Dacorum Borough Council Local Plan Consultation on Emerging Growth Strategy 2020-2038

This response has been agreed unanimously by Northchurch Parish Councillors

Jon Clarke: Chair, Northchurch Parish Council

1. Question 1 – Do you think the overarching vision, the vision for Dacorum’s places and the strategic objectives are right for the Borough?

1.1 Nobody supports Dacorum’s vision

Northchurch Parish Council (NPC) has not found one person who believes that Dacorum’s vision or strategic objectives are right for the Borough.

Dacorum’s Vision 1.37: “For housing, we are making a bold commitment to significantly increasing the supply of land to deliver 922 dwellings per year, more than double the number (430 dwellings per year) in the previous Core Strategy.”

The views of Northchurch residents reflect those of the country at large. For example, In October 2020, when the government consulted on its proposed changes to the planning system, respondents expressed concerns that “the distribution of need was not right...too much strain was being put on our rural areas, and ... “in some places the numbers produced by the standard method pose a risk to protected landscapes and Green Belt.”

https://www.gov.uk/government/consultations/changes-to-the-current-planning- system/outcome/government-response-to-the-local-housing-need-proposals-in-changes-to-the-current- planning-system

The views of Northchurch residents reflect those of people across the Borough. For example, only 5% of people who responded to Dacorum’s 2017 Local Plan Issues & Options agreed with Dacorum’s proposed approach to Green Belt and Major Developed Sites.

http://www.dacorum.gov.uk/docs/default-source/strategic-planning/appendix-6---q9-to-q11---i-and-o- consultation-report-of-responses-september-2019.pdf?sfvrsn=6b530c9e_6

The views of Northchurch residents also reflect those of Dacorum’s Borough Councillors, none of whom appear to agree with this “bold commitment” to double the number of dwellings. On 18 November 2020, Dacorum Borough Councillors voted unanimously in favour of a motion expressing concern about the effects on the borough of having to deliver 922 dwellings per year. On 20 November 2020, the Leader of

Dacorum Borough Council wrote to the Secretary of State saying that the housing figure was too high and would harm the Green Belt:

“At the moment the housing target generated by both current and proposed standard housing methodologies ignore these constraints and produces a figure well in excess of the Office of National Statistics projection of housing need based on the 2018 figures, if this is accepted it would result in a reduction in the annual target and therefore would help to reduce the current figure suggested for Dacorum which is currently 922 per annum, a level of growth that can only be achieved with significant development in the Green Belt”.

So, neither residents nor councillors, support Dacorum’s vision.

NPC believes that Dacorum’s vision is fundamentally flawed because it is based on out-of-date 2014 household projections which over-estimate demand and prioritise growth at the expense of other considerations such as the importance of the Green Belt:

The vision would have a devastating effect on the 2800 people who live in Northchurch. New developments would add over 1500 new residents to Northchurch, a population increase of over 50%. The additional buildings and residents would destroy the semi-rural character of Northchurch and the quality of life for local people.

1.2 The vision excludes Northchurch

Northchurch is a large village with its own distinct appearance, community, and semi-rural character but the vision does not even mention Northchurch; it has been whitewashed from existence.

Northchurch predates the neighbouring town of Berkhamsted: the parish church of St. Mary is one of the oldest churches in Hertfordshire; the two-storey half-timbered alms-houses in the Conservation Area were built in the 15th and 16th centuries. Northchurch has two conservation areas and includes the hamlets of Dudswell, Norcott Hill, Northchurch Common and part of the Cow Roast.

The overarching character of Northchurch is that of a large village, within a semi-rural area. Most dwellings are set to the south of the Grand Union Canal, elevated from the valley bottom with sloping hills across Green Belt to the north and south. Our houses have a different style to Berkhamsted. In contrast with the tall, Victorian, high-density, London-style red-brick houses, common in Berkhamsted, the core of 1940s and 1950s dwellings broadly found in the south eastern part of Northchurch create a strong design identity. Here, most buildings have simple brickwork alleviated in part by angled front bays and front tile hanging. A wide-open feel is created by the low density (around 15 dwellings/ha), roadside verge planting and dwellings set back from the road.

In terms of demographics, people of Northchurch are older and less affluent than those of Berkhamsted. Unlike Berkhamsted, a town with many large, impersonal shops, Northchurch has just a handful of small shops and only one pub where customers recognise each other.

