Our consultation submission, Herts Minerals & Waste Draft Local Plan 2040

We challenge the overall level of provision for land-won sand and gravel. We believe there is an over estimation of future development (both housing and infrastructure) and an under-estimation of secondary and recycled aggregate available from alternative sources. These factors mean that the Draft Plan would result in needless destruction of the countryside including three new quarrying sites in the Green Belt. These are Ellenbrook Fields on the site of the former Hatfield Aerodrome; land at Coopers Green Lane in Hatfield; and the Briggens Farm estate east of Stanstead Abbotts.

After a full analysis, we have made our consultation submission on the Regulation 18 Hertfordshire Minerals and Waste Draft Local Plan (“the Draft Plan”).  We are very concerned by many of the proposals in the Draft Plan.

Summary of our concerns

We challenge the overall proposed level of provision for land-won sand and aggregates given the lack of evidence and information regarding future demand, and the failure to assess properly the potential and likely contribution from alternative supply sources.

In our view the Draft Plan over-estimates significantly the scale of future development and construction activity in the plan period. The data on proposed new housing in district local plans is outdated with some assumptions still based on 2014-based household projections which have now proved to be excessive.

The Draft Plan over-estimates the need for land-won aggregates to support ‘Major Growth Projects’ some which are already complete and others are speculative.

The Draft Plan under-estimates the supply of secondary and recycled aggregate available. We want to see greater ambition and stronger policy in the Draft Plan to maximise the re-use and recycling of materials available at regeneration and redevelopment sites. This will reduce reliance on land-won aggregates.

We also want to see stronger policy in the Draft Plan to ensure that any new waste management applications in the Green Belt are required to demonstrate that the need for the facility cannot be met from existing and already proposed sites and that there are no suitable non-Green Belt alternative locations.

Minerals extraction and waste processing have the potential to threaten Green Belt land with development that would cause major environmental and social harm for a generation or more.  We are mindful of recent and repeated Ministerial statements regarding protection of the Green Belt.

We do not believe that the proposed allocation of three new minerals extraction sites in the Draft Plan is either reasonable or properly justified. All are in the Green Belt. They are at the Briggens Estate, east of Stanstead Abbots; Coopers Green Lane, Hatfield; and Ellenbrook Fields on the site of the former Hatfield Aerodrome.

What you can do

Our full submission is available for reference, and we encourage everyone to make a submission, expressing your own concerns. It’s important that as many local Hertfordshire people as possible respond to this consultation.

The consultation closing date has been extended to 31^st October 2022.

The Draft Plan and supporting evidence base are available for review on Hertfordshire County Council’s website at https://www.hertfordshire.gov.uk/mwlp.

You can download a Consultation Response Form from the same link and complete it or attach it to your own ‘free form’ submittal (as we have done) and either email it to MineralsandWaste@hertfordshire.gov.uk

Or post it to:  Minerals and Waste Planning Policy Team, Spatial Planning Unit (CHN216), Hertfordshire County Council, County Hall, Pegs Lane, Hertford SG13 8DN

About us

We are CPRE Hertfordshire, the countryside charity. We campaign to protect, promote and enhance the beautiful Hertfordshire countryside for everyone’s benefit. If you share our concern about the ongoing threats to our beautiful countryside, please consider supporting our work. We are a membership charity and it’s easy to join online for as little as £36 per year. We appreciate your support!