East Herts District Plan: Topic Papers...attributabletoEastHerts.TheDistrictPlanproposestodeliver18,142homesbetween 2011and2033. ThisisinexcessofthelevelofneedidentifiedbytheSHMA(16,390

East Herts District Plan: Topic Papers

Development StrategyMarch 2017

TPA/001

21 Introduction

22 Housing Need and Development Principles

63 Proposed Development Strategy

174 Reasonable Alternatives

185 Conclusion

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1 Introduction1.1 The purpose of this Topic Paper is to summarise the way in which thedevelopment strategy contained within the District Plan has been identified. Inparticular, this Paper draws upon work that has taken place through respectiveSettlement Appraisals (SSS/001 – SSS/010), the Sustainability Appraisal (SUB/004)and the Supporting Document (SSS/001).

1.2 The Supporting Document, which was prepared in order to inform the PreferredOptions version of the District Plan in 2014, identifies how an initial 69 areas of searchacross the District were assessed, and then refined, in order to create a preferreddevelopment strategy. Following the Preferred Options consultation, further evidencehas been gathered which has led to changes to the strategy contained within thecurrent Pre-Submission version of the District Plan. This work is summarised withinthe respective Settlement Appraisals. Finally, the Sustainability Appraisal assessesthe development strategy contained within the Pre-Submission Plan, as well asreasonable alternatives, against a set of criteria in order to evaluate the potentialsocial, environmental and economic impacts of those proposals.

2 Housing Need and Development PrinciplesObjectively Assessed Housing Need (OAHN)

It should be noted that this section of the Topic Paper refers to the updated StrategyWorksheet contained within the Housing Topic Paper (TPA/004).

2.1 The Council has worked with its neighbouring authorities within the HousingMarket Area (Harlow, Epping Forest and Uttlesford Councils) in order to prepare aStrategic HousingMarket Assessment (SHMA) (HOP/001). The purpose of the SHMAis to identify the level of objectively assessed housing need within the Housing MarketArea.

2.2 The study concluded that, at that time, the level of housing need across thefour authorities was for 46,058 homes for the period 2011 - 2033. This figure wasthen disaggregated between the four authorities. For East Herts the level of needwas identified as being 16,390 homes between 2011 and 2033, which equated to aneed for 745 homes per year. Having been prepared in 2015, the SHMA utilised the2012 Household projections which represented the most up to date position at thetime.

2.3 However, in July 2016, immediately prior to the Council agreeing thePre-Submission version of the District Plan in September, the Government releasedupdated 2014 Household projections. Planning Practice Guidance (PPG) identifiesthat Household projections should provide the starting point estimate of overallhousing need. The starting point presented by these projections indicates that thelevel of need across the Housing Market Area is 50,697 homes, of which 17,243 is

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attributable to East Herts. The District Plan proposes to deliver 18,142 homes between2011 and 2033. This is in excess of the level of need identified by the SHMA (16,390homes) and the 2014 based Household projections.

2.4 The Council acknowledges that further work is required to identify an up todate OAHN figure, and is committed to undertaking this work prior to the ExaminationHearing sessions. Should the level of need be in excess of 18,142 homes, a partialreview of the District Plan may be required in order identify additional sites fordevelopment.

2.5 More information on objectively assessed housing need can be found in theHousing Topic Paper (TPA/004).

2.6 As part of the overall housing requirement, the NPPF requires a supply ofspecific deliverable sites in order to meet housing needs in the first five years of theplan period following adoption. For East Herts, the first five year period is 2017 –2022. Since 2011, there has not been sufficient development to meet the annualtarget of 745 homes(1). In line with national policy, the Plan seeks to make up thisshortfall in the first five year period (2017 – 2022).

2.7 The NPPF also requires the provision of an additional buffer in the first fiveyear period (moved forward from later in the plan period) to ensure choice andcompetition in the market for land. A 20% buffer should be applied where there is apersistent record of under-delivery. Given the significant shortfall in housing deliverysince 2011, the Council accepts that a 20% buffer should be applied. Taking intoaccount identified need, the shortfall and the 20% buffer, the total housing requirementfor the first five year period is 6,106 new homes(2) (or 1,221 homes per year).