The roads in Northchurch are also different from Berkhamsted. In the part of Berkhamsted to the East of the proposed developments, roads running north/south, from the High Street uphill towards Shooters Way are heavily parked and busy with traffic. In contrast, Northchurch Lanes are much quieter. For example, Darrs Lane, which edges the Chiltern Area of Outstanding Natural Beauty, and Bell Lane, which runs between the two Green Belt fields, are narrow with steep grassy banks and hedging. They are country lanes.

The Green Belt fields that lie between Berkhamsted and Northchurch fulfil the primary aim of Green Belt policy: to prevent urban sprawl. They act as a buffer between the town of Berkhamsted and the village of Northchurch. They stop the communities of Berkhamsted and Northchurch from merging into each other. The proposed developments fill these fields with houses which means that Berkhamsted and Northchurch become one. Dacorum have not included the Bulbourne Cross proposal in the Local Plan, despite its advantages, because it would join Berkhamsted to Bourne End. The proposed developments in Northchurch do the same thing: they join Berkhamsted to Northchurch.

So Dacorum’s vision fails to preserve the special character and community of Northchurch.

2. Question 2 – Do you have specific comments about the Sustainable Development Strategy?

2.1 Dacorum’s Strategy uses out-of-date projections

Dacorum’s Strategy is based out-of-date projections that do not reflect a true picture of housing demand. Since the projections were made in 2014, significant social and economic changes have reduced the need for dwellings in Dacorum. The 2014 Household Projections: England, 2014-2039 Report acknowledges, on page 2, that their projections cannot predict changing circumstances:

“The assumptions underlying national household and population projections are based on demographic trends. They are not forecasts as, for example, they do not attempt to predict the impact of future Government policies, changing economic circumstances or other factors that might influence household growth.”

The Government acknowledges that circumstances have changed since 2014 when these projections were made. The recent Government response to the local housing need proposals states:

“Since we published the consultation, the way that the country lives, works and travels continues to change more rapidly than at any time since the war.”

In 2014 people needed to live near London to commute to work. This has changed. Even before Covid, surveys repeatedly showed that most employees want to work from home at least some of the time and over a third would take a pay cut in exchange. The experience of working at home, during Covid, has given workers and managers a taste of what could be. according to a report.

According to ‘The future of towns and cities post-Covid-19 report’ in January 2021 by the auditing firm KPMG, a permanent shift towards working from home and increased online shopping could cost more than 400,000 retail jobs on England’s high and vacant retail space. Microsoft, Facebook and Twitter have told staff that they will have the option of working from home permanently. On 23 February 2021, HSBC announced its intention to reduce its office space by nearly 40% to capitalise on new part-office-part- homeworking arrangements after the pandemic. As Global Workplace Analytics concludes: “The genie is out of the bottle and it’s not likely to go back in.”

https://globalworkplaceanalytics.com/work-at-home-after-covid-19-our-forecast

So, the 2014 projections are out-of-date and far too high. Even by 2016, the Office for National Statistics (ONS) were projecting far less demand for housing in Dacorum. By 2018 their projections had more than halved.

2.2 Dacorum’s strategy fails to protect the Green Belt

Dacorum’s Sustainable Development Strategy does not comply with the duty to protect the Green Belt under the National Planning Policy Framework (NPPF). It seeks only to protect the Chilterns AONB:

Policy DM27 - “Landscape Character and Chilterns Area of Outstanding Natural Beauty 1. All development shall help conserve, restore or enhance the prevailing quality, character and condition of Dacorum’s natural and historic landscape. 2. Permission for major developments in the Chilterns Area of Outstanding Natural Beauty (AONB) will be refused unless exceptional circumstances prevail as defined by national planning policy”.

Dacorum’s strategy fails to offer the same protection to the Green Belt. The paragraphs dealing with the Green Belt are concerned only with an intention to build on it:

19.7: “We have undertaken a review of the Green Belt and identified those areas on the edge of the main settlements where exceptional circumstances exist to release land for development or where other minor adjustments are necessary”.

“These proposed releases will make a significant contribution to meeting the long term housing and other development needs of the Borough. Green Belt land has been released to enable the delivery of the spatial strategy for Dacorum.”

In contrast, Dacorum’s previous strategy (2017) contained principles to protect the Green Belt:

10.2.2 “These cover the need to make the best use of brownfield land to maximise opportunities for urban regeneration”.

“National planning policy is also clear that Green Belt boundaries should only be changed in exceptional circumstances. The protection of the Green Belt from inappropriate development is an important national and local principle”.

10.2.3 “Another important principle is to ensure that our urban areas do not sprawl into other existing settlements undermining their distinct and separate identities. Likewise, isolated development which has poor connections with local services and facilities should be discouraged. Protecting the character of our town and villages, and that of important landscapes and countryside will also be important considerations, as will using development to help fund and deliver essential new infrastructure”.

