Three Rivers District Council (TRDC) is consulting on a new Local Plan. You can view the consultation here.
Part 2: Sites for Potential Allocation
80% of the additional dwellings set out in the potential sites allocation document are allocated to sites previously in the Green Belt. There are many sites of serious concern including:
CFS10 – Land between Millhouse Lane and Bell Lane, Bedmond – Open grassland
CFS19 – Land adjacent 62-84 & 99-121 Sycamore Road – Amenity Grassland
CFS18b – Hill Farm, Stag Lane – Agricultural
EOS12.2 – Land to the west and south of Maple Cross – Agricultural
CFS69a – Land at Carpenders Park Farm – Agricultural
PCS47 – South of Little Oxhey Lane – Agricultural
OSPF22 – Batchworth Golf Course
Part 1: Preferred Policy Options
Housing numbers
Based on a national ‘standard methodology’ for calculating the District’s housing need, Three Rivers must provide 630 dwellings per year, resulting in an overall target of 12,624 dwellings over the plan period to 2038. However, TRDC has come up with its own figure of 10,678 dwellings (1,946 already committed and 8,973 additional homes). It’s not entirely clear from the consultation documents what the Council’s alternative methodology is for this new figure. CPRE Hertfordshire has already published an initial assessment stating TRDC is accounting for an overprovision of housing due to the projections being out of date. The latest projections show a decrease in new households and therefore a reduced number of houses which should be planned for. The Council has failed to take account of local planning authorities’ ability to challenge the Government’s calculation for housing numbers and to restrict the scale of development due to planning constraints of an individual area.
Residents’ Associations across the district believe the Local Plan contains significantly too much housing resulting in unnecessary damage to our environment and, in particular, Green Belt.
Please sign and share the petition calling to reduce the housing target.
Affordable housing
The need for affordable housing is equivalent to 60% of the District’s total housing requirement (see 4.48 of Part 1). However, the preferred policy option states all new development with a net gain of one or more dwellings will be expected to provide only 40% for affordable rent. Developments delivering 10 or more dwellings should provide an additional 10% for affordable home ownership.
It is also stated that where developers justify a lower amount of affordable housing (which happens too often) the Council will seek to secure the preferred tenure split (i.e. rented accommodation over home ownership) as a priority over a higher percentage of affordable housing overall.
The affordable housing target should at least meet the identified need and be backed up by strong policies. Considering the extreme unaffordability of housing in Three Rivers and the poor delivery rate of affordable housing on recent developments, the Local Plan should be utilised to its fullest potential to hold developers to their obligations. Unfortunately, the current policies feel watered down and come across as pandering to developers.
Biodiversity
The policy options refer to biodiversity as an asset but mainly as a setting for development and opportunities for recreation and leisure. It includes the policy statement: “Development should result in a net gain of biodiversity value.” However, no specific targets are set. Furthermore, no details are given for how a biodiversity net gain should be measured. The Plan requires clear targets and deliverables otherwise it is useless.
Climate change
TRDC declared a Climate Emergency in May 2019 and the Local Plan is the key mechanism for the Council to implement the requirements of this declaration. Although the objectives identify climate change issues in the most general terms, the policy options clearly prioritises housing provision and greenfield land development over such considerations. The proposed policies fail to take account of the need for carbon reduction targets and sustainable transport provision, amongst many other concerns, and a carbon reduction pathway is needed to meet national obligations for net zero emissions by 2050.
Your response
It’s really important that local residents, who are familiar with the potential development sites, have their say to highlight if and how a site will have a detrimental impact on the community. Some sites have already been dropped prior to consultation as they were considered to cause “particular harm to existing communities and residents’ quality of life without providing compensating benefits to the community”. This shows that pressure from local residents can have an impact on the choice of sites taken forward.
We also believe it is important to support sites that will have the least detrimental impact, that can deliver benefits to the wider community, and contribute to the overall vision of a sustainable and healthy district.
This is a draft version of The Plan which means that elements of it can still change before it is published. Alterations can be made based on the feedback received from this consultation or the findings of any emerging evidence.
We are seeking views from members and supporters in order to compile a comprehensive view of sites across the whole district. We encourage you to get in touch with your views. Please do respond to the consultation directly and encourage your neighbours to do so as well.