Redbourn Parish Council – St Albans City and District Strategic Local Plan (Regulation 19)
Representations
Redbourn Parish Council: Representations to St Albans City and District Strategic
Local Plan (SLP) 2011-2031 Regulation 19 Consultation
Introduction:
Redbourn Parish Council submits the following representations to the St Albans City and District
Consultation on its Pre-Submission (Regulation 19) Strategic Local Plan (“SLP”) being prepared for the
area. The relevant policies and sections to which each sub-heading in our representations relates to are
included in the box below each heading.
1. Approach to the Strategic Local Plan
Policies / Sections to which this sub-heading
Relates:
Legal Compliance and Duty to Cooperate
Yes
No
Legally Compliant?
X
Satisfies Duty to
X
Cooperate?
“Introduction”; ‘Strategy”; and SLP1
Soundness
Justified
Effective
Consistent with
National Policy
Positively Prepared
Yes
No
X
X
X
X
1.1. The current Local Development Scheme (LDS) for St Albans District is that dated September
2015. Under Paragraph 4, the LDS notes that ‘a Local Plan may be a single document or a suite
of documents’. Redbourn Parish Council considers that this approach is not, without clear
justification, consistent with National Policy, which confirms that in preparing a Local Plan for
its area, any additional documents should only be used where clearly justified (NPPF Paragraph
153). NPPG ID: 12-012-20140306 provides further confirmation of the importance of this
approach:
“The National Planning Policy Framework makes clear that the Government’s
preferred approach is for each local planning authority to prepare a single
Local Plan for its area (or a joint document with neighbouring areas). While
additional Local Plans can be produced, for example a separate site allocations
document or Area Action Plan, there should be a clear justification for doing
so.”
1.2. The current LDS does not list previous rounds of consultation and aborted plan preparation.
Paragraph 1.7 of the Pre-Submission SLP details the extensive period over which the emerging
Plan has been considered. These events date as far back as 2006 and 2007 and detail round of
‘Issues and Options’ Consultation for the (as then) Core Strategy DPD.
1.3. The current LDS proposes to pursue a separate “Detailed Local Plan” (DLP) and it is said that
“through the detailed policies, site allocations and policies maps that the DLP will add detail to
the Council’s long term spatial planning strategy set out in the SLP”. The desire to prepare the
‘Part 2’ DLP appears to be in large part a legacy of previous plan programmes, which included a
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commitment to prepare separate ‘Site Allocations’ and ‘Development Policies’ Development
Plan Documents.
1.4. For these representations, it is sufficient to highlight that following the revocation of the East of
England Regional Plan and introduction of the NPPF and NPPG the plan-making context has
altered substantially since the Council previously adopted an approach of preparing a suite of
Development Plan Documents. For St Albans in-particular, it can be considered that the
implications are magnified as a result of the significant changes in terms of how the assessment
of housing need and the extent to which this can be provided for within the administrative area
are approached. For instance, the judgement in St Albans City and District Council vs Hunston
Properties and SSCLG1 highlights that it is no longer possible, for the purpose of decisionmaking, to rely on constrained housing requirements in revoked policy and that the only way
for the authority to demonstrate how it can meet identified requirements (as far as consistent
with other polices in the NPPF) will be through preparation of the new Local Plan. This evolving
context also includes any resulting discussions under the Duty to Cooperate – including on how
unmet need can be provided for elsewhere (or how St Albans can provide for the unmet needs
of others).
1.5. Redbourn Parish Council does not consider that deferring significant levels of detail to later
Local Plan documents is appropriate under these circumstances. The Parish Council considers it
significant that the Local Planning Authority has undertaken only one formal consultation on
the emerging SLP since the revocation of the East of England Plan and the introduction of the
NPPF in 2012. This comprised the September 2014 Strategic Local Plan ‘Draft for Consultation’
(Regulation 18). That document was substantially similar in essence to the SLP currently subject
to consultation.
1.6. As a result, the Parish Council and other stakeholders have not had an opportunity to comment
to any significant degree on the range of options being considered. This is significant not only
in-light of the changes to national policy and guidance mentioned above, but also the
completion of important elements of the evidence base and the plan-making activities of
adjoining authorities (see also Duty to Cooperate Section of this representation). These include:




SHMA;
Green Belt Review (Stages 1 and 2); and
Adoption of the Dacorum Core Strategy (2013)
Strategic Housing Land Availability Assessment (most recent drafting being 2009 some 7
years prior to the Regulation 19 consultation)
1.7. Paragraph 155 of the NPPF recommends ‘early and meaningful engagement and collaboration’
in preparing Local Plans, so that pro-active engagement can reflect, as far as possible, an
agreed set of priorities and collective vision for sustainable development. It is argued that this
has not been achieved due to the advanced stage of plan preparation presented by St Albans
1
[2013] EWCA Civ 1610
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Council despite significant changes in policy and guidance and the findings of the evidence
base.
1.8. The approach followed has in effect limited the scope for the Strategic Local Plan to provide a
“clear and decisive answer” on key issues such as the Green Belt. It has limited the range of
options considered in sufficient detail. The need for such “answers” was first identified by
David Vickery in a PINS ‘LDF Advisory Visit’ (November 2009, Paragraph 5), who recommended
that a “local adjustment” would be possible to establish a future strategy for development.
Instead, the scope of the Strategic Local Plan is restricted to a limited number of Broad
Locations, partly conceived in a sub-regional context but without the necessary agreement or
evidence to substantiate the approach at this time. Decisions on other elements that may
complement the most effective strategy for the Local Plan area are unnecessarily deferred to
future stages with uncertainty over whether they will ever be fully addressed.
1.9. On the basis of the above points, Redbourn Parish Council considers that St Albans and its SLP is
unsound as it is not positively prepared, not effective, not justified or consistent with national
policy. St Albans has failed to meet the Duty to Cooperate which is elaborated on further in the
section below.
2. Duty to Co-Operate
Policies / Sections to which this sub-heading
Relates:
Legal Compliance and Duty to Cooperate
Yes
No
Legally Compliant?
Satisfies Duty to
X
Cooperate?
SLP1; SLP2; SLP8; SLP10; SLP13a
Soundness
Justified
Effective
Consistent with
National Policy
Positively Prepared
Yes
No
X
X
X
X
2.1. It cannot reasonably be argued that St Albans City and District Council has satisfied the Duty to
Cooperate as set out in national policy, guidance and the Localism Act (2011). Whilst this
criticism affects the Plan as a whole, it is particularly significant in respect of the proposed
Broad Location ‘East of Hemel’ and because delivery of key elements of the supposed strategy
are dependent on this area.
2.2. Redbourn Parish Council acknowledges that land East of Hemel is a relevant consideration for
the plan-making context in St Albans, albeit within the context of significant further technical
work and investigation being required to understand the contribution that the site may make
towards the strategic priorities for sustainable development. There is also an acknowledged
understanding of the area’s strong functional relationship with the adjoining settlement at
Hemel Hempstead, and that further consideration of the land would take into account
arrangements for meeting development needs in Dacorum Borough alongside those in St
Albans.
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2.3. The initial findings of the Inspector for the Dacorum Core Strategy (2013) were not
uncontentious in suggesting that further robust assessment of land East of Hemel should have
been undertaken for that Plan and in terms of the weight the area could be given in meeting
Dacorum’s housing needs more fully. However, in reality those views broadly represent the
spatial strategy in the revoked East of England Plan, whereby any development in this location
would solely contribute to growth in Dacorum Borough. However, the Parish Council considers
that the most satisfactory outcome possible was achieved in the Proposed Main Modification
recommended for a partial review of the Dacorum Core Strategy to consider:
“(c) the role that effective co-operation with local planning authorities could
play in meeting any housing needs arising from Dacorum. This element will
include St Albans district and relevant areas lying beyond the Green Belt.”
2.4. Under such circumstances, Redbourn Parish Council considers that full and effective
compliance with Duty to Cooperate should ensure that any future opportunity for growth East
of Hemel is appropriate in planning terms. The production of some joint evidence broadly on
this basis is supported, in-particular the Phase One Green Belt Review covering Dacorum and St
Albans (and also Welwyn Hatfield). This source is covered elsewhere in our representations, but
in summary is highly relevant in setting the overall context for a relatively limited release of
land that might be considered appropriate in Green Belt terms to the East of Hemel. In its
representations to the Draft Strategic Local Plan Consultation (November 2014), Dacorum
Borough Council provided the following caveat for any further support in considering the broad
location East of Hemel:
“this support is predicated on the integration of the new development with the
wider town; the comprehensive assessment of infrastructure needs of the town
and the ability of the land to help meet some of Dacorum’s own future housing
needs.”
2.5. The St Albans City and District Council Local Development Scheme 2015-2018 contains no
agreed timetable for production of the East of Hemel Area Action Plan, which is a prerequisite
document for any effective delivery of land East of Hemel in strategic planning terms or on the
basis of the extract presented above. There is presently no agreement in place between
Dacorum Borough Council and St Albans City and District Council to determine how relevant
strategic planning matters will be taken forward and key infrastructure issues assessed, both
for the small geographic area East of Hemel but also more widely between the two authorities.
2.6. There is no clear boundary presented nor any parameters set out for defining the future
development concept in terms of scale, land uses, tenure mix, the ability to meet needs arising
in Dacorum or the basis for future infrastructure modelling (in-particular highways and
education) and detail for how these could be achieved.
