senior Disagree The NPPF para 62 states that where a need for affordable No change justify or explain Lifestyle (1186910) housing is identified planning policies should specify the 40% requirement level and type required. Evidence available in full, including for care Castleoak Care in HCC documents and representations. accommodation. Communities (1187716) Should not refer to McCarthy & Stone C2. Retirement Lifestyles Ltd (1186072) Affordable housing London Colney Parish Disagree Evidential basis for specific mix is summarised in Appendix 6 No change contributions Council (52477) and more detail supporting the Local Plan is available in full. should be increased

This mix not appropriate due to viability, deliverability and community balance / cohesion. A 75% affordable London Colney Parish Agree 75% 25% split not proposed in Policy No change and 25% market Council (52477) split has no reasonable prospect of being delivered The policy should London Colney Parish Disagree Evidential basis for specific mix is summarised in Appendix 6 No change be worded as an Council (52477) and more detail supporting the Local Plan is available in full. aspiration to meet local needs in full No justification for Mr Dean Ivory (52552) Disagree Policy L3 sets out appropriate approach based on local No change requiring schemes evidence at fewer than 10 Shonleigh Nominees (net) to make a (978420) financial Trustees GA Simons contribution to off- Family Trust (1187408) site provision Kenneth Ivory (978427) Mr Richard Blair (977889) Mr Antonio Barba (1187384) D’Arblay Investments (1187404) Watford Borough Council (1122500)

No justification that Mr Dean Ivory (52552) Disagree Affordable housing will be sought by way of Planning No change the landowner Obligation. Landowners can receive receipts for affordable should receive Shonleigh Nominees housing by means of those obligations. nothing for land for (978420) affordable housing Kenneth Ivory (978427) Mr Richard Blair (977889) Mr Antonio Barba (1187384) D’Arblay Investments (1187404) The requirement Kenneth Ivory (978427) Disagree Policy L3 sets out a clear approach and is justified in the No change that a building has context of the District and the LP approach overall. not been in Mr Richard Blair economical (977889) beneficial use for Mr Antonio Barba at least 3 years, (1187384) and has been marketed for the D’Arblay Investments same, period is not (1187404) justified Mr Dean Ivory (52552) Shonleigh Nominees (978420) Review process Mr Dean Ivory (52552) Noted Review process will take both values and costs into No change would need to account. consider not only Shonleigh Nominees return values but (978420) costs as well Mr Richard Blair (977889)

Mr Antonio Barba (1187384) D’Arblay Investments (1187404) The provision of Sandridge Parish Disagree Policy L3 provides an overall set of requirements. Policy S6 No change affordable housing Council (869186) sets out a minimum requirement for affordable housing and is considered to be other policy requirements in Broad Locations. inadequate, as Viability/deliverability have been agreed for all Broad recent experience Locations by the landowners/developers in the District has been that developers fail to deliver the agreed percentage of affordable housing often citing viability as a reason Concerns that Sandridge Parish Disagree Cross refer development strategy in S1 and S2. Policy L3 No change future development Council (869186) provides an overall set of requirements. Policy S6 sets out a would be on Green minimum requirement for affordable housing and other Belt sites in policy requirements in Broad Locations. preference to Viability/deliverability have been agreed for all Broad Brownfield and that Locations by the landowners/developers developers would not provide the targeted percentage of affordable housing No evidence base Anderson Group Noted Updated evidence regarding economic viability of No change to demonstrate (1146719) development has been made available on the council whether the policy website. Further evidence may be made available in due course.

position has been tested for viability Viability matters Anderson Group Noted Updated evidence regarding economic viability of No change must be tested (1146719) development has been made available on the council through the plan website. Further evidence may be made available in due preparation and course. not negotiated on a site by site level (other than exceptional circumstances) Support updated Gladman Developments Noted Support Noted No change definition of Ltd (1187201) Affordable Housing which recognises Starter Homes and Discounted Market Sales homes as types of affordable housing Concerns over the Mr Marcello Cannatella Disagree Policy L3 and Appendix 6 sets out a clear approach. No change potential limitations (1187377) imposed on site promoters as Mr Dean Ivory (52552) affordable housing Shonleigh Nominees is restricted to a (978420) given type (social rent) Kenneth Ivory (978427) Concerns over the Crown Estate (51946) Disagree Evidential basis for specific mix is summarised in Appendix No change homogenous 6 and more detail supporting the Local Plan is available in housing mix full.

proposed for all tenures Need for two Crown Estate (51946) Disagree Evidential basis for specific mix is summarised in Appendix No change separate mixes for 6 and more detail supporting the Local Plan is available in affordable and full. market housing Remove the Home Builders Disagree L3 sets out a clear approach given likely varying conditions No change default mechanism Federation Ltd and context over the Plan period. for non-provision (1156936) The percentage Mr Dean Ivory (52552) Disagree Evidential basis for specific mix is summarised in Appendix 6 No change requirement of and more detail supporting the Local Plan is available in full. 40% is excessive Kenneth Ivory (978427) Shonleigh Nominees (978420) Aurora Properties Limited (1151817) D’Arblay Investments (1187404) Mr Richard Blair (977889) Mr Antonio Barba (1187384) Trustees GA Simons Family Trust (1187408) Support the range Settle (1187516) Noted Support noted No change of affordable housing options

Note the Settle (1187516) Note Support noted No change acknowledged need for specialist accommodation within the broader onward supply of affordable homes Encourage a Settle (1187516) Disagree The terminology used reflects NPPF wording and is No change clearer definition to consistent with national policy. the terms included in describing ‘Social Rent’ levels Affordable housing CEG (1158030) Noted Evidential basis for specific mix is summarised in Appendix Publish updated mix should be 6 and more detail supporting the Local Plan is available in evidence based on robust full. evidence and up- to-date evidence Identifying land for Crest Strategic Projects Disagree Policy L3 sets out an appropriate approach No change affordable housing and Bloor Homes in planning (1158079) permissions and obligations is not an appropriate practice Policy should Crest Strategic Projects Disagree Policy L3 sets out an appropriate approach that will not No change reflect normal and Bloor Homes impede delivery market practices (1158079) and avoid an onerous situation that may impede delivery.

Allow alternatives Crest Strategic Projects Disagree Policy L3 sets out a clear approach No change to provision, in and Bloor Homes kind, on site. (1158079) Specific policy Crest Strategic Projects Disagree Policy L3 sets out a clear approach. Will be agreed with the No change wording suggested and Bloor Homes identified provider as part of Masterplanning / planning in relation to (1158079) application / obligation stage. default provision in case of non- provision. Policy fails to Hallam Land Disagree Policy L3 sets out a clear approach No change provide a degree of Management Limited flexibility with (11859998) regards to the methods of securing affordable housing provision in respective planning obligations Policy percentage Mr Dean Ivory (52552) Disagree Evidential basis for specific mix is summarised in Appendix 6 No change for affordable and more detail supporting the Local Plan is available in full. housing is too high Kenneth Ivory (978427) Shonleigh Nominees (978420) D’Arblay Investments (1187404) 1184750

L4- Affordable housing development in the Green Belt (rural exceptions sites) Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) If a site is already RF Sinclair and Sons Disagree Proposals, even on allocated sites in a Neighbourhood No change designated in a (1058251) Plan, will still need to comply with policies in the Local Plan. made Neighbourhood 52064 Plan, it would already not be subject to the policies in this Plan. The policy seeks 973180 Disagree NPPF paragraph 71 refers to “one or more” types of No change only to allow for affordable housing. Therefore one type – social rented social rented housing, is in accordance with the NPPF. housing on exception sites rather than “one or more types of affordable housing” as set out in paragraph 71 of the NPPF. Therefore L4 is not considered to be consistent with national policy. This policy is likely Hunston Planning Disagree This is an additional route for housing development, subject No change to reduce the Limited (1185622) to the details set out in the policy. Other routes in the LP or number of through national policy in the NPPF are also available. affordable houses

delivered in the Trustees of James Henry Green Belt rather Frank Sewell Deceased than increase it (1185630) Shonleigh Nominees (978420) Does not seek to Hunston Planning Disagree Overall, housing requirement/targets are based on the No change meet the area’s Limited (1185622) standard methodology set out by the government – see S4. objectively assessed needs as Site selection is firmly based on comprehensive GB work it excludes the which identified the allocated Broad Locations. provision of some Concentrating development in larger sites that can create forms of affordable new communities and deliver infrastructure is a key part of housing the development strategy. This is an additional route for development to meet some localised needs, subject to the details of the policy. Criterion (iii) may Hunston Planning Disagree NPPF allows for the principle of limited affordable housing, No change unintentionally Limited (1185622) subject to Local Plan policies – which this is detailing. make ‘limited affordable housing’ inappropriate in the District, rather than appropriate development allowed by the NPPF The policy seeks to Hunston Planning Noted The planning application was determined under the No change set a maximum Limited (1185622) currently adopted Local Plan (1994), and full justification number of can be found in the officer’s report. Policy L4 defines affordable homes ‘limited’ as required by paragraph 145 of the NPPF 2018. per site at just two- thirds of the amount the Council

recently approved for itself in the Green Belt The NPPF states Colney Heath Parish Noted Policy L4 does not state a requirement to demonstrate ‘very No change that “limited Council (51891) special circumstances’. Policy L4 defines ‘limited’ as required affordable housing by paragraph 145 of the NPPF 2019. This requirement is also for local community Hunston Planning reflective with paragraphs 77-79 of the NPPF 2019, needs under Limited (1185622) supporting development that meets local need whilst policies set out in Trustees of James Henry avoiding homes in isolated areas. the development Frank Sewell Deceased plan” is considered (1185630) appropriate development in the 347648 Green Belt and as such does not have to demonstrate “very special circumstances”. This should not be used to justify development where it would not otherwise meet the test of “very special circumstances” The text should be Trustees of James Henry Disagree The current wording reflects the approach actually taken to No change rewritten to reflect Frank Sewell Deceased the strategic approach of the LP. The new NPPF wording a more positive (1185630) 2019 is generally similar and not contradictory to the approach to approach taken. appropriate M Scott Properties development in the (1185993) Green Belt which will boost the

supply of housing rather than make it more difficult to achieve Highlight the need St Stephen Parish Noted Policy L4 states any site designated solely for affordable No change for Neighbourhood council (51804) housing in made Neighbourhood Plan will be supported. Plan consideration Criterion (iv) is Aurora Properties Disagree. This requirement is reflective with paragraphs 77-79 of the No change unnecessary. If the Limited (1151817) NPPF 2019, supporting development that meets local need area is “dominated whilst avoiding homes in isolated areas. Not all settlements by buildings” it is are excluded from the Greenbelt, as set out in Policy S2. unlikely to be performing any Green Belt purpose and the Council should consider the release of that area from the Green Belt This policy could St Albans Civic Society Disagree The NPPF sets out that limited affordable housing for local No change allow ‘carte (1156974) community needs can be appropriate in the Green Belt. blanche’ building These requirements are also reflective with paragraphs 77- across the Green 79 of the NPPF 2019, supporting development that meets Belt if the housing local need whilst avoiding homes in isolated areas. is designated as affordable The policy St Albans Civic Society Disagree Para 145 of the NPPF sets out that limited affordable housing No change suggests that a (1156974) for local community needs can be appropriate in the Green developer could Belt. put their entire affordable housing quota for a scheme on the Green Belt, leaving any urban

brown field site to be developed exclusively for private housing. The policy must guard against such possibility As currently M Scott Properties Disagree Para 145 of the NPPF sets out that limited affordable housing No change permitted, the (1185993) for local community needs can be appropriate in the Green policy only allows Belt, in accordance with Local Plan policies. L4 defines what for development is considered limited. that is no larger than 10 dwellings on a maximum site area of 0.5 Ha. The definition of a rural exception site in the NPPF (2012) advises that rural exception sites are ‘small sites’ but it does not define the number of dwellings. Given the acute need for affordable housing in the District they consider that this threshold should be increased Encourage the M Scott Properties Disagree NPPF paragraph 71 refers to “one or more” types of No change revision of the (1185993) affordable housing. Therefore one type – social rented wording for policy housing, is in accordance with the NPPF. requirement (ii) to be more reflective

of the new definition of affordable housing set out in the NPPF (2018) The requirement Shonleigh Nominees Disagree NPPF paragraph 71 refers to “one or more” types of No change that affordable (978420) affordable housing. Therefore one type – social rented housing is in some housing, is in accordance with the NPPF. way restricted to Social Rent will effectively mean that viable sites will not come forward given Government funding The policy fails to Anderson Group Disagree Para 145 of the NPPF sets out that limited affordable housing No change recognise the close (1146719) for local community needs can be appropriate in the Green relationship some Belt, in accordance with Local Plan policies. L4 defines what Green Belt is considered limited. Housing not identified as local settlements have community needs is not considered to fall within this with the major exception in the NPPF. settlements of the District. Therefore, distinguishing between the priority need for housing for local community and that of major settlements will be hard to evidence. This approach overlooks a significant contribution medium scale sites

on the edge of non- Green Belt areas could provide to meeting both market and affordable needs in the District. Account should be Hertfordshire County Noted This requirement is reflective with paragraphs 77-79 of the No change taken of LTP4’s Council (837689) NPPF 2019, supporting development that meets local need Policy 5: whilst avoiding homes in isolated areas. Greenbelt Development settlements are defined under S2. Management, part G, which states: Development will be required to comply with Policy L18 and “Resist L19. development that would either severely affect the rural or residential character of a road or other right of way, or which would severely affect safety on rural roads, local roads and rights of way especially for vulnerable road users. This should include other routes which are important for sustainable transport or leisure”

Supports the CPRE Hertfordshire Noted Support noted No change principles of policy (872572) L4 Suggests an CPRE Hertfordshire Disagree Policy states size of sites must be below this, at 0.5 hectares, No change amendment of the (872572) and defines ‘limited’ as required by paragraph 145 of the site size criterion to NPPF 2019. encourage the optimal use of sites, particularly for smaller dwellings, through either reducing the qualifying site size to 0.75 hectares, or increasing the number of dwellings to 15 The policy should CPRE Hertfordshire Disagree Policy defines ‘limited’ as required by paragraph 145 of the No change require the impact (872572) NPPF 2019. The policy also identifies what type of housing on the Green Belt constitutes ‘Local Community Need’, and evidence of this, to be ‘minimal’, and legal agreement, will be sought at planning application rather than stage. ‘limited’. There should be a requirement that this is also demonstrated in a Planning Statement accompanying the planning application Recommend the Historic England Disagree Cross reference with Policy LP30. No change addition of a (929489) criterion to read

‘the development will conserve and where appropriate enhance the historic environment’ L5- Small Scale Development in Green Belt Settlements Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Current policy St Stephen Parish Partly Cross refer to S2 - The NPPF and draft Local Plan support No Change (to L5 – wording fails to Council (51804) Agree Neighbourhood planning. The Local Plan deals with the minor modification to S2) give the local overall need for new housing and is not reliant on NPs. NPs community, in the 867587 must make their local own justification for additional housing form of the provision (and for other uses); this is their intended role. Neighbourhood Given the specific wording used in the final NPPF 2018 plan, the specific (after the Council decision on 11 July 2018 based on the opportunity to draft NPPF) a minor modification should be made to make review and modify clear that if detailed local evidence justifies development at the Green Belt a neighbourhood scale, on land currently designated as Settlement Green Belt, it is supported in principle. boundary Policy L5 differs Jarvis Homes (973180) Disagree The proposed policy does not preclude development which No change from national policy is already acceptable under para 145 of the NPPF. as it effectively Belgrave Land precludes certain (Northern) No 2 Limited types of (1185928) development that DB Rees (Builders) Ltd the NPPF (1160056) specifically provides for Hunston Planning Limited (1185622)

Trustees of James Henry Frank Sewell Deceased (1185630) There is a lack of Jarvis Homes (973180) Disagree Policy sets out all four criteria are relevant. No change clarity with the policy. The reader DB Rees (Builders) Ltd must assume that (1160056) all four criteria set out must be satisfied Given all criteria in Jarvis Homes (973180) Disagree The proposed policy does not preclude development which No change L5 must be met, it is already acceptable under para 145 of the NPPF. would indicate that DB Rees (Builders) Ltd only previously (1160056) developed sites are included. This conflicts with paragraph 145 of NPPF which permits infill development on greenfield and brownfield land The description of Jarvis Homes (973180) Disagree Definition of Previously Developed Land set out in Glossary No change previously of NPPF. developed land DB Rees (Builders) Ltd that includes “part (1160056) of a previously developed property area” is unclear. The restriction of Jarvis Homes (973180) Disagree NPPF refers to Infilling, whilst LP provides clarity as to what No change development to 10 constitutes Infilling in this context in this District.

dwellings does not DB Rees (Builders) Ltd accord with the (1160056) NPPF which places no size Hunston Planning restriction on sites, Limited (1185622) providing it does not have a greater impact on openness The definition of Jarvis Homes (973180) Disagree NPPF refers to Infilling, whilst LP provides clarity as to what No change infill development constitutes Infilling in this context in this District. being restricted to DB Rees (Builders) Ltd a gap is (1160056) considered inappropriate. There are many potential infill sites that are not gaps in frontages but are nevertheless infill development in terms of being within a settlement and part of the built form. Policy L5 should DB Rees (Builders) Ltd Disagree Policy L5 refers to small scale development in Green Belt No change be deleted as the (1160056) Settlements. The proposed policy does not preclude content of development which is already acceptable under para 145 of paragraph 145 Jarvis Homes (973180) the NPPF. NPPF adds plenty 52064 of meaningfulness to the policy coverage.

No justification has Jarvis Homes (973180) Disagree The excluded area is considered separate to the main area, No change been provided for and is not considered part of the Green Belt Settlement. excluding part of 52064 Sleapshyde village from the boundary of the Green Belt Settlement There is no Belgrave Land Disagree NPPF refers to Infilling, whilst LP provides clarity as to what No change definition of (Northern) No 2 Limited constitutes Infilling in this context in this District. “infilling” or “limited (1185928) filling” in the NPPF. This can result in difficulty for sites to come forward as the decision-maker is left to form a view on an application The definition of an Belgrave Land Disagree NPPF refers to Infilling, whilst LP provides clarity as to what No change infill site is overly (Northern) No 2 Limited constitutes Infilling in this context in this District. prescriptive and (1185928) has no basis for introduction into Minister Court Frogmore the policy as a key (1185980) test. The wording is therefore a barrier to sustainable development

Request for the Belgrave Land Disagree Policy L5 refers to small scale development in Green Belt No change criterion 3 of Policy (Northern) No 2 Limited Settlements. The proposed policy does not preclude L5 to be deleted to (1185928) development which is already acceptable under para 145 of ensure consistency the NPPF. with national policy in the Framework and to ensure the policy can effectively deliver sustainable development Support L5 CPRE Hertfordshire Noted Support noted No change (872572) St Albans Civic Society (1156974) 1185945 Disagree with the 1185945 Noted Boundaries of Green Belt Settlements based on evidence. No change Smallford village Cross reference to Policies Map. hatched area, denoting allowable small scale development, and request for it to be corrected A separate limb to Minister Court Frogmore Disagree The proposed policy does not preclude development which No change policy L5 should be (1185980) is already acceptable under para 145 of the NPPF. included to reflect the development exceptions set out in the Framework.

The boundaries of 52064 Disagree Boundaries of Green Belt Settlements based on evidence. No change many of the “Green Cross reference to Policies Map. Belt Settlements” are arbitrarily drawn, with cases where substantial areas of the settlement are shown excluded from the definition The draft plan’s 52064 Disagree Approach is consistent with national policy. No change criteria within this proposed policy lack clarity and will not provide the predictability that developers need. The third bullet point of this draft policy is too subjective and open to varied interpretation Policy wording CPRE Hertfordshire Disagree Proposed developments will also be required to comply with No change needs to refer to a (872572) the other criterion set out in L5 and other LP and NPPF maximum site size, policies on making best use of land, appropriate density etc. and not a maximum of 10 dwellings. This can lead to a large, very low density, development which would be inconsistent with

the objectives of the Plan and National Planning Policy Suggest that a CPRE Hertfordshire Disagree Proposed developments will also be required to comply with No change maximum site size (872572) the other criterion set out in L5. of 0.75 hectares should be specified by the Policy No justification has DB Rees (Builders) Ltd Disagree The excluded area is considered separate to the main area, No change been provided for (1160056) and is not considered part of the Green Belt Settlement. excluding part of Radlett Road ( Frogmore) village (including the report site) from the boundary of the Green Belt Settlement The definition of DB Rees (Builders) Ltd Noted Approach is consistent with national policy. Policy L5 refers No Change Green Belt (1160056) to small scale development in Green Belt Settlements. The settlement proposed policy does not preclude development which is envelope is not Jarvis Homes (973180) already acceptable under para 145 of the NPPF. necessarily determinative of whether a proposal could be considered limited infilling in terms of the NPPF. Case law has established that a judgement will

need to be made “ on ground”, based on relevant factors, rather than simply relying on a Local Plan designation The policy should Hunston Planning Disagree Approach is consistent with national policy. Policy L5 refers No Change allow limited Limited (1185622) to small scale development in Green Belt Settlements. The infilling in villages proposed policy does not preclude development which is on non- previously already acceptable under para 145 of the NPPF. developed land and allow the redevelopment of previously develop land even if its outside a village The policy has Hunston Planning Disagree Approach is consistent with national policy. Policy L5 refers No Change conflated two Limited (1185622) to small scale development in Green Belt Settlements. The separate forms of proposed policy does not preclude development which is appropriate Trustees of James Henry already acceptable under para 145 of the NPPF. development to the Frank Sewell Deceased detriment of both (1185630) (“Limited infilling in villages” and “limited infilling and the partial or complete redevelopment of previously developed land”). This will increase the difficulty in delivering them

The wording of the Colney Heath Parish Disagree The current wording reflects the approach actually taken to No change policy needs to be Council (51891) the structure of the LP. The new NPPF wording 2019 is clearer generally similar and not contradictory to the approach London Colney Parish taken. Council (52477) 347648 Limited Colney Heath Parish Noted Approach is consistent with national policy. No change development of Council (51891) previously undeveloped land 347648 should be considered on a case by case basis judging the specific proposal for any individual site and ensuring the openness to the settlement is not lost over time and ultimately being taken out of the Green Belt ‘washover’ entirely The policy should Trustees of James Henry Disagree Approach is consistent with national policy. Policy L5 refers No change be split in two Frank Sewell Deceased to small scale development in Green Belt Settlements. The sections to reflect (1185630) proposed policy does not preclude development which is the exceptions as already acceptable under para 145 of the NPPF. set out in the NPPF

