Environment
East Hemel - St Albans Council's Plan to Build Houses close to Leverstock Green
ST ALBANS DISTRICT COUNCIL (SADC) LOCAL PLAN 2041
SADC has launched a Regulation 18 consultation on a new draft Local Plan up to 2041. The purpose of the consultation is to inform interested parties of the content of the plan and to invite representations. The deadline for the submission of comments is 25th September 2023, and Leverstock Green residents are encouraged to make their views known. The consultation document is available at the following link. A copy of the draft plan and the associated documents can be viewed in the village library. https://www.stalbans.gov.uk/new-local-plan
SADC’s current local plan dates from 1994 and is one of the oldest in the country. Two previous attempts to develop a new plan in 2016 and 2020 were rejected by the Planning Inspector on grounds of legal compliance and soundness including a failure to co-operate with other authorities.
The new draft plan gives prominence to both the emerging Hemel Garden Communities (HGC) (see below) and the Joint Strategic Plan for SW Herts to 2050 which involves SADC, Dacorum Borough Council (DBC), Herts County Council (HCC), Hertsmere, Three Rivers and Watford. The new plan places considerable emphasis on the environment and the challenges of climate change and has been informed by a new review of the Green Belt in the St Albans district. The purpose of the review is to give SADC the ability to assess the relative importance of each area against the five ‘purposes’ of the Green Belt.
Based on the Government’s National Planning Framework method for calculating housing need, SADC proposes the provision of some 15,000 new houses across the St Albans district by 2041. After an allowance for future ‘windfall’ builds and permissions which have already been granted, the figure is reduced to about 11,700. In common with other councils, SADC believes the methodology is illegitimate because it is based on out of date information dating back to 2014. The Government intends to publish new methodology in 2024 which will be based on the 2021 census, and it is anticipated the housing numbers could be reduced. SADC wishes to avoid any further delays in producing a new plan and has decided to get the lengthy approval process underway. The plan will be amended as necessary prior to the Regulation 19 consultation which is scheduled for July to September 2024. The aim is to submit the draft plan for public examination by December 2024. Assuming the plan passes the examination, it will be adopted in December 2025.
Needless to say, the majority of the SADC plan does not affect Leverstock Green. However, a tract of land to the north and east of the village is within the St Albans district and is owned by The Crown Estate. Since Hemel Hempstead was developed as a new town over 70 years ago, this tract of land has been earmarked for eventual use as housing. In 2018 work began on the HGC which aims to transform Hemel Hempstead and involves some 11,000 new houses and 10,000 new jobs by 2050. The HGC is a partnership comprising DBC, SADC, HCC, the Herts Local Enterprise Partnership, the Herts Innovation Quarter, The Crown Estate and other landowners. More information can be found on the website: https://www.hemelgardencommunities.co.uk.
The following map shows the full extent of the HGC which will involve extensive new infrastructure including roads, schools, neighbourhood centres and improvements to Junction 8 of the M1. Please note the locations of these facilities on the map are purely indicative at this stage of the project.
Of the 11,000 new homes, HGC are proposing to build 5,500 within the SADC area by 2050. Of these 3,100 are intended for areas to north of Maylands and 2,400 on land between Junction 8 of the M1 and the point where the A4147 crosses the M1. This latter area involves Leverstock Green and is covered in more detail on page 9 of the SADC Local Plan under H4 East Hemel Hempstead (South). The first houses are scheduled to be built in 2028/2029 although it seems this timescale may already be optimistic.
The 2016 draft of the SADC Local Plan proposed 1,000 houses would be built between Junction 8 and an imaginary line from the current south eastern extremity of the village on the A4147 to the M1. The LGVA argued against these proposals, but with affordable housing in Leverstock Green likely to be in such short supply, it was eventually acknowledged that some new development would be needed by 2030. The new Green Belt review has also recommended this area for development.
By the time the 2020 draft appeared, the HGC project was underway and a further 1,400 houses had been added. The LGVA argued strongly that this number of houses represented over development of the area and would encircle Leverstock Green. A planning consultant was engaged to represent our case, but the SADC plan failed the Public Examination before it reached this level of detail. LGVA intends to object to the new draft plan on the same grounds.
The following map shows the HGC area with the 5,500 houses proposed in the SADC draft plan marked in the areas with the black lines. The red line is the boundary between Dacorum and St Albans.
Whilst the SADC exhibition was useful, LGVA is equally concerned about the Hemel Garden Communities project (see above) which will also have a huge impact on Leverstock Green as it overlaps the St Albans plan. A couple of Dacorum planning officers were present at the SADC meeting but LGVA will be urging them to hold their own exhibition at the Village Hall.
LEVERSTOCK GREEN VILLAGE ASSOCIATION (LGVA) SUBMISSION ON THE REGULATION 18 CONSULTATION OF THE SADC LOCAL PLAN 2041
LGVA is concerned Leverstock Green was not included in the exhibition programme for the new Local Plan. An exhibition was subsequently added after intervention by our local DBC councillors. The event was extremely useful and was well attended by village residents.
We are grateful to the St Albans City and District Council (SADC), Dacorum Borough Council (DBC) and Hemel Garden Communities (HGC) staff for their hard work in setting up and manning the exhibition. The high level of interest shown by local residents indicated there is a great deal of concern and in some cases anger over SADC proposals to build large numbers of dwellings adjacent to Leverstock Green. This concern must not be ignored, and it is vital Leverstock Green residents are kept involved in SADC’s proposals.
LGVA strongly supports the thrust of the submissions made by Leverstock Green residents (especially Ross Smith – reference Comment ID 54 d. 22/8/23) and also the comments by National Highways, the Campaign for the Protection of Rural England (Hertfordshire) and Redbourn Parish Council.