2.7. As evidenced by Dacorum Borough’s response to St Alban’s previous consultation, it considers
that the scale of work necessary in the future to identify and define greater levels of release of
land in the Green Belt to meet needs arising outside St Albans District is unnecessarily deferred
to subsequent plans.
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2.8. Redbourn Parish Council disagrees with any view that whilst Dacorum Borough Council
considers it undesirable to defer meeting needs arising in its area to future plans, the
subsequent assertion that future outcomes from joint working will necessarily provide
justification and pressure to release further land East of Hemel for this purpose. It is further
concerned that Dacorum Borough Council might logically read this conclusion from the
proposed drafting of Policy SLP1:
“Part of the land excluded from the Green Belt in this location will be reserved
land retained to meet longer-term development needs, potentially beyond the
Plan period. Boundaries of areas for immediate development and reservation
will be defined in the DLP.”
2.9. It is entirely unclear what area or extent of ‘reserved land’ is being referred to, given that the
entire area considered potentially suitable for development through the Phase 2 Green Belt
Study is identified to meet needs arising solely in St Albans and within the Plan period. None of
the land currently identified in the broad location appears suitable to meet longer-term needs
(or needs arising in Dacorum) on that basis.
2.10.
These concerns highlight that the approach is flawed in terms of national policy. In
terms of NPPF Paragraph 83, there is little prospect of any intended Green Belt boundaries
enduring beyond the plan period insofar as they affect the site. The consequences for
sustainable development are not fully considered, in that scope to meet needs closest to where
they arise in urban areas (in particular Hemel Hempstead) is overridden by St Albans’ decision
to wholly meet its own needs on the full extent of the broad location that is capable of being
supported by evidence in the Green Belt Study (NPPF Paragraph 84).
2.11.
This view is not supported by the evidence base prepared to support the Pre-Submission
Strategic Local Plan, in-particular due to the relatively limited area of land considered suitable
for Green Belt release and in the absence of modelling any detailed infrastructure requirements
for unknown levels of development. Nor does it accord with the broad scope for the East of
Hemel Area Action Plan set out in the adopted Dacorum Core Strategy (2013), which more
appropriately allows for the focused and detailed joint-working to consider whether extensive
constraints may be overcome before planning for even a relatively limited scale of crossboundary growth.
2.12.
The basis upon which the Broad Location ‘East of Hemel’ is proposed in the Strategic
Local Plan appears to have a limited resonance with the parameters for the area’s functional
relationship with Dacorum and St Albans set out in other policies. For the reasons set out
below, it provides no clear rationale for why the site is more appropriate to meet needs arising
in St Albans or that identifying the land at this stage furthers effective plan-making.
2.13.
National guidance states that although the Duty to Cooperate is not a ‘duty to agree’,
however it clearly states that local authorities should make every effort to cooperate on
strategic cross boundary matters before the plan is submitted for examination:
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“but local planning authorities should make every effort to secure the
necessary cooperation on strategic cross boundary matters before they submit
their Local Plans for examination” (NPPG ID: 9-002-20140306).
2.14.
Key flaws and questions in the Council’s evidence indicate that it cannot demonstrate
that it has produced the “effective and deliverable policies on strategic cross boundary matters”
(NPPG ID: 9-002-20140306). For instance, neither Local Development Scheme for Dacorum
Borough or St Albans contains an adopted timetable for preparation of the East of Hemel Area
Action Plan and Paragraph 4.19 of the Pre-Submission SLP states: “The DLP may offer an
alternative route to policies for delivery of development at East Hemel Hempstead”.
2.15.
By extension, the Strategic Local Plan also sets out a broad framework for development
that imposes significant potential constraints and questions for the preparation of future
policies. Effective delivery of Land East of Hemel necessarily relies on integrated evidence for
the range of ‘strategic priorities’ referenced at NPPF Paragraph 156, such as provision for
transport, community services and facilities and water and energy infrastructure. There is a
failure to present adequate evidence in the Pre-Submission Draft Strategic Local Plan that these
elements can be achieved or present the most effective strategy to meet needs arising in St
Albans District; or to acknowledge that, in-accordance with Paragraph 179 of the NPPF, delivery
of these priorities will need to be coordinated across local authority boundaries.
2.16.
Based on the SLP as drafted, Dacorum Borough Council could not clearly reflect in its
own Local Plan any opportunities to align its priorities with delivery of Land East of Hemel in a
manner consistent with other evidence, such as the extent of land potentially suitable for
Green Belt release. This is because the SLP asserts that the entire Broad Location East of Hemel
can and will be delivered as part of a strategy to meet needs specifically identified for St Albans.
2.17.
National guidance notes that where agreed evidence or agreed position on cooperation
cannot be demonstrated, there is a requirement for the authority to provide comprehensive
and robust evidence of engagement undertaken and the extent of outcomes reached is
required to allow them the question of whether there has been lawful compliance with the
duty to be fully tested at Examination. As a means of reducing risks and the burden of the Duty
to Cooperate for plan-making in these circumstances, guidance states “Local Planning
Authorities should have explored all available options for delivering the planning strategy within
their own planning area” (NPPG ID: 9-003-20140306).
2.18.
The Council’s reporting of work under the Duty to Cooperate cannot be considered to
demonstrate the requirement for a proactive, positive and ongoing approach to strategic
planning and partnership working required by guidance (NPPG ID: 9-004-20140306). The
Authorities Monitoring Report (2015) provides the main recording of engagement activity, but
does not present any schedule of meetings or, more importantly, record actions, agreed
outcomes and priorities for further work. Redbourn Parish Council is more aware than many
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areas of the close functional relationship with Dacorum Borough, and therefore concerned that
engagement between Local Authorities is summarised as:
“A series of meetings and discussions at political level with all nearby and
adjoining local planning Authorities affected by the Strategic Local Plan (AMR
2015 p.24)”
2.19.
The Authority’s Monitoring Report also provides only a brief summary of work to
prepare technical evidence with potential cross-boundary implications for plan-making under
the Duty to Cooperate. In relation to direct participation on housing needs assessment,
employment land and urban capacity work, only the Authorities of Luton, Central Bedfordshire
and Welwyn Hatfield are referred to. The outcomes and effects for strategic planning decisions
are not identified.
2.20.
By contrast, national guidance highlights well-defined relationships such as housing
market and travel to work areas that may provide a more effective basis on which to plan for
issues such as housing and job creation; providing the appropriate basis for Local Plans to
approach strategic planning (NPPG ID: 9-008-20140306). Claims in the Strategic Local Plan itself
cannot be substantiated in terms of having specifically considered such evidence, for example
at Paragraph 1.25 stating that the Local Plan is informed by:
“Very considerable joint work on Evidence Bases, including in areas such as
Employment, Housing, Biodiversity / Ecology, Green Infrastructure, landscape
character appraisal, Green Belt Review, Sustainable Building and Community
Infrastructure Levy (CIL)”
2.21.
A detailed (and in all likelihood agreed) position on this evidence would be anticipated
to support later claims in the Strategic Local Plan, particularly at Paragraph 4.19:
“The SLP Development Strategy includes providing for the District’s future
development needs partly through a major eastern expansion of Hemel
Hempstead (Broad Locations – Mixed Use (East Hemel Hempstead North and
South). This is an appropriate strategy because Hemel Hempstead has Town
status and is recognised as a potential growth and regeneration location in the
M1 corridor in the Local Enterprise Partnership’s (LEP) Strategic Economic Plan
(SEP) and the Dacorum Local Plan. Joint working with the LEP and Dacorum
Borough Council on detailed plans for the expansion of Hemel Hempstead is
envisaged.” (Our emphasis)
2.22.
To achieve effective planning outcomes on the separate topics identified in the extract
above would require a clear understanding of the housing market relationships between the
two areas. The St Albans Strategic Housing Market Assessment Update (2015) treats the
administrative area of the District as a single housing market and fails to acknowledge the
cross-boundary relationship introduced in the Strategic Local Plan. There are compelling
arguments to conclude that St Albans does not in-fact comprise a single housing market area in
its own right. This is most recently summarised in the Strategic Housing Market Assessment for
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South-West Hertfordshire (January 2016)2, identifying a larger housing market covering
Watford, Dacorum, Three Rivers and Hertsmere as well as St Albans:
“During consultation St Albans City and District Council has criticised the
inclusion of St Albans district within the HMA, referring mainly to evidence on
house prices. We have reviewed the evidence in the light of this Council's
comments, both at an early stage and later in the Study. Our conclusion is that
there are very strong grounds for including St Albans within the HMA ... St
Albans City and District achieves insufficient migration and commuting selfcontainment on its own to be regarded as a separate HMA in its own right. It
has been assessed as in a common Broad Rental Market Area with other South
West Hertfordshire authorities by the VOA; and two independent studies – the
CURDS national research on housing market geographies; and work to defined
HMAs by ORS for Luton, Bedfordshire and surrounding areas – alongside this,
place it within a common HMA to the commissioning authorities. The evidence
herein shows significant commuting and migratory links with other South West
Hertfordshire authorities. “(SW Hertfordshire SHMA 2016, Paragraph 2.13)
2.23.