In Dacorum’s new strategy, the “exceptional circumstances” required by the NPPF to build houses on Green Belt seems to consist of little more than, “because we want to build houses”.

2.3 Dacorum’s strategy fails to protect the River Bulbourne

The Bulbourne is a rare chalk stream: there are only 250 in the world and most are endangered. The river is a sanctuary for all kinds of wildlife and a source of biodiversity. Hertfordshire's State of Nature report 2019 by the Herts & Middx Wildlife Trust explains the importance of the River Bulbourne:

“Hertfordshire has a national and international responsibility for protecting its special chalk rivers, which have a unique ecology due to their clean, mineral-rich water and consistent flows. A high proportion of the world's global numbers of chalk streams can be found in the South-East of England, specifically in Hertfordshire”.

The Bulbourne rises at Dudswell, and runs for 10km alongside the Grand Union Canal through Northchurch and Berkhamsted and joins the Gade at Two Waters, Hemel Hempstead. The Bourne Gutter, a winterbourne, periodically rises and joins it at Bourne End.

Chalk streams are beautiful, flowing crystal-clear over a gravel bed and supporting rich ecologies. Rainfall enters the river basin, works through the chalk strata and emerges via springs as crystal clear water. As this process takes months, the river level rises and falls slowly. However, abstractions for public water supply and for the canal have seriously depleted the quantity and quality of water in the Bulbourne. The Environment Agency recently concluded that unsustainable levels of abstraction for public water supply are contributing to low flows:

https://environment.data.gov.uk/catchment-planning/WaterBody/GB106039029890

http://dacenvforum.org.uk/wp-content/uploads/2019/03/DEF-EA-Presentation-21-Feb-2019.pdf

The wetland features of the River Bulbourne are fragile and threatened by groundwater abstraction for domestic water. Houses in Northchurch, supplied with water pumped from the chalk aquifer, reduce the water available for the river. To avoid further abstraction from the chalk aquifer and further damage to the River Bulbourne, the proposed developments in Northchurch would require a new reservoir and water imported from other areas. These massive and expensive infrastructure projects would not only take years but would also require additional land which Dacorum’s Strategy has not identified.

The proposed new developments will also damage the quality of the water. Impermeable surfaces, such as roads, paths, roofs and carparks, mean that rainwater, rather than seeping through chalk, runs into drains which flow directly into the river causing it to rise and fall rapidly. Silt, rubbish, chemicals and effluent turn the river into a thick layer of dark, polluted silt and cause localised flash flooding.

Dacorum’s Strategy has not considered the negative impact of water supply on the River Bulbourne. The proposed developments will cause irreversible harm to the quantity and quality of the water and its fragile wetland ecology.

2.3 Dacorum is not obliged to meet these 2014 figures

The Government has made it clear that Councils are not compelled to meet these 2014 figures at the expense of their legal duty to protect the Green Belt and the environment:

“We should be clear that meeting housing need is never a reason to cause unacceptable harm to such places.”

Dacorum’s strategy conflicts with Government policy because it causes unacceptable harm to the Green Belt and to the River Bulbourne. It is, therefore, flawed and should be revised to meet current housing needs.

3. Question 3 - Do you have specific comments about any of the Guiding Development policies?

3.1 The Guiding Development policies provide no justification for building in the Green Belt and fail to prevent urban sprawl

The Guiding Development policies do not give sufficient weight to preserving the Green Belt. The NPPF makes it clear that development in the Green Belt is “inappropriate". The National Planning Policy Framework 2019 (NPPF) paragraph 143 notes that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances:

‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.’ (para 144)

The main considerations are the effect that developments have on the openness and purposes of the Green Belt, the character and appearance of the area, and whether any harm is outweighed by other considerations which would justify the development.

Taking any benefit of the proposed developments into account, the harm to the Green Belt on the Growth Areas in Northchurch has not been “clearly outweighed”, and very special circumstances do not exist to justify allowing the “inappropriate development".

In addition, NPPF, paragraphs 133-147, emphasise the fundamental aim of the Green Belt to prevent urban sprawl by keeping land permanently open. Dacorum’s Guiding Development policies do not give sufficient weight to preventing urban sprawl. As a result, the proposed developments in Northchurch ‘sprawl’ into Berkhamsted.

The Guiding principles do not justify building in the Green Belt and fail to prevent urban sprawl.