The policy seems Trustees of James Henry Disagree Approach is consistent with national policy. The proposed No change to allow infilling Frank Sewell Deceased policy does not preclude development which is already only in those parts (1185630) acceptable under para 145 of the NPPF. of a villages where there is no room 347648 for infilling Recommend for Trustees of James Henry Disagree Concentrating development in larger sites that can create No change the text regarding Frank Sewell Deceased new communities and deliver infrastructure is a key part of the policies and (1185630) the development strategy. extent of the village envelopes to be Approach is consistent with national policy. The proposed reviewed to policy does not preclude development which is already promote acceptable under para 145 of the NPPF. appropriate development in the Green Belt rather than frustrate it L5 paragraph 1 Aurora Properties Disagree Approach is consistent with national policy. Policy L5 refers No change should be deleted. Limited (1151817) to small scale development in Green Belt Settlements. The The NPPF proposed policy does not preclude development which is paragraph 145 (e) already acceptable under para 145 of the NPPF. does not require limited infilling in the Green Belt to be previously developed land L5 relaxes Wheathampstead Parish Support Support Noted No change planning rules for Council (51941) the re designated ‘Green Belt Settlements’ of Folly Fields, Lea Valley and Gustard

Wood. By more readily permitting small scale development within the localities the need for additional housing and facilities may be addressed without eroding the Green Belt Notes that the plan London Colney Parish Noted Approach is consistent with national policy. No change seeks to spread Council (52477) future development around existing towns via the identified broad locations /circumstances and not in others Suggest a Watford Borough Council Disagree The policy refers to small scale development in Green Belt No change clarification on (1122500) settlements, as defined in S2 and the proposals map. A gap what constitutes a is defined under point 3 of the policy. The proposed policy gap in such does not preclude development which is already acceptable situations (i.e. if a under para 145 of the NPPF. lone building is considered sufficient to define a gap suitable for infill or if a gap requires stronger definition of its boundaries and

relationship to the existing settlement) The assessment of Watford Borough Council Disagree Proposed developments will also be required to comply with No change extensions is (1122500) the other criterion set out in L5. This includes point 3 (infill) based on its and point 4 (character). relationship to the existing building and any potentially adverse impact on the surrounding area. If these are the critical factors it is unclear why the size thresholds would be required rather than assessing a scheme on its design merits Sandridge green Owner of Pound Farm & Disagree The excluded area is not considered to be within the Green No change belt settlement East of Sandridge Belt Settlement envelope. The proposed policy does not boundary (1187227) preclude development which is already acceptable under constraints para 145 of the NPPF. potential growth Policy L5 allocation Notcutts (1160112) Disagree The excluded area is not considered to be within the Green No change should be Belt Settlement envelope. The proposed policy does not extended to allow preclude development which is already acceptable under small scale para 145 of the NPPF. development such as ‘Notcutts Garden Centre’

SADC should Welwyn Hatfield Borough Disagree Proposed developments will also be required to comply with No change consider modifying Council (52397) the other criterion set out in L5. This includes point 3 (infill) L5 to include an and point 4 (character). additional criterion, which would allow for the open character of the settlement which contributes to the openness of the Green Belt to be protected. This is particularly important where the settlement lies in a fragile gap between towns In addition to the Hertfordshire County Disagree L5 refers to Green Belt requirement is reflective with No change requirement set out Council (837689) paragraphs 77-79 of the NPPF 2019, avoiding homes in in this policy, isolated areas. Greenbelt settlements are defined under S2. account should be taken of LTP4’s Development will be required to comply with Policy L18 and Policy 5: L19. Development Management, part g, which states: “Resist development that would either severely affect the rural or residential character of a road or other right of way, or which

would severely affect safety on rural roads, local roads and rights of way especially for vulnerable road users. This should include other routes which are important for sustainable transport or leisure.” Recommend the Historic England Disagree Cross reference to Policy L30 which addresses this. No change addition of a (929489) criterion to read ‘the development will conserve and where appropriate enhance the historic environment’

Policy L6 - Extension or Replacement of Dwellings in the Green Belt Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point (see below for list Reply (including any Changes of abbreviations) to Plan) Policy is RF Sinclair and Sons Disagree Policy applies to development that is not permitted No change unnecessary as (1058251) development and planning permission is required. Permitted many of the development rights are a separate process. works referred to 52064 would be permitted development Policy should RF Sinclair and Sons Disagree Policy L6 applies to specifically to dwellings. The principle of No change refer to (1058251) replacement buildings in the Green Belt are addressed in replacement of the NPPF. ‘buildings’ not 52064 ‘dwellings’ Policy too Jarvis Homes (973180) Disagree The Policy establishes important principles for Green Belt No change detailed/restrictiv development e/complex Aurora Properties Ltd (1151817) 1185956 Part i) conflicts Jarvis Homes (973180) Disagree Policy provides further detail as to what would be No change with NPPF which disproportionate additions. There is no conflict with the only requires NPPF extensions to not be disproportionate to size of original dwellings

‘Replacement Jarvis Homes (973180) Disagree Policy provides further detail to assess replacement No change Dwellings’ section dwellings which are not inappropriate in the Green Belt in conflicts with principle. There is no conflict with the NPPF NPPF which doesn’t require assessment on location or character/size Support policy - St Albans Civic Society Noted Support noted No change acceptable (1156974) 1185630 Policy L7 Gypsies, Travellers and Travelling Show People Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point (see below for list Reply (including any Changes of abbreviations) to Plan) Sites should be St Stephen Parish Disagree Sites have been allocated in the most appropriate locations, No change more evenly Council (51804) based on evidence, as set out in L7. distributed across the District Colney Heath Parish Council (51891) DBC (1186054) 1144419 1185704 1185821 1186046 1181723 347648

498103

Additional pitches DBC (1186054) Disagree Sites have been allocated in the most appropriate locations, No change in EHH Broad based on evidence, as set out in L7. There is considerable Location would flexibility within these large Broad Locations to locate sites result in an over- sensitively. concentration in the area, exacerbating existing problems. EHH (Central) DBC (1186054) Disagree Cross reference to Policy S6. No change Broad Location is a proposed Sites have been allocated in the most appropriate locations, employment site based on evidence, as set out in L7. There is considerable and not therefore flexibility within these large Broad Locations to locate sites an appropriate sensitively. location for a travellers site SADC should not Berkhamsted Residents Disagree Sites have been allocated in the most appropriate locations, No change allocate sites in Action Group (186012) based on evidence, as set out in L7. There is considerable an extension of a flexibility within these large Broad Locations to locate sites town in another sensitively. district SADC is the responsible LPA and is committed to working jointly with DBC on planning in these areas. Policy needs DBC (1186054) Disagree Updated draft GTANA work 2019 has been published. No No change amending to need to amend Policy or approach. include a target WHBC (52397) following updated GTANA

Question Herts GATE (1151880) Disagree Updated draft GTANA work 2019 has been published. No No change robustness of need to amend Policy or approach. evidence base and level of need Sites do not Herts GATE (1151880) Disagree Updated draft GTANA work 2019 has been published. No No change reflect traveller need to amend Policy or approach. need and will have a long lead- in time Management Herts GATE (1151880) Disagree Will be agreed as part of Masterplanning / planning No change arrangement for application/obligation stage. proposed new sites is unclear Land adjacent Herts GATE (1151880) Disagree Sites have been allocated in the most appropriate locations, No change existing Barley based on evidence, as set out in L7. Policy L7 already sets Mow site should out that the potential and suitability of extending existing be considered sites will be considered. Policy supported St Albans Civic Society Noted Support noted No change as (1156974) sound/acceptable 1185630 Should be HBC 51934 Noted SADC and HBC are working together through the SWH JSP No change collaborative process. For all issues where there might be a cross- masterplanning boundary implication for Hertsmere/SADC then appropriate work with HBC to involvement in Masterplanning will take place in due course. consider site provision that have the potential to affect Hertsmere

Evidence base WHBC (52397) Disagree Updated draft GTANA work 2019 has been published. No No change should take need to amend Policy or approach. account of need from Hertsmere’s transit site Policy L8 - Primarily Residential Areas Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point (see below for Reply (including any Changes list of abbreviations) to Plan) Converted units 1144419 Noted Cross reference to policy L24 which sets out the No change need to be of a development amenity standards. These are applicable to all reasonable size forms and scales of development and must be followed in principle. Policy should 1185956 Disagree Policy L8 sets out a very clear approach. Housing targets are No change discourage rather based on evidence on local housing need and standard than refuse methodology set out by the government. Development which conversion of flats results in a loss of housing units will be detrimental to these to dwellings aims. Multiple 1144419 Noted Appendix 1 table sets out parking requirements for houses No change occupation in multiple occupation. properties must be provided with As set out in policy L20, parking provision for changes of sufficient parking use or extensions shall reflect the number of spaces required for the new use of the extension. Policy will not Thames Water (931213) Noted Cross reference with Policy L24, which sets out a clear No change effectively protect approach to Development Amenity Standards. residential amenity

Support policy – St Albans Civic Society Noted Support noted No change approach (1156974) acceptable. Gladman Developments Ltd.(1187201) Residential area 867312 Disagree Evidence based boundaries chosen based primarily on No change boundaries usage on the ground and local character. Cross refer L12 should be amended to include ‘Kingston Smith’ site and Aboyne Lodge School (given that no zoning category for schools near the City Centre will be made) L9 - Primarily Business Use Areas

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point (see below for list Reply (including any Changes of abbreviations) to Plan) Policy ineffective 1058251 Disagree It is one of the strategic objectives of the plan to provide No change as has been appropriate commercial development. The policy aims to overtaken by the support business uses in principle from the loss of premises change of use in Class B arising from permitted development rights of the freedoms under GPDO through Article 4 directions. GPDO More flexibility for HCC (837689) Disagree It is acknowledged that Para 81 (d) NPPF states that No change mixed uses, policies should be flexible enough to accommodate needs including housing Watford BC (1122500) not expected in the plan, allow for new flexible working practises such as live-work accommodation and to enable

required in 52552 response to changes in economic circumstances. However designated areas. this is a very selective policy for a small number of key 978427 employment areas. 872572 Define business 872572 Agree The Policies Map already refers to L9 business use areas. No change use areas on policies map Include high St Stephen Parish Agree Cross reference to Policy 17. Plan policy encourages high No change speed broadband Council(51804) speed broadband and next generation telecommunications and next level provision in new development. telecommunicatio ns in all new business / commercial developments Concerns relating St Albans Civic Society Disagree The LP aims to enhance and protect the vitality and viability No change to decentralised (1156974) of centres through a presumption against retail outside retail uses (in centres. business use areas) that could L9 concurs stating that additional retail uses will not be undermine central permitted (in primarily business use areas) unless strictly area shopping related to a primarily Class B activity. Allocate Goodman (1153774) Disagree Cross reference to Policy S2, L10 and 11. No change development site at Roehyde for An additional Green Belt employment location is not 25ha mixed required. This site is not suitable for such development and industrial and is in part an existing waste site. research facilities BRE and Rothamsted Research are established areas of (as employment employment within the Green Belt and areas designated as land or special part of the multi-site Hertfordshire Enviro-Tech Enterprise employment Zone supported by the Government. They have important location in Green functions supporting business start-ups and attracting UK

Belt) – to support and international investment. Whilst it is acknowledged the University of importance of teaching and research undertaken by the Hertfordshire University of Hertfordshire, it is not incorporated within the Herts Enterprise Zone. L10 Strategic Office Locations

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Plan policy Eskmuir Properties Ltd. Disagree The policy does not rule out mixed use; it only prioritises No change should allow (1156728) office use and development and protects existing office use. flexibility for alternative uses Waford BC (1122500) within Strategic Office Locations Shortage of Pegasus (1186098) Disagree Policy S6 ii) East Hemel requires delivery of a circa 17ha No change supply of office business park for primarily Class B1 office uses. Also part space/ additional of the multi-site Hertfordshire Enviro-Tech Enterprise Zone. space required The allocation of Article 4 directions within the strategic office locations will protect much of the remaining stock. Employment Pegasus (1186098) Disagree 2016 evidence is still highly relevant. St Albans SW No change need evidence Hertfordshire Economic Study update published February (2016) is out of 2019. Takes into account recent economic forecasts, the date changes to the commercial property stock including that lost through PD, revisit growth scenarios and assesses demand and supply. Special Pegasus (1186098) Disagree There is scope for further development in strategic office No change employment locations. BRE and Rothamsted Research are established locations and new areas of employment and will support sectors with strong provision at East growth potential. A new business park of circa 17ha for Hemel primarily office development at East Hemel Hempstead will Hempstead

Broad Location meet all quantitative need and is well located for central are remote from services and facilities. St Albans City Centre. Special Pegasus (1186098) Agree BRE and Rothamsted Research are established areas of No change employment employment within the Green Belt and areas designated as locations only part of the multi-site Hertfordshire Enviro-Tech Enterprise cater for limited/ Zone supported by the Government. They have important specialist sectors functions supporting business start-ups and attracting UK of the economy and international investment. Green technology is a business sector with strong growth potential to create jobs over the plan period. A new business park of circa 17ha for primarily office development at East Hemel Hempstead will meet all quantitative need and is well located for central services and facilities. Site at Pegasus (1186098) Disagree There is no need for additional land (cross reference No change Copsewood, St policies S 2/5/6). The proposed site is a Green Belt location. Albans should be There are no exceptional circumstances for allocation of allocated for further employment land. commercial use (offices) Allocate 1153774 Disagree Cross reference Policy S2, L9 and 11. No change development site at Roehyde for BRE and Rothamsted Research are established areas of 25ha mixed employment within the Green Belt and areas designated as industrial and part of the multi-site Hertfordshire Enviro-Tech Enterprise research facilities Zone supported by the Government. They have important (as employment functions supporting business start-ups and attracting UK land or special and international investment. employment Whilst it is acknowledged the importance of teaching and location in Green research undertaken by the University of Hertfordshire, it is

Belt) – to support not incorporated within the Herts Enterprise Zone and there University of is need for related employment land provision. The Hertfordshire proposed site is a Green Belt location. There are no exceptional circumstances for allocation of further employment land. L11 - Special Employment Locations in the Green Belt

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Redevelopment, Ramblers Association Disagree BRE and Rothamsted Research are established areas of No change intensification and (52420) development / employment within the Green Belt and are extension of built designated as part of the multi-site Hertfordshire Enviro- development at CPRE (872572) Tech Enterprise Zone. They have important functions these sites is Harpenden Society supporting business start-ups and attracting UK and unacceptable. (51870) international investment. Additional development is St Albans & District Future growth will be carefully planned and controlled in only acceptable Footpaths Society relation to Green Belt openness; through masterplanning within existing (723340) and agreements, as set out in the Policy. built ‘footprint’, possibly including redevelopment of underused or redundant temporary/ ancillary buildings such as glasshouses

Policy should British Horse Society Disagree BRE and Rothamsted Research are established areas of No change differentiate (1187597) employment within the Green Belt and areas designated as between part of the multi-site Hertfordshire Enviro-Tech Enterprise development Zone. They have important functions supporting business supported in start-ups and attracting UK and international investment. principle and that Policy indicates that for these sites, Green Belt very special which circumstances are important and may apply in relation to demonstrates the proposed masterplan / agreements. very special circumstances Policy should 975683 Disagree Policy L11 sets out a very clear approach, including No change include provisions reference to business carrying out complementary for off-shoot knowledge-based research and development activities. businesses. Residential General housing development is not supported. Some schemes within accommodation may be required as ancillary to and the Green Belt supporting research activity and essential staffing that relate to these businesses should include some provision for staffing Need for active Ramblers Association Disagree Cross reference Policy 18 which generally promotes No change travel/travel plans (52420) sustainable modes and transport infrastructure. Policy L11 and multi-user concurs with the representation in that criteria (3) seeks routes for leisure St Albans & District improved pedestrian and cycle links to Bricket Wood Station Footpaths Society (which lies North of the Common, BRE and adjacent (723340) housing). Rothamsted is well located for central area Hertfordshire County transport access. Depending on the nature of any Council (837689) redevelopment/expansion in the future, travel plans may be required – cross reference L18.

Release of land Hill Residential Disagree Cross reference to representations re Policy S2. No change at Townsend (1158064) Lane for Land at Townsend Lane does not fall within one of the (affordable) Lawes Agricultural Trust Broad Locations for development within the LP 2018. (1187615) housing would There are two planned Broad Locations for development support within Harpenden to the NE and NW of the town lying Rothamsted approx. 1.5-2 miles from Rothamsted Institute in proximity Research as and accessible via a range of active transport. employer Policy L3 facilitates a minimum of 40% affordable homes as a proportion of the overall dwelling numbers on site to include ‘social rent’, ‘affordable rent’ and ‘subsidised home ownership types’. Ambitions/needs of Rothamsted Research alone cannot determine Plan development strategy. BRE & 1186098 Agree BRE and Rothamsted Research are established areas of No change Rothamsted cater employment within the Green Belt and areas designated as for specific part of the multi-site Hertfordshire Enviro-Tech Enterprise sectors of Zone supported by the Government. They have important economy functions supporting business start-ups and attracting UK and international investment. Green technology is a business sector with strong growth potential to create jobs over the plan period. The BRE section Historic England Disagree Cross reference Policy L30 which supports conservation of No change should include (929489) heritage assets as appropriate to their significance. This criteria to afford issue will also be addressed in proposed Masterplanning protection to the and agreements Mohne Dam monument and in Rothamsted to conserve the Harpenden Conservation

Area and Rothamsted Manor Policy could be St Stephens PC (51804) Disagree General housing development is not supported. Some No change used to support accommodation may be required as ancillary to and inappropriate supporting research activity and essential staffing. housing development at these locations Allocate 1153774 Disagree Cross reference Policy L9. No change development site at Roehyde for BRE and Rothamsted Research are established areas of 25ha mixed employment within the Green Belt and areas designated as industrial and part of the multi-site Hertfordshire Enviro-Tech Enterprise research facilities Zone supported by the Government. They have important (as employment functions supporting business start-ups and attracting UK land or special and international investment. employment Whilst it is acknowledged the importance of teaching and location in Green research undertaken by the University of Hertfordshire, it is Belt) - to support not incorporated within the Herts Enterprise Zone and there University of is need for related employment land provision. Hertfordshire L12 - Centre for Retail, Services and Leisure

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Lack of evidence/ Aboyne Residents Disagree Evidence can be found online in the South West No change policy on Association (1181214) Hertfordshire retail and leisure study and its draft update changing retail 2019. market; 867312 suggestion to

include a strategy for dealing with parking and traffic as barriers to retail growth in City Centre Increase 1185717 Noted The policy supports the creation of new services that No change development of contribute positively to the vitality and viability of the area. service and leisure in ‘Key Shopping Areas’ Remove St Albans Civic Society Disagree NPPF supports positive policies such as this to support No change protection on (1156974) town centres and these limited numbers of retail frontages. retail in defined Supported also by retail evidence studies. frontages 52064 Remove Kentucky Fried Chicken Disagree The policy sets out an appropriate and balanced approach No change restriction on Hot (Great Britain) Limited which provides for consumer choice and also aims to Food Takeaways. (1050716) promote healthier lifestyles and protect residential amenity. Policy revision suggested. McDonalds Restaurants (1187475) Introduce public St Albans Civic Society Agree Refer to policy L23 which supports the provision of public art No change art to attract (1156974) in public realm. footfall Support Local Wheathampstead Parish Noted Support noted No change Centre Council (51941) Designation for Wheathampstead Out of centre London Colney Parish Noted The LP aims to enhance and protect the vitality and viability No change retail Council (52477) of centres through a presumption against retail outside development centres.

should not be at Colney Heath Parish Please refer to policy L30 for guidance on the approaches the expense of St Council (51891) taken to preserve the historic environment. Albans centre, and must ensure the unique character of the medieval city is preserved Clarification Watford Borough Council Noted Policy L12 sets out an overarching approach for retail No change needed on how (1122500) centres. Consideration for changes of use will be retail variation considered on an individual basis and depending on the and changes of individual nature of the application. use will be considered in primary and secondary retail areas Support Crest Strategic Projects Noted Existing LP approach supported No change additional retail, and Bloor Homes services and (1158079) leisure provisions in Broad Location Sites Marshalswick Sainsbury's Agree Proposal for minor adjustment noted Minor modification – Lane food store, Supermarkets Ltd Policies Map minor not just petrol (376338) amendment to district forecourt canopy, centre boundary should be included in District Centre boundary

Town centre and 867312 Disagree Evidence based boundaries chosen based primarily on No change key shopping usage on the ground and local character. Cross refer L8 area boundaries should be amended to not include Aboyne Lodge School, residential gardens, Kingston Smith site and Coupers Garage Policy does not Legal & General Disagree The LP aims to enhance and protect the vitality and viability No change comply with tests Investment Management of centres through a presumption against retail outside set out in the (1185943) centres. NPPF NPPF supports positive policies such as this to support town centres. Supported also by retail evidence studies. L13 - Attractive and Vibrant Cultural and Civic Areas Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) The Plan does Hunston Planning Ltd. Disagree Policy L13 refers to entertainment and visitor facilities. No change not refer to (1185622) tourism development 1181750 Policy does not Theatres Trust Disagree Policy L13 supports the retention of existing cultural and No change protect against (1179001) entertainment facilities. Policy L22 supports the retention of loss of existing leisure and other community buildings facilities

Additional hotel Hunston Planning Ltd. Disagree Delivery of additional and improved hotel provision is No change provision should (1185622) supported by Policy L13. be identified in or close to Harpenden There are no site- Abbey Theatre Disagree Policy L13 gives site specific proposals, amongst others are No change specific policies (1186123) St Albans City Centre, Cathedral Quarter, Harpenden which support the leisure redevelopments etc. improvement of cultural and entertainment facilities Environmental St Albans Cycle Disagree Sustainable transport is addressed in Policy L18 No change enhancements Campaign (346623) should include reference to Growth & Infrastructure schemes to Unit Hertfordshire encourage County Council (837689) sustainable forms of transport. Enhancements St Stephen Parish Disagree Requirements for Park Street Garden Village addressed in No change should be sought Council (51804) Policy S6 xi) specifically for the proposed Park Street Garden Village Proposals to Harpenden Town Noted L13 requires enhancement and management of area to No change enhance these Council (51870) encourage activities that are a focus on community activity facilities need to and pride. Detailed design of be accessible / improvements/enhancements/additional facilities will be inclusive addressed at the planning application stage.