The fact that St Albans District Council was not a commissioning body for this work in
itself shows a lack of ongoing and constructive engagement in the face of earlier evidence for a
wider housing market. More importantly, any future joint working envisaged cannot proceed
on the basis of taking housing market linkages into account within the scale of housing
proposed on land East of Hemel, because precedence is inevitably given to meeting the housing
needs erroneously associated solely with the District as indicated at the outset of Paragraph
4.19 (extract above). This is demonstrated by Appendix 2 of the Strategic Local Plan (‘Housing
Trajectory’) that shows how full delivery on land East of Hemel would need to be achieved (by
2031) to deliver the housing requirement identified solely for St Albans.
2.24.
The contradictions within the approach set out above cannot be ignored under the Duty
to Co-Operate.
2.25.
The outcome of much of the potential and largely unreported engagement that may
have taken place in the context of the points above does not appear sufficiently comprehensive
to demonstrate that the Duty to Cooperate has been satisfied or how it will inform future
policies that can meet current and future projected levels of development (NPPF Paragraph
181) as part of the most appropriate strategy for the area. For example, the SLP as drafted and
based on current evidence (including that intended to support long-term and enduring Green
Belt boundaries) leaves no scope for Dacorum Borough Council to consider meeting any of its
needs on land East of Hemel.
2.26.
Redbourn Parish Council considers that at present outcomes under the Duty to
Cooperate do not move the understanding of how best to meet strategic priorities across local
2
http://www.dacorum.gov.uk/home/planning-development/planning-strategic-planning/new-single-localplan/technical-work-for-the-early-partial-review
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authority boundaries or the position for plan-making beyond the parameters set out by the
Inspector for the Dacorum Core Strategy. At most, the available evidence may indicate that a
relatively small area of land East of Hemel should be safeguarded for further consideration on
this basis, but in general the above highlights that St Albans City and District Council also needs
to revisit and rethink the most effective strategy to plan for the needs of the area.
2.27.
As evidenced above, Redbourn Parish Council considers that St Albans has failed to
meet the Duty to Cooperate.
3. Site Selection Process
Policies / Sections to which this sub-heading
Relates:
Legal Compliance and Duty to Cooperate
Yes
No
Legally Compliant?
X
Satisfies Duty to
X
Cooperate?
SLP1; SLP2; SLP5; SLP8; SLP13a;
“Sustainability Appraisal”
Soundness
Yes
Justified
Effective
Consistent with
National Policy
Positively Prepared
No
X
X
X
X
3.1. St Albans City and District Council has published a range of supporting evidence to justify the
preferred development strategy comprised by the Pre-Submission Strategic Local Plan. The
Sustainability Appraisal notes that this assessment and information looks at two
complementary but distinct elements of the overall strategy:


Strategic Sub-Area Options; and
Development Strategy Options
3.2. Consideration of the range of options for the ‘Housing Requirement / Target’ has also been
explored by the Sustainability Appraisal but is not directly relevant to these representations. It
is critical to note that selection of Preferred Broad Locations (‘Strategic Sub-Areas’) cannot be
distinguished from the overall Preferred Development Strategy “Option 1(a) ‘Mixed Location /
Scale Development”, broadly summarised as follows:
“This is a combination of limited releases from the SKM recommendations list
to meet shorter term needs and development of east Hemel Hempstead in the
medium and long term. This option offers reasonable prospects of delivery and
also allows for some site choices from within the SKM recommendations. As
east Hemel Hempstead is included, it offers a prospect of addressing subregional housing ‘need’ and sub-regional employment ‘need’/ambition over
the long term and the safeguarding of land beyond the Plan period. Duty to Cooperate issues identified by Dacorum’s Plan Inspector would also be able to be
addressed.” (p.16 – Officer Site Selection Report)
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3.3. The main sources in relation to comparable site assessments are summarised in the
Sustainability Appraisal:
“In addition to the study undertaken by SKM, SADC officers undertook a
separate assessment of the strategic sub-areas. They also undertook a similar
assessment for the development strategy options.
For the evaluation of the relative merits and constraints associated with the
strategic sub-areas and the development strategy options SADC developed an
evaluation framework based on a range of criteria and a weighted scoring
system. This framework included a wide range of economic, social and
environmental factors that together were seen to effectively represent the
concept of sustainable development as defined in the NPPF.” (SA 2015, p.4950)
3.4. Please note that the approach to the SKM Green Belt Study is considered separately under a
separate section of these representations.
3.5. Paragraph 1.8.1 of the ‘Strategic Local Plan Technical Report – Development Site and Strategy
Options Evaluation’ also notes the following:
“This evaluation methodology respects, and draws on, the initial SA work for
the Plan described above and the general SA Framework. However, it is a
specific evaluation method designed to examine geographical options in more
detail than would be possible using the general SA Framework. It therefore
represents a part of the evolution of the SA always envisaged.”
3.6. Redbourn Parish Council accepts that greater detail and planning judgment is to be applied for
any detailed site-specific evaluation based upon the high level indicators used in the
Sustainability Appraisal exercise. The Parish Council also accepts that this represents a more
comprehensive analysis of the ability for sites to achieve the broad objectives of sustainable
development set out in the SLP, compared with the indicative considerations in the SKM study.
3.7. However, having reviewed the various sources listed above, the Parish Council considers that in
combination the assessments do not support the Broad Locations contained within the
Preferred SLP. It is considered that a number of the indicators adopted by SADC are not
consistent with national policy as well as elements of the SLP itself and that as a result the sites
chosen will not secure the most effective outcomes.
3.8. Key comparisons and concerns are as follows:
Settlement Hierarchy
3.9. Appendix 4 of the Development Site and Strategy Options Evaluation contains details of the
evaluation Framework. A weighting of ’10’ is given to sites’ relationship with various aspects of
the settlement hierarchy, listed under Part 2’ Settlement Hierarchy’. However, it is notable that
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the framework does not indicate how scoring on each category will be based and also that no
mention is made of Hemel Hempstead as a relevant settlement:
“Main factors to consider:
Main urban settlements (excluded from the Green Belt): St Albans, Harpenden,
and London Colney
Other settlements excluded from Green Belt: Bricket Wood, Chiswell Green,
How Wood, Park Street, Frogmore, Redbourn, Wheathampstead
Green Belt settlements: Colney Heath, Folly Fields, Gustard Wood, Kinsbourne
Green, Lea Valley Estate, Sandridge, Sleapshyde, Smallford
Rest of Green Belt: Everywhere else”
3.10.
Despite this, the summary results from the overall scoring matrix (page 189) show both
sites SA-S1 and SA-S2 (Land East of Hemel North and South) as scoring 10 (the maximum score)
for their relationship to the settlement hierarchy. Comments under this domain for site SA-S1
note that the site is located adjacent and well-related to Hemel Hempstead and highlights that
this is ‘classed as a town in the Dacorum Borough Local Plan’ (sic). This finding is not considered
justified based on the policy framework set out in the emerging SLP.
3.11.
Policy SLP1 makes reference to Hemel Hempstead in parentheses, noting its relevance
as a main urban settlement in Dacorum Borough, on the basis that expansion into the District is
planned. This directly contrasts with the approach to the local housing requirement at Policy
SLP8 of the emerging Plan, which sets out a housing figure of 436 dwellings per annum based
on the need for new housing development “in the District” (SLP, Paragraph 6.37).
3.12.
Elsewhere, the SLP acknowledges that “under this Strategy the urban areas of St Albans,
Harpenden and London Colney are the main foci for new development” but that it is also
considered necessary to select additional ‘Broad Locations’ that “fit within the spatial strategy”
(Paragraph 4.5). On this basis, Policy SLP1 provides an important counterpart to any test of
exceptional circumstances that the Local Authority considers is met, for example when
assessing the consequences for sustainable development of delivering various levels of growth
and channeling them to locations across the settlement hierarchy. Whether the test is met to
the extent and scale of housing growth as currently included in the Pre-Submission SLP, having
regard to the intended permanence of the Green Belt, its wider benefits and whether there is
specific need to keep land open (taking into account the findings of the Green Belt review) is a
separate matter.
3.13.
Paragraph 4.5 of the Draft SLP confirms that any consideration of land East of Hemel is
“conceived in a sub-regional planning context”. Redbourn Parish Council does not agree that
considering land East of Hemel to meet needs arising in St Albans can be applied consistently
under the settlement hierarchy as it is set out. Any opportunities to support the future
expansion of Hemel Hempstead in the future would more appropriately be part of a separate
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test. This should greatly reduce the weight given to the merits of the location as a matter of
planning judgment (however consistently or thoroughly reached) as set out in the Officer’s
Evaluation. This may not in itself meet the test for exceptional circumstances. This is
particularly relevant, as in the case of Land East of Hemel, where there are other options that
may cause less harm to the Green Belt; there is no robust justification that the location has
greater benefits for meeting needs arising in St Albans; and that any boundaries would be less
likely to endure as the area identified as potentially suitable has no prospect of meeting needs
arising in Dacorum Borough under the strategy set out.
Public Transport
3.14.
This criteria is considered under point 7 of the Evaluation Framework. The main issues
to consider, based on Appendix 4 of the Development Strategy and Site Options document are
listed below. The Framework does not appear to give any further guidance on how individual
scores have been reached using the various domains:



“Distance to train station including assessment of frequency of service
Distance to a bus route including assessment of frequency of service
Potential for new or improved bus services”
3.15.
