Date: 16 August 2016 Your Ref. Our Ref: Contact: Laura Wood Email: Laura.wood@dacorum.gov.uk Directline: 01442 228661

Ms Louise St John Howe PO Services Civic Centre PO Box 10965 Marlowes Sudbury Hemel Hempstead Hertfordshire Suffolk HP1 1HH CO10 3BF Telephone: 01442 228000 www.dacorum.gov.uk ! DX 8804 Hemel Hempstead D/deaf callers, Text Relay: 18001 + 01442 228000

Dear Ms St John Howe Luton Local Plan examination – stage 2 hearings

With reference to your email of 2 August 2016, I confirm that Dacorum Borough Council does not wish to be represented at the stage 2 hearing sessions.

We are content to rely on our representations of 7 December 2015 on the pre-submission plan, but would also like to comment briefly on Matter 2, question 17 which asks:

“Is the Luton HMA correctly and accurately described in paras 1.18, 4.5 and 4.7 of the Plan? In particular, is any part of Dacorum Borough Council within the Luton HMA? [see Council’s ‘minor modifications’ MOD9 & MOD29]”

The ‘Luton and Central Bedfordshire Strategic Housing Market Assesment Refresh 2014’ (examination document HOU 003b) included two small parts of Dacorum in the Markyate and Gaddesden Row areas within the Luton Housing Market Area. In our letter of 20 July 2014 in response to the Draft Luton Local Plan we commented that the Dacorum parts of the Luton HMA were rural areas, not well served by services and facilities and therefore not considered suitable locations for growth.

The boundaries of the Luton HMA were reviewed in the ‘Housing Market Areas in Bedfordshire and surrounding areas’ report (examination document HOU 003d). The conclusions are set out in section 5 and Figure 38 shows that Luton HMA’s functional boundary no longer extends into Dacorum.

Figure 38 in document HOU 003d appears in the report prior to dentification of a ‘best fit’ for each functional HMA based on local planning authority boundaries (see paragraphs 5.20- 5.38). Paragraphs 5.20 and 5.21 refer to the previous 2007 CLG advice note and the Planning Advisory Service Objectively Assessed Need advice note, which recommended a best fit approach. Paragraph 5.32 concludes that the combined area of

Luton borough and Central Bedfordshire represents the most appropriate best fit for the Luton functional HMA.

Paragraphs 5.39-5.46 in document HOU 003d summarise stakeholder feedback about the document’s conclusions and the proposed HMAs. Paragraphs 5.45 and 5.46 set out the response from Dacorum Borough Council on behalf of the South West Hertfordshire SHMA partnership (Dacorum, Hertsmere, Three Rivers, Watford). The response stated that the partnership agreed with the broad conclusion of the study. It also noted the consistency with the SW Herts SHMA (January 2016), which concluded that the logical best fit HMA for SW Herts comprises the Dacorum, Watford, Three Rivers, Hertsmere and St Albans Council areas.

Please follow the link below to view the SW Herts SHMA (section 2 and Appendix A deal with the definition of the HMA): http://www.dacorum.gov.uk/home/planning-development/planning-strategic-planning/new- single-local-plan/technical-work-for-the-early-partial-review

In view of the above, the Council considers that the Luton HMA is correctly and accurately described in paras 1.18, 4.5 and 4.7 of the submitted Luton Local Plan, and that no part of Dacorum Borough Council is within the Luton HMA.

Yours sincerely

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Laura Wood Team Leader (Strategic Planning and Regeneration)