Three Rivers Local Plan – We’ve submitted our consultation response

We have now submitted our comprehensive response to the Council regarding their consultation on a new draft Local Plan to 2038.  We hope this will be helpful to local people and groups in formulating your own responses to the consultation.

We have seven principle concerns for which the headlines are listed below.  Full details including our responses to the individual consultation questions are available to read here  –  Three Rivers District Council Local Plan Reg. 18 Preferred Policy Options CPRE Hertfordshire Comments

1. Impact on designated protected areas; including Green Belt (GB) and Chilterns Area of Outstanding Natural Beauty (AONB)

76% of Three Rivers District is designated as Green Belt and it also contains 546 hectares of the Chilterns AONB and 159 nationally and locally designated environmental sites. These are key characteristics of the district and contribute massively to the quality of life of residents and visitors. Despite the statement that “great importance is attached to the Green Belt in Three Rivers”, 8,973 additional houses are identified as being necessary of which 80% are allocated to sites in the Green Belt.

2. Lack of protection of Green Belt and Chilterns Area of Outstanding Natural Beauty (AONB) as a Strategic Objective for the Local Plan

With more than three quarters of the land area of the District being Green Belt, it is unacceptable that its protection is not regarded as a Strategic Objective for the Local Plan. A basic characteristic of the Green Belt is its permanence, and it should be regarded as a principal constraint to development and a huge asset for the District to be protected and enhanced for the benefit of everyone.

3. Overprovision of housing and out-of-date projections

The overall strategy underlying the Preferred Policy Options (PPO) fails in relying on out of date information and an apparent misunderstanding of key aspects of national policy in respect of housing numbers and prioritising use of previously developed land. The use of out of date information also affects the scale of provision likely to be needed for employment and retail uses, and should be revisited.  CPRE accepts there is a need for housing in Three Rivers as elsewhere, especially truly affordable housing for young and older households, but the projections used in the Local Plan are excessive and out of date.

4. Failure to address climate change

Climate change mitigation and resilience, which are now legal requirements for Local Plans, should be at the centre of the plan preparation process but there is no indication of their significance in Chapter 1, and scant reference under key topics such as transport and housing.  This is notwithstanding the declaration of a climate emergency by the Council in May 2019.

5. Inadequate provisions for water supply and wastewater disposal

The level of new housing proposed is expected to put severe strain on water supplies to Three Rivers during the 2020s under drought conditions, and further pressure will be put on chalk aquifers and affect the rivers which give the District its name. Similarly, the growth proposed will put undue stress on waste water and sewerage networks and substantial infrastructure investment will be required in the next ten years, which is not specified.

6. Loss of biodiversity

Strategic Objectives 11 and 12 make passing references to the issue of biodiversity as an asset but mainly as a setting for development and opportunities for recreation and leisure. This is a wholly inadequate response to the legislation regarding net biodiversity gain, which will become increasingly significant in the future.

7. Underestimation of the opportunities for regeneration and reuse of land.

The reuse of previously developed land is considered mainly in terms of the release of Green Belt land and some urban sites, which greatly underestimates the likely changes which are already affecting town centres, out of town centres retailing and commercial uses more generally. The impact of the pandemic and projected social and economic trends are likely to create many more opportunities for the conversion of commercial and other space to residential use and changes in the form and function of workspace, which are not taken into account.