These criteria are scored as ‘5’ for both sites SA-S1 and SA-S2 (land East of Hemel) and
represent the highest scores by any of the strategic sub-area options. The overall conclusion in
the comments related to East of Hemel (North) are as follows:
“Access to railway stations and connecting public transport is good as a result of the
town location. Large scale development in the form of a new neighbourhood allows
for effective and economically viable bus service improvements. A high evaluation
score results.”
3.16.
Redbourn Parish Council objects to these conclusions and overall score. Whilst there is
the potential to improve bus services (although no other forms of mass transit are mentioned)
this is highly likely from any strategic scale extension. The key issue is that the minimum
distance to a train station is approximately 5km; and greater still to links from St Albans.
3.17.
The Sustainability Appraisal Working Note (July 2014): Appendix B ‘Strategic Sub Areas’
identifies an unsustainable and minor-adverse effect for Greenhouse Gas Emissions and Air
Quality for all 8 sub-areas considered. However, the note is significant as it provides
comparable distances to town centres and railway stations against the other sub-areas. With
the possible exception of sites at London Colney and Chiswell Green, land East of Hemel
provides the greatest distance from town centre and rail facilities.
3.18.
Appendix 7 to the Development Strategy and Site Options Evaluation (October 2014)
also contains a Matrix demonstrating that from the centre of the site, East of Hemel (North) is
second only to East of Hemel (South) in terms of its distance from facilities such as a town
centre, railway station and secondary school.
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3.19.
On this basis, Redbourn Parish Council does not accept that scores for ‘public transport’
at land East of Hemel Hempstead should be materially greater than other locations; particularly
with regards the towns of Harpenden and St Albans.
4. Sustainability Appraisal
Policies / Sections to which this sub-heading
Relates:
Legal Compliance and Duty to Cooperate
Yes
No
Legally Compliant?
x
Satisfies Duty to
x
Cooperate?
“Sustainability Appraisal”; SLP1; SLP8; SLP13a
Soundness
Justified
Effective
Consistent with
National Policy
Positively Prepared
Yes
No
X
X
4.1. Redbourn Parish Council has reviewed the Sustainability Appraisal prepared to support the PreSubmission Strategic Local Plan (and documenting all stages of plan preparation). It does not
consider that the Sustainability Appraisal presents a robust or realistic assessment based on the
outcomes for strategic planning associated with the “Development Strategy Options” compiled
from the potential selection of sites from the findings of the Green Belt Review and Officer
Evaluation.
4.2. It is noted that Options 1a and 3 (Mixed Location / Scale Development and Concentrated
Development respectively) comprise separate approaches, although the precise selection of
and quanta of development for individual sites to inform these are not presented. This is
contrary to national policy, which requires any assumptions used in the testing of the
significance of effects to be documented (NPPG ID: 11-018-20140306). The Parish Council’s
main concern is that neither of these two options, which are shown as preferred by the Officerlevel assessment and have the most positive combination of effects following Sustainability
Appraisal, can actually achieve their stated aims as ‘reasonable alternatives’ nor are they
accurately reflected in the preferred Strategy put forward by the Strategic Local Plan.
4.3. Each option indicates that the inclusion of land East of Hemel provides the prospect of meeting
sub-regional housing needs and addressing the Duty to Cooperate with Dacorum Borough over
the long-term and with safeguarding of land beyond the Plan period. It is not clear whether the
preferred strategy proposed in the Pre-Submission Strategic Local Plan represents Option 1a or
Option 3 as tested by the Sustainability Appraisal. The overview for Option 1a notes:
“This is a combination of limited releases from the SKM recommendations list
to meet shorter term needs and development of east Hemel Hempstead in the
medium and long term. This option offers reasonable prospects of delivery and
also allows for some site choices from within the SKM recommendations. As
east Hemel Hempstead is included, it offers a prospect of addressing subregional housing ‘need’ and subregional employment ‘need’/ambition over the
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long term and the safeguarding of land beyond the Plan period. Duty to Cooperate issues identified by Dacorum’s Plan Inspector would also be able to be
addressed.”
4.4. As drafted, the Pre-Submission Strategic Local Plan relies on delivery of the full-scale of land
considered suitable for Green Belt release to meet needs arising in St Albans over the plan
period. On that basis, it would not be possible to achieve the outcomes in the options tested as
stated above. National guidance requires that any alternatives tested must be realistic and
deliverable (NPPG ID: 11-018-20140306) but in the absence of an agreed position under the
Duty to Cooperate and by deferring substantial detail on delivery to the subsequent DLP, this
cannot be confirmed. The evidence base for the plan, in-particular the Green Belt review, does
not support any greater extent for the release of land East of Hemel therefore the effects of the
options tested are inconsistent with the stated aim of longer-term safeguarding and meeting
sub-regional housing need.
4.5. A related issue with the Sustainability Appraisal process is that the scale of growth relative to
any of the Development Strategy Options is not stated relative to the ‘Housing Requirement /
Target’ Options tested separately. Inevitably, this implies a degree of flexibility for matters such
as remaining suitable land possibly relevant to safeguarding which is in fact unachievable when
certain Development Strategies (such as those placing a high reliance on land East of Hemel)
are adopted for a relatively higher level of growth. The table below uses the example of the
possible combinations of development for scenarios of either 550 dwellings per annum or 450
dwellings per annum taken the Officer’s Evaluation of Development Strategy Options – Option
1a:
Figure 1: Scale of Growth at Broad Locations relative to Development Strategy Options
450 dpa
Proportion of
550 dpa
Proportion of
(200 dpa from
Total (of
(300 dpa from Total (of
strategic sites) strategic sites)
strategic sites) strategic sites)
S1 – East of Hemel
1500
37.5%
1500
25%
(North)
S2 – East of Hemel
1000
25%
1000
16.7%
(South)
Other Strategic Sites from 1500
37.5%
3500
58.3%
SKM Recommendations
Total – Strategic Sites
4000
100%
6000
100%
Source: St Albans Strategic Local Plan Sustainability Appraisal (December 2015)
4.6. Although it is not clear that this mix is identical to those considered by the Sustainability
Appraisal, the 450 dpa scenario effectively reflects that in the Pre-Submission SLP. This
demonstrates that the local effects of selecting land East of Hemel would be identical to other
scenarios that might propose a higher target e.g. 550dpa. Conversely, selecting a reduced
‘Housing Target’ in effect increases the burden on development in some locations
disproportionately and may increase risks for non-delivery but would not as shown above
introduce any potential for longer-term safeguarding. This does not appear to be documented
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in the Sustainability Appraisal. Additional reasonable alternatives, such as changing the scale of
individual broad locations directly in-line with changes to the housing requirement, do not
appear to have been considered.
4.7. Another significant risk to this approach is the high reliance on the ‘baseline’ housing provision
of 250 dwellings per annum (comprising factors such as windfall, existing completions and
commitments) that complements any of the potential Development Strategies tested equally.
This is referred to in the Appraisal results for Policy SLP8 of the Pre-Submission Plan, noting for
example the positive effects for ‘brownfield land’ of delivering approximately 50% of the
housing requirement through sites of this type.
4.8. There is significant uncertainty regarding whether this baseline can be maintained (particularly
given the high assumptions for windfall development and recycling of previously developed
land). The requirement met through the Broad Locations is therefore effectively the
‘remainder’ from this baseline. Inevitably, if a lower overall requirement is provided for, the
remainder will be smaller. However, be seeking to deliver a larger requirement in the midrange of those tested places greater demands on the proportion of housing required across
Broad Locations; and greater still if development is concentrated at fewer locations as per
Options 1a and 3. The effect of this is to place an unrealistic level of weight on the delivery of
an equally limited number of sites, contrary to NPPF Paragraph 154 and the need for Plans to
be aspirational but realistic; addressing feasible spatial implications for social, economic and
environmental changes.
4.9. In suggesting that the combination of effects is the same for each ‘Development Strategy’
Option regardless of the requirement provided for, the assessment appears to take no account
of the risks of non-delivery or the opportunity cost of not selecting additional or alternative
suitable sites with similar potential.
Consideration of Small Sites as part of Reasonable Alternatives
4.10.
The Parish Council also does not consider that the Sustainability Appraisal is consistent
with national guidance, having not fully assessed the potential of delivery from other ‘Smallscale Sub-Areas’ recommended for release from the Green Belt in the initial study. It is
anticipated that 8 areas within St Albans could contribute around 500 units, although with
additional support from Neighbourhood Planning and a review of SHLAA data it is likely that
this number could be significantly greater.
4.11.
The Development Site and Strategy Options Evaluation (October2014) presents a
confused picture on whether additional capacity from the release of small-scale sub-areas for
Green Belt release form part of any option considered. A note on p.240 of the Officer
Evaluation Report states as follows:
“Green Belt Review part 1 SKM small scale sub area potential is not included in
these Options other than in 1a above. This is to allow flexibility for
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consideration as a longer term Detailed Local Plan (DLP) and Neighbourhood
Planning issue.”
4.12.
