The HBF wrote to Go East due to its concerns about the way in which it considered that Hertfordshire County Council was seeking to evade making the necessary levels of housing provision during the plan period. Go East's response to the document was to suggest that the Council redirect its attention to undertaking the work necessary for ensuring the publication of draft RPG14 in early 2004. The Council has agreed to do this, and further work on the Structure Plan Alterations has been suspended.
Bryan Young
Environment Group
Government Office for the Eastern Region
Victory House
Vision Park
Histon
Cambs. CB4 9ZR
2nd April 2003
Dear Mr Young,
HERTFORDSHIRE STRUCTURE PLAN ALTERATIONS 2001 - 2016
I write further to the public consultation now being undertaken in respect of the above document.
The House Builders Federation (HBF) has major concerns with regard to the publication of the Hertfordshire Structure Plan Alterations at this point in time. It is extremely concerned that the County Council is rushing to place its Plan on Deposit in order to be able to proceed with it through to adoption evading the Governments new planning legislation and responsibilities made on authorities. The HBFs concerns relate to the fact that the County Council is seeking to avoid the levels of housing growth realistically necessary for Hertfordshire given the major development pressures it is under. By placing heavy emphasis on an inflated (and unrealistic) housing capacity figure the County Council seems to be seeking to avoid allocating sufficient land to meet the Countys housing demand. The HBF is worried that other County and District Councils may adopt such an approach in order to avoid meeting the levels of housing growth that will be identified in RPG14.
I would draw your attention to a letter dated 13th December 2002 from your colleague Colin Campbell on behalf of Go-East to Bedfordshire County Council concerning the Bedfordshire and Luton Structure Plan 2016 Deposit Draft.
The aforementioned letter referred to a major issue for the review of the Structure Plan being its relationship to the emerging RPG14 and in particular the sub-regional work in respect of the Milton Keynes/South Midlands growth area. It went on to state that although Government advice is that in general authorities should continue to prepare plans, this advice needed to be considered in the light of individual circumstances, including the most effective use of resources and the timing implications in respect of the other relevant plans. Go-Easts letter stated that it felt that the more appropriate order would be for the Structure Plan EIP to follow the sub-regional strategy Public Examination, given that this will set the strategic framework for longer-term growth in parts of the county.
Go-East was not persuaded that the Bedfordshire and Luton Structure Plan - Deposit Draft which also runs to 2016 accorded with the longer-term growth strategy for the sub-region. It pointed out that the sub-regional work is certain to have implications for the rate of growth of parts of the county and therefore the Structure Plan Strategy, which will have a bearing in the plan period and which will not have been fully considered in the Plans preparation. It was then stated that central to the implications for the longer-term growth of Bedfordshire in the sub-regional context, and so the Structure Plan strategy, is the amount and distribution of housing.
The HBF strongly supports the stance taken by Go-East in relation to the Bedfordshire and Luton Structure Plan 2016 Deposit Draft. It sees strong parallels with the Hertfordshire Structure Plan Alterations. In this instance, the importance of the Stansted/M11 Corridor sub-region study and the Governments Communities Plan. Indeed, if anything, it is probably true to say that these will be likely to have as much, if not more, of an impact on shaping the future growth of Hertfordshire than the sub-regional work in respect of the Milton Keynes/South Midlands will have on Bedfordshire. Particularly given the potential implications of the SERAS (South-East and East of England Regional Air Study) which may well result in additional housing and employment growth in the area.
The London-Stansted-Cambridge sub-regional strategy is a response to the Governments desire to see a fundamental step-change in housing delivery, focusing on four growth areas. The Hertfordshire Structure Plan EIP will need to take account of issues relating to planning in the higher level of growth consequent on identification as part of a growth area.
I would also refer your attention to the very recent Regional Spatial Strategies Supplementary Guidance to PPG11. In particular, paragraph 9 Annex B which specifies how County Councils need to consider the best way of utilising their resources. This suggests that they should consider devoting their resources to work on the new Regional Spatial Strategies, rather than seeking to progress Structure Plan Reviews.
May I take this opportunity to thank you in anticipation of your Offices co-operation in this matter. I would be extremely grateful if you would copy me in on any correspondence you may have with County Council on this matter in due course.
Yours sincerely,
Paul Cronk
HBF Regional Planner, Eastern Region