2.8 The level of development identified within the first five year period is significantlygreater than the 4,321 homes previously identified within the Preferred Optionsversion of the District Plan (2014). There are two reasons for this change. Firstly,the housing target for the first five year period contained within the Preferred Optionsdocument was based on a 5% buffer, moved forward from later in the plan period.As noted above, the Council now accepts that this position was unsound, and assuch, a 20% buffer has been applied. Secondly, the Preferred Options plan alsosought to provide for the shortfall (as described in paragraph 2.3) over the course ofthe entire plan period. However, national policy indicates that the shortfall should bemade up in the first five year period (2017-2022) if there are sites available to achievethis. Having undertaken a further assessment of potential site options, in particularin relation to land East of Stevenage, it is now the view of the Council that it is possibleto meet the shortfall in the first five year period.

2.9 Paragraph 47 of the National Planning Policy Framework (NPPF) states that:

1 The pre-plan period is 2011 – 2017. Therefore the level of housing need in this period is 745 homes x 6 years = 4,470homes. Expected number of housing completions in this period is 3,107 homes. This leaves a shortfall of 1,363 homes(4,470 – 3,107).

2 The first five year period is 2017 – 2022. The level of need for this period is 745 homes x 5 = 3,725 homes. 3,725homes plus the shortfall of 1,363 homes = 5,088 homes. The 20% buffer is then added: 5,088 homes x 1.2 = 6,106homes.


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‘local authorities should use their evidence base to ensure that their Local Planmeets the full, objectively assessed needs for market and affordable housingin the housing market area, as far as is consistent with the policies set out inthis Framework.’

2.10 It is therefore clear that East Herts Council must seek to meet its full housingneeds having regard to other policies contained within the NPPF. The processundertaken to identify a sustainable development strategy to meet this need, includingthe challenging level of identified need in the first five years of the Plan period, issummarised in the remainder of this Topic Paper.

2.11 The Council has sought to demonstrate that each of the sites contained withinthe Plan are available for development and are deliverable within a certain period oftime. With this in mind, the Council has only proposed to allocate sites where theyhave been promoted to the Council for development, either by landowners ordevelopers.

Brownfield Land

2.12 Paragraph 111 of the NPPF states that:

‘Planning policies and decisions should encourage the effective use of land byre-using land that has been previously developed (brownfield land), providedthat it is not of high environmental value’.

2.13 Given the rural nature of East Herts, the number of available brownfield sitesis very limited. Where such sites do exist they have been proposed for developmentwithin the District Plan. These sites are:

The Goods Yard in Bishop’s Stortford for 400 homes (Policy BISH7);The Causeway/Old River Lane site in Bishop’s Stortford for 100 homes (PolicyBISH8); andMead Lane in Hertford for 200 homes (Policy HERT2).

2.14 In addition, a further town centre brownfield site in Bishop’s Stortford, knownas the Mill Site (Policy BISH10), is also identified for re-development should it becomeavailable, either in the current plan period or beyond.

2.15 However, the sites combined would only deliver a total of approximately 700homes. The remaining housing needmust therefore be provided on greenfield/GreenBelt sites.

Green Belt and Rural Area Beyond the Green Belt

2.16 The term ‘Green Belt’ does not relate to the environmental or aesthetic qualityof land. It is a planning tool devised in the 1940’s which was created in order toprevent sprawl of large urban areas. Therefore not all ‘greenfield’ land is categorisedas Green Belt. As illustrated in Figure 2.1, the lower third of the District is located


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within the Metropolitan Green Belt (the area of Green Belt that seeks to prevent thesprawl of London), while the upper two thirds is designated by the Council as RuralArea Beyond the Green Belt.

2.17 With the exception of Buntingford, which in itself is a small town with limitedservices and facilities, the area that is designated as Rural Area Beyond the GreenBelt is mainly characterised by a large number of small, relatively isolated villages.

2.18 In order to avoid development of Green Belt land, the Council could havechosen to locate the vast majority of homes within the Rural Area Beyond the GreenBelt. However given the lack of access to services and facilities, it is not consideredthat this would be a sustainable approach and such a strategy would therefore notbe in conformity with the policies contained within the NPPF. The principle of releasingGreen Belt, including consideration of ‘exceptional circumstances’, is presented inthe Green Belt Topic Paper (TPA/003).


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Figure 2.1 The current extent of Green Belt and Rural Area Beyond the Green Belt

3 Proposed Development StrategyBuntingford

3.1 While it would not be sustainable to locate the majority of the District’s housingneeds within the Rural Area Beyond the Green Belt, it is considered appropriate todirect some development to this area. The Preferred Options version of the DistrictPlan (2014) identified two sites in Buntingford, one to the north of the town and oneto the south (the former Sainsbury’s depot) totalling around 480 homes.


