Please note – Dacorum’s online consultation is split into separate questions. We have indicated below where we believe these issues fit against those questions.
1. The Vision (Q1 of the consultation)
Dacorum’s Vision emphasises environmental sustainability and highlights the potential to deliver new green spaces, but fails to mention that the cost of delivering the Vision is a 25% increase in houses and population and the loss of 2,000 acres of Green Belt and open spaces across the Borough.
2. Overprovision of housing (Q2 of the consultation)
We accept that the country needs more houses, but this plan is based on figures that the government has now withdrawn because of the impact on Green Belt land in the south east. As a result, most of the south east received lower housing targets, but for some reason the revised target for Dacorum (and the rest of Hertfordshire) increased despite the significant impact on Green Belt land.
The Government’s most recent target is based on estimates from the Office of National Statistics (ONS) from 2014. We believe that the Local Plan should be based on the most recent ONS figures from 2018 which suggest a housing target for Dacorum of c. 500 houses pa; almost half the figure on which the Plan is based which would significantly reduce the need to build on Green Belt.
Dacorum is challenging the Government target, but with such a major uncertainty outstanding this undermines the validity of the draft Plan.
3. Impact on the Green Belt and the Chilterns Area of Outstanding Natural Beauty (AONB) (Q2 of the consultation)
Although Dacorum states that a key objective is “minimising and managing the requirement for development on the Green Belt land and the impact on the Chilterns AONB”, the scale of the proposed housing development can only have a significant and detrimental impact on the natural environment. It is even possible that it might jeopardise recent proposals to upgrade the AONB to a National Park.
4. Underestimating brownfield potential (Q2 of the consultation)
Although the Plan includes some brownfield site development, the major housing developments are on the outskirts of Hemel, Berkhamsted and Tring. The Plan fails to take into account the likely impact of the coronavirus pandemic and recent changes to planning which may free up more sites in town centres.
Anything which reduces the potential impact on the Green Belt should be explored exhaustively.
5. Unsustainable development (Q3 of the consultation)
Focusing building on the outskirts of the main towns means that the developments are some distance from existing transport infrastructure. The Plan states that “the local and strategic road network [has] sufficient capacity providing there is a greater uptake in walking, cycling and passenger transport”, which is unlikely as the proposed developments are so far from the existing rail and road transport hubs .
The Plan goes on to say that “we are continuing to develop the transport proposals”, but the development area allocated to the north of Hemel doesn’t have any existing transport infrastructure and the Plan doesn’t set out what would be put in place. Without a credible plan for sustainable transport, it is likely that the development will result in several thousand more cars on local roads.
6. More congestion on the roads (Q3 in the consultation)
The Plan appears to involve restricting the width of the already congested A414 through Hemel to accommodate a new Mass Rapid Transit system to Harlow and other public transport initiatives. It suggests traffic coming from Tring and Berkhamsted would use the new link road in North Hemel from the Dagnall Rd (B440) to J8 on the M1 rather than go through Hemel using the A414.
How is traffic supposed to get from the A41 to the B440? The most direct route passes through the middle of Potten End before descending into the narrow streets north of Berkhamsted, then via one of three single lane crossings of the railway, the sites of frequent accidents, before inevitably arriving at the already highly congested crossroads in the centre of Berkhamsted. No improvements are proposed to existing roads and there isn’t a new link between the A41 and Dagnall Rd.
It appears that Hemel’s traffic problems are to be exported to Water End, Potten End and Berkhamsted. This is unacceptable.
There is no assessment of how these existing routes will cope with significantly increased traffic volumes.
7. Digital connectivity (Q3 in the consultation)
The Plan includes a commitment to the introduction of new digital technology but explicitly links it to new developments. Existing settlements which will not have new housing also need to be included in this commitment.
8. Passenger Transport (Q3 in the consultation)
The Plan includes a commitment to improving passenger transport which is rightly regarded as essential for people living in rural parts of the Borough, but again the implication is that improvements will be linked to new developments. This needs to be expanded to include all settlements.
9. Water supply and waste water disposal (Q6 of the consultation)
With the chalk aquifer already described as “over-abstracted” and local residents only too aware of the fragility of their water supply, the level of new housing proposed will put severe strains both on supply and disposal. With a significant time-lag in the availability of new water supplies we are concerned that the new developments will increase calls on the aquifer, potentially leading to significant inconvenience for residents but more importantly risking damage to the Borough’s precious chalk streams. Dacorum and Affinity Water have recently spent time and money on improving the River Gade, only for this Plan to put that improvement at risk.