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13th February, 2007
Dacorum Environmental Forum
Supplement to the Forum’s response to Dacorum Borough Council’s Site Allocations
Issues And Options Consultation document |
As stated in our response to the Core Strategies Issues And Options consultation
document, we do not accept the proposed target figure of 12,000 extra houses
for Dacorum, and believe that there must be a re-working of national policies,
that address the issues of the North-South divide, and reverse the incentives
towards lower house occupancy levels, and net inward migration to the UK and
to the East of England in particular.
Our response to many of the questions in the Site Allocations Issues And Options
consultation document should be read in that context. In particular, our opposition
to development sites within the boundaries of Hemel Hempstead, individually and
collectively, should not be seen as support for unloading demand onto the Green
Belt peripheral sites listed in the Core Strategies. As far as Green Belt is
concerned we fully support the Planning Policy Guidance Note 2 (PPG2) objectives
you set out in the preamble to Question 5:
1) Check the unrestricted sprawl of large built-up areas;
2) Prevent neighbouring towns from merging into one another;
3) Assist in safeguarding the countryside from encroachment;
4) Preserve the setting and special character of historic towns; and
5) Assist in urban regeneration, by encouraging the recycling of derelict and other urban land
Of these, 5) is the one of most relevance to the Site Allocations document.
As a general principle we prefer "recycling" i.e. change of use of already developed
land, rather than developing sites that are described as "derelict", since any
would-be developer can ensure that land is or becomes derelict if that is the criterion
for obtaining planning permission, and since even a derlict site may have conservation value.
The Forum does not have the resources to examine all of the development sites listed
in the document. Therefore the following observations on specific questions are couched
in terms of principles rather than of detail:
Question 9: Should there be any exclusions from the list of sites in Appendix A (Urban Capacity Study)?
Yes: Many of these site descriptions contain warning phrases that indicate
that their development would be detrimental to wildlife, the amenity and enjoyent
of neighbouring properties and/or informal leisure use. These phrases are:
"Surrounded by residential"
"Unused space surrounding elderly persons home"
"Densely wooded"
Question 11: Do you support any of the sites in Appendix B? (New sites - landowner/developer proposals)
The criterion for our support is that open land is not built on.
Therefore we broadly oppose changes under the headings:
Green Belt to Residential
Existing Housing Allocations for retention / amendment
(because these are not yet developed)
Leisure to Residential
(predominantly sports pitches)
Leisure (caravan site) to Employment
(caravans have a lower and less permanent landtake than employment)
Green Belt to Leisure (West Hemel Hempstead and Shendish)
(light pollution, car parking, visual intrusion)
Open Land to Residential or Leisure
Amend Existing Open Land Designation (Bunkers Park)
And have no view on:
Garage Sites to Residential
Employment to Residential / Mixed Use
Retail / Local Centres to Mixed Use
Employment to Retail
The category
Social and Community to Residential/Mixed Use
generally refers to proposed school closures. We oppose this as argued under
Questions 53 to 55, and because use of former school sites for Social and
Community purposes is preferable to using other proposed currently undeveloped sites.
Employment: (Questions 18-25)
Insofar as it within the Planning systems remit, the Forum would support favourable treatment
being given to types of employment that contribute to sustainable Waste Management
policies, in particular:
Service and Repair
Recycling/Composting
Re-use: secondhand sales.
Sustainable energy
Insulation
Ideally, these sites would be smaller scale and locally situated, in order to reduce travel
costs and promote sustainable business.
Question 33: Land bounded by Bridge Street, Leighton Buzzard Rd., Marlowes for shopping floorspace
The Forum strangly objects to this, since it implies loss of the Water Gardens.
Transport: (Questions 36 to 44)
The Site Allocations document appears to contain no reference to the possibility
of a Northern Bypass for Hemel Hempstead. Had it done so, we would have opposed
it strongly. Indeed, the pressure for a Northern bypass that would be created by
some of the Green Belt housing proposals in the Core Issues document was one of our
reasons to objecting to those sites.
Community Development: (Questions 45 to 55)
In general, existing open spaces should be retained for informal community recreation,
particularly where the site characteristics and management do not encourage dumping,
graffiti and other antisocial behaviour.
First choice for built community accommodation should be former schools sites. We note
however that the Site Allocations document states :
"The Primary Schools Review . . .has not factored in any additional development that the
town may have to accommodate as a result of the East of England Plan. It does not preclude
the development of new primary schools in alternative locations to serve new neighbourhoods
on the edge of the town, if required in the future."
It appears therefore that it does not include an assessment of housing development
within existing built-up areas (roughly half of the 12,000 currently proposed) where new
schools would be less appropriate, and where the currently estimated over-provision by existing
schools might well disappear. Therefore nothing in the plan should prevent a re-think on this
issue by the Education Authority, and in particular ther should be no conversion to residential use.
Leisure and Recreation
Question 57: (Should proposals for built sports facilities continue to be assessed on a site
by site basis?)
No. The Forum believes that the following should always be taken into consideration:
Sterilisation of land by parking provision as well as building.
Visual intrusion
Light Pollution
Question 58: (Proposals for Open Land designation)
The following statuses should be re-confirmed or conferred as appropriate:
· Bunkers Park
· Wildlife corridor to support Shrubhill Common Local Nature Reserve, as far as Fields
End Farm, and bounded by the existing western edge of Hemel Hempstead and Pouchen End Lane.
· Marchmont Farm, land adjacent to East West link Road.
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