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3.2 As Figure 3.1 identifies, both of these sites have since received planningpermission. In addition, largely due to the fact that the Council does not have an upto date local plan in place, a number of other developments have also receivedpermission at appeal. At present, approximately 1,100 homes either have planningpermission or are being constructed in Buntingford. Despite its status as one of theDistrict’s main settlements, Buntingford is a relatively unsustainable location,particularly in relation to access to public transport. As such, it was not consideredappropriate to identify further development allocations within the District Plan.

3.3 Hertfordshire County Council has advised that, as a result of recent planningpermissions, a new First School is required in Buntingford. The District Plan thereforeincludes a proposed allocation for this use.

Figure 3.1 Committed development in Buntingford

3.4 Limited development is also proposed for the villages within the Rural AreaBeyond the Green Belt. This is discussed later within this Topic Paper.

3.5 Having identified all available brownfield sites in the District for development,and also having concluded that only a limited amount of development is appropriatewithin the Rural Area Beyond the Green Belt, it is necessary to assess the suitabilityof sites located within the Green Belt.


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Bishop’s Stortford

3.6 Bishop’s Stortford is the largest settlement in the District. It benefits fromexcellent access to the strategic road network, the West Anglia Main Line andStansted Airport and is therefore one of the most sustainable locations in the Districtfor new housing and employment. The currently adopted Local Plan (2007) allocateda significant amount of land to the north of the town for the delivery of approximately2,530 homes over a number of years along with supporting infrastructure. This areahas now received planning permission and development has recently commencedon part of the site. However, at the time that the Pre-Submission version was agreed,development had not commenced, and as such, it was considered prudent to maintainthe site as an allocation within the District Plan (Policy BISH3). A further allocationfrom the 2007 Local Plan, located off Hadham Road, has also been carried forwardwithin the District Plan for the delivery of 163 homes (Policy BISH4). The site waspreviously identified as a potential location for a secondary school. However, it iscurrently proposed that the school be provided as part of development to the northof the town. If this occurs then the Hadham Road site will be available for residentialuse.

3.7 Other sites, currently located within the Green Belt, have also been proposedfor allocation. A site to the south of the town (Policy BISH5), which is located withinthe route of the A1184 bypass, is proposed for 750 homes, employment land andnew schools. There is potential to re-locate Bishop’s Stortford High School to thisnew site. If this did occur, then the existing school site would become available forthe delivery of 150 homes. As such this site is also proposed for allocation with theDistrict Plan (Policy BISH6).

3.8 A final site, currently located within the Green Belt, is proposed as an allocationfor the delivery of 50 homes to the east of the town (Policy BISH9). The PreferredOptions version of the District Plan (2014) identified this site for 150 homes. However,following further discussions with the landowners, the developable area has beenreduced.


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Figure 3.2 Proposed development in Bishop's Stortford

3.9 In total the District Plan proposes just over 4,000 dwellings for Bishop’s Stortford.The Green Belt Review concluded that the ‘green wedges’ that protrude towards thetown centre do not perform an important Green Belt function. However, it is consideredthat the wedges form an integral part of the character of the town and thereforeshould be protected.

3.10 Due to land availability and environmental constraints, there are very fewopportunities for further development in Bishop’s Stortford.

Sawbridgeworth

3.11 The strategy for Sawbridgeworth is shaped by advice received from theHighways Authority (Hertfordshire County Council). Based on the available evidence,the County Council has indicated that provision of more than approximately 500homes in the town would require the provision of a bypass. However, at present,such a scheme has not been identified within Hertfordshire County Council’s 2050Transport Vision work, and it is therefore unlikely to be delivered within the Planperiod. Therefore as identified within Figure 3.3 below, the total amount ofdevelopment proposed for the town is 500 dwellings spread over three sites, all ofwhich are currently within the Green Belt; 200 homes to the north of the town (PolicySAWB4), 125 homes to the north of West Road (Policy SAWB2) and 175 homes tothe south of West Road (Policy SAWB3). Land to the north of West Road will alsoallow for the permanent expansion of Mandeville Primary School.


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3.12 The County Council has been undertaking transport modelling work knownas COMET. The outcomes of this work demonstrates that the A1184 corridor isalready constrained, and that provision of additional development within the GilstonArea, as well as Bishop’s Stortford and Sawbridgeworth is likely to add additionalpressure to the local highway network. As such, it would not be sustainable to directfurther development to Sawbridgeworth at present, beyond the 500 homes alreadyproposed.

Figure 3.3 Proposed development in Sawbridgeworth

Hertford and Ware

3.13 For the purposes of this Topic Paper, Hertford and Ware are referred totogether, again due to advice received from the County Council with regards totransport.