Our principal objections relate to:
- The scale of SADC’s proposals in one single area rather than being more evenly distributed across the whole area of the Borough.
- The fact that Leverstock Green is being required to bear a completely disproportionate part of the total detrimental impact of the overall development in the plan, even though the village is not within the boundary of St Albans District; and
- The loss of a significant proportion of the green belt which protects our village environment.
TIMING AND RELEVANCE
LGVA believes SADC is premature in launching the Regulation 18 consultation. As the draft plan acknowledges, the method of calculating housing requirements is about to be amended. We understand housing numbers are likely to be reduced to take account of demographic changes. The changes will also affect DBC, so the overall HGC numbers are likely to be reduced. We strongly recommend that further consideration of the plan is postponed until updated and more accurate housing requirements across the area as a whole can be calculated.
DEVELOPMENT PROPOSALS
Impact
LGVA recognises some additional housing is required and supports modest and proportionate development. However, we object strongly to the sheer scale of the SADC proposals which would envelope and overwhelm Leverstock Green. Despite being part of the Hemel Hempstead urban area since the construction of the new town from the 1940s, Leverstock Green retains a distinct and proud village character and a strong sense of community. Under the proposals, Leverstock Green would nearly double in size and would lose much of the surrounding Green Belt which defines its identity. The character of the village would be changed out of all proportion, and the necessary infrastructure requirements would be unsustainable in a village environment.
HGC
We recognise the vision of HGC, but we are concerned there is no comprehensive infrastructure and transport plan to support the proposals. We also have misgivings that such a large-scale project involving two local authorities and multiple other agencies over such a protracted period is deliverable.
We appreciate the planning is at an early stage, but the task of coordinating all aspects of the HGC will be a major challenge. The timely delivery of infrastructure and particularly roads will be essential.
Green Belt
As already stated, Leverstock Green is defined by its semi-rural environment with Green Belt to the east, south and southwest of the built-up area. These areas are prime agricultural land which creates a green buffer around Leverstock Green and which needs to be protected wherever possible. The loss locally of such a significant amount of prime agricultural land is considered foolhardy in the current climate.
Residential Unit Numbers
The plan envisages 2,400 dwellings in the East Hemel South area adjacent to Leverstock Green. This represents 18% of SADC’s total requirement. This area of Green Belt is shown as H4 on Appendix 1 (Local Plan Sites) pages 9 and 10. The area extends from J8 of the M1 to the point where the A414 and A4147 cross the M1.
We believe this area of 150 hectares is inadequate to accommodate over 2,000 dwellings at an acceptable level of density. Moreover, the Green Belt review recommends that only the smaller area adjacent to Junction 8 of the M1 (shown in orange on the map) should be considered for possible development.
As a consequence, the number of residential units in the H4 area should be drastically reduced, probably to less than a 1,000.
Buffer Zones
The Green Belt Review Methodology (Section 4) includes an assessment of settlement area buffer zones. We suspect strongly the Green Belt Review was influenced by SADC to suit the purposes of the draft Plan. Despite Hemel Hempstead qualifying as a ‘highest order settlement’ with 400m buffer zones, the review uses the presence of the M1 to conveniently justify the removal of the buffer zones from the whole of the East Hemel area. If the buffer zones had stayed in place, the number of dwellings which could accommodated in East Hemel would be reduced considerably. This would also significantly reduce the HGC ambition to build 11,000 homes. We consider the 400m buffer zone should be applied to the whole of the Site H4 East Hemel (South) (Green Belt Review Sub-Area SA165).
SADC REGULATION 19 DRAFT LOCAL PLAN 2041 CONSULTATION
St Albans City and District Council (SADC) has launched the expected Regulation 19 consultation on the draft Local Plan 2041. The draft plan together with details of how to respond can be found at: https://www.stalbans.gov.uk/draft-local-plan-publication.
As far as the planned East Hemel development is concerned, the proposals are generally unchanged from the Regulation 18 consultation in 2023. The new housing figures are 1,940 plus a further 460 after 2041. The Regulation 19 consultation is a formal and statutory process and will run for 6 weeks ending on 8 November 2024. The new consultation focuses on matters of legal compliance and soundness which will be examined by the government-appointed Planning Inspector. These matters are explained on the opening page of the draft Local Plan. Anyone wishing to comment should concentrate on these issues and is encouraged to use the online Representation Form. LGVA will be preparing a representation with a planning consultation in collaboration with Redbourn Parish Council. The Crown Estate, as the landowner and developer of the East Hemel project, has employed a consultant Keith Murray Associates (KMA) to lead on Community Engagement for the development. KMA will be arranging events in the local area to obtain views from local residents and stakeholders.
SADC has brought forward the Regulation 19 in the light of the Government’s intention to revise the National Planning Policy Framework (NPPF) by introducing mandatory annual housing targets based on ‘affordability’. These new targets take into account average houses prices in relation to average earnings in each authority area. SADC’s housing target will increase by 75% from 855 a year to 1,544. This will raise the number of houses needed by 2041 by 11,000 on top of the current target of 16,000. SADC is hoping to avoid the new target by submitting the draft Plan to the Government before the new figures come into effect. In the meantime, SADC is already receiving ‘hostile’ planning applications which are being refused initially but subsequently granted on appeal. SADC believes the best defence against uncontrolled development is to get the new Local Plan in place as soon as possible.
The Dacorum target under the revised NPPF will increase by 29% from 1,016 a year to 1,313. DBC is considering the timescale for the Regulation 19 consultation on its own draft Local Plan.
NOTE
During 2017 local resident and video producer, Orthodoxos Theodoulou (Oxo Productions), prepared the following four minute video of Leverstock Green which was shown at the AGM in November 2017. The video features members of LGVA and the previous MP Sir Mike Penning. LGVA’s position has not changed.