FM016
If this modification is about showing where the age profile of North Herts population diverges from Hertfordshire it fails to do this by not identifying the age group where the district has above average population representation, it only identifies below average representation in the 15-29 age grouping.
FM017
This paragraph has been adjusted to give the population prediction for next ten years based on now outdated 2016 predictions. However, the plan, and housing numbers are for 20 years so it would be helpful to also identify the total population growth over the 20 years period by indicating the growth that has occurred up to 2021. Given that population growth predictions have been reviewed downwards in both ONS 2016 and 2018 population projections is it accurate to say there is ‘considerable’ pressure on housing, ‘moderate’ might be a better description.
FM020
For balance it would be helpful to add the life expectancy figure for women in the most deprived areas of North Herts.
FM028
The OAN of 11,500 was subject to considerable challenge during the hearing sessions. 2018 ONS housing projections suggest an OAN of at most 8,800. With the heavy reliance on green belt land that underlies this plan, over-provision of housing has a huge environmental cost and TTL would like to see North Herts make a case for a lower OAN based on the need to protect the green belt and in respect of the ONS 2018 population projections.
FM031
TTL would expect NHDC to acknowledge and focus on developing housing in places that can sustainably access the growing Cambridge employment area.
FM035
The phrase “have regard to this strategy” appears to refer to LTP3 as adopted in 2011. Because the Hertfordshire Transport vision to 2050 was not produced by 2016, but is now close to publication, it would in our view be sound to adopt its vision and strategy for the Local Plan 2011-2031.
Should the deleted wording of this paragraph be replaced by a brief explanation of how LTP4 and the various local plans across the county, including this local plan will be reconciled to provide a consistent solution for transport, housing and employment?
FM038
The final bullet point says “good quality”, what does this mean in terms that can be put into practice and verified by measurement? TTL would like these words replaced with “zero carbon” which would align with ambitions in the NHDC Climate Strategy.
MM017 / FM050
At the hearings concerns were raised that the modelling and data which informed the retail space allocations in the draft local plan were considered out-of-date, shopping behaviours have radically changed. TTL’s expectation is that land allocated for retail could be reassigned for housing, reducing the need to build on green belt land. It is not clear why NHDC did not take the opportunity offered by the hearing to suggest a reduced allocation of land for retail.
Now that we appear to be emerging from the main Covid-19, it is becoming clear which outlets have survived, which have not and which retail modes of operation have changed substantially. It seems to us unsound to exclude that reality from the Plan.
FM052
Twelve months into the adoption of this plan seems too late to review the outdated Town Centre strategies (which were published between 2004 and 2008). If a review could take place prior to adoption of this plan, it seems likely that a number of brown field sites could be reallocated to housing, allowing green belt land to be removed from the plan.
The proposed change causes a contradiction between “Town centre strategies have been produced” and “Work on these town centre strategies will commence…”. In view of drastic changes noted above for FM50, could this be clarified by proposing that revised strategies be produced now for this Local Plan?
FM053
The proposed wording seems muddled, with “related” (to “shops) and “pubs or drinking establishments” acting as constraints upon the permissible “retail and service uses” .
In practice, the primary frontages already have lots of eating and drinking establishments so the value of identifying primary and secondary frontages is unclear. ‘Shops’ are locating in secondary frontage areas where the rents are lower.
MM035/FM057
Given so many of the housing sites in this plan are on the green belt and have associated sustainable transport issues, TTL do not consider it appropriate for any land to be allocated to meet needs above the OAN, or which will not be built within the plan period.
FM058
If 2018 ONS data is applied the housing need would be in the region of 8,800 to meet the needs of North Hertfordshire. Building excessive homes in North Hertfordshire does not align with the UK Government’s ‘levelling up’ agenda.
FM062
Has there been a road building programme to support new housing in the period to 2021? Our understanding is that LTP4 has identified building new roads as unsustainable. It is unclear that this paragraph provides the rationale as to why North Herts are backloading housing delivery.
FM063
This paragraph indicates that “innovative approaches to construction” may be required. TTL would like this to make clear that the expectation is that these innovative approaches will be to deliver zero carbon homes.
MM040/FM064
A jump (already in effect) from 330 homes per year to 500 stretches credibility, whilst a further jump 3 years hence from 500 to 1,120 (with infrastructure in place) just seems incredible. What evidence or grounds for confidence are available for the latter target, in view of the uncertainties expressed in FM062?
MM045 / FM001
This modification is a good addition to the local plan. We note that siting and layout that minimise commuting distances and rely on “well-connected footpaths and cycle ways” would greatly reduce dependency on new highway infrastructure.
FM190 / FM193
FM190 states a whole plan review will occur by the end of 2023. FM193 says a whole plan review will commence by the end of 2023. Are these referring to the same review and if so can it be made clear when the review is expected to start and end?
FM195
TTL are glad to see that a comprehensive review is planned which will be completed by 2025 at the latest. Given that this could lead to a comprehensive update on the way forward it is really important that the existing plan does not constrain that prospect by seeking to allocate any land for the period beyond 2031, particularly green belt land.