06 Oct 2023
It was billed as the most important public consultation for a generation, but how many people have actually had their say on the draft St Albans Local Plan?
St Albans council leader Cllr Chris White insists there has been a very good response to the consultation from residents, stakeholders and public bodies.
The response totals were:
Questionnaire – 1,240 respondents plus 600 identical/nearly identical ‘proforma’ responses;
Quick survey – 1,057 respondents;
Public exhibitions – 1,245 attended including the eight sessions across the district and one in Leverstock Green in Dacorum;
Local Plan YouTube Video – 2,214 views;
Facebook campaign – ‘Reach’ of over 28,000 people.
Cllr White said: “These now all need to be read and recorded. Once that is done, work can begin on revising the plan as necessary. These revisions will also take into technical submissions from various bodies like the county council and National Highways.
“At some point next year a revised version will emerge which will go out to a second consultation (Regulation 19). This may of course also respond to changes to the National Planning Policy Framework and the Levelling Up Bill which is still struggling through Parliament.”
Protest groups were unhappy that the consultation clashed with both the summer holidays and the return to school, despite pleas for the dates to be changed.
It has also been criticised by campaigners for requiring respondents to register via the SADC portal, and for being inaccessible for anyone who did not have previous experience of the planning process.
Last week, Harpenden Town Council voted to recommend the removal of two sites, North West Harpenden and Cross Lane, from the draft Local Plan, having recently objected to planning applications for both pieces of land.
HTC also expressed severe concern over the large development in Batford and highlighted concerns over the quality of the infrastructure proposals in the Local Plan, given the huge traffic and other infrastructural issues already affecting Harpenden.
Meanwhile, campaigners against a development in north St Albans have been less than complimentary about the Local Plan process in general.
Gee Smeadley, on behalf of CLASH, said: “We have spent a lot of time over the last 10 months focused on the Local Plan. Attending meetings, educating councillors, sharing updates and trying to get a better Local Plan in place ready for consultation.
“Depressingly, we find ourselves as a community with a very weak plan at this stage. We are advised that it is likely to fail the Planning Inspectors rigorous process for plan assessment. Who is responsible for these repeated failures? The council officers or the leadership of the council? Probably a combination of both.
“We have written Ministerial guidance that the Local Plan does not have to use the very outdated and hugely inflated population projections from 2014, they are and always have been advisory. Why does the local Lib Dem leadership at SADC pursue this strategy?”
Talking specifically about the north St Albans site, she added: “SADC and HCC have not provided any traffic counts, transport modelling or any other rigorous infrastructure assesments.
“The cycling proposals are described as ‘high-level concept’. This is not acceptable.”
She continued: “SADC could ask for a lower housing target due to legitimate constraints in the local area ie protected Green Belt. If SADC feel confused by the changing landscape in NPPF which will strengthen Green Belt protection, they can ask for a pause to the Plan.
“We need our Green Belt to remain in the current boundary and not cannibalized by developers with the support and recommendation of SADC. St Albans is already part of the biggest and most densely populated area in the county. Our services and infrastructure are already failing to deliver what is needed for the current population, our district does not even have a 24-hour medical urgent care centre, instead we have to go to Hemel, Luton or Watford, yet we are proposing a massive increase in population and residents over the plan period of over 30% compared the current population of the district.
“We see no joined up strategic approach to manage and mitigate for the declared climate emergency.
“Statements about the supply and demand balance of water are outdated and ignore the most recent projections from Affinity Water in their latest review, that using these growth projections the water supply in the district will have a short-fall. Aquifer recharge areas must be kept as open green field land to mitigate climate change.
“Even central government agrees that there is no statutory requirement on St Albans to deliver the housing projections from 2014 (pre-Brexit). We have a clear letter from the Minister for Housing that states the current calculations are advisory.”
Paul King, from pressure group Greenbelt, said in response to the consultation: “We are extremely concerned about the strategy and the formulation of the draft Local Plan in relation to the Green Belt.
