CPRE Hertfordshire comments on the draft ‘2018 Herts Minerals Local Plan’
Spatial Planning and Economy Unit, fao Minerals Planning Team, Hertfordshire County Council –
I apologise for these comments not being submitted on individual forms on each issue addressed, but our resources are currently extremely stretched because of the concurrent examination of three Local Plans in the County, and another four current Local Plan consultations affecting Hertfordshire, including a new one by the County Council on the Waste Local Plan.
If you have any questions arising out of our comments, please contact Steve Baker by email at the address above, or by telephone on a Wednesday or Friday, when our Planning Team is normally in the office.
We will be seeking to contribute further at the Pre-Submission Draft Plan stage of the Plan, but at the present stage, we have the following comments:
Section 4 (Key Challenges)
1) At paragraph 4.4, under ‘Population’ the Plan states that future population levels are is based on the 2014 ONS projections. These projections are excessive, and the Plan should be based on more recent and forthcoming projections and trends, and in the context of the reviewed National Planning Policy Framework to be published this summer.
2) Paragraph 4.5 on ‘Housing’ is also based on excessive assumptions about future housing development in the County. This is because they are based on the draft Local Plan Housing Targets that have not completed their statutory examination by their Planning Inspectors and adopted through the Local Plan process, and which are being strongly opposed during those examinations. Hence the figure of 91,000 additional dwellings is not a sound basis for future Minerals Planning in Hertfordshire.
Section 5 (Minerals in Hertfordshire)
3) The figure in paragraph 5.6 under the ‘Need for Aggregates’, of 1.39 million tonnes per annum (mtpa) to be planned for, was set in 2009, nearly a decade ago, for the period to 2020, only two years away. This figure is carried forward in Section 8 (Strategic Aggregates Supply), in paragraph 8.4, as a commitment that Herts is obliged to meet under this out of date apportionment, but this figure is only valid until 2020, and the Plan should be based on future requirements, not forecasts from over a decade ago, or out of date development plan assumptions. CPRE strongly advises against the use of pre-recession, pre-NPPF, and pre-Brexit projections, and the Plans based on them, that would in our view render the Minerals Plan unsound. This is particularly the case when the figures for future supply (paragraph 8.6) are intended to ensure supply not just for 15 years, but also a further 7 years, which would mean the use of the now arbitrary provision of 1.39 mtpa, for 31 years, nearly a third of a Century, from the date it was originally agreed in 2009.
4) In terms of scale of export of aggregates from the County noted in paragraph 5.16, 41% in 2014, we would urge HCC to set out measures to promote more self-reliance by the areas importing Hertfordshire aggregates, particularly through recycling and secondary aggregate production in their own areas, in order to minimise the need for primary aggregates production in the County and its resultant impacts.
Section 6 (Vision and Objectives)
5) Objective 1 is currently worded ‘to meet the requirements of the Local Aggregates Assessment’ (LAA), but in our view this should be set out as ‘to meet the requirements of Hertfordshire, in the context of an updated LAA’, and not therefore ‘driven’ by that Assessment.
Section 8 (Strategic Aggregates Supply)
6) In addition to points ‘3’ and ‘4’ above on aggregates supply, we wish to support Policy 3 insofar as it states that the Council will seek to maintain supply in accordance with Government guidance, but this must be an ‘in principle’ commitment, with the actual provision determined in the context of the finally adopted local plans for the County taking into account a new NPPF, and the forecast economic and social consequences over the Plan period, of the nation leaving the European Union in 2019.
7) Specific Sites for aggregates working are proposed in paragraphs 8.14 to 8.17, a summary table, and Policy 4. CPRE strongly opposes the proposal for a new quarry at the Briggens Estate east of Stanstead Abbotts, as shown on Inset 4. We are particularly concerned that there is no specific justification or evidence presented in the Plan or referenced in the Plan for the creation of a new quarry in this location. Given the Green Belt location and its environmental sensitivity, especially in terms of landscape and ecology, the absence of such justification, and in our opinion conflict with the NPPF, would render the proposal unsound if included in a submitted Minerals Local Plan. We note that the ‘Site Selection Report, March 2017’, did not identify this site as one of the most appropriate site options, which is described in paragraph 7.7 as having potential for high impacts against five criteria considered at stage 3 of the sieving process, worse than any of the other sites identified in the consultation draft.
8) Policy 5 is not proscriptive enough on avoiding aggregate recycling in designated areas that should be protected from such development, which includes greenfield Green Belt locations. Policies for such development should be consistent with policies for similar types of development in local plans and the NPPF.
Section 9 (Industrial Minerals Policies)
9) Both Policy 6 (Brick Clay) and Policy 7 (Chalk) should include criteria that are sufficient to prevent adverse impacts on neighbouring land uses, the environment and the community, and therefore also be consistent with policies set out in local and neighbourhood plans for the area in every case, and not just the policies in the Minerals Plan.
Section 12 (Protecting Hertfordshire)
10) Policy 13 for minerals development in the Green Belt should also require proposals to be consistent with local and neighbourhood plan policies as well as the other policies in the Plan and the NPPF. The wording of the first line of the final paragraph of the Policy should include the words ‘any of’ so that it reads ‘The proposed restoration of the site must not conflict with any of the five purposes …’
Thank you for inviting us to comment on the consultation draft and we look forward to a formal opportunity to make representations on the Pre-submission Minerals Local Plan at the Regulation 19 stage.