However, this potential source of supply is not included in the ‘Preferred Strategy’
Option set out on Page 26 of the Evaluation. In the Pre-Submission version of the Strategic
Local Plan (based on SLP Paragraph 6.37 and Appendix 2) it does not appear that exceptional
circumstances are justified to profile additional supply on this basis. It does not appear that
these sources have been tested in detail or subject to Sustainability Appraisal, despite the fact
that they could contribute to the most effective strategy under any Option. Within the
Development Strategy Options (October 2014) only Option 3 (‘Concentrated Development’
p.240) includes an assumption of 500+ units on small sites not part of the strategic sub-areas
identified in Phase 1 of the Green Belt Review.
4.13.
As the Officer Evaluation (October 2014) post-dates the Sustainability Appraisal:
Working Note (Appendix C – Development Strategy June 2014) the assumptions about any
provision for smaller sites contributing to the significant effects of any of the Development
Options cannot be considered clearly documented.
4.14.
Redbourn Parish Council considers that additional allocations of this nature offer choice
and flexibility under any Option and should be included as part of all scenarios on this basis.
4.15.
It is not considered appropriate to defer such detailed testing or consideration for the
review of Green Belt boundaries until the subsequent DLP, particularly as the strategy and
requirement put forward by the Strategic Local Plan is devised without any future reliance on
additional allocations (profiling supply only from Broad Locations).
4.16.
As part of the iterative process required for Sustainability Appraisal, and taking account
of the uncertainty in the scale of housing requirement relevant to each Development Strategy
Option, testing of each option with or without the effects of smaller-scale allocations should be
undertaken. This offers a strong opportunity to reduce the overall proportion of delivery from
the Broad Locations and meet needs more widely where they arise across the District. In
accordance with Paragraph 152 of the NPPF, such consideration also offers the opportunity to
avoid or mitigate significant adverse effects from other alternatives, such as the extent of
Landscape and Townscape harm at land East of Hemel.
5. Justification of Exceptional Circumstances and Release of Land from the Green Belt
Policies / Sections to which this sub-heading
Relates:
Legal Compliance and Duty to Cooperate
Yes
No
Legally Compliant?
Satisfies Duty to
Cooperate?
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SLP2; SLP8
Soundness
Justified
Effective
Consistent with
National Policy
Positively Prepared
Yes
No
X
X
X
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5.1. NPPF Paragraph 85 requires Local Authorities to “ensure consistency with the Local Plan
strategy for meeting identified requirements for sustainable development” when defining Green
Belt boundaries. Paragraph 14 of the NPPF sets out that for plan-making, the presumption in
favour of sustainable development should be applied as follows:
“Local planning authorities should positively seek opportunities to meet the
development needs of their area;
Local Plans should meet objectively assessed needs, with sufficient flexibility to
adapt to rapid change, unless:
– any adverse impacts of doing so would significantly and demonstrably
outweigh the benefits, when assessed against the policies in this
Framework taken as a whole; or
– specific policies in this Framework indicate development should be
restricted [including land designated as Green Belt as set out in Footnote
9]”
5.2. In Green Belt terms, the Parish Council considers that there is little if any material difference
between the need to apply the NPPF as a whole when considering boundaries (as described
above) and the basis for deciding planning applications in the Green Belt which requires
potential harm through inappropriateness and any other harm to be outweighed by other
considerations (NPPF Paragraph 88, our emphasis).
5.3. Aside from the point that the Local Plan should seek to meet objectively assessed housing
needs ‘as far as is consistent with the policies set out in [the] Framework (NPPF Paragraph 47)
and that the extent and purposes of Green Belt land may comprise one circumstance that may
restrain an Authority’s ability to achieve this (NPPG ID: 3-045-20141006), Local Plans as a whole
must contribute to the objective of achieving sustainable development (NPPF Paragraph 151).
5.4. The approach adopted by St Albans City and District Council cannot be considered sound in
terms of how it has applied and shaped the findings of the SKM Green Belt Review Purposes
Assessment (November 2013) and “St Albans Green Belt Review: Sites and Boundaries Study”
(draft December 2013 and final draft February 2014) to inform the preferred spatial strategy.
5.5. The Parish Council’s principle concerns in terms of whether evidence from the Green Belt
Review continues to inform the objectives for sustainable development are the editorial
changes made to the “Boundaries Study” between the December 2013 draft and final
published version of February 2014. Between these two documents, the consultants’
recommendations for land East of Hemel were revised; but more concerning is that relevant
considerations for the site assessments are treated differently between the two documents.
5.6. Table 2.1 of the February 2014 Phase 2 Green Belt Review compares the proposed and
‘updated’ approach between the two drafts. Of greatest importance is the modification that
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“the SWOT analysis has been removed as it only previously provided a summary of assessment
findings.”
Figure 2: Methodological Approaches in the Stage 2 Green Belt Review (December 2013 vs.
February 2014)
Source: “St Albans Green Belt Review: Sites and Boundaries Study” (February 2014)
5.7. This is particularly relevant as the SWOT analysis was originally presented as an early part of
work at the ‘Desktop Review’ stage and therefore important to identify relevant constraints
and opportunities; rather than summarising later assessment finings as suggested. This is
important in providing the context to evaluate potential implications for sustainable
development.
5.8. For example, in the 2014 final draft, the presence of designated heritage assets within the site
is introduced simply as “three Listed Buildings lie within the sub-area, including buildings within
Wood End Farm and Wood End Farm Cottages” and later included as ‘lower sensitivity aspects’
of the landscape (p.14).
5.9. This contrasts with the December 2013 draft, identifying Listed Buildings within the sub-area as
a specific weakness potentially introducing setting issues and subsequently, at Paragraph 3.7.3
‘Heritage Assets’ being listed as a key feature to be considered as part of future landscape
measures. A further insight is given on Figure 4.2 of the 2013 Draft (Page 18) showing Listed
Buildings at Woodend Farm indicated as a potential ‘New Village Hub’. The Parish Council
would not wish to comment on the achievability of any such scheme in detail – other than to
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add that cost and ownership factors would be relevant and any such ‘Village Hub’ would be farremoved from the main areas of any extension. However, this at least highlights that relevant
factors were raised. In contrast, there is no such indication on Figure 3.3 of the 2014 study,
despite the identical importance of the need to take into account the significance of affected
assets.
5.10.
There are also differences in terms of how the location East of Hemel has been assessed
in relation to its contribution to ‘Sustainable Patterns of Development’. The February 2014 final
draft simply notes the location to the east of Hemel Hempstead, adjacent the District
boundary, as part of a focus for new jobs and employment. This omits references in the
December 2013 assessment, noting ‘cross-boundary issues’ as a ‘Threat’ to achieving
development in the SWOT analysis and the distance of over 5km to Hemel Hempstead Train
Station as a specific weakness.
5.11.
The implications for these and other differences in assessment outcomes are
subsequently reflected in the overall approach to ‘Site Classification’ in the Phase 2 Green Belt
review. Each draft of the report contains an Appendix 1 with more detailed aspects of the
methodology, although the February 2014 report acknowledges that “it should be noted that
the evaluation / classification method has been evolved significantly over that originally set out
in the brief for the Study (Page 129).”
5.12.
Within the December 2013 Draft Report, land East of Hemel (North) is recommended to
be safeguarded and considered for development beyond the 20-year horizon on the following
basis:
“the site is not subject to significant primary constraints to development. In the
long term, it offers the potential to become integrated to form a new
community on the east edge of Hemel Hempstead. This is due to the land
allocated for housing and employment development on existing open urban
land within Dacorum Borough Council to the west of the site. The site should
not come forward until this land has been developed and any plans should be
designed to be well integrated into this adjoining area.”
5.13.
Without any attention as to how this issue will be overcome, or secondary constraints
such as Listed Buildings and higher landscape sensitivity could be addressed without such wellintegrated development, the final 2014 Phase 2 Green Belt Review considers that all sites can
be achieved within the plan period. This appears to be because less attention is drawn to
relevant constraints or consideration of the objectives for sustainable development required by
NPPF Paragraph 84.
5.14.
The selection of the broad location East of Hemel on this basis appears pre-conceived
and at odds with the objective to “meet the needs of the St Albans housing market area” as set
out at the start of Policy SLP13a.
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5.15.
It is acknowledged that the revised methodology instead ranks sites by three ‘Tiers’, of
which the land East of Hemel scores last and the report at Paragraph 11.3.5 states that such
locations are unlikely to be built out in the plan period:
Figure 3: Categorisation of Sub-Strategic Green Belt Parcels
Source: “St Albans Green Belt Review: Sites and Boundaries Study” (February 2014)
5.16.
This outcome itself highlights that the emerging Strategic Local Plan is unlikely to
provide a deliverable strategy as proposed, given that the Plan relies on completion of all
intend included land East of Hemel within the plan period to meet the stated requirements.
The more substantive failing is, however, that this ranking does not justify how the longer-term
integration of the sites with Hemel Hempstead can be secured without initially safeguarding
the locations or demonstrate that any revised Green Belt boundary would have strong
prospects of enduring beyond the plan period.
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5.17.
The evidence, both in terms of harm to the Green Belt and the wider priorities for
strategic planning supports the delivery of any new housing from a wider range and at a greater
scale of sites from the Tier 1 and Tier 2 Classification prior to any assumptions for development
East of Hemel.
5.18.
Further elements of the Pre-Submission Strategic Local Plan can be highlighted as
unsound as unjustified and ineffective in light of this evidence. For example, the second bullet
of paragraph 6.20 states “Broad Locations have been selected as locations where development
will cause least damage to Green Belt purposes”, which is inconsistent with the evidence
presented above.