“In particular the Green Belt locations earmarked in the Plan, which have been driven by speculative developers via the various ‘calls for sites’”, and are not located in the most sustainable locations.
“The proposed sites have just been lifted from a Green Belt review produced by ARUP, with no assessment of sustainability having been undertaken by the Spatial Planning department. To make things worse, this Green Belt review includes some flaws in its methodology, which have not been addressed.
“The draft Plan is therefore a document that has been formulated around inaccurate housing requirement figures, is in conflict with the government’s evolving Green Belt policy and has been driven by speculative developers, in deference to the community.
“The application of the Regulation 18 consultation process was also flawed in its preparation and implementation. Only a very small proportion of the district’s population were aware that the consultation was taking place, due to inadequate publicity and it being undertaken during the summer holidays.
“Public presentations were made at a handful of locations in the three weeks before the deadline, but these were poorly attended, since they were not well advertised.
“The portal site used to obtain comments was complex and very difficult to use, causing many to give up, unaware that that they could email their comments, since this hadn’t been made known on the site. This all led to the response being very small in relation to the population of the district.
“Overall the process should not have taken place with such haste, and lack of any real evidence base or scrutiny. “It was badly organised at a strategic level and poorly implemented on a technical level.
“The draft Plan should be withdrawn and the process should be recommenced in a more systematic fashion, once up-to-date data is available and appropriate research has been undertaken.
Keep Chiswell Green also commented: “KCG is hugely disappointed that St Albans council has missed the opportunity to advance the process of having a Local Plan that defends us from the speculative development that has dominated and blighted the lives of local residents for so long.
“With the same team at the helm as the last four failed Local Plans, the council clearly does not have the expertise or the courage to deliver the Local Plan we so badly need.
“Most respondents to the consultation expressed significant concerns about the draft Plan so it will be interesting to see what the council does – plough on, head in the sand, in ostrich fashion, declaring that the consultation responses were in support of the Plan, or embrace the expertise, commitment and drive that there is in the local community to ditch the Standard Method and to create robust and proactive policies to save our Green Belt and build the houses that we need.
“Keep Chiswell Green and the St Albans Green Belt Alliance would welcome the opportunity for a constructive round-table discussion with the Local Plan team at the council to advance the Plan and to make it a Local Plan that works for the district and its people.”
KCG also highlighted how SADC had faced repeated challenges by councillors and members of the public as to why they had continued to use the Standard Method to determine the local housing target figure.
They said correspondence in April between Rachel Maclean MP, Minister of State for Housing and Planning, and Kwasi Kwarteng MP, clearly stated that the Government does not see the standard method of assessing housing need as a mandatory housing target. Ms Maclean wrote: “The current National Planning Policy Framework (NPPF) sets out that the Standard Method is used for assessing local housing need and is only a starting point for helping to address projected household growth and historic under supply. It is not a mandatory target and should be used by councils to help inform the preparation of their Local Plans.
“Councils should decide on their own housing requirement once they have considered their ability to meet their own needs in their area.”
KCG’s report on the Local Plan said: “It appears that planning officers at SADC confuse housing demand and housing need. St Albans is a desirable place to live with good schools, good transport links, and good access to green open spaces and the countryside, as well as being within good commuting distance of London and other employment hubs. This means there will always be strong demand for housing in St Albans; however, providing significant quantities of new housing in St Albans will not satisfy the demand.
“Comparatively, St Albans has a real and significant need for affordable and social rented housing. Officers are working on the assumption that building more houses will bring down the price of houses in the district and make housing more affordable.
“This assumption is erroneous as demand in the housing market is a function of many factors including availability of credit, unemployment rates, public confidence, and the current economic situation and future outlook.
“Additionally, the features that make St Albans a desirable district draw in new residents from London, the Home Counties and from abroad, attracted by the schools, accessibility and local quality of life. In combination, these keep the prices of houses high in the district.”