Proposals to Harpenden Town Agree Parking requirements addressed at L20 and Appendix 1. No change enhance these Council (51870) facilities need to be provided with sufficient parking Support hotel Harpenden Town Noted Policy L14 requires a sequential approach to non-residential No change provision, but Council (51870) uses in residential areas. hotel proposals in Harpenden should only be developed near Town and Local Centres Support reference Historic England Noted Addressed in Policy L30 No change to culture and (929489) history but should reference conserving/enhan cing historic environment L14 Location of Non Residential Uses Serving Residential Areas

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point (see below for list Reply (including any Changes of abbreviations) to Plan) No strategy / lack St Albans Deanery Disagree Cross reference Policy S6, L12 and L22 which require No change of detail in Synod (1185929) community facilities and opportunities for new provision of providing for the places of worship as part of development of new Local social and Centres in Broad Locations, including in joint use pastoral needs for community buildings. the Broad

Location developments Support 347648 Noted Support noted No change additional retail units where viable outside urban locations Support provision St Stephen Parish Noted Support noted No change of small scale Council (51804) community development Facilities that St Albans Civic Society Noted Cross reference Policies 6, 23 and 29 which include No change serve (1156974) requirements for green infrastructure, public open space communities in and retention of important landscape features. Broad Locations should be ‘green’/ landscaped Community Watford Borough Council Agree A minor clarification setting out that these services ‘support Suggested minor services should (1122500) and contribute towards’ sustainable communities rather than modification say ‘support and deliver them is suggested. contribute ‘support and contribute towards’ towards’ instead of sustainable ‘deliver’ communities rather than deliver them. Policy on Sainsbury's Disagree The approach taken is consistent with national policy. Need No change sequential Supermarkets Ltd. should be considered as part of the assessment. approach should (376338) not refer to need

Policy should Hertfordshire County Disagree Cross reference Policy L18 which references sustainable No change include health Council (837689) transport and air quality. Policies are based on the draft impact and NPPF which includes sustainable transport and health. sustainable transport references L15 Leisure Uses

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Approach to Sport England (824971) Disagree The NPPF para. 92 states that planning policies should plan No change provision is too positively for community facilities such as recreational negative. facilities. Policy L15 states that high intensity uses and medium intensity type A uses will only be permitted within towns and villages. This positively directs these uses to these areas. Medium intensity Sport England (824971) Disagree The NPPF para. 92 states that planning policies should plan No change uses are positively for community facilities such as open space. acceptable in Policy L15 states that medium intensity uses type B will Green belt – normally be permitted in the Green Belt. This positively Policy should not supports these uses in these areas, but with appropriate be conditional. caveats. Support policy Ramblers Association Agree Proposal for minor adjustment noted Minor modification - to with amendment (52420) include mention of horse to recognise riding/carriage driving horse The British Horse riding/carriage Society (1187597) driving. 1157340

Policy for High St Albans School Disagree The NPPF requires an approach to these issues. Policy L15 No change Intensity Uses is (1187032) states that high intensity uses and medium intensity type A incorrect as not uses will only be permitted within towns and villages. This all non-residential 52064 positively directs these uses to these areas. activities can be provided through a sequential approach or without use of Green Belt / open land. Park Street St Stephen Parish Agree Cross reference Policies L12 and L13 which references No change Garden Village Council (51804) provision of retail and service developments. development should comply with policy on Medium Intensity uses Type A and B and also be considered for High intensity uses Leisure uses in St Albans Civic Society Noted Cross reference Policies L12, L13 and L14 which require No change Broad Locations (1156974) environmental enhancements to take place for preserving should be ‘green’ and enhancing the local setting. / landscaped Support policy Hertfordshire County Noted Cross reference to Policy L18 which addresses transport No change subject to Council (837689) strategy. reference to travel planning Support noted requirement.

L16 Mixed Use Opportunity Areas

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Mixed use, 1055738 Agree Policy L16 specifically encourages mixed use, including No change including high residential in these areas. Cross reference with L1 which density relates to density. residential, needed for Colney Fields Retail Centre and Griffiths Way Griffiths Way Albans Civic Society Agree Policy L16 specifically states retail and services should not No change retail (1156974) adversely affect town centre vitality and viability. Cross development – reference with L12 which relates to the vitality and viability should not of town centre locations. adversely affect town centre viability/ vitality Development at Historic England Noted Noted - Cross reference to policy L30 No change Griffiths Way has (929489) the ability to impact surrounding Listed Buildings.

Colney Legal & General Disagree Retail/service uses are positively supported in the policy. No change Fields/Ridgeview Investment Management should be a (1185943) preferred location for retail/service Sainsbury’s use, and mixed Supermarkets Ltd. use should not (376338) constrain this purpose. Retail planning consent on Ridgeview Lodge should be recognised. Promote Policy Hertsmere Borough Noted There has been and will be ongoing joint working with No change L16 (ref Colney Council (51934) neighbouring local authorities including Hertsmere and the Fields Retail South West Herts Group. Centre) through joint working

Colney Fields St Albans Civic Society Noted Policy L16 states retail and services should not adversely No change Retail Centre – (1156974) affect town centre vitality and viability. Cross reference with no further L12 which relates to the vitality and viability of town centre expansion of 1055738 locations. retail space should be permitted / should not adversely affect town centre Ridgeview, 1055738 Disagree Mixed use, including residential, encouraged in L16. No change London Colney / Colney Fields Retail Centre –

continue residential usage Support the St Albans Civic Society Noted Support noted No change development at (1156974) CCOS. CCOS Historic England Noted Cross reference to Policy L30 which sets requirements for No change development has (929489) new developments in conservation areas, which must the ability to respond to the character, appearance and local impact on distinctiveness of the area. Conservation Area. L17 Infrastructure Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Reference to Harpenden Town Noted Support noted No change utilities Council (51870) infrastructure and St Stephen Parish broadband are Council (51804) supported High speed St Stephen Parish Noted Support noted No change broadband is Council (51804) essential for new development Providers will not Legal and General Disagree This matter can be properly detailed through the No change commit resources (1051022) masterplanning work. to confirm high CEG (1158030) speed connections until outline planning permission is obtained. Should

be considered rather than addressed.

There is St Albans Civic Society Disagree New infrastructure will be provided in association with new No change inadequate (1156974) development. Further details can be found in IDP updates / infrastructure to master planning work / planning application process. support new Verulam Residents development in Association the district and in (1185823) particular at Bricket Wood Residents Broad Locations Association (1186066) & locality. There is an existing STACC (346623) infrastructure 789007 deficit / existing infrastructure is 759883 already under strain or 863632 overstretched 867587 such as roads, traffic, parking, 871923 cycle network, schools, NHS etc 1187590 1185714 Specific locations include: 1048449  District 1056580  Broad Locations and 1152471 locality  Hemel 1158536 Hempstead 1182733

 Other 1182793 locations 1183112 1184271 1184378 1184569 1184784 1185483 1185583 1185821 1185935 1186129 There is limited Redbourn Parish Council Disagree Evidence on development strategy / site selection is No change evidence to (759908) available in full. support identification of Evidence is available and landowner/developer teams have broad locations. confirmed deliverability of Broad Location related Robustness of infrastructure. strategy is under question. IDP / Redbourn Parish Council Disagree Work on the infrastructure evidence base has been ongoing IDP will be updated on an infrastructure (759908) and IDP updates will be made as required to reflect the ongoing basis. planning is latest position. Hertfordshire County inadequate / Council (837689) contrary to NPPF / not up to date. It Harpenden Green Belt is based on lower Association (866541) housing allocation / does not relate

to the scale of Aboyne Residents development Association (1181214) being proposed. Leverstock Green Village More evidence Association (1185907) required / Update required. 334023 759883 1185704 Need for update Gladman (1187201) Partly Evidence is available and landowner/developer teams have Updated viability report to to demonstrate agree confirmed deliverability of Broad Location related be added to evidence on deliverability / infrastructure. website. viability of the LP. Unclear whether Updated viability report has been prepared and will be BL & planning added to the website. policy are viable. NPPF para 67 & NPPG requirement. Add ref to LTP4 & Hertfordshire County Agree IDP update to include ref to LTP4 & GTPs IDP will be updated on an GTPs in IDP. Council (837689) ongoing basis. Some transport Hertfordshire County Agree IDP update to include ref to s278 works IDP will be updated on an mitigation may be Council (837689) ongoing basis. carried out as S278 works, add ref in IDP. Robust evidence Harpenden Town Noted IDP includes reference to utilities network. Further details No change of capacity within Council (51870) can be found in IDP updates / master planning work / the existing planning application process utilities network is required. An independent 759883 Disagree HSE safety guidance is available and HSE have been No change report on the consulted by landowners. This matter can be properly impact of building

within the shadow detailed through the masterplanning work/ planning of the Buncefield application process oil depot is required. GB Review Redbourn Parish Council Disagree Evidence on development strategy / site selection is No change should be (759908) available in full. updated to demonstrate it is appropriate to consider development at NHH New garden Hertsmere Borough Noted It is one of a number of different options under consideration No change village in Council (1182733) by Hertsmere. SADC has raised concerns about potential Hertsmere is impacts. Ongoing consideration under Duty To Cooperate under and joint working arrangements. consideration by Hertsmere. Potential infrastructure needs for Hertsmere garden village A more radical 1185460 Disagree LP policy together with HCC’s LTP4 provides an appropriate No change and ambitious overarching strategy for transport. overarching transport strategy should be developed to prevent ‘the residual cumulative impacts on the road network becoming severe’

IDS does not plan Harpenden Green Belt Disagree IDS includes a column for ’other non-BL development’ No change for growth outside Association (866541) BLs. IDS is missing St Albans Cycle Disagree The IDS is included at appendix 4 of the LP. No change from list of Campaign (346623) supporting documents. IDS does not Hertfordshire County Agree The IDS is designed to provide a one page summary No change have a detailed Council (837689) overview. Master planning and IDP updates should provide list of all more details. Legal and General infrastructure (1051022) schemes. CEG (1158030) Masterplanning Hallam Land Noted IDS explanatory notes deals with this. No change will inform the Management (1185998) IDS The most Aboyne Residents Noted Work on the infrastructure evidence base has been ongoing No change significant Association (1181214) and IDP updates will reflect the latest position. infrastructure issues for BLs relate to transport and schools For BL at NW Legal and General Noted This matter can be properly detailed through the No change Harpenden, (1051022) masterplanning work / planning application onsite health CEG (1158030) facility is shown on IDS if NHS do not have existing GP capacity nearby; but it is not listed at S6viii. Requirement should be tested

against capacity as part of master planning. For BL at Adrian Irving (Trustee) Disagree This matter can be properly detailed through the No change Chiswell Green, and Alban Developments masterplanning work/ planning application IDS should be Limited (1156368) reviewed to remove ref to healthcare floorspace. It is too small and not necessary in view of existing healthcare capacity in the area. At EHHS option West Hertfordshire Disagree In Press Release Oct 2018 WHHT indicated that “The No change for one new Hospitals NHS Trust proposal to develop planned care on the St Albans and hospital of c7ha (1183618) Hemel Hempstead hospital sites as set out in the original to serve SOC currently remains our preferred way forward.” population of West Herts. On St Albans hospital site is considered in principle to be the completion of the best location to serve the SADC population. It is also new facility in centrally located within the West Herts area. 2024/26, closure No substantive evidence has been submitted to justify a of St Albans deliverable alternative in a sequentially preferable location Hospital and HH to serve SADC population. hospital would release land for other uses, although site disposals may occur before this date.

The latest Leverstock Green Village Disagree There has been and continues to be ongoing engagement No change position regarding Association (1185907) with WHHT. WHHT hospital has not been taken into account and evidence needs to be updated. Hospital provision Wheathampstead Parish Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an should be Council (51941) and IDP updates will reflect the latest position. ongoing basis. addressed HVCCG provided Herts Valleys Clinical Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an detailed Commissioning Group and IDP updates will reflect the latest position. ongoing basis. comments about (1177790, 1183617) capacity of GPs to absorb some of the proposed development and where there is a shortfall of space. New development expected to make a proportionate contribution towards additional facilities. There are Herts Valleys Clinical Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an possible plans for Commissioning Group and IDP updates will reflect the latest position. ongoing basis. a community hub (1177790, 1183617) in St Albans and ongoing work to look at redeveloping Harpenden

Memorial Hospital into a fit for purpose community site. HVCCG formula is set out to calculate the cost per dwelling of mitigating the impact that additional growth brings. Should include Environment Agency Disagree Already covered by ‘green’ infrastructure No change reference to (1147557) environmental infrastructure to help to meet NPPF paragraph 149 IDP should Environment Agency Noted The updated SFRA report has been added to the website. No change include an (1147557) updated Flood Risk Assessment IDP should refer Environment Agency Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an to Thames Basin (1147557) and IDP updates will reflect the latest position. ongoing basis. Management Plan 2015 under strategic green infrastructure - river corridors. Policy should Thames Water (931213) Disagree Policies L23 and L29 address drainage and flood risk. No change include additional Suggested text would be appropriate as planning conditions references to or informatives, rather than policy. waste water and

planning conditions.

Infrastructure St Stephen Parish Noted Approach is consistent with national policy. No change must be Council (51804) supported by S106 & CIL Policy should Crown Estate (51946) Disagree Approach is consistent with national policy. No change reference Hill Residential planning (1158064) obligations and be consistent with Crest Strategic Projects, NPPF Bloor Homes, and Mr Scott (1158079) Hallam Land Management (1185998) It is not lawful to Hill Residential Disagree Approach is consistent with national policy. This matter can No change remedy existing (1158064) be properly detailed through the masterplanning work and infrastructure planning applications. Hallam Land deficits / Management (1185998) Clarification required for contributions sought which go beyond mitigating the impact of development. Need to introduce Crown Estate (51946) Disagree Approach is consistent with national policy. This matter can No change a proportional be properly detailed through the masterplanning work. approach to infrastructure improvements over and above

those required to make development acceptable Support policy / Hertfordshire County Noted Support noted No change support delivery Council (837689) of infrastructure Environment Agency (1147557) Crest Strategic Projects and Bloor Homes (1158079) Hunston Planning Limited (1185630) Hallam Land Management (1185998) Department for Education (1186955) Vehicle charging St Stephen Parish Partly Policies L18 and L20 require consideration of technology No change points are Council (51804) Agree and infrastructure for sustainable travel. essential for new development For Wheathampstead Parish Noted Policy L18 requires consideration of bus related measures. No change Wheathampstead Council (51941) village transport connections are important. Good bus services required. The delivery of St Albans School Disagree Appropriate infrastructure should be provided where No change social (1187032) required in association with new development. infrastructure, 52064 e.g. community

leisure & education, should not be burdened by infrastructure contributions. Concern that Aurora Properties Disagree Policy L17 relates to a wide range of infrastructure and No change policy relates to Limited (1151817) related facilities. This includes community facilities. infrastructure and not community facilities. St Albans District Greater London Authority Noted Policy L17 recognises need for strategic infrastructure. No change is within new (1157729) London Plan strategic infrastructure priority ' Midland and west coast mainline..' policy SD3 & fig 2.15 Lack of clarity in Leverstock Green Village Noted Work on SADC infrastructure evidence base has been IDP will be updated on an the Dacorum IDP Association (1185907) ongoing and IDP updates will reflect the latest position. ongoing basis. in relation to Dacorum are at an earlier stage in Plan making. increased Appropriate liaison is ongoing. quantum of growth, joint area action plan & cross boundary working. Underground St Stephen PC (51804) Noted Policy L17 deals with this. No change ducting must be accessible without disturbance to road surfaces

New 347648 Disagree New infrastructure must be provided within an appropriate IDP will be updated on an infrastructure timescale. ongoing basis. must be provided Work on SADC infrastructure evidence base has been before or at the ongoing and IDP updates and Masterplanning will reflect the same time as latest position. development e.g. new schools, healthcare facilities Concern that the 1184750 Disagree Work on SADC infrastructure evidence base has been IDP will be updated on an increase in traffic ongoing and IDP updates will reflect the latest position. ongoing basis. from development will provide the opportunity for government to introduce J8A at Redbourn L18 Transport Strategy Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Support policy or Legal and General Noted Support noted No change general thrust of (1051022) policy Crest Strategic Projects and Bloor Homes (1158079) The Overall Hertfordshire County Noted This matter can be properly detailed through the No change Approach outlined in Council (837689) Masterplanning / planning application / EIA process, with Policy L18 supports appropriate consultation. the aims of LTP4. However, HCC as Highways Authority would like to see

strong links to the application of the transport user hierarchy in the development of transport mitigations. Plan should reduce 1185967 Noted Policy L18 seeks to support this approach. No change car dependency and car use. Benefits will be improved public health through active travel increase and air pollution decrease and reduced congestion Modal shift should Harpenden Town Noted Policy L18 seeks a balanced approach to supporting No change be encouraged by Council (51870) sustainable travel, while acknowledging the reality of high making sustainable levels of car ownership. Aspects of this matter can be travel more properly detailed through the Masterplanning / planning accessible not by application / EIA process, with appropriate consultation. making driving less accessible Expectation is 867312 Disagree Approach is consistent with national policy. No change unrealistic for modal change to buses and bicycles There is a lack of Harpenden Green Disagree Site selection is firmly based on comprehensive GB work No change evidence to support Belt Association which identified the allocated Broad Locations. claim that selection (866541) of BLs are based on Opportunities for sustainable travel formed part of that site opportunities for 1185775 selection work and is available online. sustainable travel. 1185704

NPPF para 138 Aurora Properties Noted Site selection is firmly based on comprehensive GB work No change requires first Limited (1151817) which identified the allocated Broad Locations. consideration to sites well served by Opportunities for sustainable travel formed part of that site public transport. selection work and is available online. Better transport Wheathampstead Agreed Supported by approach taken in L18. Work on the transport IDP will be updated on an through district is Parish Council infrastructure evidence base has been ongoing and IDP ongoing basis. required for road / (51941) updates will reflect the latest position. cycle / footway Bullet 4 - Add ref to Legal and General Disagree Policy L20 and appendix 1 deals with parking. No change “Residential (1051022) development will provide a reasonable level of parking for residents, in order to protect amenity for existing residents.” Bullet 4 add 'at non- Legal and General Disagree Policy L20 and appendix 1 deals with parking. No change residential (1051022) development' CEG (1158030) Bullet 6 - employers Hertfordshire County Noted Policy L18 already deals appropriately with travel plans. No change should be Council (837689) encouraged to produce travel plans which encourage sustainable modes of transport Bullet 8 - add STACC (346623) Noted Minor modification for clarification Minor modification to add “secure” to “cycle “secure” parking in new developments…"

Bullet 12 - should Hertfordshire County Disagree There are clear standards in Plan policy which relates to all No change refer to all roads and Council (837689) roads. not just major roads. Add new bullet - STACC (346623) Noted Minor modification for clarification Minor modification - access by cycle access by cycle “provision of “provision of appropriate appropriate amenities and community amenities and facilities easily accessible community facilities on foot to major new easily accessible on development sites” foot to major new development sites” A more radical and 1185460 Disagree Work on the transport infrastructure evidence base has No change ambitious been ongoing and IDP updates will reflect the latest overarching position. transport strategy should be developed A transport evidence workplan has been agreed with HCC. to prevent the residual cumulative impacts on the road network Main Transport Crown Estate (51946) Disagree This matter can be properly detailed through the No change Schemes (MTS) Masterplanning / planning application/ EIA process, with appropriate consultation. Sentence 1 - add ref to 'the funding of the main transport schemes will be agreed through the planning application process and accord with CIL regs.' Support policy / British Horse Society Noted Support Noted No change support overall (1187597) approach

Hill Residential (1158064) Para 1 - delete ref to Hertfordshire County Noted Minor modification for clarification Minor modification - 'utility and leisure' Council (837689) delete ref to 'utility and before 'trips' leisure' before 'trips' Para 1, replace British Horse Society Disagree There are clear standards in Plan policy. Approach is No change 'alongside primary (1187597) consistent with national policy. roads’ with 'alongside roads Footpaths Secretary likely to have high Ramblers Association traffic volumes'. (52420) 1157340 Para 2 - Replace Crown Estate (51946) Disagree There are clear proposals in Plan policy. Approach is No change existing wording with consistent with national policy. new. “(2) a new route between the intersection of the B487 (Hemel Hempstead Road / Redbourn Road) and the Nickey Line, running south along the East Hemel Hempstead site spine road to the A4147 in the south. This will be funded by Broad Locations S6(i), (ii) and (iii). There may also be potential to extend this route further afield to St Albans

and Redbourn, subject to detailed assessment”. Extension of green London Colney Parish Noted Policy L29 deals with this. No change ring required to Council (52477) provide cycle route for London Colney children to secondary school Extension to green Wheathampstead Noted Support noted – also Policy L29 deals with this. No change ring in villages Parish Council welcomed (51941) RoWIP is welcomed Wheathampstead Noted Support Noted No change and links to health & Parish Council wellbeing. (51941) Improvement to Hertfordshire County Noted Work on the transport infrastructure evidence base has IDP will be updated on an inter-urban cycling Council (837689) been ongoing and IDP updates will reflect the latest ongoing basis. routes should be position. identified in the IDP Add ref to secure 1048449 Noted Policy L18 deals with this. See also minor modification No change cycle parking. above. Priority should be 1048449 Noted Both are supported in L18. Work on the transport No change given to urban infrastructure evidence base has been ongoing and IDP cycling routes, rather updates will reflect the latest position. than inter-urban routes. A commitment to STACC (346623) Noted Approach is consistent with national policy and regulations. No change maintaining cycle paths is required. 1048449 Lack of coherent 1048449 Disagree Work on the transport infrastructure evidence base has No change cycle network in the been ongoing and IDP updates will reflect the latest District should be position. acknowledged.

Better defined cycle St Stephens Parish Disagree Work on the transport infrastructure evidence base has No change routes required Council (51804) been ongoing and IDP updates will reflect the latest position. Cycle routes should Harpenden Town Noted Both cycling and free flow of traffic are supported in L18. IDP will be updated on an contribute to free Council (51870) Work on the transport infrastructure evidence base has ongoing basis. flow of traffic rather been ongoing and IDP updates will reflect the latest than have a negative position. impact Add ref to horse Footpaths Disagree Not necessary here. Approach is consistent with national No change carriage drivers. Coordinator St Albans policy. & District Footpaths Society (723340) Preferable for horse Hertfordshire County Disagree There are clear proposals in Plan policy. Approach is No change riders to be treated Council (837689) consistent with national policy. separate to cycling & walking. Preparation and 1048449 Disagree Overall support for cycling and walking in L18. LCWIPs not No change implementation of within Plan remit. Local Cycling and Walking Infrastructure Plans (LCWIPs) should be included. Additional bus Hertfordshire County Noted Overall support for bus provision in L18 and S6. This matter No change routes in all BLs will Council (837689) can be properly detailed through the masterplanning / be essential and planning application / EIA process, with appropriate must be included in consultation. travel plans. Improved roads will Colney Heath Parish Noted Overall support for bus provision in L18 No change result in more Council (51891) reliable bus services & help mode shift London Colney Parish Council (52477)

More buses required St Albans Labour Noted Overall support for bus provision in L18 No change / Improved bus Group (1183933) service welcomed. For eg to connect Wheathampstead villages & urban Parish Council centres. (51941) St Stephens Parish Council (51804) 1056580 Consider bus hubs Colney Heath Parish Noted Overall support for bus provision in L18. No change which allows Council (51891) villagers to cycle or drive to a local site for access to bus services Reliance on buses is Aboyne Residents Noted Overall support for bus provision in L18. National approach No change not credible for e.g Association to bus funding not within planning remit. funding cutbacks in (1181214) recent years. 1152471 Welcome Abbey Flyer Users Noted Support Noted No change improvement to Group (1156861) Abbey Line. More detail needed. St Albans Labour Group (1183933) St Stephens Parish Council (51804) 1185775 867068

Agreement is 867068 Noted Work on the transport infrastructure evidence base has No change required from other been ongoing and IDP updates will reflect the latest parties to make position. improvements. Abfly have Abbey Flyer Users Noted Requirement for improved Abbey Line service in S6. No change commissioned a Group (1156861) detailed feasibility study from independent expert railway consultants. Part one of the study indicates that the capital costs of a passing loop will be considerably less than previous estimates and that there is a sound business case for investment in upgrading the Abbey Line. London 1181750 Noted Requirement for improved Abbey Line service in S6. Work No change Northwestern have on the transport infrastructure evidence base has been plans to upgrade the ongoing and IDP updates will reflect the latest position. Abbey Line which are different to policy. All mention of rail 1055738 Disagree Requirement for improved Abbey Line service in S6. Work No change links to be explored- on the transport infrastructure evidence base has been abbey line or ongoing and IDP updates will reflect the latest position. midland mainline should be excluded.

