St Albans City & District Draft Local Plan – our initial review

St Albans City & District Council is conducting a public consultation on its new Draft Local Plan out to 2041. If the Plan goes ahead, a massive 792 hectares (1,957 acres) of Green Belt land will be lost to development. It’s vital that as many local people respond to the consultation as possible. To help people to develop their response, our planning specialists and volunteers have completed an initial review and site analysis. We will publish our full submission well before the consultation closing date of 25th September, which can also be used to support your response.

We believe that Local Plans are best developed using an integrated approach that puts climate change, biodiversity, well-being, and social inclusion at the centre of the Plan. We also believe our countryside is precious and finite, and should not be lost to development unnecessarily.

More new homes are needed, especially genuinely affordable homes for local people and key workers. But there is scope to use previously developed land (‘brownfield’) and to take advantage of changes in town centres and working practices to address this need.

We have significant concerns about the St Albans City & District Draft Local Plan

A brief summary of our concerns is outlined below. Further guidance, including instructions for submitting your own consultation response, is available to download.

Download

And please see our photo gallery at the bottom of this web-page to see some of the countryside that is now under threat of development. This includes –

• 459 hectares of Green Belt land at Hemel Hempstead
• 116 hectares of Green Belt land at St Albans
• 80 hectares of Green Belt land at Harpenden
• 41 hectares of Green Belt land at Park Street
• 40 hectares of Green Belt land at Redbourn
• And smaller amounts of Green Belt land at many other settlements around the District.

Context and timing

We believe it is unnecessary to move forward with the Draft Local Plan in the present period of uncertainty regarding the Government’s imminent amendments to the National Planning Policy Framework. Dozens of other Councils across England have paused their Draft Local Plans while awaiting these amendments so it is unclear why St Albans is determined to press ahead now.

Over-provision of housing

The Draft Local Plan relies on old projections of future household growth dating from 2014. Also, the Council has failed to take account of provisions in national planning policy that permit restrictions on the scale of development based on planning constraints such as Green Belt and other designated and protected areas. These two factors lead to an unnecessarily high housing target of nearly 16,000 dwellings and the proposed release of a massive amount of Green Belt land for development.

Growth and development

The Draft Local Plan confuses ‘growth’ with ‘development.’ Economic development does not automatically mean that there is demand for greenfield sites to accommodate it. This is important because the Draft Plan presents the unquestioned need for ‘growth’ as justification for the loss of land in the Green Belt.

Lack of protection of the Green Belt as a Key Priority

Given that 80% of the land area in the District is within the Green Belt, it is an unacceptable omission from the Draft Local Plan that protecting and enhancing the Green Belt is not seen as a key priority.

Failure to address climate change

The Council declared a Climate Emergency in 2019 and addressing climate change is stated as a key priority in the Draft Local Plan. But the generalised policy statements in this regard do not constitute a meaningful pathway for implementing and achieving real change.

Underestimation of the opportunities for reuse of land

The Draft Local Plan specifies the redevelopment of urban car-parks and this is welcomed. But there is insufficient consideration of social and economic trends that are likely to create many more opportunities for the conversion of commercial and other space to residential use.

Affordable housing

The provision of affordable housing is given prominence in the Draft Local Plan, as is warranted. But based on past practice we believe that it is misleading to suggest that truly affordable housing can be provided by private sector developers on Green Belt sites. This calls into question the justification of the release of Green Belt land for development.

Water, waste, and other utilities provision

Known water supply deficiencies are not sufficiently addressed, and waste water treatment capacity is noted as only sufficient up until 2031.

Natural resources and biodiversity

The Rivers Ver, Colne and Lea are globally significant chalk streams but provisions in the Draft Local Plan to ensure their survival, let alone improvement, are woefully inadequate. Similarly, the treatment of biodiversity issues in the Draft Plan is minimal, with only bland statements of intent and minor proposals such as bird and bat boxes.

What you can do

You can read more about each of our concerns in these areas in our initial review and site analysis, as you begin to prepare your own consultation response.

We hope that all local people and communities throughout the District will respond to the consultation and have your say about the proposals. It’s imperative that the Council understands local residents’ concerns, so your comments are important.

The consultation documents can be viewed at https://www.stalbans.gov.uk/new-local-plan

And finally….

We are CPRE Hertfordshire, the countryside charity. We work on behalf of everyone across Hertfordshire to protect and promote the beautiful countryside, for now and for the future. Our charity relies entirely on memberships and fundraising. Please help the countryside and become a CPRE member today – it’s easy and quick to join online. Or make a recurring or one-off donation – any amount is most welcomed.