5.19.
The Parish Council’s concerns in this regard should be read alongside their
representations as a whole, in-particular whether identification of the Broad Location East of
Hemel satisfies the Duty to Cooperate and whether due to the area’s location and constraints it
is appropriate or able to best deliver for needs arising in St Albans over the Plan Period.
6. The Approach to Housing Delivery
Policies / Sections to which this sub-heading
Relates:
Legal Compliance and Duty to Cooperate
Yes
No
Legally Compliant?
Satisfies Duty to
Cooperate?
SLP8; SLP10; SLP13a; “Appendix 2”
Soundness
Justified
Effective
Consistent with
National Policy
Positively Prepared
Yes
No
X
X
X
X
6.1. Policy SLP8 in the Pre-Submission Strategic Local Plan sets out the housing requirement / target
to be delivered over the plan period to 2031. Redbourn Parish Council does not consider this
total to be deliverable over the plan period based on the high reliance placed on delivery on
land East of Hemel to meet needs solely arising in St Albans and due to the lack of an effective
or justified evidence base for the wider components of supply.
6.2. Appendix 2 of the Pre-Submission SLP provides an indicative housing trajectory indicating that
aside from existing completions of 1,388 units and current known / expected delivery of 3,771
units (detailed in the AMR) all remaining supply is expected to come from the four Broad
Locations, delivered in-full by 2031.
6.3. This level of delivery is not considered achievable, particularly in the context of constraints
affecting land East of Hemel and pressure to work jointly with neighbours in Dacorum Borough.
The indicative trajectory requires delivery of an average 225 units per annum from 2021, with
not variation in the proposed trajectory. For land at East of Hemel (North) this would require an
annual delivery of 136 units, likely to require at least three separate developer outlets
operating consistently from the start of completions. Evidence of similar extensions elsewhere
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demonstrates that this is unlikely to support the level of completions assumed in Year 1, or be
sustained over the whole period.
6.4. The Parish Council is concerned that since publication of the Draft Strategic Local Plan in 2014,
an estimated quantum of 500 dwellings to be provided as “Small scale greenfield Green Belt
supported by local communities through DLP, or Neighbourhood Plan process, including
exceptions policies for affordable housing” (previously supporting text for SLP8) has been
removed from the Pre-Submission Draft. Such a source is no longer shown in the Appendix 2
Housing Trajectory.
6.5. In addition, the following supporting text has been removed from the supporting information
for the 4,000 dwellings to be provided for at the Broad Locations:
“[This] Includes potential for flexibility in scale and timing of development at
these locations – especially East Hemel Hempstead.”
6.6. It is clear that in combination with the point above, there is no longer any such flexibility in the
Development Strategy, despite this being an important element of national policy in terms of
the flexibility ability to adjust to rapid change and in the context of providing a realistic and
deliverable plan. Due to the extensive constraints at land East of Hemel, flexibility and
contingency is considered paramount to overcome the high likelihood of any shortfall.
6.7. The Parish Council also considers that the nature of existing supply and commitments relied
upon is likely to further reduce flexibility and contingency and put even greater pressure on the
Broad Locations. The Pre-Submission Strategic Local Plan is not supported by an up-to-date
Strategic Housing Land Availability Assessment prepared in-line with the latest planning
practice guidance nor is the plan informed by any list of sites informed by a public ‘Call for Sites’
exercise since 2009.
6.8. The Authorities Monitoring Report (2015) provides limited detail on the clear and convincing
justification for adoption a significant windfall allowance of around 98 dwellings per annum and
includes other sources such as Office-to-Residential Permitted Development which may be hard
to predict. Although it is hoped that these sources can be delivered, it may be preferable to
identify alternative, contingency, provision on land recommended for release from the Green
Belt to provide the necessary flexibility and contingency and reflect that much, if not all, land
East of Hemel should at most be safeguarded for development beyond the current plan period
and potentially at a significantly reduced scale.
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7. Strategic Housing Market Assessment
Policies / Sections to which this sub-heading
Relates:
Legal Compliance and Duty to Cooperate
Yes
No
Legally Compliant?
Satisfies Duty to
Cooperate?
SLP8; SLP9; SLP10
Soundness
Justified
Effective
Consistent with
National Policy
Positively Prepared
Yes
No
X
X
X
X
7.1. The Strategic Housing Market Assessment (SHMA) position in St Albans is much less clear than
in other authorities. St Albans’ SHMA is based on more dated information (despite the latest
2015 publication date the main projections that inform it are from 2013 or earlier). Also,
because it has not been informed by work with neighbours or a clear understanding of the
wider housing market, the outputs are less easy to follow. However, a summary of the headline
information we understand that the Council is using to inform potential developers of the
requirements for the major urban extensions is set out below.
7.2. The emerging Local Plan is not prescriptive on any combination of dwelling types and sizes. It
points to the SHMA as providing the best local evidence:
Figure 4: Policy SLP10
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7.3. The promoters of the site are The Crown Estate who gave a presentation to St Albans Members
on 17th November 2015 regarding the site and what they say they can make it deliver. Slide 17
of the presentation is copied below and relates to the mix of house sizes:
Figure 5: Crown Estate Presentation to Members (17th November 2015) Slide 17 (Housing Mix)
7.4. Data which precisely matches that used by The Crown Estate can be found in the document
“Independent Assessment of Housing Needs and Strategic Housing Market Assessment”
(hereafter “SHMA 2013”) dated December 2013. Table 6.5 from Page 259 of the document is
copied below:
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Figure 6: “Independent Assessment of Housing Needs and Strategic Housing Market
Assessment” (hereafter “SHMA 2013”) dated December 2013.
7.5. It is important to note that these figures are based on an annual need of 586 new dwellings per
year, which in-turn is based on 5-year migration trends. The upshot is a higher proportion of
growth amongst younger age groups who tend to occupy smaller houses. Whilst all SHMAs are
usually ‘trend-based’ and lock-in certain patterns about house size, the outcomes in the table
above are more balanced than St Albans is actually planning for. It is also significant that the
proportion of housing need for ‘all sectors’ by bedroom size are in-fact based on the same
distribution across each tenure e.g. the need for 1-bed accommodation is 21.49% for both
owner occupied and social rented housing. A further issue is that the mix reflects an unrealistic
split of market and affordable dwellings; with the affordable housing requirement far in excess
(over 65% of the total) compared with Policy SLP9 seeking 40%.
7.6. The emerging St Albans Local Plan is based on a dwelling target of 436 dwellings per year. The
supporting evidence for this is provided in “Independent Assessment of Housing Needs and
Strategic Housing Market Assessment” (hereafter “SHMA 2015”) dated October 2015. This is
based on a longer 10-year trend for migration, which is not recommended by national guidance
but which, we infer, helps to justify the lower housing figure.
7.7. The upshot, is that population flows of those most likely to migrate are reduced, which tends to
affect younger people, those in smaller households and the 35-44 year-old groups usually
attracted to the area most. The latest SHMA 2015 also reflects the generally larger household
size since the recession. The same issues of failing to apportion different housing needs by
sector and tenure are present in this version.
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Figure 7: Projected Housing Mix by Size and Tenure
Source: “Independent Assessment of Housing Needs and Strategic Housing Market Assessment Update”
dated October 2015.
7.8. The 2015 SHMA includes a useful table to help compare the difference of the most affected
groups between the SHMA 2013 and SHMA 2015:
Figure 8: Comparison between St Albans SHMA 2013 and SHMA 2015
Source: “Independent Assessment of Housing Needs and Strategic Housing Market Assessment Update”
dated October 2015.
7.9. It can therefore be demonstrated that any testing of potential delivery for the Broad Location
East of Hemel has thus far been based on use of out-dated information by the promoters of the
site and using a SHMA that may not be considered methodologically robust. Proposed Policy
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SLP10 is unsound as it cannot effectively inform a locally appropriate mix of housing, and
demonstrate how this can be delivered, using the Council’s own evidence.
7.10.
Dacorum Borough Council has recently completed its own SHMA3 (February 2016), which
will cover the town of Hemel Hempstead next to the Broad Location. This is using an approach
which looks at a wider housing market and identifies overlaps with St Albans (and therefore
identifies potential housing requirements for St Albans as part of a ‘South West Hertfordshire’
housing market).
7.11.
The document is critical of St Albans City and District’s Council’s decision to consider itself a
separate housing market, and the Dacorum SHMA believes that available evidence (e.g. on
migration) does not support this view.
7.12.
It can be seen from a relatively simply analysis of migration flows between Dacorum and St
Albans that the former is a net recipient on migrants from St Albans. Taken in isolation, this
balance of migration would not create any net additional demand for housing in St Albans
itself, and any such need would be reflected in the additional population received by Dacorum.
Figure 9: Analysis of UK Internal Migration Flows Between Local Authorities 2011-2014
Dacorum with St
2011
2012
2013
Albans
Inflow4
510
520
490
Outflow
330
340
350
Net Change
180
180
140
Source: https://www.neighbourhood.statistics.gov.uk/HTMLDocs/dvc25/
2014
560
360
190
7.13.
This entirely accords with the view of the Inspector for the Dacorum Core Strategy that
the District is also unlikely to be able to meet its own housing needs in full and reinforces that
the authorities should not be considered in isolation. This also further calls into question the
Preferred Strategy of the St Albans Strategic Local Plan to meet a high proportion of its
requirement at locations on the edge of the District, furthest from where they may arise in
practice and closest to where the main urban centre of Hemel Hempstead is likely to generate
its own high demand.