By reinstating the 1186081 Noted Work on the transport infrastructure evidence base has No change link to the Abbey line been ongoing and IDP updates will reflect the latest freight trains would position. have additional access to the west coast main line and midland main line. This is not a Network Rail Noted Noted requirements for feasibility. Long lead-in time No change committed rail (1184616) acknowledged in timeline for delivery. No evidence industry scheme and supplied to support closing of Cotton Mill Lane crossing. delivery would be Work on the transport infrastructure evidence base has subject to a been ongoing and IDP updates will reflect the latest feasibility study and position. funding, together with all necessary consents. In addition we cannot support any increase in frequency along the Abbey line unless the level crossing at Cotton Mill Lane is closed. Decked car park at Hertfordshire County Disagree Policy L18 seeks a balanced approach to supporting No change Harpenden Station – Council (837689) sustainable travel, while acknowledging the reality of high Delete reference / levels of car ownership. Priority should be STACC(346623) given to improving accessibility by sustainable modes. Improved St Albans Labour Noted Support noted No change accessibility to Group (1183933) Harpenden station by public transport is welcomed

Better cycle access 1185775 Noted Supported by approach in L18. No change and storage is required for Harpenden Railway Station. Query if Thameslink St Albans Labour Noted Additional planned rail capacity has been noted. Work on No change trains will be unable Group (1183933) the transport infrastructure evidence base has been ongoing to cope with extra and IDP updates will reflect the latest position. commuters from new 1185714 development plus impact of railfreight scheme. A new London 1183210 Noted Sustainable rail transport improvements sought under S6 xi. No change Colney station would be an aspirational and realistic improvement and meet sustainability needs Detailed traffic Hertfordshire County Noted Required by L18 No change mitigation measures Council (837689) for Broad Locations should be included in the Transport Assessment accompanying any planning application. Due to the lack of Hertfordshire County Noted A transport evidence workplan has been agreed with HCC. No change Modelling work it is Council (837689) unclear at the current time what highway improvements will

be required for the Local Plan. Extra highway Hertfordshire County Noted Work on the transport infrastructure evidence base has No change capacity is not Council (837689) been ongoing and IDP updates will reflect the latest supported unless position. required to enable new development. A transport evidence workplan has been agreed with HCC. Improvement to road Colney Heath Parish Noted Work on the transport infrastructure evidence base has No change infrastructure is Council (51891) been ongoing and IDP updates will reflect the latest required in advance position. of new development Junction Hertfordshire County Noted Work on the transport infrastructure evidence base has No change improvement Council (837689) been ongoing and IDP updates will reflect the latest required. Junction position. re-design should STACC (346623) A transport evidence workplan has been agreed with HCC. explore St Albans Labour improvement for Group (1183933) safety of cyclists and pedestrians and 1183210 increased bus priority. Junction Redbourn Parish Noted This matter can be properly detailed through the No change Improvement will Council (759908) Masterplanning/ planning application / EIA process, with increase traffic appropriate consultation. Para 4 - add ref to Hertfordshire County Disagree Policy L20 deals with this No change new residential and Council (837689) non-residential developments Provision of St Albans Civic Disagree Policy L18 & L20 deals with this No change recharge points in St Society (1156974) Albans needs further investigation to deliver extra provision.

A ring road for the 1181750 Disagree Work on the transport infrastructure evidence base has No change city with been ongoing and IDP updates will reflect the latest infrastructure position. improvements at bottlenecks is A transport evidence workplan has been agreed with HCC. wanted. It would traffic calm the entire city at a budget cost. A414 upgrade needs 1186081 Disagree Work on the transport infrastructure evidence base has No change to be completed as a been ongoing and IDP updates will reflect the latest matter of urgency. position. The proposed 'hamburger' style A transport evidence workplan has been agreed with HCC. roundabout at London Colney North needs to be an up and over as does Park Street roundabout. A414 proposals will 1186046 Noted Work on the transport infrastructure evidence base has No change impact on the other been ongoing and IDP updates will reflect the latest routes crossing the position. A414 in St Albans area in London A transport evidence workplan has been agreed with HCC. Colney and Colney Heath Welcome policy STACC (346623) Noted Support Noted No change Add text “Residential CEG (1158030) Disagree Policy L20 & appendix 1 provides clear standards. No change development will provide a reasonable level of parking for residents, in order to

protect amenity for existing residents.” It is considered that Hertfordshire County Disagree Policy L20 & appendix 1 deals with this. No change support for car- Council (837689) share/shared mobility options could be mentioned. More park and ride Colney Heath Parish Disagree Work on the transport infrastructure evidence base has No change is required Council (51891) been ongoing and IDP updates will reflect the latest position. Parking impact 867312 Disagree Policy L20 & appendix 1 provides clear standards. No change assessment for town centre and transport hubs required Increased parking is Aboyne Residents Disagree Policy L20 & appendix 1 provides clear standards. No change needed for eg at Association Harpenden, St (1181214) Albans, local roads. Harpenden Town Council (51870) Verulam Residents Association (1185823) Policies on car Hertfordshire County Noted Policy L18 seeks a balanced approach to supporting No change parking provision Council (837689) sustainable travel, while acknowledging the reality of high and management levels of car ownership. can have a direct impact on the uptake of sustainable modes and need to be considered in a comprehensive manner, looking at

both on and off street facilities, pricing and availability. HCC would prefer Hertfordshire County Noted This matter can be properly detailed through the No change that Travel Plans are Council (837689) Masterplanning / planning application / EIA process, with sought through the appropriate consultation. Section 106 process which enables the county council to seek a monitoring fee. it is unduly RF Sinclair & Sons Disagree Policy L18 sets out a clear approach, supported by the No change excessive to expect (1058251) NPPF travel plans and air quality statements 52064 from all development of 10 + dwellings To comply with Crest Strategic Disagree Policy L18 sets out a clear approach which is consistent No change NPPF para 111 Projects and Bloor with national policy. amend policy to say Homes (1158079) “All developments that will generate significant amounts of movement should be required to provide a Travel Plan”. Travel plan Hertfordshire County Noted This matter can be properly detailed through the No change requirements should Council (837689) Masterplanning / planning application / EIA process, with be in line with the appropriate consultation. latest HCC guidance. School travel plans 1181750 Disagree Policy L18 sets out a clear approach No change should apply to all

schools, new and existing; public and private. There is no Redbourn Parish Noted Work on the transport infrastructure evidence base has Update to IDP adequate, up to date Council (759908) been ongoing and IDP updates will reflect the latest evidence about position. traffic movement Aboyne Residents and traffic Association A transport evidence workplan has been agreed with HCC. (1181214) congestion. Current Some matters can be properly detailed through the evidence relates to a Leverstock Green Masterplanning / planning application / EIA process, with lower level of growth Village appropriate consultation. than in the LP. IDP Association(1185907) is out of date / COMET does not North Herts District cover all relevant Council (1185674) roads. Luton Borough More evidence Council (861967) required for specific locations such as: Welwyn Hatfield  Broad Borough Council Locations & (52397) locality  St Albans 867312 central area Central Bedfordshire  A414 corridor Council (861963)  Roads close to Luton eg North Herts District M1, A1081, Council (1185674) B653, Bricket Wood A5183/B4540 Residents Association  Other eg (1186066) district wide

Harpenden Green Belt Association (866541) 334023 1185714 1144419 Assurance required London Colney Parish Noted No ‘showstoppers’ identified. Work on the transport No change prior to submission Council (52477) infrastructure evidence base has been ongoing and IDP that transport updates will reflect the latest position. modelling will not flag up significant A transport evidence workplan has been agreed with HCC. issues. Some nearby Luton Borough Noted Addressed on an ongoing basis through DC arrangements. No change councils would like a Council (861967) better understanding of potential cross- Central Bedfordshire boundary issues. Eg Council (861963) Central Beds, N North Herts District Herts, Luton Council (1185674)

Transport evidence Crest Strategic Noted Work on the transport infrastructure evidence base has No change for some BLs shows Projects and Bloor been ongoing and IDP updates will reflect the latest that there are no Homes (1158079) position. highway constraints preventing Legal and General A transport evidence workplan has been agreed with HCC. (1051022) development. Some matters can be properly detailed through the Adrian Irving and masterplanning / planning application / EIA process, with Alban Development appropriate consultation. Ltd (1156368)

There is inadequate Redbourn Parish Disagree Work on the transport infrastructure evidence base has No change transport Council (759908) been ongoing and IDP updates will reflect the latest infrastructure to position. support new Ellenbrook Area development in the Residents Association A transport evidence workplan has been agreed with HCC. Committee (1185802) district and in Some matters can be properly detailed through the particular at Broad Colney Heath Parish masterplanning / planning application / EIA process, with Locations & locality. Council (51891) appropriate consultation. There is an existing infrastructure deficit / Wheathampstead existing Parish Council infrastructure is (51941) already under strain St Albans Labour or overstretched; Group (1183933) such as roads; parking; bus; rail; 1184750 cycle network. 1185460 Specific locations include: 1185704 1183210

 Broad Locations 1185744 and locality 1184864  Colney Heath 1187008  Southern part of 1184839 St Albans, in particular around 1158536 King Harry roundabout and 863091 King Harry Lane 1184271  Proposed new 1182480 school at London Road 1185244  Other eg district 1185478 wide 1185481 1185482 1185479 1185633 1185640 871923 1182697 1185469 1184378 347648 867587

1184567 1183112 1055683 840795 1184569 1153741 1187590 1185714 1182793 1182518 1185971 760045 1185821 1185728 Housing at PSGV DB Cargo (1184888) Noted Site selection is firmly based on comprehensive GB work No change will frustrate delivery which identified the allocated Broad Locations. of an important part Freight on Rail of the national SFRI (1187503) Concentrating development in larger sites that can create network, contrary to new communities and deliver infrastructure is a key part of Network Rail the development strategy. government policy (1184616) objectives. The main site owner has promoted the site as available and deliverable for housing. Considerations have taken into account the existing planning permission for an alternative use and other relevant factors.

Radlett is v Freight on Rail Noted Site selection is firmly based on comprehensive GB work No change important to help (1187503) which identified the allocated Broad Locations. improve access to rail services in GB Railfreight Concentrating development in larger sites that can create London and the (1187613) new communities and deliver infrastructure is a key part of wider Southeast. the development strategy. Radlett location is The main site owner has promoted the site as available and exceptionally good deliverable for housing. Considerations have taken into for rail freight. It is account the existing planning permission for an alternative able to serve a large use and other relevant factors. proportion of customers in the region. If Radlett is not delivered it will be a major setback to the industry. Opportunities to DB Cargo (1184888) Noted Site selection is firmly based on comprehensive GB work No change develop SRFI in which identified the allocated Broad Locations. southern England GB Railfreight are very few. (1187613) Concentrating development in larger sites that can create new communities and deliver infrastructure is a key part of the development strategy. The main site owner has promoted the site as available and deliverable for housing. Considerations have taken into account the existing planning permission for an alternative use and other relevant factors. SRFI is important to DB Cargo (1184888) Noted Site selection is firmly based on comprehensive GB work No change secure modal shift which identified the allocated Broad Locations. for freight to be Freight on Rail transported by rail (1187503) Concentrating development in larger sites that can create rather than road. new communities and deliver infrastructure is a key part of GB Railfreight the development strategy. Modal shift cannot (1187613)

be achieved without The main site owner has promoted the site as available and SRFIs. deliverable for housing. Considerations have taken into The likely saving in account the existing planning permission for an alternative road miles is use and other relevant factors. immense. A daily service would avoid 18 million truck miles. SRFI is supported. DB Cargo (1184888) Noted Support Noted. Site selection is firmly based on No change comprehensive GB work which identified the allocated Freight on Rail Broad Locations. (1187503) Concentrating development in larger sites that can create GB Railfreight new communities and deliver infrastructure is a key part of (1187613) the development strategy. Network Rail The main site owner has promoted the site as available and (1184616) deliverable for housing. Considerations have taken into account the existing planning permission for an alternative use and other relevant factors. 1. Support policy Harpenden Town Noted Support Noted No change /policy sound Council (51870) Hunston (1185630) St Stephens Parish Council (51804) STACC (346623) Central Beds (861963) Policy is not clearly CEG (1158030) Disagree Policy L18 sets out a clear approach No change written. Formatting and wording should LRM Planning Limited obo Hallam Land

be amended to Management distinguish between (1185998) the formal policy and the reasoned justification. Policy is difficult to Hallam Land Disagree Policy L18 sets out a clear approach No change understand in Management relation to BLs. Limited(1185998) For Nickey Line, Friends of Nickey Line Noted The Nickey Line footpath / cycleway is an important IDP will be updated on an action is required to (1184312) landscape, commuting and recreational route feature. As it ongoing basis. improve safety at will need to be crossed there will inevitably be some crossing. Eg regular localised adverse impacts. There will also be considerable maintenance of opportunities for enhancement. Masterplanning will consider verge; speed limits damage mitigation, integration and maximising opportunities on approaching within and beyond the development. roads; crossing upgrade; reposition Some matters can be properly detailed through the of crossing at masterplanning / planning application / EIA process, with roundabout. appropriate consultation. Some elements are not within planning remit. Greater housing 1158258 Disagree Site selection is firmly based on comprehensive GB work No change density should be which identified the allocated Broad Locations. provided near railway stations and Concentrating development in larger sites that can create bus routes. new communities and deliver infrastructure is a key part of the development strategy. Napsbury park has Countrywide Planning Noted Site selection is firmly based on comprehensive GB work No change access to great (1186783) which identified the allocated Broad Locations. network of major roads & is 10 mins Concentrating development in larger sites that can create drive from mainline new communities and deliver infrastructure is a key part of stations. the development strategy.

Planner should read 1187504 Noted Issue acknowledged. Policy L18 seeks a balanced No change RAC report BBC approach to supporting sustainable travel, while News - Young acknowledging the reality of high levels of car ownership. couples 'trapped in car dependency' We would like to see STACC (346623) Noted Policy L18 sets out a clear approach No change more car clubs.

Lower Luton Road is Wheathampstead Noted Work on the transport infrastructure evidence base has No change unsafe for journey Parish Council been ongoing and IDP updates will reflect the latest route to school (51941) position. A transport evidence workplan has been agreed with HCC. Some matters can be properly detailed through the masterplanning / planning application / EIA process, with appropriate consultation. Transport Wheathampstead Noted Policy L18 sets out a clear approach No change connections are Parish Council important to villages (51941) eg Wheathampstead Roads and 1185945 Noted Work on the transport infrastructure evidence base has No change Infrastructure should been ongoing and IDP updates will reflect the latest be delivered before position. or at the same time as new A transport evidence workplan has been agreed with HCC. developments. Some matters can be properly detailed through the masterplanning / planning application / EIA process, with appropriate consultation. Enforcement should 1185945 Noted Not within planning remit No change be used if HGV's stray from primary roads.

At EHH, rise in air 1144419 Noted Issue and approach identified in S6 No change pollution will impact people who would potentially be living and working next to a motorway. Before deciding on 1185704 Noted LP required to be based on proportionate evidence. Not all No change quantity and detailed issues will reasonably be fully worked through at timescales for this stage. Work on the transport infrastructure evidence development - all base has been ongoing and IDP updates will reflect the transport issues latest position. should be addressed. A transport evidence workplan has been agreed with HCC. Some matters can be properly detailed through the masterplanning / planning application / EIA process, with appropriate consultation. Opportunities have 1153802 Disagree Policy L18 sets out a clear approach No change been missed to promote sustainable travel. Suggested additions to policy are listed in full response. There are no traffic 863632 Disagree Policy L18, L19, L20, Appendix 1 and IDP set out a clear No change considerations and approach No parking improvements

L19 - Highways / Access Considerations for New Development

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Plan is not based Redbourn Parish Council Disagree Work on the infrastructure evidence base has been ongoing IDP will be updated on an on up to date & (759908) and IDP updates will reflect the latest position. ongoing basis. relevant evidence Harpenden Society about transport A transport evidence workplan has been agreed with HCC. (1156761) movement and traffic congestion. Aboyne Residents Association (1181214) Leverstock Green Village Association (1185907) Scale of growth Leverstock Green Village Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an and distribution of Association (1185907) and IDP updates will reflect the latest position. ongoing basis. development must be properly A transport evidence workplan has been agreed with HCC. assessed and considered in transport terms. Provision for St Albans School Disagree Policies L19 sets out a clear approach No change setting (1187032) down/picking up in a safe and acceptable manner can be a challenge. Eg St Albans School. Aspects of policy needs to be reworked.

More clarity St Albans Civic Society Disagree Policies L19 sets out a clear approach No change required including (1156974) implementation and enforcement. Eg school coaches in George St & Fishpool Street For education STACC (346623) Disagree Policies L19 sets out a clear approach No change facilities and day nursery/creches, setting down/picking up should be minimum of 300m from entrance. Illegal parking in the vicinity of these uses must be enforced. Support policy Footpaths Secretary Noted Support noted No change Ramblers Association (52420) Criteria (i) add ref British Horse Society Disagree Policies L19 sets out a clear approach, including “horse- No change to 'carriage (1187597) riders and other non-motorised users” drivers' For para 3, add Footpaths Secretary Disagree Policies L19 sets out a clear approach No change ref to horse rider Ramblers Association and carriage (52420) drivers. / Add more refs to British Horse Society horse rider and (1187597) carriage drivers. 1157340

For non- British Horse Society Disagree Policies L19 sets out a clear approach No change motorised users, (1187597) improve crossings where existing routes cross busy roads. Local RoW & STACC (346623) Agree Minor modification would be a useful clarification Minor modification – local foot/cycle “including to local paths require amenities such as shops connection to and schools” to L19 para local amenities 4 such as shops and schools. In (ii) it should not CEG (1158030) Partly Minor modification to add word “reasonable” would be a Minor modification – add require Agree useful clarification “reasonable” Legal and General assessment of 'all (1051022) alternatives and their cost’. It should relate to reasonable alternatives where appropriate. Direct routes from Aboyne Residents Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an EHH to St Albans Association (1181214) and IDP updates will reflect the latest position. ongoing basis. via Bluehouse Hill

/Verulam Road / A transport evidence workplan has been agreed with HCC. Folly Lane to city Additional work may be detailed through the Masterplanning station. This route / planning application / EIA process, with appropriate is virtually consultation. gridlocked with long tailbacks in the morning

Hemel Friends of the Nickey Noted As above IDP will be updated on an Hempstead Line ongoing basis. crossing - (1184312) problem with speed and traffic volumes. Suggested measures for speed limits and crossing upgrade. A5183 Redbourn Friends of the Nickey Noted As above IDP will be updated on an Bypass / B487 Line ongoing basis. Redbourn Lane (1184312) Roundabout Crossings - detailed measures suggested for speed limit, crossing upgrade & verge management. A1081, Ambrose Harpenden Society Noted As above IDP will be updated on an Lane & Lower (1156761) ongoing basis. Luton Road are a Wheathampstead Parish concern as they Council (51941) will be affected by new development in a severely adverse way. East and North Leverstock Green Village Noted As above IDP will be updated on an Hemel Association (1185907) ongoing basis. Hempstead Redbourn Parish Council Broad Locations - (759908) traffic impact on

B487 Redbourn Road

Must plan for Aboyne Residents Noted As above IDP will be updated on an traffic Association (1181214) ongoing basis. impediments to 867312 retail in the city centre N St Albans & E 867587 Noted As above IDP will be updated on an St Albans broad ongoing basis. locations - Tinkering with junctions will not enable the network cope with the current traffic levels let alone the increased traffic generated by 2,500 new homes N St Albans BL - 840795 Noted As above IDP will be updated on an Increased road ongoing basis. widths are required. Roads are gridlocked. BL Chiswell 1158536 Noted As above IDP will be updated on an Green - ongoing basis. inadequate 1184271 narrow local roads were not designed for this level of vehicle increase and they are unsuitable to

accommodate any proposed development. East and North 1153741 Noted As above IDP will be updated on an Hemel ongoing basis. Hempstead Broad Locations - New developments will have a disproportionate and unsustainable impact on access from/to the M1 from/through/to Redbourn and Harpenden. Concern 1184750 Noted As above IDP will be updated on an regarding ongoing basis. introduction of new J8A at Redbourn. BL East Hemel Friends of the Nickey Noted As above IDP will be updated on an /Nickey Line - Line (1184312) ongoing basis. developers have indicated a number of improvements to the Nickey Line including crossings & all weather surfacing.

BL - Park Street 1185744 Noted As above IDP will be updated on an Garden Village ongoing basis. requires a significantly improved road network and traffic management schemes. Consideration should be given to a Park & Ride Scheme. BL S6v E St Ellenbrook Area Noted As above IDP will be updated on an Albans - Primary Residents Association ongoing basis. Network Route Committee (1185802) (PNR) (The A1057) is failing to cope as it is, the additional vehicles coming from these developments will choke this route to a standstill. The increased traffic will also increase the noise pollution and air pollution. BL EHH - Not 1185704 Noted As above IDP will be updated on an enough work ongoing basis. seems to have been done on defining the

required changes to the road network to cope with the extra cars (+ buses and lorries presumably. Before deciding on quantity and timescales for development - all transport issues should be addressed Redbourn Lane Friends of the Nickey Noted Not within planning remit. No change Car Park - Line (1184312) detailed measures suggested for maintenance, improvement to entrance and larger size. Policy support/ Barton Wilmore obo Noted Support noted No change various policy Bloor Homes (1158079) aspects British Horse Society welcomed (1187597)

Reliance on Aboyne Residents Disagree Policy L18 deals with this. Buses are not ‘relied on’ but are No change buses is not Association (1181214) an important part of the sustainable transport approach credible. Parking Aboyne Residents Noted Policy L18, L20 & Appendix 1 deals with this. No change implications for Association (1181214) city centre must 867312 be dealt with

For key Hunston (1185630) Noted Approach is consistent with national policy. No change considerations in assessing new development, NPPF paras 108- 111 are relevant. LTP4 / GTP Leverstock Green Village Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an outline potential Association (1185907) and IDP updates will reflect the latest position on LTP4 & ongoing basis. schemes for EHH GTPs. relate to lower growth assumptions. They will have some disbenefits. The formatting CEG (1158030) Disagree Policy L19 sets out a clear approach No change and wording should distinguish between policy and ‘reasoned justification’. Criterion (iii) gives Hallam Land Noted Policy L19 sets out an appropriate approach No change weight to advisory Management Limited documents. It (1185998) should be recognised that material considerations may justify an alternative approach. Policy says new RF Sinclair & Sons Disagree Policy L19 sets out a clear approach. No change roadside services (1058251) will be refused in 52064 GB. This is too negative and

needs to be reworked. In BLs, residential STACC (346623) Noted This matter can be properly detailed through the No change roads should Masterplanning / planning application / EIA process, with 1048449 have 20mph limit. appropriate consultation. For Wheathampstead Parish Noted Policy 18 deals with this. No change Wheathampstead Council (51941) village, transport connections are paramount. Better transport required throughout district with connectivity by road/cycle/footpat h between settlements. Add ref to railway Network Rail (1184616) Disagree No evidence supplied to justify the approach suggested. No change level crossing. Detailed wording suggested. Amend para 2 to Hertfordshire County Noted Minor modification will provide helpful clarification. Minor modification to reflect the NPPF Council (837689 reflect minor updated 2018 to ‘A Travel wording in NPPF - ‘A and Traffic Travel and Traffic Transport Transport Assessment Assessment and and an Air Quality an Air Quality Assessment will be Assessment will required for major be required for developments’. major developments.’

