Our submission in the Three Rivers Potential Sites consultation Dec 2018

Three Rivers District Council is preparing a new Local Plan.  We’ve submitted our comments to their ‘Potential Sites Consultation’ expressing four major concerns.

• Not taking into account the latest Office of National Statistics (ONS) based housing projections when calculating housing need – these statistics show a 25% reduction in projected need versus the Council’s calculation.
• Implying that housing need must be met in full, which is not consistent with the National Planning Policy Framework (NPPF) paragraph 11 that specifies the Green Belt as the most important constraint when preparing local plans.
• The maps showing the proposed development sites do not show areas defined as nationally important policy designations and constraints (NPPF paragraph 11 and footnote 6), including areas of flood risk, Sites of Special Scientific Interest, heritage assets, and Green Belt.
• There is no map or maps provided to show the cumulative effect of the allocation of sites for development, particularly in respect of neighbouring settlements within the District and beyond the District boundary, which we consider to be a major oversight.