7.14.
The overall results in the new Dacorum SHMA may not significantly change the overall
proportion of 3-bed and 4-bed units likely to be needed, but it does more appropriately
differentiate the required mix by tenure, and also provides comparable data for Dacorum
Borough. These are provided below:
3
http://www.dacorum.gov.uk/home/planning-development/planning-strategic-planning/new-single-localplan/technical-work-for-the-early-partial-review
4
“Inflow” Represents movements from St Albans District to Dacorum Borough
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Figure 10: Requirements for Housing Size by Tenure Type – South-West Hertfordshire
Source: South-West Hertfordshire Strategic Housing Market Assessment (January 2016)
7.15.
Any scenario which is likely to include a higher proportion of larger, family-sized
accommodation (predominantly from the market sector but also dependent on the locallyspecific needs of groups unable to afford market housing), compared to the assumptions
previously used by the developers promoting the site, may have serious implications for
development outcomes in terms of the density that can be achieved or overall appearance of
development.
7.16.
It is not considered that the policy framework in the emerging Strategic Local Plan could
support development East of Hemel without taking such evidence into account and through
effective joint working with Dacorum Borough. The current use of evidence does not support
delivery of a Broad Location to solely meet needs arising in St Albans at this time, and therefore
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any subsequent decisions should rely on safeguarding the land for future consideration and
relying on alternative suitable locations in the first instance.
7.17.
The Dacorum SHMA is more robust, in the sense that it provided a different mix for
market and affordable tenures to reflect household characteristics; whereas the St Albans
SHMA (in our view incorrectly) applies the same proportion of 1-4 bed units to all tenures (see
table 6.5 above).
8. East of Hemel North Broad Location (Site Specific) Matters
Development Parameters
Policies / Sections to which this sub-heading
Relates:
Legal Compliance and Duty to Cooperate
Yes
No
Legally Compliant?
Satisfies Duty to
Cooperate?
SLP1; SLP8; SLP13a
Soundness
Justified
Effective
Consistent with
National Policy
Positively Prepared
Yes
No
X
X
X
X
8.1 Redbourn Parish Council has instructed its own development capacity plan and parameters
mapping for the potential Broad Location East of Hemel (North). Initial outputs based on
digitizing and mapping the indicative area suitable for Green Belt release in the Phase 2 SKM
Green Belt Review (given this is the are shown below:
Figure 11: Broad Estimates of Gross Land Use – Broad Location East of Hemel North
Total Ha
Exclusion Ha
Developable Ha
Infrastructure Ha
Net Buildable Ha
Density for 1,500 units
56.1 ha
8.8 ha
47.3 ha
18.9 ha
28.4 ha
52.9 DU/ha
8.2 An extract from the Phase 2 SKM Green Belt review (February 2014) for the broadly comparable
area is included overleaf, appreciating that the boundaries are indicative at this stage.
8.3 An initial assumption of 40% provision for infrastructure, services and facilities based on the
gross site area is adopted consistent with the SKM study. Given constraints also affecting the
East of Hemel (South) location and overall need for infrastructure to support the site, the
assumption of 40% is likely to be conservative. We have assumed the following initial
components:
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Figure 12: Estimated Land Use of Main Built Infrastructure Requirements
Main Infrastructure Element
Listed Buildings+Greenspace
Local Centre (x2)
Primary School
Secondary School
Total (Excl Roads + Ancillary)
Land Area
2.9 ha
2 ha
2.5 ha
9. 9 ha
17.3 ha
8.4 It can be shown that there would be very little of the area originally assumed for infrastructure
to allow for distributor roads or additional green space.
8.5 Opportunities to provide any of the main built infrastructure within the 8.8ha within the current
DPZ / HSE consultation zone are considered limited due to risk associated with the Buncefield Oil
Depot and are therefore excluded from the gross development area. However, this may provide
land for open space and sports pitches, which would appear likely based on the assumptions
above. The Secondary School is smaller than the 12ha recommended in the Officer Evaluation
partly on the basis of some of its open space being provided by the exclusion zone.
8.6 There is also no adjustment to the land budget for infrastructure to account for any easements
(believed to between 6m and 8m) for oil pipelines crossing the site, although this may affect the
width of road corridors and associated green space further. The Parish Council understands that
these pipelines do not comprise “High Pressure” routes affected by consultation distances and
land use considerations under HSE “PADHI” guidance, but considers that the pipelines may form
a greater constraint than currently envisaged.
8.7 An indicative line is also given for a potential re-drawn consultation zone based on the location
of new tanks associated with remodeling of the Buncefield Oil Depot. Although at present no
change to consultation zones is envisaged due to storage of jet fuel at the location indicated on
the plan, increased risk in the future cannot be ruled out. Potential revision to the consultation
zone is acknowledged in the Officer Level Evaluation (October 2014) as a potential (although as
yet unrealised) scenario following planning application 5/2009/0906. Therefore, the extent of
the exclusion zone adopted is considered reasonable and justified.
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Figure 13: Health and Safety Executive (HSE) Proposed Zone Boundary Distances (Revised land
use planning arrangements around large scale Petroleum depots 2007)
Figure 14: Image of Buncefield Explosion 11 December 2005 (vapour from thousands of gallons
of petrol ignited causing an explosion measuring 2.4 on the Richter Scale. It was Britain's most
costly industrial disaster)
Source: http://www.hse.gov.uk/news/buncefield/
8.8 The Listed Buildings identified within the parcel are highlighted as an initial Masterplanning
consideration not shown on the indicative suitable area identified in the February 2014 Phase 2
Green Belt Review. It is envisaged that net density around these assets is likely to be significantly
below the average net density that would need to be achieved across the developable area as a
whole; consequently increasing the density that needs to be provided elsewhere on site. These
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assets are also likely to have a greater reliance on structural landscaping given their location in
more visually sensitive areas of the site. It may be necessary to account for some (but not
necessarily all) of this area within the 40% of the site area assumed for infrastructure, especially
if this is also associated with the provision of other facilities such as a local centre and open
space.
Figure 15: St Albans Green Belt Review: Sites and Boundaries Study (East of Hemel North)
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8.9 For information, included below is an indicative developable area provided by the promoters of
the site at a presentation to Members on 17th November 2015. This demonstrates an indicative
area for residential land use going beyond the area recommended in the Green Belt Study. This
is considered to be highly inappropriate and ignores sound planning, landscape and Green Belt
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reasons as to why the area east of the Listed Buildings should not be considered suitable for
release.
8.10 This includes the Listed Buildings themselves, and the need to maintain their open aspects to
the east as part of their existing setting and significance. Land also begins rising East of the
Listed Buildings, and leaving this area open is important to visually contain development and
prevent encroachment into the countryside and coalescence towards the village of Redbourn.
This is particularly significant due to the existing ‘Ribbon Development’ extending from
Redbourn along the B487 and near the northern boundaries of the parcel. It is noted that the
Crown Estate has excluded land north of the Nickey Line from their developable area
(potentially for the reasons as set out above) but this in no way justifies other areas of the site
exceeding the recommendations from the Green Belt Study.
Figure 16: 17th November 2015 Crown Estate Presentation to St Albans Planning Policy
Committee
8.11 Alongside the parameters mapping for infrastructure, the development capacity plan has looked
to identify broad potential development parcels. The sum total of these parcels is broadly in-line
with the remaining developable area for residential land use originally assumed from the gross
total. However, there are a number of existing residential properties comprising approximately
2.85ha in the centre of the site and this land has not been identified as available for
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development. It has therefore been deducted from the remaining land and not considered as
part of the developable area.
Figure 17: Calculation of Land Parcels for Net Developable Residential Land Use East of Hemel
Parcel Name
Land Nr Listed Buildings
Land Nr Local Centre
Western Parcels
Central Area
Land Nr Secondary School (Urban Edge)
Land Nr Exclusion Zone
Existing Properties – Unavailable for Dev’mt
Net Total Area (Excluding Unavailable
Properties)
Indicative Area (ha)
4.7
1.92
6.74
4.5
6.32
2.27
(2.85)
26.45
Density
Policies / Sections to which this sub-heading
Relates:
Legal Compliance and Duty to Cooperate
Yes
No
Legally Compliant?
Satisfies Duty to
X
Cooperate?
SLP11; SLP13a
Soundness
Justified
Effective
Consistent with
National Policy
Positively Prepared
Yes
No
X
X
X
X
8.12 Redbourn Parish Council notes that Members have expressed concerns at a number of points
during the emerging Strategic Local Plan regarding the density of development that might need
to be achieved on proposed Broad Locations. This appears to be documented in the minutes of
the Planning Policy Committee for 18th December 2013 as a request to look at the density of
other large sites across the District and then supported by the “Strategic Local Plan Background
Note – Residential Density (October 2014). It must be stressed that none of the examples used
address the context of Hemel Hempstead, or deal with the degree of sensitivity associated with
Land East of Hemel.
8.13 None of the examples of major development listed have a net density greater than 31 dwellings
per hectare, yet Officers have consistently maintained that 40 dwellings per (net) hectare can be
achieved across the Broad Locations. Redbourn Parish Council welcomes that minor
modifications prior to publication of the Pre-Submission Strategic Local Plan were made to
remove reference to achieving densities of 50dph on the Broad Locations. However, 40dph is
still considered to be the very upper limit of what might reasonably be achieved, particularly on
Land East of Hemel.
