St Albans Labour Party Group Submission to the St Albans Draft Local Plan 2020-26 Public Consultation, Sept-Oct 2018
Members of the St Albans Labour Party met on 3rd August 2018 to consider the soundness of key policies in the St Albans Draft Local Plan, during its Regulation 19 Consultation, Sept-Oct 2018.
The Council’s consultation notes suggest that it be would prefer to receive a Group Submission rather than lots of identical submission. As a result, this Group Submission is being made on behalf of 24 members who attended. Members who did not attend the meeting or who wish to add their own points on other policies will still be invited to do so.
In respect of the way the Plan was prepared, noting the supporting information provided with the Plan and also that the Council is acting as part the South West Herts Group of districts, working together on a Joint Strategic Plan, we conclude that the Local Plan is:
- Legally compliant; and
- Complies with the Duty to Cooperate
However, it was the general view of the members’ meeting that a number of Policies in the Local Plan are not Sound. As required by the Consultation, which allows the submission of an attached document, we set out the reasons why the Policies are Unsound and also what Modifications are required to make it Sound.
Policy L3 – Provision of and Financial Contributions towards Affordable Housing
The members were concerned that the percentage of affordable housing sought was too low and that the mix of affordable housing types did not reflect the evidence base.
The Policy seeks to achieve a minimum of 40% affordable homes on sites of 10 or more dwellings.
However, Appendix 6 states that the Strategic Housing Market Assessment “shows more than 75% of all housing need in the District is for Affordable homes”.
If the need is for more than 75% affordable housing, we believe it is only reasonable that the minimum target should be 75% affordable homes on sites of 10 dwellings or more.
Affordable housing type requirements
Of the affordable housing contribution, the Policy seeks a split of 30% social rent, 30% affordable rent and 40% subsidised home ownership.
However, Appendix 6 refers to Table 4.5 of the SHMA Update 2015. An examination of this Table shows that the split was actually: 81% social rent, 16% affordable rent and 3% shared ownership.
If taxpayer-funded evidence has identified the manner in which affordable housing need is split, we believe the Local Plan should reflect that evidence.
Consequently, we have concluded that Policy L3 is Unsound because:
- it has not been Positively Prepared as it is not seeking to meet the needs of the District as identified in the SHMA; and
- is not Justified, because it is not based on proportionate evidence
The modifications required to make Policy L3 Sound would be:
- to raise the percentage of affordable housing required; and
- to change the split of affordable housing types to reflect the evidence.
Policy S5 – Economic Development Strategy and Employment Land Provision
The members were concerned that the Local Plan promoted the building of a business zone adjacent to Hemel Hempstead but nothing specific adjacent to our own District’s main urban areas of St Albans, Harpenden and London Colney.
St Albans, in particular, is home to a high number of digital employers (earning the moniker “Silicon Abbey”), and the Members believed the Local Plan should include a digital business park and associated high quality, fast internet office space in or adjacent to the city to build on this success.
Consequently, we believe that Policy S5 is Unsound because:
- it has not been Positively Prepared as it is not seeking to meet the economic development needs of the District in the right location; and
- is not Justified, because it is an appropriate strategy
The modifications required to make Policy S5 Sound would be :
- to identify employment land close to St Albans to add a second specialist business zone.
Policy L22 – Community, Leisure and Sports Facilities
The Members were concerned that the Local Plan lacked ambition when it came to the provision of key community facilities.
The Local Plan is a once-in-a-generation opportunity to shape our district to reflect the needs of its local communities. The members thought that whilst Policy L22 was right to seek to deliver more Places of Worship, to protect our Public Houses, to extend Cemetery facilities and to support the principle of a new stadium for St Albans City FC, there were also major deficiencies in this wish list.