L20 – New Development Parking Guidance and Standards

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Protection of St Albans Cycle Disagree A realistic approach supporting sustainable travel whilst No change existing parking Campaign (346623) acknowledging the ongoing role of the car has been taken. spaces is contrary to switch to sustainable travel. Existing parking spaces could provide local amenity space or cycle parking instead. NPPF & NPPG Hertfordshire County Noted Policy L20 & appendix 1 sets out a clear approach No change support reduced Council (837689) levels of parking Low car / no car Hertfordshire County Noted Policy L20 & appendix 1 sets out a clear approach No change parking provision Council (837689) is supported in highly accessible areas and where additional car trips would lead to adverse impact on highway network e.g. congested areas / junctions at capacity nearby. Car share supported.

Provision needs Hertfordshire County Noted Policy L20 & appendix 1 sets out a clear approach No change to be made for Council (837689) the disabled persons parking spaces Clarify the Legal and General Disagree Policy L20 & appendix 1 sets out a clear approach No change parking standards (1051022) for visitors and unallocated parking in policy and appendix 1 Appendix 1 Hilton House Properties Disagree A realistic approach supporting sustainable travel whilst No change standards will Limited (1057476) acknowledging the ongoing role of the car has been taken. lead to an over- Policy L20 & appendix 1 sets out an appropriate approach provision of parking spaces outside of city centres but in highly accessible locations e.g. How Wood Broad Location at 1187590 Disagree A realistic approach supporting sustainable travel whilst No change Chiswell Green acknowledging the ongoing role of the car has been taken. will worsen Policy L20 & appendix 1 sets out a clear approach parking issues Policy opposes 52064 Disagree This matter is appropriately addressed by the overall LP No change the loss of garage policy framework courts, even though the Council’s is delivering affordable housing through

making better use of such sites. The whole issue 760045 Disagree A realistic approach supporting sustainable travel whilst No change of the older acknowledging the ongoing role of the car has been taken. residents and Policy L20 & appendix 1 sets out a clear approach their need always to use a car to shop has been ignored Government 760045 Disagree Misstatement of Government policy. Policy L20 & appendix No change requires 1.5 1 sets out an appropriate approach spaces per unit. The plan is 863632 Disagree A realistic approach supporting sustainable travel whilst No change derelict in its acknowledging the ongoing role of the car has been taken. approach to 1144419 Policy L20 & appendix 1 sets out a clear approach parking. This is the number one problem of the district / Sufficient parking is required. Need to 867312 Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an demonstrate that and IDP updates will reflect the latest position ongoing basis. parking in town centres and transport hubs, e.g. train stations, can cope with the needs of a higher population. Proposed Adrian Irving and Alban Disagree A realistic approach supporting sustainable travel whilst No change residential Developments Ltd acknowledging the ongoing role of the car has been taken. parking standards (1156368) Policy L20 & appendix 1 sets out a clear approach are onerous.

Cambridge City St Albans Cycle Disagree Policy L20 & appendix 1 sets out a clear approach. No change Council Local Campaign (346623) Cambridge Cycle Parking Guide is already directly Plan appendix D referenced in L20. However Cambridge has an 1048449 & Cycle Parking exceptionally large student and young person population Guide are that means some aspects relating to cycling are not directly considered to be comparable. best practice. SADC proposed standards at appendix 1 falls short of this requirement. Bring it fully into line with Cambridge guidance. Numerous changes suggested to LP appendix 1. Clarify the cycle Legal and General Disagree Policy L20 & appendix 1 sets out a clear approach No change parking standards (1051022) Reference to Hilton House Properties Disagree Cambridge is an acknowledged leader with regard to No change other authority for Limited, (1057476) supporting cycling. Policy L20 & appendix 1 sets out an cycle standards appropriate approach does not respond to local circumstances Plan is very weak 1185967 Disagree Policy L20 & appendix 1 sets out a clear approach No change on cycle parking

Specific policy Crown Estate (51946) Disagree Policy L20 & appendix 1 sets out a clear approach No change wording Hertfordshire County suggested Council (837689)

Size of parking St Albans Civic Society Disagree Policy L20 & appendix 1 sets out a clear approach No change bays should take (1156974) account of the fact that cars have got larger. East Hemel Crown Estate (51946) Disagree Policy L20 & appendix 1 sets out an appropriate approach No change Hempstead (Central) should be in parking zone 3. 2002 parking St Albans Cycle Disagree Policy L20 & appendix 1 sets out a clear approach No change policy should be Campaign (346623) revised to reflect new best practice Elements of the Legal and General Disagree Policy L20 & appendix 1 sets out a clear approach No change policy are unclear (1051022) Requirement for Hilton House Properties Disagree Policy L18, L20 & appendix 1 sets out a clear approach No change vehicle charging Limited (1057476) points is not very 1185525 aspirational and should be increased. Car share parking 1144419 Disagree Policy L20 & appendix 1 sets out a clear approach No change is not going to work.

L21 – Education

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Policy should Crest Strategic Projects Noted Policy L21 /IDP sets out an appropriate approach. No change allow the and Bloor Homes possibility of (1158079) delivery of school by developers Where school Crown Estate (51946) Noted Policy L21 /S6 / IDP sets out an appropriate approach No change capacity is higher than BL population requires, transfer site at nil cost should be for a proportion of the school only ‘Transferred to Hunston Planning Disagree Policy L21 /IDP sets out an appropriate approach No change education Limited (1185622) authority at nil cost' may prevent flexibility to deliver bespoke educational facilities Sites to be 1185775 Disagree Policy L21 /IDP sets out an appropriate approach No change transferred to Local Education Authority will benefit HCC in respect of land values. May

conflict with government policy re free schools New schools Colney Heath Parish Noted Policy L21 /IDP sets out an appropriate approach. Timing No change must be provided Council (51891) of school provision will be decided during in a timely Masterplanning/planning application processes. London Colney Parish manner, before or Council (52477) at the same time as development. A full business 1153742 Noted Policy L21 /IDP sets out an appropriate approach. Exact No change case to show that nature of school provision will be decided during the "appropriate Masterplanning/planning application processes. contribution" from the developers will be both sufficient in its own right and supported by other funding. Support policy / London Colney Parish Agree Support noted No change support delivery Council (52477) of new schools St Stephen Parish Council (51804) Add ref to each CEG(1158030) Noted Add reference in IDP IDP will be updated on an new school ongoing basis. Site requirement Department for Noted Add reference in IDP IDP will be updated on an should accord Education (1186955) ongoing basis. with BB103 or BB104 Do not refer to Crown Estate (51946) Disagree Policy L21 / IDP sets out a clear approach No change state funded education

Broad Locations: Hallam Land Disagree Policy L21 sets out a clear approach – when not in the No change At BL - North St Management Limited Green Belt, new school playing fields will be designated as Albans new (1185998) Local Green Space. school playing fields will serve a community joint use function but not designated Local Green Space. Covenants would restrict use of land.

Policy seeks to Hunston Planning Noted Support for Policy L21 which addresses this already is No change prevent future sell Limited(1185622) noted. off of school playing fields by confirming community value School Harpenden Green Belt Disagree Policy L21 /S3 / S6 sets out an appropriate approach No change development in Association (866541) GB is contrary to Historic England NPPF (929489) Leverstock Green Village Association (1185907) St Albans Civic Society (1156974) 1185714 Remove school Department for Disagree Policy L21 /S3 / S6 sets out an appropriate approach No change site &/or school Education (1186955) built zone from GB. Show school

boundary on Hertfordshire County map. Council (837689) Crown Estate (51946) No difference Chair of Governors Disagree Concentrating development in larger sites that can create No change between building Townsend School new communities and deliver infrastructure – including a new primary (1186028) schools - is a key part of the development strategy. Cross school at BL and reference S6 vi. building one on the Townsend site. Blocks of GB 1055738 Disagree Policy L21 /S3 / S6 sets out an appropriate approach No change adjacent to BLs at NW Harpenden, E St Albans, EHHN & London Colney is erroneous. They should be included within broad locations and designated as local green space. Add ref to the Historic England Disagree Policy L30 deals with this No change historic (929489) environment Object to new CPRE (872572) Disagree Policy L21 /S3 / S6 set out a clear approach No change school in GB due Ramblers Association to lack of (52420) exceptional circumstances / very special circumstances

Land off London Beechwood Homes Disagree School site allocations based on evidence and work with No change Road (LOLR) (1123837) HCC. Work on the education infrastructure evidence base unsuitable and has been ongoing and IDP updates will reflect the latest Gorhambury Estates unjustified. position. Company Ltd (375996) Landowners do not support Verulam Golf Club therefore it is not (1185810) deliverable. 1185565 1186015 1185761 Support housing Verulam Golf Club Disagree Policy S4 deals with housing requirement No change at land off London (1185810) Road site. 1186015 Add ref to protect Historic England Disagree Policy L30 deals with this No change the historic (929489) environment Support policy St Albans Labour Group Noted Support noted No change (1183933) London Road is 1185728 Noted / Policy L18/L19 deals with this. Site selection in part No change congested & the Disagree because of proximity to areas where primary school pupils junction of live/will live and will be able to access by walking. London Road/Verulam Industrial Estate, particularly with the railway bridge being so close and would become very dangerous. Infrastructure to support cycling

and walking is difficult, the lives of school children at risk if this proposal goes ahead. There are few primary age children within walking distance of the land which means any pupil will travel by car. HCC request an Hertfordshire County Noted / School site allocations based on evidence and work with No change additional school Council (837689) Disagree HCC. Work on the education infrastructure evidence base allocation is has been ongoing and IDP updates will reflect the latest required at position. HCC still working on evidence base regarding Ariston site for intended location for school and approach to provision. state funded primary education. Do not support FOBH (1181795) Noted School site allocations based on evidence and work with No change school at Ariston HCC. Work on the education infrastructure evidence base Site has been ongoing and IDP updates will reflect the latest position. HCC still working on evidence base regarding intended location for school and approach to provision. Add ref to Footpaths Coordinator St Disagree Policy L18 deals with this No change appropriate local Albans & District infrastructure to Footpaths Society encourage (723340) cycling and British Horse Society walking to school. (1187597)

London Colney Parish Council (52477) STACC (346623) Ramblers Association (52420) Add ref to travel British Horse Society Disagree Policy L18 deals with this. No change plan (1187597) Ramblers Association (52420) Lack of evidence Department for Noted Work on the education infrastructure evidence base has No change base for Education (1186955) been ongoing and IDP updates will reflect the latest education / IDP position. Redbourn Parish Council update required (759908) 1185583 Policy L21 is not Harpenden Green Belt Disagree Approach is consistent with national policy. No change justified or Association (866541) consistent with national policy. Include ref to St Albans Labour Group Disagree Included in overall approach to school provision No change special education (1183933) need. Existing schools 1185469 Noted Concentrating development in larger sites that can create No change are already new communities and deliver infrastructure – including 1185714 oversubscribed / schools - is a key part of the development strategy. strain on existing 1184569 schools by new 1184784 development, especially at 1153741 Broad Locations.

More primary St Stephen Parish Noted Work on the education infrastructure evidence base has IDP will be updated on an school places are Council (51804) been ongoing and IDP updates will reflect the latest ongoing basis. required at position. Chiswell Green / Park Street Secondary school St Stephen Parish Noted Policy S6 xi provides for this. No change required at PSGV Council (51804) Concern about St Albans Labour Group Disagree Concentrating development in larger sites that can create No change lack of new (1183933) new communities and deliver infrastructure – including secondary places schools - is a key part of the development strategy. for St Albans Secondary places North Herts District Disagree Concentrating development in larger sites that can create No change for Kimpton are Council (1185674) new communities and deliver infrastructure – including required schools - is a key part of the development strategy. BL North St 1184862 Disagree Concentrating development in larger sites that can create No change Albans - object to new communities and deliver infrastructure – including 840795 primary school. schools - is a key part of the development strategy. Margaret Wix, an 1184966 excellent primary school, is substantially under used. / Additional secondary places are required. The whole of the 334023 Disagree Concentrating development in larger sites that can create No change East Hemel area new communities and deliver infrastructure – including proposals should schools - is a key part of the development strategy. be totally reconsidered.

For Verulam Verulam Residents Disagree Concentrating development in larger sites that can create No change area, the Association (1185823) new communities and deliver infrastructure – including proposed plan schools - is a key part of the development strategy. does nothing to remedy the inadequacy of infrastructure in this area - particularly schools BL at NE 1183112 Disagree HCC support approach here and in S6 vii. Concentrating No change Harpenden - HCC development in larger sites that can create new have no plans for communities and deliver infrastructure – including schools - improvement is a key part of the development strategy. except those related to new school. Lack of ref to St Albans Labour Group Disagree Included in overall approach to school provision. No change Extended (1183933) Learning facilities More clarity Legal and General Disagree Policy L21 sets out a clear approach, in conjunction with No change required due to (1051022) other policies. policy overlap in CEG (1158030) categories: new school; broad locations; GB education sites. Policy does not St Albans School Disagree There is no evidence of additional need in the independent No change make provision (1187032) sector that needs to be separately addressed in the LP. for schools in the This matter can be appropriately addressed by the overall independent LP policy framework sector. Policy is vague Aurora Properties Disagree Policy L21 sets out a clear approach No change Limited (1151817)

Proposals at EHH 1185037 Noted Not within planning remit. No change for a new secondary school will affect access to Roundwood School for Redbourn children. Unclear whether 1153741 Noted Policy S6 deals with this. They are two separate schools. No change NE Harp and NW Harp will deliver a single 2FE school or two 2FE schools. L22 - Community Leisure and Sports Facilities

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Policy Harpenden Town Noted Support noted No change requirement for Council (51870) community, Crest Strategic Projects leisure, sports and Bloor Homes facilities and local (1158079) centre at Broad Locations is supported Policy supports Hunston Planning Noted Policy L22 sets out a clear approach. No change the early Limited (1185630) allocation of BLs from which the majority of funding for such

facilities will come. ‘Suitably re- St Albans School Disagree Examples given show suitable re-provision along lines set No change provided (1187032) out in policy L22. elsewhere’ is very 52064 subjective. Loss of existing community infrastructure may be needed to fund improvement elsewhere but with an overall net loss. (e.g. Museum of St Albans, Harpenden Public Halls). Delete policy. Joint use facilities St Albans School Disagree Policy L22 sets out an appropriate approach No change at educational (1187032) development are not always feasible and should be deleted. The policy should Sport England (824971) Disagree Policy L22 sets out a clear approach No change be reworded to say that replacement provision of equivalent or better provision in terms of quantity

and quality in a suitable location will need to be provided. There is a need 1185960 Noted Policy L22 acknowledges that there is a deficit of worship No change for new purpose space and sets out an appropriate approach to provision. built mosque. Not enough St Albans Deanery Noted Policy L22 acknowledges that there is a deficit of worship No change thought has gone Synod (1185929) space and sets out an appropriate approach to provision into providing for the social and pastoral needs of the people who will live in the proposed developments. The provision of a Community Hall or Multi-Faith Centre should also be included in any development. Marketing should Watford Borough Council Noted Policy L22 deals with this. No change be undertaken to (1122500) demonstrate demand for existing use if any. Support policy to St Albans Civic Society Noted Support noted No change protect public (1156974) houses

St Albans Labour Party (1183933) Text on public Theatres Trust Disagree Has been considered in depth at PPC. Policy L22 sets out a No change houses lacks (1179001) clear approach. sufficient guidance and justification The land Gallagher Estates Disagree The need for additional cemetery provision and the No change proposed for (1143916) identification of an extension to London Road cemetery as cemetery the most appropriate location is clear. extension is not available from landowner and should be deleted from the map. Landowner wishes to work with the council to identify alternative land next to the existing cemetery, which can be provided alongside new residential development. Criteria for very CPRE (872572) Disagree Policy L22 sets out a clear approach. No change special 1019306 circumstances is insufficient. In relation to St CPRE (872572) Disagree Has been considered in depth at PPC. Policy L22 sets out a No change Albans City clear approach

Football Club - need reference to suitable alternative locations beyond the district boundary in criteria 1. Criteria 2 should recognise that new development would have a severe impact. Criteria 3 scale of development should be minimised. Public scrutiny of viability assessment is required. Primary public access to stadium to be by sustainable transport modes guaranteed through legal agreement. The enabling St Albans Civic Society Noted Has been considered in depth at PPC. Policy L22 sets out a No change development (1156974) clear approach must conform to NPPF it must not be a Trojan horse

for large housing estates Existing football St Albans Civic Society Noted The LP sets out an appropriate policy framework for future No change club site must be (1156974) decision making. returned to the This matter can be properly detailed through the park for public masterplanning/ planning application/ EIA process, with enjoyment. appropriate consultation. Support policy in St Albans Labour Party Noted Support noted No change principle (1183933) The Council has Ramblers Association Disagree Has been considered in depth at PPC. Policy L22 sets out No change not demonstrated (52420) an appropriate approach that it is the public interest to support a private commercial facility in the Green Belt. Enabling Ramblers Association Noted Has been considered in depth at PPC. Policy L22 sets out No change development (52420) an appropriate approach must be restricted to that which is essential to ensure the deliverability and viability of the stadium. Add ref to CPRE (872572) Noted Policy L22 sets out an appropriate approach. No change significant Sport England (824971) community benefits (beyond benefits to St Albans City FC)

can be demonstrated / including how the development would help meet identified community, sports and leisure facility needs. Travel to multiple Colney Heath Parish Noted Not directly within LP remit No change hospital locations Council (51891) is unacceptable Wheathampstead Parish eg Watford & Council (51941) Stevenage. Travel is difficult, especially by public transport and should be addressed. Health and well- St Albans Labour Party Noted Health and well-being is appropriately addressed by LP No change being policy (1183933) policy framework overall – including transport, green needs to be spaces, provision of special needs accommodation, Wheathampstead Parish expanded community facilities etc. Council (51941) Hospital provision Colney Heath Parish Noted There has been and continues to be ongoing liaison with the IDP will be updated on an should be Council (51891) West Herts Hospital Trust. Work on the infrastructure ongoing basis. addressed / evidence base has been ongoing and IDP update will reflect London Colney Parish adequate the latest position. Council (52477) provision needed. Wheathampstead Parish Council (51941) GP and other London Colney Parish Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an healthcare Council (52477) and IDP update will reflect the latest position. ongoing basis. facilities are

important. Adequate provision required. A&E is required St Albans Labour Party Disagree There has been and continues to be ongoing liaison with the IDP will be updated on an (1183933) West Herts Hospital Trust. Work on the infrastructure ongoing basis. evidence base has been ongoing and IDP update will reflect the latest position. Where health NHS Property (911547) Disagree Policy L22 sets out a clear approach. Where NHS facilities No change facilities are no are genuinely no longer required then uses such as longer required residential can be supported. there should be a presumption for housing use on NHS land. Policies aimed to prevent loss of NHS facilities can harm delivery of services for the community. Disposal of unneeded NHS facilities can be delayed or prevented. CCG detailed Herts Valleys Clinical Noted Work on the infrastructure evidence base has been ongoing No change comments about Commissioning Group and IDP update will reflect the latest position. capacity of GPs (1177790, 1183617) to absorb some of the proposed development and

where there is a shortfall of space. New development Herts Valleys Clinical Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an is expected to Commissioning Group and IDP update will reflect the latest position. ongoing basis. make a (1177790, 1183617) proportionate contribution towards additional facilities. Herts Valleys Clinical Commissioning Group formula is set out to calculate the cost per dwelling of mitigating the impact of additional growth. CCG’s strategy of Herts Valleys Clinical Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an ‘Your Care, Your Commissioning Group and IDP update will reflect the latest position. ongoing basis. Future’ focuses (1177790, 1183617) on moving care out of large acute sites into more community focused delivery points. There are possible plans for a community hub in St Albans and ongoing work to look at redeveloping

Harpenden Memorial Hospital into a fit for purpose community site. The local acute Herts Valleys Clinical Noted There has been and continues to be ongoing liaison with the IDP will be updated on an provider is Commissioning Group West Herts Hospital Trust. Work on the infrastructure ongoing basis. working through (1177790, 1183617) evidence base has been ongoing and IDP update will reflect options for the latest position. reconfiguring their current sites. St Albans City Hospital is part of that. Current 789007 Noted A local centre is identified at Batford – see also L12. This No change infrastructure is matter can be properly detailed through the masterplanning insufficient at / planning application/ EIA process, with appropriate Batford. consultation. Infrastructure must be improved including restoration of local centre and resources. For North East 789007 Noted This matter can be properly detailed through the No change Harpenden Broad masterplanning/ planning application/ EIA process, with Location, football appropriate consultation. pitches is assumed, but it is traditionally male. Sports provision should be gender neutral.

Retention of Hallam Land Noted This matter can be properly detailed through the No change existing Management Limited masterplanning/ planning application/ EIA process, with community (1185998) appropriate consultation. leisure and sports is consistent with NPPF & Sport England. Part of the Broad Location site at North St Albans is currently used for playing fields for Old Albanians Sports Club. In preparing master plan consideration will need to be given as to how these are accommodated. Policy should give Sport England (824971) Noted Policies S6 & L22 set out a clear approach - This matter can No change consideration to be properly detailed through the masterplanning / planning extending or application / EIA process, with appropriate consultation. enhancing existing sports facilities that adjoin the Broad Location such as the Verulam School, Beaumont School and Oaklands College sites

New community Harpenden Town Noted Ownership of community facilities can be properly detailed No change facilities should Council (51870) through the masterplanning/ planning application/ EIA be transferred to process, with appropriate consultation. the town council Additional St Albans Labour Party Disagree The police have not identified such requirements. Work on IDP will be updated on an manned police (1183933) the infrastructure evidence base has been ongoing and IDP ongoing basis. station(s) update will reflect the latest position. required. Improved St Albans Labour Party Noted Not directly within Local Plan remit – cross reference S3 No change changing rooms (1183933) and support for sport and recreation facilities. for sports facilities is required. A local road Verulam Cycling Club Noted This matter is appropriately addressed by LP policy No change circuit with a (1187616) framework Cyclo Cross element on top is top priority for the cycling club. HCC early Hertfordshire County Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an childhood Council (837689) and IDP update will reflect the latest position. ongoing basis. services identify that 4 children’s centre areas may not have sufficient places. HCC library Hertfordshire County Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an services: Council (837689) and IDP update will reflect the latest position. ongoing basis. Redbourn & Wheathampstead to be co-located with fire stations, construction to commence 2018.