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8.14 It is therefore concerning that these realities have not been reflected in the capacity of sites
assumed to support the Preferred Strategy in the Strategic Local Plan. It also noted that such
assumptions cannot be considered sound on the basis of selection and assembly of sites from
the Officer Evaluation which still assume that densities can be maximized and potentially allow
for safeguarded land beyond the plan period.
8.15 Nor can the approach be considered sound in the context of NPPF Paragraph 52, which identifies
broad support for urban extensions that reflect ‘Garden Cities’ principles. Land nearby in
adjoining Dacorum Borough is proposed for large scale development (including areas west of
Cherry Tree Lane but also other land identified for Green Belt release) at much lower indicative
density ranges. This was set out in Dacorum Borough Council’s representations to the 2014
Consultation Draft Strategic Local Plan (p.12) and it follows the Land East of Hemel will not
achieve successful integration with the adjoining urban area if brought forward at densities in
excess of 40dph. Any delivery should therefore be through a highly coordinated approach, which
would logically see a significant reduction in any scale and density of development sought.
8.16 For purposes of comparison, the Woodhall Farm area of Hemel Hempstead, immediately to the
north-west of the proposed Broad Location East of Hemel provides an overall gross density of
23dph. The area contains relatively limited public open space, but includes a primary and
secondary school, medical centre and supermarket. Overall, an assumption of 40% land use for
infrastructure and open space has been assumed, consistent with the capacity assessments in
the SKM Phase 2 Green Belt Study. This gives an estimated net density of 40dph – within the
parameters of the Strategic Local Plan policies but insufficient to deliver the scale of
development sought at the Broad Location.
Figure 18: Estimate of Gross and Net Residential Density at Woodhall Farm, Hemel Hempstead
Dwellings Persons
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Areas
Density
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Redbourn Parish Council – St Albans City and District Strategic Local Plan (Regulation 19)
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Rate
Count
Hectares DPH
per ha
11-Mar 11-Mar 11-Mar
11-Mar
11-Mar
Count
Woohall Farm – LSOA Codes
Dacorum 005A
Dacorum 005D
Dacorum 005B
Dacorum 005C
Dacorum 007C
677
67
1,533
23
n/a
694
89.2
1,531
17
n/a
709
56.9
1,493
26
N/A
494
55
1,208
22
N/A
644
33.9
1,632
48
N/A
Totals - Gross
3218
302
Totals - Net*
3218 *Net total assumes 40% of gross area POS and infrastructure
7397
136 23.66176
81.6 39.43627
Figure 19: Output Areas and Aerial Photography, Woodhall Farm Hemel Hempstead
8.17 The table below indicates that even based upon the site area considered suitable for Green Belt
release in the final February 2014 Green Belt Study, delivery of the full capacity included against
the Broad Locations could not be achieved at 40dph:
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Figure 20: Estimated Development Capacity of Sub-Strategic Land Areas Identified in the SKM Phase 2
Green Belt Study at 40dph
Site Area – Dec
2013 GB Parcels
Total
Site Area – Feb
2014 GB Parcels
Dev’able 30dph 40dph 50dph
Total
Dev’able 30dph
40dph
50dph
East of St
Albans
39
23.4
702
936
1170
55
33
990
1320
1650
Northwest
Harpenden
18
11
330
440
550
18
11
330
440
550
East of
Hemel
(North)
61
36.6
1098
1464
1830
57
34
1020
1360
1700
East of
Hemel
(South)
56
33.6
1008
1344
1680
38
23
690
920
1150
Source: Source: “St Albans Green Belt Review: Sites and Boundaries Study” (February 2014)
8.18 This assumes only 40% of land for infrastructure and public open space. In reality, the gross
developable area is likely to be reduced due to constraints on land falling within the HSE / DPZ
Consultation Zone for the Buncefield Oil Depot, meaning it is unlikely to all be suitable for
providing the necessary area for infrastructure, services and facilities.
8.19 This contrasts with Paragraph 2.5 of the Officer’s Evaluation for the Preferred Development
Strategy (‘Option 1a’) which relies on delivery of the full 1500 dwellings from across the SKM
defined site and relying on ‘densities maximised’. The option also assumes that some land could
be safeguarded for long-term release, which would not be possible alongside meeting the
housing requirement sought by the Strategic Local Plan unless densities significantly in excess of
40dph were achieved. It is not considered realistic that additional urban capacity could reduce
the need to bring forward greenfield land at the Broad Locations – as considered in the Officer’s
Evaluation – due to already optimistic assumptions for windfall.
8.20 Contingency for providing the total of 1500 units (and presumably any development to meet
needs arising in Dacorum) may be indicated by reference to ‘possible further extension’ of the
Broad Location East of Hemel (North). This is not supported by any evidence in the current
Green Belt Review, which identifies the location as the most sensitive area potentially suitable
for Green Belt release. Any further extension would therefore be inappropriate in Green Belt
and wider strategic planning terms.
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Site Assumptions and Production of Development Capacity Plan
Policies / Sections to which this sub-heading
Relates:
Legal Compliance and Duty to Cooperate
Yes
No
Legally Compliant?
Satisfies Duty to
X
Cooperate?
SLP4; SLP11; SLP13a
Soundness
Justified
Effective
Consistent with
National Policy
Positively Prepared
Yes
No
X
X
X
X
8.21 Redbourn Parish Council has taken the parameters for land use within the site further to inform
a development capacity plan of how development across Land East of Hemel may appear. In
order to achieve the stated total of 1500 units, a net density of 56.6dph would need to be
reached across the net available land for residential development. However this is unlikely to be
delivered at an even rate across the land for a number of urban design and land use
considerations. Indicative densities are given in the table below for individual parcels, allowing
with estimated dwelling outputs:
Figure 21: Density Profile of Development Parcels to Achieve Proposed SLP Capacity
Parcel Name
Land Nr Listed Buildings
Land Nr Local Centre
Western Parcels
Central Area
Land Nr Secondary
School (Urban Edge)
Land Nr Exclusion Zone
Existing Properties –
Unavailable for
Development
Net Total Area
Indicative Area (ha)
4.7
1.92
6.74
4.5
6.32
Density (dph)
25
80
40
80
80
Total Dwellings
118
154
270
360
506
2.27
(2.85)
35
N/A
79
0
26.45
56.18
1486
8.22 Robust reasons exist for the parts of the site achieving lower densities. The area ‘Near Listed
Buildings’ comprises a steeper landform rising to the south as well as reflecting the need to
protecting the setting of the assets themselves. “Land near the Exclusion Zone” sits at the most
elevated part of the site and is also likely to open out onto areas of undeveloped land and open
space at the edge of the development and associated with the DPZ consultation and exclusion
zone.
8.23 The ‘Western Parcels’ may in other circumstances be expected to achieve a higher density than
40dph, however it is necessary to take into account their relationship with neighbouring land in
Dacorum Borough. Appendix 1 to these representations comprises a Consultation Leaflet issued
in relation to the ”Spencer’s Park Phase 2” development for up to 600 dwellings. The “red line”
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plan included on this appendix includes the Land West of Cherry Tree Lane (including areas
within St Albans City and District Council’s area). To avoid ‘double counting’, any land and
dwelling estimates overlapping on Spencer’s Park Phase 2 will need to be deducted from the
proposed Broad Location East of Hemel.
8.24 At this stage, the approximate are for Spencer’s Park Phase 2 as a whole has been estimated as
25.4ha (using Google Earth imagery). Assuming a generous 40% allowance for infrastructure and
open space (given the smaller nature of the scheme) a remaining net developable area of
15.24ha would achieve 600 dwellings at approximately 39dph. This justifies the use of the 40dph
assumption on the ‘Western Parcels’.
8.25 It is also instructive to note that when land West of Cherry Tree Lane was assessed as part of the
2009 SHLAA (site: SHLAA-U-OS-332) a net density of only 30dph was applied to the site area.
8.26 The other parcels are effectively treated as the ‘remainder’ and need to achieve a density of
around 80dph. This is more than double the density sought in the Strategic Local Plan and is
likely to be particularly sensitive on the eastern parts of the site at the urban edge. This raises
extensive concerns regarding the overall outcomes of development, and departs significantly
from any examples in the nearby area. Urban extensions typically achieve net densities between
30 and 40dph, therefore the deliverability of the Broad Location as proposed is unsound and
highly likely to appear unviable to housing developers.
8.27 Appendix 2 contains a development capacity plan of the development based on the above
parameters to demonstrate the outcomes that would be achieved. It should be noted that the
parameters and development site capacity work are by no means proposals and are presented
without prejudice to our overriding objections to the SLP as proposed but are a representation
of SLP policies demonstrating that the proposals are wholly inappropriate and undeliverable
as a broad area or as an allocation in any subsequent plan.
8.28 The parameters are considered to reflect that any such scheme would be inappropriate in terms
of use of the Green Belt, urban design or even based on the policy framework set out in the PreSubmission SLP itself and for this reason the Broad Location is not justified, effective or
positively prepared. An extract from the development capacity plan is shown below:
Figure 22: Development Capacity Plan – Land East of Hemel (North)
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