3.14 The initial advice, received in July 2015 (TRA/010), indicated that the capacityof the A414 to cater for future growth is severely constrained, particularly on thesection of the route that passes through Hertford. As a result, the amount ofdevelopment that can be delivered in this area is limited, not only within Hertford,but also Ware.

3.15 Nevertheless, development proposed within the District Plan prior to 2024was deemed by the County Council to be acceptable. In addition to the Mead Lanesite identified earlier in this Topic Paper, proposed development within the GreenBelt includes:

300 homes to the West of Hertford, north of Welwyn Road (Policy HERT3);250 homes to the West of Hertford, west of Thieves Lane (Policy HERT3;150 homes to the North of Hertford (Policy HERT4); and50 homes to the South of Hertford (Policy HERT5).


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3.16 The County Council clarified that further growth would not be deliverable untila strategic intervention (such as a Hertford bypass) is identified and delivered(TRA/010).

3.17 Following this initial advice, further work by the County Council (TRA/011)established that there is additional capacity on the network to deliver a further 1,000homes to the North and East of Ware. However, in order to ensure the ongoingresilience of the A414 corridor, it was suggested by the Highway Authority thatdevelopment in this location should be phased with only 300 homes being deliveredprior to 2024, with the remaining 700 homes coming forward after that date. Havingregard to this advice, the District Plan proposes an allocation of 1,000 homes to theNorth and East of Ware (Policy WARE2), along with supporting infrastructure.

3.18 The Plan also includes an allowance for a further 500 homes in this location,subject to the delivery of a strategic highway scheme which will provide additionalcapacity. The County Council’s advice with regards to A414 capacity is located withindocument reference TRA/010.


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Figure 3.4 Proposed development in Hertford


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Figure 3.5 Proposed development in Ware

Villages

3.19 East Herts is a rural District, and as such contains a large number of villagesof differing sizes. The District Plan seeks to maintain the existing character of thevillages while providing some limited development to meet local needs.

3.20 The Plan includes a village hierarchy to help guide future development inrural areas. This is based on the findings of the Village Hierarchy Study (HOP/010).Policy VILL4 of the District Plan requires that at least 500 homes are delivered in thevillages over the course of the Plan period. Rather than allocating sites through theDistrict Plan, Parish Councils are encouraged to prepare Neighbourhood Plans todeliver growth. In particular, the most sustainable villages (Group 1) located withinthe Rural Area Beyond the Green Belt are required to provide for a minimum 10%increase in housing stock from 1st April 2017 onwards:

Braughing: 35 homesHunsdon: 37 homesMuch Hadham: 54 homesStandon & Puckeridge: 146 homesWalkern: 55 homes

3.21 Therefore a minimum of 327 homes will be delivered in these villages. All fivesettlements are located within parishes that have had Neighbourhood Planning AreaDesignations approved. The Standon Neighbourhood Plan is most advanced havingcompleted a Regulation 14 consultation in December 2016. In addition, in a numberof these villages some development has already been permitted. This is explainedfurther within the Housing Topic Paper (TPA/004). The residual figure of at least


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173 homes will be provided across the remaining villages in the District, either throughNeighbourhood Plans or windfall development (unplanned development that comesforward through the planning application process).

3.22 The Plan could potentially have sought to deliver a greater amount ofdevelopment within the rural area. However, it is considered that the chosen strategyprovides a suitable balance between the delivery of homes and maintaining theexisting character of the District’s villages.

Development Adjacent to Neighbouring Towns.

3.23 The proposed sites identified so far in this Topic Paper will make a significantcontribution towards the District’s overall housing need of 16,390 homes by 2033.In addition, with the exception of land to the North and East of Ware, all sites willmake a contribution to the particularly challenging level of need in the first five yearsof the Plan period following adoption (6,106 homes between 2017 and 2022).

3.24 However, in order for the Council to meet its needs in full, further sites arerequired. There are three large towns immediately bordering East Herts; Harlow,Welwyn Garden City and Stevenage. Each of these towns contains significantservices and facilities, as well as public transport options for travelling to other majorurban centres including London. As such, it is considered that providing developmenton the edge of these neighbouring towns, but within the East Herts local authorityarea, is a sustainable option in order to contribute towards the District’s housingneeds. These proposed developments are discussed in turn below. Again, furtherdetail can be found in the respective Settlement Appraisals (SSS/002 - SSS/010).

The Gilston Area

3.25 This large site to the north of Harlow (Policy GA1) will provide for a substantialamount of East Herts housing needs, both within this Plan period and beyond. Thesite is proposed as an allocation to ultimately deliver 10,000 homes along with arange of supporting infrastructure including new roads, schools, health facilities,parklands and other green spaces.