No additional libraries are planned for St Albans, so additional demand will need to be met by increasing capacity at existing locations nearest to proposed development. Appropriate contributions are required. Drive for efficiencies means that floorspace of existing libraries may change. HCC Community Hertfordshire County Noted Work on the infrastructure evidence base has been ongoing IDP will be updated on an Protection: No Council (837689) and IDP update will reflect the latest position. ongoing basis. change required to Hertfordshire Fire and Rescue Services facilities. An integrated risk management plan is being produced which considers relocation of stations. Hertfordshire Fire and Rescue

Services wished to be consulted on water supply. Sprinkler systems in all new buildings and development is recommended. Up-to-date sports Sport England (824971) Noted New evidence base for Playing Pitch Strategy has been No change facility strategy published. (indoor and outdoor sports) required Should address Sport England (824971) Noted Policy L22 sets out an appropriate approach. No change the principle of alternative sports and recreation provision (where the benefits clearly outweigh the loss) being acceptable on open space, sports and recreation land/buildings. Existing 1181750 Noted Policy L22 sets out an appropriate approach. No change settlements also need much better access to community facilities. There should be plans to upgrade

existing housing areas with poor community facilities e.g. Verulam, Batchwood. L23 Urban Design and Layout of New Development

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Plan should do Sport England (824971) Disagree The principles included in the Guidance are already Minor modification - more to promote embedded in various Plan policies. Cross reference (reference to HCC health and Hertfordshire County Policies S2 /L18 / L24 / L26-29. Guidance) wellbeing in new Council ( 837689) developments A reference to the guidance can be added. including designing attractive and safe access and facilities for sustainable modes Reference ‘Hertfordshire’s Health and Wellbeing Planning Guidance, May 2017 ’https://www.hertf ordshire.gov.uk/h ertfordshires-

health-and- wellbeing- planning- guidance No evidence Martin Grant Homes and Disagree SHMA evidence (and forthcoming SW Herts update) No change underpinning the Kearns Land (975683) indicates changing demographics and increasing numbers need for M4 (2) of older persons aged 85 and over. New homes should be dwellings Thakeham Homes designed in a flexible way to ensure that housing is (accessible and (1187005) accessible and adaptable, maximising ability to remain in adaptable) Home Builders homes and/or provide for people with a disability. This Federation (1156936) presents a clear case for all housing to meet an accessible standard. This policy would positively impact on equality of opportunity. Mandatory St Albans Civic Society Disagree To stipulate a threshold for the minimum amount of green Addition to associated amount of green (1156974) space provision (green roofing) is overly prescriptive. online glossary roofing should be stipulated. 1153802 Definition of green roofing can be included in online Clarification of glossary. meaning of term requested. Lighting Hertfordshire County Disagree Policy acknowledges the adverse impact on the No change references in Council (837689) environment from light pollution and seeks to mitigate. The Policy are guidance notes referred to are relevant to all cases and inadequate / lack 1153802 provide sufficient detail. This is only possible where the detail. They 52064 LPA has planning control. Planning control is not possible should refer to all on small scale installations. developments not just major developments.

Section J St Albans School Disagree Policy is required to adverse impact on the environment No change ‘Lighting’ should (1187031) from light pollution and seeks to mitigate. The guidance be removed as notes referred to are relevant to all cases and provide modern lighting sufficient detail. systems can be added to facilities without harm to residential amenity / ecology Landscape Hertfordshire County Agree Cross reference to Policy L24 / 29 No change impact Council (837689) assessment and Policy L23 concurs, stating that development should take EIA is required at 1184750 account of its landscape context. Policy L29 seeks feasibility stage to landscape impact assessments for all major development ensure no loss of and those which may have significant effect on the local ecology. landscape. Development covered by EIA are set out in the Additional criteria Town and Country Planning (Environmental Impact are required Assessment) Regulations 2017. The Council will determine within design likely impact through a ‘screening’ procedure and whether principles and an EIA is required. details. All buildings 1184750 Noted Not within planning remit No change should be maintained by a management company to prevent individuals modifying the fronts of houses

Policy will result 1184750 Disagree Cross reference to Policies S6 and L1. No change in housing densities that are 840795 High(er) density does not result in poor quality design. The too high. This NPPF para 123 (a) states that plans should contain policies does not allow for to optimise the use of land in their area to include the use of good design. minimum density standards that should seek a significant uplift in the average density of residential development. Work on density assumptions are based on HCA research recommending residential densities of 30-50dph in suburban locations (the BLs for development).

Policy too RF Sinclair and Sons Disagree This is essential design policy. The NPPF (Section 12) No change detailed / (1058251) supports local design policy and guidance. prescriptive - Plan should rely on Crest Strategic Projects NPPF. and Bloor Homes (1158079) Hallam Land Management Limited (1185998) St Albans School (1187031) 52064 Requirement for Jarvis Homes (973180) Disagree NPPF (Section 14) supports appropriate approaches to No change surface water flooding risk. drainage information for non-major development not in line with national policy

Specific policy Hertfordshire County Agree Minor modification to reflect more recent usage of SUDS to Minor modification – wording Council (837689) refer to ‘Sustainable Drainage Systems’ rather than older remove word ‘urban’ suggested usage as ‘Sustainable Urban Drainage Systems’ relating to SUDS acknowledged minor clarification – remove word ‘urban’ Supporting text Thames Water (931213) Disagree Matter can be dealt with as planning application stage No change should be included encouraging early consultation with Thames Water / recommendations to prevent sewer blockages Point (D) requires Hill Residential Disagree The NPPF para 9 states that the required development No change the scale and (1158064) must ‘take local circumstances into account, to reflect the massing to be character, needs and opportunities of each area’. Para 122 subservient- Jarvis Homes (973180) criteria d states ‘desirability of maintaining an areas unclear what is prevailing character and setting’. meant by subservient and The policy does not unduly constrain potential development unjustified as to locations. why new buildings should be so. The location of the development and size of the site do not require this generic approach, scale and massing should

be appropriate to existing context. New development Hill Residential Disagree The NPPF para 9 states that the required development No change should be (1158064) must ‘take local circumstances into account, to reflect the compatible with character, needs and opportunities of each area’. The Plan the pattern and Jarvis Homes (973180) approach takes specific account of the nature of the mature character of the and verdant suburbs with their particular characteristics existing such as large plots. Not all the district has that particular development in character. Due regard to relationships with existing all cases not just development in all cases is acknowledged already. in verdant and mature suburban areas Design Advice Jarvis Homes (973180) Disagree Design Advice Leaflet 1 is still highly relevant to smaller No change Leaflets No 1 & 2 scale development within existing urban areas. The policy are outdated Trustees of James Henry also refers to Herts Building Futures (design guidance) and Frank Sewell Deceased does not unduly constrain design for potential (1185630) developments. Plan design Environment Agency Disagree Cross reference policies L25/26. No change policies do not (1147557) acknowledge the Criteria xi deals directly with this issue. Herts building role that urban futures provides more guidance. design and development layouts play in reducing the impacts of climate change Potential for Legal & General Noted Cross reference to L24 No change adjusted / relaxed (1051022) specific design Sufficient clarity provided in policy. standards within CEG (1158030)

BL requires Historic England clarification. (929489) Design review St Albans Civic Society, Disagree Whilst the content of the policy exchange document is No change policy should (1156974) acknowledged as general background evidence and include reference context - with reference in particular to affordable housing to ‘Building More Hallam Land (1185998) delivery - it is ‘London centric’ and does not wholly reflect Building 1185950 the context of SADC and has no official status. Beautiful’. https://policyexchange.org.uk/wp- 1184967 content/uploads/2018/06/Building-More-Building- Beautiful.pdf Independent St Albans Civic Society, Agree This is the intent of the policy No change design review (1156974) opinion should be sought from 1184967 residents and 1185950 Civic Society

Pre-application Hallam Land (1185998) Disagree The importance of design quality is acknowledged in the No change expert design NPPF and this is an appropriate way to secure it. review should not be a requirement for the Broad Locations. Not clear what the difference is between a pre- application expert design review and a subsequent and additional independent design review

Clarification St Albans Civic Society Noted The NPPF focuses on high quality buildings and good No change required on (1156974) design standards and reference character and sense of definition of good place rather than a particular design typology. urban design and Hallam Land welcoming Management Limited contemporary (1185998) design. 1185950 Street design 1184967 Agree The policy seeks to achieve a high standard of detailed No change should allow for design and layout through design and layout principles. The social interaction NPPF states the need to support communities’ health, for health, safety, social and cultural wellbeing and para 91 (a) states the aim social cohesion, to promote social interaction to achieve healthy and the environment inclusive places. and citizenship.

Clarification St Albans Civic Society Disagree Must is a deliberately used stronger word. Should is more No change required on the (1156974) flexible and possibly less restrictive. The policy uses both distinction words. The NPPF uses the wording ‘should’ more between ‘should’ frequently and ‘must’ when referring to policies reflecting and ‘must’ in international obligations and statutory requirements (for Policy example). Building height Historic England Disagree Cross reference Para 1.10. No change control area (929489) should be shown Elements of the policies map will be in the form of online on policies map information. Policy should Historic England Disagree Cross reference Policy 30 No change refer to need to (929489) conserve and The policy states that these aspects must be sensitively enhance, considered in relation to the host building and streetscene. particularly in Reference to conserve and enhance where location within relation to re- conservation area best placed within policy L30. instatement of

historic shopfront designs. L24 Development Amenity Standards

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Support good 1184750 Noted Support noted No change urban design (residential & industrial) through this policy Landscape Hertfordshire County Agree Cross reference to Policy L23 / L29 No change impact Council (837689) assessment and Policy L23 concurs, stating that development should take EIA is required at 1184750 account of its landscape context. Policy L29 seeks feasibility stage to landscape impact assessments for all major development ensure no loss of and those which may have significant effect on the local ecology. landscape. Development covered by EIA are set out in the Additional criteria Town and Country Planning (Environmental Impact are required Assessment) Regulations 2017. The Council will determine within design likely impact through a ‘screening’ procedure and whether principles and an EIA is required. details Policy will result 1184750 Disagree Cross reference to Policies S6 policies and L1 / L24 No change in housing densities that are 840795 High(er) density does not result in poor quality design. The too high. This NPPF para 123 (a) states that plans should contain policies does not allow for to optimise the use of land in their area to include the use of good design. minimum density standards that should seek a significant uplift in the average density of residential development. The minimum density set out in the BL policies is 40dph. Work on density assumptions are based on HCA research

recommending residential densities of 30-50dph in suburban locations (the BLs for development).

Strict controls of Jarvis Homes (973180) Disagree The Policy establishes important design principles. Update of design guidance amenity space planned following Plan compromise Home Builders Policy allows for a reduction in the standards of amenity adoption. viability and Federation Ltd provision to reflect the less constrained design opportunity delivery of urban (1156936) provided by the BL’s and any coherent design approach. optimisation 1058251 52064 Unclear ‘internal Jarvis Homes (973180) Disagree Plan policies deliberately do not specify internal (national No change space’ minimum technical standards) space standards to allow flexibility to requirement. St Albans Civic Society design for varied and changing lifestyles. (1156974) The policy properly requires suitable provision of external Home Builders space (where internal space is limited). Federation Ltd (1156936) Crest Strategic Projects and Bloor Homes (1158079) CEG (1158030) Hertfordshire County Council (837689) 1185704 1185630

Clarification of Jarvis Homes (973180) Disagree A studio is by definition a single room. ‘Room’ as related to No change definition of studios are multi-purpose. ‘room’ would be St Albans Civic Society helpful to clarify (1156974) what amenity Home Builders space is required Federation Ltd for studios. (1156936) Crest Strategic Projects and Bloor Homes (1158079) CEG (1158030) Hertfordshire County Council (837689) 1185704 1185630 1185630 Landscape Jarvis Homes (973180) Agree Cross reference to Policy L29 No change planting should be recognised in St Albans Civic Society its contribution to (1156974) amenity. Home Builders Federation Ltd (1156936) Crest Strategic Projects and Bloor Homes (1158079) CEG (1158030)

Herts County Council (837689) 1185704 1185630 L25 Energy and environmental performance of new development

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Reducing need to 1182314 Noted The NPPF puts a high priority on meeting housing need. No change build in the Green This requires some use of green field/ Green belt land. Belt would be 1153802 Policy states that the larger broad locations will be expected more to deliver renewable/low carbon energy supply. environmentally friendly through less carbon emissions Policy should give 1153802 Noted It is acknowledged that the environment in which we live, No change greater work and socialise plays a significant role in the health of consideration to individuals and communities. The policy by its title of ‘energy the needs of the and environmental performance of new development’ seeks end user (building to reduce carbon dioxide and other emissions that has occupier) to impacts on air quality and public health and gives those assist them in opportunities. The policy does ref to energy conservation in living sustainably. use. Policy should 1153802 Noted L25 supports minimising construction waste generation and No change reference the reuse/recycling materials and the principles of the waste issue of hierarchy. construction waste, the Hertfordshire County Council is the waste planning authority ‘circular economy’ for Hertfordshire. Waste is managed through the Hertfordshire Waste Development Framework 2011-2026. A

and design for key objective is to find alternatives to allow the movement disassembly. away from landfill by embracing alternative technologies. Proposals for waste management should be in accordance with this framework. Policy does not 1153802 Noted The energy hierarchy would inform the design, construction No change recognise the and operation of new buildings. The priority is to reduce energy hierarchy energy demand, supply energy efficiently and incorporate (Lean, Clean, new renewable technologies. This is the purpose of the Green). policy and does not require a specific hierarchy namecheck. Renewable London Colney Parish Disagree Under current NPPF this focuses on effective and No change energy policy / Council (52477) proportionate implementation of policy and it is more difficult proposals should and less proportionate to apply this aspect of policy to relate to all 1153802 smaller scale development. developments, not just those over 50 units, classed as major developments or those broad locations stated. Requirement for Martin Grant Homes and Disagree Embedding sustainable principles from the earliest stage No change environmental Kearns Land (975683) possible can ensure appropriate measures are built into performance and design. Pre-application stage provides greater opportunities sustainability for maximising the benefits. statement at pre- application stage is onerous

Parking should be Ver Valley Society Noted Policy concurs stating that sustainable construction should No change surfaced with (826041) be an integral part of all planning applications. Policy L20 permeable states ‘parking surfaces should be permeable’. materials

Plan should make Environment Agency Disagree This is a matter dealt with generally in the NPPF. No change reference to (1147557) remediation of The Council may impose planning obligations/conditions to contaminated ensure remediation of specific sites. land High risk development proposals such as petrol stations and cemeteries should be avoided within vulnerable groundwater areas Plan should Hill Residential Noted Para 149 of the NPPF states that local councils should take No change include targets (1158064) proactive approach to mitigating and adapting to climate and standards for change taking into account the long term implications for carbon emissions Environment Agency water supply. BREEAM BRE HQM considered best method and energy (1147557) for setting performance standards. efficiency. Thames Water (931213) Referring to performance St Stephen Parish targets in Council (51804) conditions and St Albans Labour Party agreements is Group (1183933) insufficient. Need for clear policy 1153802 guidance how development will demonstrate compliance. Set targets for Environment Agency Noted Policy applies optional water consumption technical No change non-domestic (1147557) standard. water consumption and London Colney Parish Para 149 of the NPPF states that local councils should take requirement to Council (52477) proactive approach to mitigating and adapting to climate change taking into account the long term implications for implement water 1153802 recycling for non- water supply. potable uses. Land use activities can indirectly/directly impact upon surface and groundwater quality. May be of benefit to state

Protect certain uses must submit and assessment of the potential groundwater. impact of the use on groundwater such as petrol stations, cemeteries, waste treatment facilities and non-landfill waste management activities, storage of slurry etc Policy L23 states that SUDS principles will be applied as a drainage management tool to manage surface water runoff. Recommend Adrian Irving and Alban Disagree This is addressed by relevant building control legislation No change modification to Developments Ltd refer to Part L of (1156368) Building Regulations L26 Local Green Space

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Ariston site Friends of Bernards Disagree The Policies map designates the recreation ground at No change should be Heath (1181795) Bernards Heath adjacent to Sandridge Road as local green designated as space, in accordance with the Green Space technical Local Green evidence. Ariston Playing Fields are not a public open Space space. Green Belt, 840795 Noted Policies S1 and S2 provide a clear development strategy. No change greenspaces, Development need, overall Plan context and site specific parks and analysis in GB work provide exceptional circumstances for woodland are GB release. being sacrificed to development

Local green Ramblers Association Noted Policy L29 prioritises enhanced public access improvements No change spaces that are (52420) to the Green Infrastructure Network. Opportunities are publically detailed in the Green Infrastructure Plans that support accessible should St Albans & District access to recreation and open space such as the St Albans be provided by Footpaths Society Radial Greenway. The County Council are responsible for a village green (723340) ‘Rights of way improvement plan’ which is incorporated into designation and The British Horse policy L18 regarding the transport strategy. new public rights Society (1187597) of way The designation St Albans School Disagree The NPPF para 99 states that local green spaces should be No change criterion (1187032) designated when a plan is prepared. The designation of the ‘demonstrably local green spaces correlates with the criteria in NPPF para special’ is 52064 100 as they are within settlement limits in proximity to local unclear. communities and have particular local significance in terms of recreation or natural value. The designation St Albans School Disagree The Plan provides for development need. Local green No change restricts urban (1187032) spaces have important functions for health and wellbeing of area development communities and protection of the environment. sites 52064 Harpenden Harpenden Town Noted The council are committed to supporting neighbourhood No change Neighbourhood Council 51870) plans; the HNP designations now form part of the Plan designates Development Plan. 12 local green spaces The policy should Hertfordshire County Noted Policy gives clarity on when ancillary development to No change ensure there are Council (837689) support local green space would be acceptable. no unrealistic requirements on developers

L27 Green Space Not Designated as Local Green Space

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Policy scope and Martin Grant Homes and Disagree Policy is deliberately criteria based to support well balanced No change application is Kearns Land (975683) planning judgements on when ancillary built development unclear and would be supported and when loss of green space may be doesn’t provide acceptable. NPPF is focused on sport and recreation facility necessary clarity issues, and does not deal with all relevant open space and certainty- considerations (e.g. wildlife and urban landscape / visual better to rely on value) NPPF Policy should 1153802 Noted Policy stipulates criteria that wildlife conservation is to be No change ensure wildlife provided for in the design and landscaping of proposed conservation development, maintain watercourses and would not damage or destroy the environment.

Policy should St Albans School Noted Policy gives clarity on when loss of areas of green space No change ensure no (1187032) would be acceptable. Inevitably the intention is to place unrealistic appropriate requirements on development proposals. requirements are 52064 placed on developers Policy should Environment Agency Disagree This issue is covered generally in Policy L29. There is no No change include reference (1147557) need to include all detailed guidance/ EA policy as this is to 8m buffer available in supporting documents. along watercourses

Not explicit how Sport England (824971) Agree The wording can be amended from ‘clearly demonstrated Minor modification land which no that the building or facility is no longer required’ to longer serves incorporate the precise wording of para 97 criteria (a) of the Amend to reflect specific recreational/sporti NPPF to ensure that an assessment is undertaken to NPPF wording criteria that ng purposes will demonstrate surplus. ‘an assessment has been be assessed undertaken which has clearly shown the open space, buildings or land to be surplus to requirements’. Does not specify Sport England (824971) Agree The wording can be amended from ‘unless suitably re- Minor modification that replacement provided elsewhere’ to incorporate the precise wording of land and facilities para 97 criteria (b) of the NPPF to ensure that facilities are Amend to reflect specific needs to be the same or better and in the most appropriate locations. NPPF wording that equivalent or ‘suitable replacement land better and facilities of equivalent or better provision in terms of quantity and quality can be provide elsewhere’ Would prefer Ver Valley Society Noted These are detailed matters about implementation of policy. No change specific mentions (826041) They will be covered through detailed sector / local of rivers Red, Ver guidance. and Lea, rather than vague term ‘Watercourse’

L28 Green Space Standards and New Green Space Provision

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Policy allows no Jarvis Homes (973180) Disagree Cross reference Policies L26/L27 which set out when it may No change flexibility if there be acceptable to lose green space. The purpose of the is overprovision policy is to establish a baseline standard of provision required in new development.

Policy should Hertfordshire County Disagree ‘Teenage areas’ is a term derived from PPS 17 typology of No change clarify what is Council (837689) green spaces. SADC Green Spaces Technical Report 2016 meant by defines this as areas for wheeled sports and pieces of ‘teenage areas’ equipment within existing parks. Multi-games courts and within tables youth shelters are taken into consideration. The NPPF does not define a typology for this form of open space however in terms of equality and inclusion it is important that the local plan caters for all the community.

Policy should Batford Community Disagree Cross reference Policies Map. Porters Hill Park lies No change clarify whether Action Group (1185696) immediately adjacent to the south of the Broad Location at Porters Hill Park NE Harpenden and is clearly not within the boundary. No is included within need to refer to in the Policy. North East Harpenden Broad Location All development Batford Community Noted Cross reference L24 and S6. The policy sets out green No change should contain Action Group (1185696) space standards for new residential areas. The policy states open spaces and that designs must respond positively to environmental sports 789007 context and integrate with existing environmental character centres/facilities. 1184750 reflecting landscape character. Policies S6 within BL require These areas delivery of recreation space and public open space and in

should not the case of S6 i), S6 iii) and S6 iv) (East Hemel North, East encroach upon Hemel South and North Hemel) managed woodland and proposed country new Country Park. The BLs will be planned in detail through park and should masterplanning processes and the factors referred to will be not affect tree important considerations. retention /landscaping. Topography should be respected. Provision of Sport England (824971) Noted Cross reference Policy L17. Policy covers this. Direct No change green space and provision of and financial contributions to infrastructure will its management St Albans Civic Society be secured through S106 and CIL. must be secured (1156974) by planning Watford Borough Council obligations. (1122500) Quantity Sport England (824971) Disagree Quantity standards refer to the area of open space in sq m No change standards for required for every person, within a set area. amenity green space is not Greenspace Strategy 2016 (SADC) set local quantity based on robust standards Green Spaces Technical Report 2011 evidence The open space required from new development is based on the anticipated increase in population resulting from the new development. Quantity Sport England (824971) Disagree Greenspace Strategy 2016 (SADC) set local quantity No change standards for standards Green Spaces Technical Report 2011 amenity green space does not satisfy CIL Regulation 122 tests

Policy only covers Sport England (824971) Agree Baseline and further work since Regulation 19 has been No change grass pitches. undertaken to inform specific development proposals. Does not reflect Playing Pitch Strategy update 2019 provides baseline data priority for on grass and AGPs across the District taking into account artificial grass the significant investment of SADC in AGP provision and pitch (AGP) trends within sports. provision. Policy L28 states that the specific form/mix of provision will be negotiated in relation to the consideration of policy and green space deficiencies. Does not reflect Sport England (824971) Agree Baseline and further work since Regulation 19 has been No change Rugby Football undertaken to inform specific development proposals. Union priority for St Stephen Parish Playing Pitch Strategy update 2019 provides baseline data improvements to Council (51804) on grass and AGPs across the District taking into account existing capacity the significant investment of SADC in AGP provision and rather than new trends within sports. pitches. Junior rugby pitch Policy L28 states that the specific form/mix of provision will provision missing be negotiated in relation to the consideration of policy and from Park St, green space deficiencies. Policy L28 also supports the East and North enhancement of existing facilities. Hemel. Does not distinguish between individual sports Does not refer to Sport England (824971) Agree Baseline and further work since Regulation 19 has been No change Sport England undertaken to inform specific development proposals. latest guidance to Playing Pitch Strategy update 2019 utilises the latest calculate pitch guidance from Sport England. Specific reference not needs of new needed in Policy. development

Accessibility Sport England (824971) Disagree The LP aims to promote sustainable transport through No change standard is accessibility and NPPF para 104 states planning policies inappropriate should provide for high quality walking and cycling networks. Natural England ‘Accessible natural greenspace guidance’ recommends greenspace no more than 300m from home. SADC Technical report green spaces refers to the FIT standards for play (HA per 1000 persons) and ANGS (size OS 2ha = 300m) Greenspace Strategy 2016 (SADC) set local accessibility standards. Green Spaces Technical Report 2011 Natural England Nature nearby 'Accessible natural greenspace guidance' 2011 300m is the typical distance threshold to small and local parks and areas of greenspace with a multi-functional role. Policy threshold Sport England (824971) Disagree Appropriate open space is important in developments of this No change of 100 dwellings size. This is particularly the case in respect of play. for making green space provision is too low Policy should Sport England (824971) Agree Design of sports facilities captured within the general design Minor modification refer to detailed principles L23. Design principle (j) captures floodlighting design of sports guidance from ILP and design for non-residential Refer to Sport England facilities developments in excess of 1,000sqm will be subject to pre- design guidance as (floodlighting etc) application expert design review with appropriate community footnote P.61 LP. support. Policy L28 refers to play facilities designed and provided in accordance with national best practise guidance set out in Fields in Trust, supplementary planning documents and other local guidance. Reference could also be made to Sport England guidance.

