Land North Of The Stort Valley And The A414, Gilston, Hertfordshire
Ref: 3/19/1045/OUT
January 2023
Prepared by Nicholas Cox
The Green Belt was established in 1955 to contain urban sprawl, to maintain the separation of settlements, to protect prime agricultural land around settlements, and to encourage urban regeneration and compact towns and cities. It now covers 13% of England; but increasing development in Hertfordshire’s green belt risks suburbanising the London to Cambridge corridor, swallowing East Hertfordshire into a massive conurbation.
EHDC’s District Plan includes two greenbelt developments of some 18,485 new homes. Northeast Ware and Harlow North (Gilston Area Applications) are planned on the largest release of green belt land in England, representing over 6% of our green belt. It is important to appreciate that the two developments are two sides of the same coin and should be considered as one development when considering infrastructure and services, to avoid the risk of massive under provision.
The expectations set out by Rt Hon Michael Gove MP, Secretary of State for Levelling Up, Housing and Communities in his letters of 1st and 5th December 2022 to Council Leaders and MPs, set out three very clear expectations for future development and housing:
1. Planning should be about delivering “enough of the right homes in the right places and will do that by promoting development that is beautiful, that comes with the right infrastructure, that is done democratically with local communities rather than to them, that protects and improves our environment, and that leaves us with better neighbourhoods than before”.
2. Councils should refuse planning permissions for development that is not well-designed and housing targets should not be used as justification to grant permission.
3. Local authorities will not be expected to build at densities wholly out of character with existing areas or which would lead to a significant change of character. The new Office for Place will support the Council and its community in achieving this goal.
The Gilston area development should not proceed for the following reasons:
- A massive tract of (former) green belt land will be built upon to deliver a very low proportion of affordable housing which falls far short of policy requirements.
- Education, healthcare, open space, and community facilities will be delivered considerably later than required, contrary to the Garden City principles and the principle of land value capture enshrined in Policy GA1 and the requirement of GANP Policy AG9, putting further pressure on existing communities and already very overstretched infrastructure.
- Road building, particularly the controversial Eastern Stort Crossing (ESC) has taken priority in the allocation of funding and is being secured through S106 negotiations, whilst sustainable transport measures are insufficiently developed and unlikely to be successful. This will result in development becoming car dependent to the point that both the new community and existing communities will become excessively congested.
- The proposals totally ignore GANP Policy EX1 which requires the mitigation of impacts of the development on existing communities to ensure a comprehensive and integrated development. The applicants have failed to respond to community concerns about local impacts and have not demonstrated where and how impacts on existing settlements and residents will be mitigated as part of an overall and comprehensive scheme. EHDC have ignored legitimate requests for clarification, thereby failing to act in the best interests of the area and its communities.
- The Village Developable Areas (VDAs) are such that the villages are not separated by meaningful green corridors (as required by GANP Policy AG4). This had been previously raised by the Council’s own Landscape Officer. The Development Specifications (DS) refer to a minimum width of corridor of 10-40m. This is clearly inadequate and should not be approved. The landscape and countryside should be treated as a structural element to create individual villages set in the landscape as required by policy and the HGGT documents.
- Building Heights are of particular concern. The Development Specification (Para 4.7.7) identifies a height up to 18m with further 10-15%, and buildings along the edges of the Strategic Green Corridors have a proposed height of 14m plus 5m ‘Limit of Deviation’ – i.e. potentially 19m tall. This is not locally appropriate ‘village character’, in conflict with GANP Policy AG6 and Appendix 3. The applicant also ignores the GANP policy requirements to explain how they intend to create soft edges, a balance between landscape and built form or even to explain what a village built in 2023 could look like.
- East Hertfordshire has one of the worst healthcare provisions in the country, with no inpatient or emergency services provision at all. Hertford County Hospital and the Queen Elizabeth II Hospital in Welwyn Garden City were run down on the understanding that a university teaching hospital would be established in Hatfield. This was cancelled by the austerity coalition, with inpatient and emergency services transferred to the Lister Hospital at Stevenage in October 2014. No additional provision was made for East Herts residents, with no direct public transport links provided and no additional or allocated car parking facilities. What happened to the forty (40) new hospitals promised by central government? What happened to the £350m per week ‘Brexit dividend’ for the NHS? Clearly none of this has been allocated to East Herts! The NHS Clinical Commissioning Groups for the area have made it clear that there will be a lack of hospital care for the growing population and that they will struggle to staff the primary care centres within the development. This will obviously impact upon the existing population as well as the new residents. To permit new housing in the knowledge that there will be an increase in demand for healthcare which cannot be provided would potentially be in breach of the Councillor Code of Conduct requirement to “exercise reasonable care and diligence”, and a breach of health and safety legislation with the risk of litigation, possibly including corporate manslaughter (Section 11(1) and Schedule 1 of the Act provide that specified government bodies can be prosecuted for Corporate Manslaughter.)*
- The applicants have failed to make provision for burial grounds in contravention of Policy GA 1. This is an important point considering the lack of healthcare, likely increase in air pollution and road traffic accidents given that local cemeteries will not have the capacity to serve an increase in population.
- The proposed housing mix will not meet East Herts identified housing needs or target of 40% applied to larger sites in Policy HOU3. A figure of 21% (which could in practice be further reduced over time) is totally unacceptable for a development of this size and on a site which has been released from the Green Belt on the premise of the planning benefits that would be secured. The level of affordable housing provision should be maximised in accordance with policy GA1 and the shared vision for the Gilston area.
- We have about 10% of the Earth’s chalk streams in Hertfordshire. Over-abstraction of water from the chalk aquifer has resulted in our chalk streams being reduced to dangerously low flows; the source of the River Rib has moved downstream to Buntingford, while the Ash is reduced to just 11% of long-term average flows. The sustainability plan linked to the district plan notes that our district is “one of the most water-stressed areas of the country” in a sub-region which
“experiences water scarcity” and the draft called for new strategic water resources to provide the 12 million litres / day of water that the new homes will require. This requirement was dropped when our district council passed the sustainability plan without scrutiny or debate, despite the plan’s failure to explain how to provide the water from resources which do not exist! Affinity Water have recently launched a discussion on strategic resource options 2 , including
pumping in water from as far away as Lincolnshire, but this is just a discussion with no funding behind it and can’t be implemented within the timescale required for this development.
In conclusion:
The East Herts Green Party is of the view that the scheme is not policy compliant and cannot be considered acceptable in planning terms. Given the gravity of the current situation, we cannot support the proposals given the grave uncertainty regarding the funding and delivery of essential
environmental, social and community infrastructure and other benefits and the substantial reduction in affordable housing provision proposed.
Moreover, the district council elections are now only five months and local residents may wish to take the opportunity to make the elections a defacto referendum on the district plan. In the interests of democracy and accountability, all further decision making on this development should
be suspended until after the elections.
Submitted by Alex Daar on behalf of East Herts Green Party
*https://www.cps.gov.uk/legal-guidance/corporate-manslaughter