Members thought the Local Plan lacked ambition as it had no explicit reference to delivering, for instance:
- a new General Hospital with full A&E facilities – the need for which will only increase if another 14,000 households become resident in the District;
- one or more manned police stations, at least one with a custody suite, to reflect local concerns about a rising crime rate and the increase in late night licensing; and
- improved grass roots sports facilities, particularly in respect of the changing rooms at the District’s parks and open spaces.
Consequently, we consider Policy L22 to be Unsound because:
- it has not been Positively Prepared as it is not seeking to meet the health and safety needs of the District;
- is not Justified, because it does not provide appropriate strategies for health and safety; and
- is therefore not Consistent with the National Planning Policy Framework which devotes an entire Chapter to “Promoting Healthy and Safer Communities”.
The modifications required to make Policy L22 Sound would be:
- to identify land in the District for the provision of a new General Hospital with 24/7 A&E, police stations in St Albans, Harpenden and London Colney and grass roots sports facilities that actually do justice to what we’re told is one of the wealthiest Districts in England.
Policy L18 – Transport Strategy
The members were concerned that the Local Plan lacked ambition when it came to improving sustainable transport options.
Whilst measures to improve opportunities for cycling are welcome, Members were concerned about the lack of ambition and detail in respect of other transport issues. This was considered particularly important given the additional strain on the transport network that another 14,000 households will produce.
The reference to increased frequency of trains on the Abbey Flyer was welcome but where is the detail: how, where and when will it be achieved? Members would like to see ambitious proposals to make the track dual rail throughout, as well as proposal to integrate with existing services in Watford, offering continuous transport in to London as a viable alternative and back up to the Thameslink line. As a minimum, members would like to see specific reference to the Bricket Wood Passing Loop proposed by the Abbey Flyer User Group.
Improved bus services are always welcome but as they have been cut so dramatically in recent years what, specifically, will the Local Plan to do to ensure services will be enhanced?
Improved accessibility at Harpenden Station is welcome but how will the Thameslink services be affected, first, by several thousand more households seeking to commute to London and, secondly, if the Rail Freight goes ahead?
Again, our already-congested roads will become even busier when several thousand new households take to their cars. Where are the specific measures to reduce congestion via improvements to key junctions and/or Park and Ride schemes?
Consequently, we believe Policy L18 is Unsound because:
- it has not been Positively Prepared as it is not seeking to meet the sustainable transport needs of the District; and
- is not Justified, because it does not provide the detail to demonstrate that its strategies are the most appropriate
The modifications required to make Policy L18 Sound would be to
- provide specific detail on how, where and when the Abbey Line will be enhanced, how bus services will be improved and guaranteed and how road congestion will be eased.
Policy L21 – Education
The members’ meeting welcomed the delivery of new schools at the Broad Locations and the new primary school for St Albans Central Areas but were concerned about the lack of a new secondary school to meet existing/growing needs within St Albans.
Members also criticised the lack of any specific provisions for Extended Learning facilities.
Consequently, we submit that Policy L21 is Unsound because:
- it has not been Positively Prepared as it is not seeking to meet the full educational needs of the District; and
- is not Justified, because it is not, therefore, the most appropriate strategy
The modifications required to make Policy L21 Sound would be to:
- identify specific land close to St Albans that could provide a secondary school to serve the Central Area, as well as potential locations that can deliver Extended Learning opportunities.
Policy L25 – Energy and Environment Performance of New Development
The members were concerned that the Local Plan lacked ambition when it came to delivering zero-carbon development through self-generation.
In a District which is home to the Building Research Establishment, Members were concerned about the lack of specific detail on demanding targets for environmentally-friendly new development. The Local Plan, it was thought, should be a leader in the provision of zero- carbon initiatives.
Consequently, we believe that Policy L25 is Unsound because:
- it has not been Positively Prepared as it is not seeking to meet the sustainable energy needs of the District; and
- is not Justified, because it does not provide the detail to demonstrate that its strategies, for instance for wind and solar energy, are the most appropriate
The modifications required to make Policy L25 Sound would be to
- provide specific detail on minimum targets for the production of sustainable energy sources.