3.26 However, despite being allocated for 10,000 homes, it is likely that only around3,000 homes could be delivered by the end of the plan period in 2033, with theremaining 7,000 coming forward after that date. This position is based on theCouncil’s evidence base which suggests that around 300 homes could be deliveredeach year in this location. Due to the size and complexity of the site, and the levelof supporting infrastructure required, it is also very unlikely that development in thislocation would contribute towards identified needs in the first five year period(2017-2022).

3.27 Development in this location should be considered in light of the successfulHarlow and Gilston Garden Town bid which has been supported by Government.


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Further information in relation to the Garden Town can be found in the Harlowand Gilston Garden Town Position Statement (SSS/015).

Figure 3.6 The Gilston Area

Birchall Garden Suburb

3.28 A site to the east of Welwyn Garden City is proposed for allocation in boththe East Herts District Plan and the Welwyn Hatfield Local Plan to accommodateapproximately 2,550 homes over the plan period. Of this figure, 1,200 homes willbe located within Welwyn Hatfield Borough and 1,350 homes will be in East Herts.As with development in the Gilston Area, a range of infrastructure will also be providedin this location including schools, health facilities and green space.


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3.29 Again due to the complexity of the site, and the fact that minerals reservesneed to be extracted in this location prior to development, it is likely that the majorityof homes will be delivered between 2022 and 2033. However, approximately 200homes could be delivered in the first five year period (2017-2022).

Figure 3.7 Birchall Garden Suburb

Gresley Park

3.30 Development to the east of Stevenage did not form part of the PreferredOptions version of the District Plan (2014). At that stage, a development of between3,000 and 5,000 homes in this location was considered less preferable when assessedalongside other options, largely due to the negative impact that large scaledevelopment could have on the environmental quality of the Beane Valley.

3.31 However, the sites identified and discussed above within this Topic Paperwould not in themselves cumulatively enable the Council to meet its full needs withinthe first 5-year period (6,106 homes between 2017 and 2022). As a result,


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development to the east of Stevenage has been reconsidered. Following furtherinvestigation into the site’s potential, it is the view of the Council that a smaller scaleof sustainable development could be provided in this location, early on in the planperiod, without causing undue harm to the Beane Valley. As such the site is proposedas an allocation to deliver 600 homes and a new primary school.

Figure 3.8 Gresley Park

4 Reasonable AlternativesA New Town

4.1 A potential alternative to the proposed development strategy would be to identifyland elsewhere in the District in order to deliver a new town. It is likely that the onlysuitable area for such a development would be in the rural north of East Herts.However, a sufficient area of land to deliver a significant new development of thiskind has not been promoted to the Council as being available. In addition, given therelative isolation of this area, and the fact that a huge amount of infrastructure wouldbe required to support it (particularly new roads connecting to existing strategicroutes), it is highly unlikely that such an option would be deliverable within the plan


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period. Nevertheless the Council will work with neighbouring authorities to furtherexplore the possibility of delivering a new settlement to help meet housing needsbeyond 2033.

5 Conclusion5.1 This Topic Paper has sought to summarise the site selection work that hastaken place in support of the District Plan. In particular it has identified the following:

the District’s housing need is significant (the 2015 SHMA indicated that the levelof need at that time was 16,390 homes by 2033, including 6,106 homes between2017 and 2022);there is a very limited amount of available brownfield sites to contribute towardsthis need;it would be unsustainable to deliver the entire housing need within the RuralArea Beyond the Green Belt, and that therefore existing Green Belt land isrequired for development;the five main towns in the District can provide some development but the amountis limited, either by highways constraints (Hertford, Ware and Sawbridgeworth)or by sustainability considerations (Bishop’s Stortford and Buntingford) and/orother environmental concerns;the villages can contribute a limited amount of development;the remaining need will be provided on sites adjacent to three towns whichneighbour East Herts;the alternative option of providing a new town is unlikely to be deliverable withinthe plan period; andthe Council recognises that, in light of the 2014 Household projections publishedin July 2016, the position presented in the SHMA is now out of date. As such,further work will be undertaken prior to the Examination Hearing sessions inorder to identify the most up to date Objectively Assessed Housing Need figure.


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Documents

East Herts District Plan: Topic Papers...attributabletoEastHerts.TheDistrictPlanproposestodeliver18,142homesbetween 2011and2033. ThisisinexcessofthelevelofneedidentifiedbytheSHMA(16,390