No up to date Sport England (824971) Disagree Baseline and further work since Regulation 19 has been No change evidence base on undertaken to inform specific development proposals. outdoor sports Playing Pitch Strategy update 2019 provides baseline data facilities on grass and AGPs across the District taking into account the significant investment of SADC in AGP provision and trends within sports. L29 Green and Blue Infrastructure, Countryside, Landscape and Trees

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Landscape 1184750 Noted Policy L29 seeks landscape impact assessments for all No change impact major development and those which may have significant assessment and effect on the local landscape. The policy biodiversity EIA is required at requirements also necessitate detailed assessment. development Development covered by EIA are set out in the Town and feasibility stage to Country Planning (Environmental Impact Assessment) ensure no loss of Regulations 2017. The Council will determine likely impact ecology through a ‘screening’ procedure and whether an EIA is required.

Habitat networks Hallam Land Noted This is integral to policy. No change and ecosystem Management Limited services are (1185998) green infrastructure Rights of Way Hertfordshire County Noted This is covered under the countryside access heading. No change Improvement Council (837689) Specific mention of this detail is not necessary. Plan implementation is 1157340 required. Horse carriage driving

provision should be made

More detail is Herts and Middlesex Noted These are detailed matters about implementation of policy No change needed on Wildlife Trust (866619) and are not required in the policy itself. biodiversity: Hertfordshire County - Landscape Council (837689) level biodiversity Redbourn Parish Council enhancement (759908) - refer to 1153802 DEFRA Biodiversity Impact Assessment Calculator - Ecological surveys based on British Standards BS 42020:2013 Biodiversity - Seek advice from Hertfordshire Ecology & Herts &

Middlesex Wildlife Trust

More detail is Forestry Commission Noted These are detailed matters about implementation of policy No change needed on (1182710) and are not required in the policy itself. woodland protection: HCC (837689) - Use Natural The Woodland Trust England’s (1185811) Ancient Forestry Commission Woodland (1182710) inventory assessment St Albans Civic Society guide to assist (1156974) appropriate 1185704 development - Use Woodland Trust standard to determine how much woodland is required - Protect ancient woodland as per the NPPF - Reference Community orchards. Should reference tree specifications, arboriculture

surveys, soil handling and preparation - Integrate trees within wider landscape

Suggest inclusion Ramblers Association Noted These are detailed matters about implementation of policy. No change of detailed (52420) They will be covered through detailed sector / local footpath guidance. improvement St Albans & District proposals (listed) Footpaths Society (723340) British Horse Society (1187597) Figure 2 Green Ramblers Association Noted Figure 2 sets out the key green infrastructure network Minor modification Infrastructure (52420) although this is noted as for illustrative purposes only. This does not indicate network is supplemented by the Green Infrastructure Plan amend footnote 24 to proposed country St Albans & District 2011 of proposed green infrastructure network and projects corrected link parks, wildlife Footpaths Society and Watling Chase Supplementary Planning Guidance sites, SSSI, (723340) (Hertsmere Council). Policy states that enhanced public rivers, specific, Crown Estate (51946) access improvements are a high priority. Watling Chase public access and Community Forest designation is outlined on Figure 2.

Watling Chase Hertfordshire County Proposed country parks within the BL for development will Community Council (837689) be subject to Masterplanning and their exact locations are Forest not presently known within the wider designation. British Horse Society (1187597) 1153245 Policy fails to Welwyn Hatfield Borough Partly Ellenbrook County Park in WHBC area is shown in Figure 2. Minor modification connect Green Council (52397) Agree The focus of the policy / Figure 2 is developing and new Ring and proposals. Add bullet p64 - Connect Heartwood Forest 867587 Green Ring and with green Heartwood Forest with corridor within green corridor within Welwyn Hatfield Welwyn Hatfield Policy should Ver Valley Society Noted These are detailed matters about implementation of policy No change specifically (826041) and are not required in the policy itself. mention main Green Corridor Tarmac (1153267) Routes / River Valleys

Plan strategy RF Sinclair and Sons Noted This is primarily a matter for evidence and the SA. This No change should better (1058251) acknowledges losses to development. SADC BLs are recognise role of acknowledged to contain some higher quality areas of agricultural land St Albans School agricultural land, which has been taken into account in the to food production (1187032) overall development approach, alongside other factors such and ecology. Hertfordshire County as the Green Belt. The reference to Council (837689) the refusal of an Crown Estate (51946) application if it results in the loss 52064 of the most 1153802 versatile agricultural land 1158064 is inconsistent with the NPPF. 1055738 Policy states 1184569 development 1185704 resulting in such land loss ‘will normally be refused is unsound since the Council’s Site Assessment Matrix confirms that some high quality agricultural land is contained within the proposed Broad Locations

Clarify where grade 1,2 & 3A agriculture land is within the BL’s.

Housing areas 1184967 Noted Reference document referred to: No change should be designed to https://www.wildlifetrusts.org/sites/default/files/2018- encourage wildlife 05/homes_for_people_and_wildlife_lr_-_spreads.pdf e.g. The Wildlife This is useful sector guidance on detailed implementation of Trusts’ building policy. homes for people and wildlife

Sympathetic 1153741 Agree Cross reference Policy S6. This is a matter for No change landscaping of masterplanning. development areas is required to preserve the character of Redbourn and East Hemel Hempstead Loss of green Aurora Properties Noted Cross reference policies L26 – 29, which protect the most No change spaces and Limited (1151817) important open spaces and woodlands. Ongoing liaison with corridors between Welwyn & Hatfield Council under DtC. Some specific St Albans and Ellenbrook Area matters are largely matters for WHBC Local Plan / policy. Hatfield; including Residents Association woodland and Committee (1185802) open space at 1186129 Wynches Farm and 1153245 Symondshyde Wood as quiet area and failure to develop Ellenbrook Fields Country Park Opportunities in Watford Borough Council Noted This is a matter for detailed masterplanning taking account No change association with (1122500) of this Policy. development should be taken 1153802 to create new green corridors and link green spaces through

new development. The policy should Historic England Noted Cross reference Policy L30. This is covered under this No change mention the role (929489) policy. Napsbury Park is a designated Conservation Area of green and Historic Park & Garden. infrastructure in enhancing and conserving the historic environment and improving setting (such as at Napsbury Park) Policy does not Hertfordshire County Disagree This is a matter sufficiently dealt with in the overall policy No change deal in sufficient Council (837689) and NPPF. More detail is available through references to detail with relevant sector guidance. Detailed area specific evidence minimising Thames Water (931213) for the Local Plan is also available. flooding and Environment Agency surface water (1147557) runoff risks. 1153802

L30 Historic Environment

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Policy serves no RF Sinclair and Sons Disagree The NPPF states that strategic policies for the conservation No change purpose because (1058251) and enhancement of the natural, built and historic it reiterates NPPF environment should set out an overall strategy for the St Albans School pattern, scale and quality of development. Para 185 states (1187032) that plans should set out a positive strategy for the 52064 conservation and enjoyment of the historic environment, including heritage assets Plan should 1153802 Noted It does - where proposed development meets the policy No change encourage criteria within conservation areas. densification of appropriate sites in conservation areas (they should be prioritised above greenfield) Review Eskmuir Properties Ltd Disagree Conservation Areas are designated under the Planning No change conservation area (1156728) (Listed Buildings and Conservation Areas) Act 1990 para boundaries in 69. The Council will ensure that the conservation area light of future justifies its special interest. The existence of a CA does not redevelopment of prevent appropriate development. land on the western side of Bricket Road

Heritage Assets / 334023 Disagree The NPPF para 189 states that ‘where a site on which No change Archaeology in development is proposed includes, or has the potential to Broad Locations 1184969 include, heritage assets with archaeological interest, local have not been 1187597 planning authorities should require developers to submit an considered appropriate desk based assessment and where necessary a field evaluation’. This will be an important issue for the masterplanning process (S6). Long views St Albans Civic Society Agree The policy concurs, stating within development affecting No change important in (1156974) heritage assets ‘new development must respect the wider Conservation context of the asset, with particular regard to important Areas for views of the districts built heritage and landscapes’. preserving heritage assets and tourism Policy should Crown Estate (51946) Agree The NPPF para 197 p.56 refers to non-designated heritage Minor modification - refer to ‘non- assets. Amend terminology to designated rather Historic England accord with NPPF. than (929489) ‘undesignated’ / Crest Strategic Projects clarify and Bloor Homes archaeological (1158079) site of national importance’ CEG (1158030) Policy paragraph Historic England Agree The NPPF para 194 refers to the ‘significance of the Minor modification - 6 ‘the significance (929489) heritage asset’. Amend terminology to of the heritage accord with NPPF asset’ should be amended. ‘Worthy of conservation’ implies

designated assets are not worthy

Policy should Crown Estate (51946) Agree Amend to accord with the Act. Minor modification - to mention setting of accord with the Act Conservation Historic England Areas & Listed (929489) Buildings. Crest Strategic Projects and Bloor Homes (1158079) CEG (1158030) Policy is incorrect CEG (1158030) Disagree Para 184 of the NPPF refers to the desirability of sustaining No change. as there is no and enhancing the significance of heritage assets. enhancement of scheduled ancient monument test in NPPF. Policy does not Legal and General Agree NPPF paras 195 & 196 refer to where a proposed No change reflect NPPF, as (1051022) development will lead to substantial harm, consent should it does not refer be refused unless demonstrated that the substantial harm is to the tests of necessary to achieve public benefits that outweigh that ‘substantial’ and harm. ‘less than substantial harm’

Include locally Historic England Disagree The NPPF includes local listing within the definition of a Website information will specific/distinctive (929489) heritage asset and conservation areas are designated be updated as necessary elements and heritage assets. Applications can be made to SADC for on ongoing basis. possible criteria inclusion of a building that falls within designated for the conservation area on the local list that at present does not designation of warrant inclusion on the statutory list. Local listed buildings locally listed are considered to make positive contribution to the character buildings. and appearance of the conservation area. LLB information and designation criteria are matters of detail recorded in CACS and GIS information.

Policy should Historic England Disagree The NPPF para 185 states that strategy for conservation No change omit criterion (a) (929489) should take into account the desirability of sustaining and regarding flexible enhancing the significance of heritage assets and putting approach to them to viable uses consistent with their conservation. It is viable uses not helpful to the future of listed buildings to preclude other viable uses which may secure upkeep and survival. Policy should Historic England Agree The NPPF refers to harm should be weighed against the Minor modification - to refer to ‘public (929489) public benefits of the proposal including securing its optimal ‘public benefits’ benefits’ rather viable use. than ‘planning benefits’ No policy for Historic England Disagree The NPPF para. 185 states that plans should set out No change Heritage at Risk (929489) positive strategy for the historic environment including or for heritage assets most at risk. This is already set out in L30. management of a Historic England maintain a list of buildings at risk (3 SADC register. – Devils Dyke & the Slad; Aubrey’s Camp and Sopwell Priory and Sopwell House). The SA Scoping report lists the Buildings at Risk within SADC.

Include historic Historic England Disagree Cross reference Monitoring Framework. No change environment (929489) within monitoring It is acknowledged that monitoring and review are essential indicators in establishing how the objectives of the plan are being achieved and whether any changes are required. However the Monitoring Framework is for core indicators only. In practice the Council will note any significant issues / changes in respect of the historic environment in its AMR. Buildings at risk records are maintained. Include heritage Historic England Noted Within the library of documents for the LP 2018 there is a No change technical terms (929489) glossary which includes technical terms on the historic within glossary environment: https://www.stalbans.gov.uk/Images/Glossary_tcm15- 64812.pdf The intention is that this would be maintained as an online resource with a link to the final plan document. Include pre- Hertfordshire County Agree The NPPF para 189 states that ‘where a site on which No change application Council (837689) development is proposed includes, or has the potential to archaeological include, heritage assets with archaeological interest, local assessments CEG (1158030) planning authorities should require developers to submit an within appropriate desk based assessment and where necessary a development field evaluation’. briefs. Include reference to This will be an important issue for the masterplanning refusal of process (S6). development that would adversely affect currently undiscovered assets.

Suggest known Hertfordshire County Noted The Hertfordshire Historic Environment Record is an online No change heritage assets Council (837689) database and public resource. It would be of benefit that all are recorded on heritage assets are recorded. This is already an agreed the Hertfordshire approach / process. It is not necessary to include this in the County Council’s Plan policy. The Plan (Para 1.10) explains that information Historic will be regularly updated on the on-line GIS based part of Environment the policies map. Record Appendix 1 – New Development Parking Guidance and Standards

Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Parking provision 1144419 Noted They haven’t been. These parking provisions are set based No change shouldn’t be set on the evidence of a mix of buyers, many of whom will not based on the be commuters. assumption that potential buyers will predominantly be commuters Sufficient parking 1144419 Disagree Appendix 1 table sets out parking requirements for houses No change must be provided in multiple occupation. to accommodate conversions to As set out in policy L20, parking provision for changes of multiple use or extensions shall reflect the number of spaces occupation. required for the new use of the extension.

Provision of more 1153802 Noted Appendix 1 sets out cycle parking requirements for C3 No change cycle parking Residential areas. spaces in residential areas Policy L20 and footnote 21 directs to guidance on the is necessary to provision of good quality cycle parking.- The sources encourage provided also cover safety and security for cycle parking cycling. They spaces. should also be Extract from LP Policy L20: provided in convenient “For guidance on the provision of good quality cycle parking locations with refer to Chapters 2,3,4 and 5 of Transport Initiatives LLP secure fixings. and Cambridge City Council ‘cycle Parking Guide for New Cycle parking Residential Development 2010’^21 and any subsequent standards to guidance/ amendments. This document is considered best reference the practice and appropriate for application in St Albans BRE Home District.” Quality Mark scheme. More cycle 1153802 Agree Appendix 1 sets out cycle parking requirements for Public No change parking required Transport facilities. at rail stations based on current Refer to policies L18 and S6 which address the need for and future providing intra-urban cycle links and ones connecting new population developments to city centres. Additionally, policy L23 sets changes and out the design and layout requirements for new commute developments by highlighting the need for prioritising patterns. This sustainable transport measures/ non-car movement. should also take Sustainable transport measures are encouraged by Policy place in 18, 19 and 20. conjunction with designing cycle routes into town from developments.

Appendix 1 table St Albans Cycle Disagree Appendix 1 sets out cycle parking requirements for C3 No change doesn’t prioritise Campaign (346623) Residential areas. cycling or follow the requirement 1185967 Policy L20 and footnote 21 directs to guidance on the for good quality provision of good quality cycle parking using the cycle provision in Cambridge’s ‘Cycle and Parking Guide for New Residential residential areas. Development 2010’. The Local Plan Extract from LP Policy L20: needs to adopt a much simpler “For guidance on the provision of good quality cycle parking Cambridge refer to Chapters 2,3,4 and 5 of Transport Initiatives LLP spaces and Cambridge City Council ‘cycle Parking Guide for New standards. Residential Development 2010’^21 and any subsequent guidance/ amendments. This document is considered best practice and appropriate for application in St Albans District.” The proposed Hilton House Properties Disagree Appendix 1 sets out cycle parking requirements for C3 No change parking provision (1057476) Residential areas. will lead to an over-provision of The Plan promotes sustainable travel behaviour including parking spaces through the introduction of parking zones where a degree of within residential parking restrain is imposed. This approach reduces on site developments provision in the locations most accessible to services and which are located facilities and to public transport. in highly Refer to policy L20 for more information on car parking accessible standards for new developments which are also based on locations that are the zonal approach. well-served by public transport Appendix 1 zoning can allow for schemes below standards services (this to be acceptable in sustainable locations. encourages vehicle use)

Appendix 2 – Housing Trajectory Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Insufficient Martin Grant Homes and Disagree Evidence on development strategy / site selection is No change evidence to Kearns Land (975683) available in full. support the strategy for CP Holdings (1158145) meeting the 973643 Council’s housing requirement. 1153650 The trajectory Martin Grant Homes and Disagree Evidence on development strategy/ site selection is No change includes a Kearns Land (975683) available in full. number of dwellings that RF Sinclair and Sons cannot be (1058251) considered to be deliverable in the context of the definition in the glossary of the NPPF without further, clear justification. No justification for Martin Grant Homes and Disagree Paragraph 68 of the NPPF states the “local planning No change the windfall Kearns Land (975683) authorities should support the development of windfall allowance of 95 sites through their policies and decisions- giving great dwellings in Hunston Planning weight to the benefits of using suitable sites within existing 2020/21 and 105 Limited (1185622) settlements for homes.” There is no conflict with NPPF. dwellings per Minister Court Frogmore annum thereafter. (1185980)

London Colney Limited (977496) Home Builders Federation Ltd (1156936) 973643 Don’t believe the Hunston Planning Disagree Evidence on development strategy / site selection is No change evidence Limited (1185622) available in full supports the assumption that an additional 80 homes will be delivered from 2025/26 No justification Martin Grant Homes and Disagree Full and detailed justification is provided by evidence No change given for the Kearns Land (975683) documents. delivery rates from the broad location sites. The trajectory is RF Sinclair and Sons Disagree The Plan necessitates a significant change in approach No change not anticipated to (1058251) from previous tight Green Belt restraint. This involves a deliver the annual carefully considered stepped trajectory for delivery of new total of 913 Minister Court Frogmore sites that are best able to deliver to the overall plan homes until after (1185980) development strategy. 2025. Thakeham Homes (1187005) Wrenbridge Land Ltd (1187023) London Colney Limited (977496)

Home Builders Federation Ltd (1156936) No evidence has Minster Court Frogmore Disagree The Plan necessitates a significant change in approach No change been provided to (1185980) from previous tight Green Belt restraint. This involves a justify the split of carefully considered stepped trajectory for delivery of new annual housing sites that are best able to deliver to the overall plan requirement into development strategy. There are sufficient deliverable three time periods sites for years 1-5. This is confirmed in relevant developer representations.

Concerned about RF Sinclair and Sons Noted The Plan necessitates a significant change in approach No change the provision of (1058251) from previous tight Green Belt restraint. This involves a 2,300 homes carefully considered stepped trajectory for delivery of new from the ‘Park sites that are best able to deliver to the overall plan Street Garden development strategy. Village’ given the fact this is a major Green Belt release and the potential challenge with rail freight. Sceptical about RF Sinclair and Sons Noted The Plan necessitates a significant change in approach No change the realistic (1058251) from previous tight Green Belt restraint. This involves a housing delivery carefully considered stepped trajectory for delivery of new on large housing Comer Group (872799) sites that are best able to deliver to the overall plan allocations. Wrenbridge Land Ltd development strategy. (1187023) Concerns about Hunston Planning Disagree The Plan necessitates a significant change in approach No change the robustness of Limited (1185622) from previous tight Green Belt restraint. This involves a carefully considered stepped trajectory for delivery of new

the housing sites that are best able to deliver to the overall plan trajectory. development strategy. There is a lack of Hunston Planning Disagree Concentrating development in larger sites that can create No change small and Limited (1185622) new communities and effectively deliver infrastructure is a medium-sized key part of the development strategy. Small sites of half a sites. hectare or less have been and will continue to be an important source of housing land supply through windfall. No detailed Wrenbridge Land Ltd Disagree The Plan necessitates a significant change in approach No change evidence has (1187023) from previous tight Green Belt restraint. This involves a been put forward carefully considered stepped trajectory for delivery of new to justify the London Colney Limited sites that are best able to deliver to the overall plan stepped (977496) development strategy. There are sufficient deliverable trajectory, nor to Home Builders sites for years 1-5. This is confirmed in relevant developer set out what Federation Ltd representations. alternative (1156936) approaches the Council has Owners of Land South of explored. Burydell Lane (1186128) 973643 1153650 1186131 There is a risk of 973643 Noted The main site owner has promoted the site as available No change a protracted legal and deliverable for housing. Considerations have taken dispute occurring into account the existing planning permission for an for the garden alternative use and other relevant factors. village site which can derail the housing trajectory assumptions about dwelling

completions on the site. Support the 973643 Noted Support noted No change standard methodology of 1153650 913 dwellings per annum Recommend 1153650 Disagree The Plan necessitates a significant change in approach No change speeding up from previous tight Green Belt restraint. This involves a delivery through carefully considered stepped trajectory for delivery of new granting planning sites that are best able to deliver to the overall plan permissions on development strategy. There are sufficient deliverable some of the sites for years 1-5. This is confirmed in relevant developer proposed representations. allocations ahead of the Local Plan adoption. The housing Aurora Properties Disagree The Plan necessitates a significant change in approach No change trajectory fails to Limited (1151817) from previous tight Green Belt restraint. This involves a meet the five year carefully considered stepped trajectory for delivery of new housing supply sites that are best able to deliver to the overall plan and appears to development strategy. There are sufficient deliverable be sites for years 1-5. This is confirmed in relevant developer unsubstantiated. representations. Recommend the Thakeham Homes Disagree The Plan necessitates a significant change in approach No change allocation of more (1187005) from previous tight Green Belt restraint. This involves a sites to ensure a carefully considered stepped trajectory for delivery of new five year housing Comer Group (872799) sites that are best able to deliver to the overall plan land supply is Home Builders development strategy. There are sufficient deliverable provided with the Federation Ltd sites for years 1-5. This is confirmed in relevant developer starting year as (1156936) representations. 2020 is the earliest realistically possible 2018.

CP Holdings (1158145) date of adoption of the Plan and is therefore appropriate in the context of the new draft and final NPPF. The plan relies on Department of Health & Disagree 2020 is the earliest realistically possible date of adoption of No change the plan period of Social Care and Bloor the Plan and is therefore appropriate in the context of the 2020-2036 which Homes (1156886) new draft and final NPPF. is inconsistent with the PPG. 977496 Lack of evidence Wrenbridge Land Ltd Disagree 2020 is the earliest realistically possible date of adoption of No change to justify the (1187023) the Plan and is therefore appropriate in the context of the reason why the new draft and final NPPF. plan period Gladman Developments begins from 2020 Ltd (1187201) and not 2018 Object to the plan Gladman Developments Noted 2020 is the earliest realistically possible date of adoption of No change period of 2020- Ltd (1187201) the Plan and is therefore appropriate in the context of the 2036. new draft and final NPPF. London Colney Limited (977496) There is a lack of Gladman Developments Disagree The Plan necessitates a significant change in approach No change flexibility provided Ltd (1187201) from previous tight Green Belt restraint. This involves a with the housing carefully considered stepped trajectory for delivery of new trajectory. Owner Pound Farm & sites that are best able to deliver to the overall plan East of Sandridge development strategy. There are sufficient deliverable (1187227) sites for years 1-5. This is confirmed in relevant developer representations. Request for the Gladman Developments Disagree 2020 is the earliest realistically possible date of adoption of No change Council to amend Ltd (1187201) the Plan and is therefore appropriate in the context of the the housing plan new draft and final NPPF. Evidence is available in full. period to align with supporting evidence base.

The adoption of a Gladman Developments Disagree The Plan necessitates a significant change in approach No change more balanced Ltd (1187201) from previous tight Green Belt restraint. This involves a strategy with a carefully considered stepped trajectory for delivery of new greater role for sites that are best able to deliver to the overall plan non-strategic development strategy. There are sufficient deliverable sites would sites for years 1-5. This is confirmed in relevant developer increase the representations. amount of development which might realistically occur within the shorter term, therefore reducing the need for a stepped housing requirement. The plan relies Owner Pound Farm & Noted Concentrating development in larger sites that can create No change heavily on large East of Sandridge new communities and deliver infrastructure is a key part of strategic growth (1187227) the development strategy. locations to meet the District’s housing needs. The base date Home Builders Disagree 2020 is the earliest realistically possible date of adoption of No change used for Federation Ltd the Plan and is therefore appropriate in the context of the assessing (1156936) new draft and final NPPF housing needs is not consistent with the approach set out in the PPG.

Do not consider it Home Builders Disagree 2020 is the earliest realistically possible date of adoption of No change appropriate for Federation Ltd the Plan and is therefore appropriate in the context of the the unanticipated (1156936) new draft and final NPPF. delay factor to be redistributed across the remaining plan period. Suggest that it would be better to rebase the plan period from 2018 and include any unimplemented planning permissions as part of their expected supply trajectory. Urban Home Builders Disagree Supply from urban optimisation is categorised separately No change optimisation Federation Ltd from windfall as it results from the new strategy set out in allowance should (1156936) the new LP/NPPF. There is no double counting. be included in windfall CP Holdings (1158145) allowance to avoid potential double counting in the supply estimates. Urban Anderson Group Disagree The LP/NPPF prioritises achieving optimal housing No change optimisation has (1146719) densities and appropriate mix of sizes / types. no status or policy driver to implement it and

should be Home Builders removed Federation Ltd (1156936)

Support the Crown Estate (51946) Noted Support noted No change housing trajectory as robust and deliverable. SHLAA should be CP Holdings (1158145) Disagree Please refer to Appendix 2. There are sufficient deliverable No change reviewed to sites for years 1-5. ensure there are enough sites to be delivered within 5 years of adoption 364 dwellings for CP Holdings (1158145) Disagree Small sites of half a hectare or less have been and will No change pre-application continue to be an important source of housing land supply and submitted through windfall. Please refer to Appendix 2. There are applications is sufficient deliverable sites for years 1-5. unreliable as there is no guarantee the application will be submitted, or be refused Housing delivery CP Holdings (1158145) Disagree Concentrating development in larger sites that can No change should be effectively deliver infrastructure is a key part of the focused on site development strategy. Small sites of half a hectare or less allocations have been and will continue to be an important source of primarily housing land supply through windfall. Please refer to Appendix 2.

Appendix 3 – Monitoring Framework Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Plan monitoring Aboyne Residents Disagree The Monitoring Framework is deliberately designed to No change arrangements Association (1181214) focus on the essential areas where the NPPF requires the undeveloped: do Council to track progress, particularly in provision of not judge relative 867312 development land. Other matters are contextual and it may progress towards be possible to include some elements in wider monitoring. long-term aims Include Historic England Disagree This is not an essential part of the Plan Monitoring No change monitoring and (929489) Framework. Other matters are contextual and it may be indicators for the possible to include some elements, including historic historic buildings at risk and conservation area appraisal and environment enhancement progress in wider monitoring. The monitoring Hertfordshire Country Disagree This is a strategy and policy issue (dealt with elsewhere). No change target for Council (837689) It is not a matter relevant to the Monitoring Framework. “Metropolitan Green Belt” justifies the need to remove associated school build zones from the Green Belt

Appendix 4 – Infrastructure Delivery Schedule Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Support ongoing Trustees of James Henry Noted Support noted No change updates to the Frank Sewell Deceased IDP (1185630) Support the IDS Department for Noted Support noted No change for providing the Education (1186955) latest information on the IDP Suggest the Department for Noted Work on the infrastructure evidence base has been IDP will be updated on an provision of an Education (1186955) ongoing and IDP updates will reflect the latest position ongoing basis. addendum to the IDS which provides a summary for projections of capacity and need for school places and schools based on the forecast housing growth at allocated sites. This should also include any need for additional special educational needs places.

IDP is not Redbourn Parish Council Noted Work on the infrastructure evidence base has been IDP will be updated on an updated (759908) ongoing and IDP updates will reflect the latest position. ongoing basis. alongside IDS. This questions Leverstock Green Village the robustness of Association (1185907) the strategy. Hertfordshire County Council (837689) Proposes an Legal and General Noted IDS is a live document which will be updated at IDP will be updated on an amendment to (1051022) appropriate intervals as and when further information ongoing basis. IDS to reflect the becomes available. Work on the infrastructure evidence full range of base for Broad Locations such as NW Harpenden has infrastructure been ongoing and IDP updates will reflect the latest benefits arising position. from the NW Harpenden allocation. Inconsistency Legal and General Disagree No inconsistency – health need and provision to be No change between policy (1051022) addressed through Masterplanning and planning S6 viii) and IDS applications, similarly to other Broad Locations. table: Appendix 4 indicates that North West Harpenden site will provide 139sqm on-site health facility which has not been stated as a requirement in policyS6 viii) policy.

Request the Adrian Irving and Alban Disagree Health need and provision to be addressed through No change removal of the Developments Ltd Masterplanning and planning applications, similarly to reference to the (1156368) other Broad Locations. delivery of 87sqm of healthcare floor-space at ‘West of Chiswell Green’ site. Given the existing healthcare capacity of the area and the size of the facility offered, this provision is not required. Supports the Welwyn Hatfield Borough Noted Support noted No change requirement to Council (52397) make appropriate provisions to infrastructure. The IDS doesn’t Hertfordshire County Disagree That level of detail is not required for the IDS at this stage. No change identify the Council (837689) The matter of highway/ transport infrastructure required necessary can be properly addressed through the IDP and highway/transport Masterplanning processes. infrastructure that will be required. IDS needs to be Hertfordshire County Noted Ongoing iterative discussions with HCC IDP will be updated on an updated in Council (837689) ongoing basis. relation to school provision and school costs

Appendix 5 - List of smaller residential sites with permission Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Suggest a better RF Sinclair and Sons Disagree This is done in Appendix 2 Housing trajectory No change presentation of (1058251) the list of small sites by totalling them up Data used on RF Sinclair and Sons Disagree Appendix 2 Housing trajectory deals with this – NB: No change small sites is not (1058251) Appendix 5 includes a couple of duplicate permissions on comprehensive same sites. due to the repeat entries and no presentation of the relationship to housing land supply. It is unclear Aurora Properties Disagree Appendix 2 Housing trajectory deals with this No change whether the Limited (1151817) housing supply for small sites is additional housing or whether it is net of any housing demolitions. Small sites will Hunston Planning Disagree The list was largely designed to be illustrative. Future No change not address any Limited (1185622) supply will include additional small sites. percentage of the housing requirement in

the Local Plan because they will be built before the start of the Plan Period. Lack of evidence Hunston Planning Agree The housing trajectory (and other evidence) shows 10% No change to show why the Limited (1185622) level is achievable. 10% target for small and medium sized sites, by the NPPF, cannot be achieved. Appendix 6 – Housing Mix Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) Question 867068 Disagree Evidential basis is summarised in Appendix 6 itself and No change justification for more detail supporting the Local Plan is available in full. mix No evidence is 867068 Disagree Evidential basis is summarised in Appendix 6 itself and No change provided to more detail supporting the Local Plan is available in full. demonstrate what percentage of the local population cannot afford to buy (or rent) at the Market Value No justification 867068 Disagree Evidential basis is summarised in Appendix 6 itself and No change has been more detail supporting the Local Plan is available in full. provided for the

proportion of affordable housing (types) Mix results in 867312 Disagree Affordable housing will be of different types; creating a No change over balanced housing offer meeting most pressing needs. concentrations of 1184750 affordable housing and will not create balanced communities Concerns that 867312 Disagree The NPPF prioritises achieving optimal housing densities No change different housing and appropriate mix of sizes / types. This will apply to any density urban development / expansion. requirements will be applied across the boundary of Dacorum and SADC. Concerns that 867312 Disagree The NPPF prioritises achieving optimal housing densities No change building mass and appropriate mix of sizes / types. This will apply to any concentrations of urban development / expansion. affordable units at the proposed mix of sizes, and on the scale proposed, will unbalance the structures necessary for thriving innovative- and

balanced- communities. The minimum St Albans Labour Party Disagree This mix not appropriate due to viability, deliverability and No change target for (1183933) community balance/ cohesion affordable housing must be set to 75% affordable homes on sites of 10 dwellings or more, to match the level indicated in housing evidence Suggest a greater 1184750 Disagree Evidential basis for specific mix is summarised in Appendix No change social mix with 6 itself and more detail supporting the Local Plan is 40% social and available in full. This mix not appropriate as doesn’t affordable correlate to evidence and due to viability, deliverability and housing, 30-40% community balance / cohesion. 2-4 bedroom housing and 20% 4-6 bedroom housing Reducing the Aboyne Residents Disagree The mix includes a substantial element of family size No change supply of large Association (1181214) housing. homes affects future flexibility for family use / community balance

Support approach Trustees of James Henry Noted Support noted No change to meeting Frank Sewell Deceased affordable (1185630) housing need, including mix Mix needs to be Dacorum Borough Disagree The mix does not differ greatly from that suggested by No change updated to match Council (1186054) existing SWHG research and also reasonably reflects SWHG research particular local needs as evidenced in more detail in SADC (once it is research evidence. completed) Annex 1 – Broad Location (BL) Area and Base Capacity Calculations (in Hectares – Ha) Representation Representor Raising Outline Recommended Reply (including notes and Suggested Actions Point Point Reply references) (including any Changes to Plan) Park Street Butterfly World Project Disagree Site selection is firmly based on comprehensive GB work No change Garden Village Ltd (1183965) which identified the allocated Broad Locations. Broad Location and its associated Concentrating development in larger sites that can create data should be new communities and deliver infrastructure is a key part of removed and the development strategy. replaced with the Butterfly World site in Chiswell Green Request school Department for Disagree Some school sites are on land excluded from the Green No change buildings as well Education (1186955) Belt and some are not, as set out here. Policy approach as the playing set out at S3 and L21 fields be removed from the green belt

Query the Department for Disagree School site allocations based on evidence and work with No change justification of the Education (1186955) HCC. Policy approach set out at S3 and L21 school site allocations Delete ‘in GB’ Hertfordshire County Disagree School site allocations based on evidence and work with No change from title of Council (837689) HCC. Policy approach set out at S3 and L21 column six. Sustainability Appraisal Representation Representor Raising Outline Recommended Reply (including notes and Suggested Actions Point Point Reply references) (including any Changes to Plan)

The SA/SEA Taylor Wimpey Strategic Noted See Sustainability Appraisal full report. No change does not consider Land (1187472) other/all specific sites that have Martin Grant Homes and been put forward Kearns Land (975683) and fails to ERLP 1 Sarl (1123561) provide an assessment for M Scott Properties them, explaining (1185993) why they have Mr Pete Hutchison been rejected (1153268) Department of Health & Social Care and Bloor Homes (1156886) Owner Pound Farm & East of Sandridge (1187227)

Helioslough Ltd (1182085)

The SA has not Leverstock Green Village Noted See Sustainability Appraisal full report. No change considered the Association (1185907) impact of increasing the 334023 East Hemel South proposed dwellings development by 140% The SA should 1153741 Noted See Sustainability Appraisal full report. No change contain a fuller assessment and development scoping exercise must be carried out on the East Hemel Hempstead (North) development to ensure that the area maintains an appropriate landscaping and character, sympathetic to the nearby settlement

The SA doesn’t Environment Agency Noted See Sustainability Appraisal full report. No change currently provide (1147557) any explicit commentary on the process the Council undertook to apply the sequential test based on the latest SFRA, taking future climate change into account Support the SA 1185695 Noted See Sustainability Appraisal full report. No change 1186062 There is no Stackbourne Limited Noted See Sustainability Appraisal full report. No change compatibility (1153646) between the Vision and Objectives listed within the Plan and the SA objectives The Plan and SA Helioslough Ltd Noted See Sustainability Appraisal full report. No change have not been (1182085) positively prepared as they Department of Health & disregard the Social Care and Bloor planning Homes permission that (1156886)

exists for the SRFI Disagree with Helioslough Ltd Noted See Sustainability Appraisal full report. No change outcomes of SA (1182085) assessment of Park Street Garden Village against the sustainability objectives SA incorrect that Helioslough Ltd Noted See Sustainability Appraisal full report. No change prior gravel (1182085) extraction will have destroyed all remains as some of the site has not been quarried. SA incorrect to Helioslough Ltd Noted See Sustainability Appraisal full report. No change refer to site as (1182085) previously developed land - land developed for minerals extraction excluded by paragraph 70 of NPPF SA and the Plan Helioslough Ltd Noted See Sustainability Appraisal full report. No change are not (1182085) considered to be consistent with

national policy as they don’t aim to deliver sustainable development The SA is Helioslough Ltd ( Noted See Sustainability Appraisal full report. No change misleading in its 1182085) assessment of PSGV. It includes ambiguous statements, does not consider site constraints which could hinder development proposals, and ignores the loss of benefits resulting from not providing the SRFI. No M Scott Properties Noted See Sustainability Appraisal full report. No change acknowledgemen (1185993) t of the planning permission for the SRFI on the site of the proposed Park Street Garden Village The SA Trustees of James Henry Noted See Sustainability Appraisal full report. No change demonstrates full Frank Sewell Deceased compliance with (1185630) the Plan’s

requirement to consider social, economic and environmental factors SA methodology M Scott Properties Noted See Sustainability Appraisal full report. No change excludes small to (1185993) medium sites in sustainable locations with facilities beneficial for any development SA is inconsistent M Scott Properties Noted See Sustainability Appraisal full report. No change with the proposed (1185993) 2020 commencement date for the Local Plan The SA should M Scott Properties Noted See Sustainability Appraisal full report. No change provide an (1185993) objective- led approach Department of Health & whereby the Social Care and Bloor potential impacts Homes of a development (1156886) plan, its allocations and all reasonable alternatives are appraised to the same level of detail in order to

identify their contribution to sustainable development Support the SA M Scott Properties Noted See Sustainability Appraisal full report. No change statement that not (1185993) all villages are suitable for accommodating growth The SA fails to Redbourn Parish Council Noted See Sustainability Appraisal full report. No change address the (759908) negative consequences of housing provision on large strategic sites and the impacts this has on supply No consultation Redbourn Parish Council Noted See Sustainability Appraisal full report. No change was undertaken (759908) for North East Redbourn site at the Issues and Options stage. Unclear how the site (as well as other ‘omission sites’) was explored as an alternative in the

Sustainability Appraisal (SA) The Plan and the Department of Health & Noted See Sustainability Appraisal full report. No change accompanying Social Care and Bloor SA rely on much Homes of the previous (1156886) work undertaken to support the Strategic Local Plan (SLP) and draft Detailed Local Plan (DLP), the evidence base for which is out of date The council Owner Pound Farm & Noted See Sustainability Appraisal full report. No change hasn’t consulted East of Sandridge on the SA (1187227) Agree with the Hertfordshire County Noted See Sustainability Appraisal full report. No change supporting Council (837689) statement in the SA with regards to flood risks but recommend the creation of an aim of new development that contributes to reducing existing flood risk (where applicable)

Sustainability Land at The Dak Noted See Sustainability Appraisal full report. No change implications of the (1186131) spatial strategy have not been Owners of Land South of properly Burydell Lane (1186128) assessed General Comments Representation Representor Raising Outline Recommended Reply (including notes and references) Suggested Actions Point Point Reply (including any Changes to Plan) The prolonged 1153741 Noted Public consultation processes are primarily statutory. No change feedback process Website used successfully by many hundreds of and website 963110 respondents. Alternative routes of submission – hard copy difficulties would 1185950 etc. – supported by SADC. deter people from submitting responses Concerns with the 963110 Noted All consultation responses that raise material planning No change existence of a considerations are taken into account during the plan knowledge and 1185950 making process. expertise gap between policy and representations, arising from a lack of knowledge of the planning procedures. This suggests that some responses will have more weight in shaping

the local plan than others Agree with the 1185775 Noted Support noted No change figures used for the preparation of the Local Plan Would like to see 1121386 Noted Policy S1 sets out a clear approach and positively No change a stronger supports residential development in existing urban areas, commitment to subject to other policies. the residential development of brownfield land, particularly rear gardens of existing residential properties, as a method of increasing the number of new dwellings in the district Support all 1185695 Noted Support noted No change aspects of the Local Plan 1186018 1185939 1186062 CALA homes 1185695 Noted Applications on this site will be assessed against relevant No change proposed planning polices and material considerations. development in 1185939 Bedmond Lane 1186062 Meadow must be

refused as it is designated an Asset of Community Value Concern with the London Wates (Bricket Disagree Policies reflect overall government / NPPF approach No change consistency of the Wood) Limited local plan due to (1186996) the existence of policies which fail 52064 to establish a link with the Government policy and guidance ‘Chapter 5- 1185950 Disagree There has been ongoing joint working with residents, No change Design, landowners, local communities and other stakeholders. Conservation and Enhancement of the natural, built and historic environment’, drawn up with the help of the communities, was not promoted Recognise the St Albans Civic Society Noted Noted No change importance of a (156974) new Local Plan The LPA must Intrasales Ltd (1157383) Disagree Housing requirement/targets are based on the standard No change adopt a more methodology set out by the government – see S4. holistic spatial approach to

delivering Site selection is firmly based on comprehensive GB work housing that which identified the allocated Broad Locations. plans positively and enables Concentrating development in larger sites that can create sustainable new communities and deliver infrastructure is a key part of locations in the the development strategy. district to play a greater role in meeting the area’s housing requirements Difficulty in Martin Grant Homes and Disagree Full and detailed justification is provided by evidence No change understanding the Kearns Land (975683) documents. It is not necessary to justify the Plan within the justification for Plan document itself. To do so would result unnecessarily the local plan in a longer and more complex document. policies due to the constant need to cross- reference with the SA

List of Site Promotions: Residential (Strategic and Small Scale), Employment and Mixed Use

Residential (Strategic and Small-scale) Burston Garden Centre CWC Group (no specific site promotion) Dunstable Road Redbourn Eaton Lodge, Punch Bowl Lane Former Butterfly World Former HSBC Training Centre at Smug Oak Lane Glinwell site, Hatfield Road, St Albans Hanstead Park Harper Green Garden Village Harper Lodge Industrial Estate and Ivory Racing Stables Land adjacent to Breakspears Land at Batchwood Drive Land at Boissy Close Land at Common Lane, Harpenden Land at Gaddesden Lane Land at Greenway to the South of London Road Land at Hill Dyke Road, Wheathampstead Land at Lye Lane- Intrasales Ltd

Land at Noke Side, Chiswell Green Land at Park Street Lane, How Wood Land West of Watling Street, Park Street Land at Piggottshill Lane Land at Roundhouse Farm Land at the Dak, Colney Heath Lane Land at Tollgate Road Land at Windridge Farm Land between Bedmond Lane and Mayne Avenue Land between Tollgate Road & Coursers Road Land East of Common Lane, Batford Land east of Redbourn Land north east of Redbourn Land north of Ragged Hall Lane, Chiswell Green Land North Of Redbourn Land North of Sandridge Land off Shenley Lane, London Colney Land Rear of the Cherry Tree, Wheathampstead Land South of Alban Way Land South of Burydell Lane Land south west of Fishpool Street

Land to the East of Napsbury Lane [Napsbury Fields] Land to the east of Sandridge Land west of Redbourn Land West of Westminster Fields Harpenden Land West of London Colney Moor Mill North Moor Mill South Sauncey View Lodge, Common Lane, Harpenden North of Napsbury North of Wheathampstead Road Notcutts Garden Centre, Hatfield Road, St Albans Orchard Drive, How Wood, St Albans Orchard Garage Woodcock Hill Park Street Baptist Church, Tippendell Lane Pound Farm Radio Nurseries Radlett Road, Frogmore, St Albans Land at Radlett Redbourn Golf Club & Aldwickbury Park Golf Club Roundhouse Farm Tollgate Farm

Townsend Lane Tyttenhanger- Tarmac Vacant Weight Training Club, Leyland Avenue Verulam Golf Club, London Road Land at Wheathampstead

Employment Land adjoining Copsewood, North Orbital Road, St Albans Land at Roehyde Land North West of Colney Fields

Mixed Use Burston Site Land east of Watling Street Smallford Works

List of abbreviations used

BL – Broad Location CCOS – City Centre Opportunity Site CHP – Combined Heat and Power DBC - Dacorum Borough Council EHH – East Hemel Hempstead EIA – Environmental Impact Assessment EZ – Enterprise Zone GBR – Green Belt Review GDPO - General Permitted Development Order GTANA – Gypsy and Traveller Accommodation Needs Assessment

HBC – Hertsmere Borough Council HCC – Hertfordshire County Council HSE – Health and Safety Executive IDP – Infrastructure Deliver Plan IDS – Infrastructure Delivery Schedule JSP – Joint Strategic Plan LEP – Local Enterprise Partnership

LGS – Local Green Space LP - Local Plan LPA - Local Planning Authority SADC – St Albans City and District Council MMTI – Multi Modal Transport Interchange MoU – Memorandum of Understanding NPPF – National Planning Policy Framework PSGV – Park Street Garden Village SA – Sustainability Appraisal SEA – Strategic Environmental Assessment SEP – Strategic Economic Plan SFRA – Strategic Flood Risk Assessment SRFI – Strategic Rail Freight Interchange SWHG– South West Herts Group SHMA – Strategic Housing Market Area WHBC – Welwyn Hatfield Borough Council