3.2 The Guiding Development policies fail to protect the environment and promote public health

The Guiding Development policies put the need to meet housing targets above considerations such as climate change, sustainability, biodiversity and the need to promote public health. The Green Belt plays a key role in protecting the environment whilst overcrowding, traffic congestion and pollution harms people’s physical and mental wellbeing. However, according to conservation group WWF, the UK is one of the most "nature depleted countries in the world". Ahead of hosting the November global climate conference, known as COP 26, the government wants councils to take action to protect the natural world, not to destroy large areas of Green Belt.

There is a consensus across the natural, social, and health sciences on the impacts of nature experience on cognitive functioning, emotional well-being, and other dimensions of mental health: “According to numerous studies carried out after the first lockdown, being around nature is crucial to people's mental and physical health.” https://advances.sciencemag.org/content/5/7/eaax0903

Connecting with nature can help us feel happier and more energised, with an increased sense of meaning and purpose, as well as making tasks seem more manageable. On 26 February 2021, Hilary McGrady, director general of the National Trust, announced plans to plant blossom trees in cities to give people access to green space. The Green Belt fields in Northchurch give residents easy access to green space: somewhere, within walking distance of their homes, that people can breathe fresh air, connect with nature, and find solace during difficult times. Replacing this green space with brick, tarmac, noise and concrete will harm people’s physical and mental wellbeing.

3.2 The Guiding Development policies fail to prioritise Brownfield land and fail to protect the environment

The Guiding Development policies fail to recognise the opportunities, presented by rapid changes to the economy, for dwellings to be built on Brownfield land. Deloitte’s Global Consumer Tracker shows that close to 30% of consumers in the UK now shop online for food and non-food. According to the British Retail Consortium (BRC), sales of non-food items in physical shops have collapsed by 24%. These changes have led to record numbers of store closures. So, Brownfield sites, that were earmarked for office and retail use, are becoming available for housing. Use of brownfield sites would reduce the need to build on the Green belt, reduce the amount of urban decay and promote urban renewal. The Guiding Development Policies fail to capitalise on these opportunities.

4. Question 4 - Do you have specific comments about any of the Delivery Strategies?

4.1 There is no Delivery Strategy for Northchurch

Northchurch is not mentioned in the Delivery Strategy. Instead, Northchurch is referred to as ‘West Berkhamsted’: there is no such place as West Berkhamsted. The Delivery Strategy blurs the clear boundaries between two very different communities: Northchurch and Berkhamsted. Policy SP20 Table 35 Growth Areas describes the developments in and around Northchurch village as ‘major urban extension’. Berkhamsted is urban; Northchurch is not. It is a semi-rural village that attracts an older resident due to its location, local amenities and rural feel, while providing easy access to Berkhamsted and Tring. By failing to acknowledge that Northchurch exists, the Delivery Strategy fails to assess the impact that overcrowding and increased traffic flows will have on Northchurch residents and their quality of life.

4.2 Proposed developments in Northchurch are too far from the town centre

The proposed developments contradict a key aim of the Delivery Strategy: ‘to focus on ensuring that developments are well connected, accessible to the town centre and railway station”. (Para 23.121)

The proposed developments in Northchurch are on a steep hill and are 5 kms from the shopping centre and train station. This is too far for residents to walk which means they will take their cars. The Development Strategy recognises that ‘there are few opportunities for new road capacity in the town’. The roads leading from the proposed development sites to the town centre are equally restricted and the increase in traffic would lead to congestion and health and environmental issues for residents of Northchurch. None of the proposed development in Northchurch would allow residents to walk to any amenities and therefore, the locations are neither sustainable nor environmentally friendly.

5. Question 5 - Do you have specific comments about any of the Proposals and Sites?

There are four proposed sites that will harm Northchurch directly:

• Bk05 Blegberry Gardens in Berkhamsted (3.5ha)

• BK06 East of Darrs Lane (22.73ha)

• Bk08 Rossway Farm (12.29ha)

• BK07 Lock Field (2.2ha)

5.1 Bk05 Blegberry Gardens, and Bk08 Rossway Farm

These sites are adjacent to each other and run between Shooters Way and the A41. Many residents enjoy walking the footpath that runs along the edge of these fields and the views across the Green Belt. These fields act as a corridor for wildlife between the houses on Shooters Way and the A41.

5.2 BK06 East of Darrs Lane

5.2.1 The proposed development is too large and will overwhelm this part of Northchurch

This site is on the north side of Shooters Way. To the east, it runs alongside Bearroc Park 2, a large, 80- dwelling development being built on the other side of Durrants Lane. Heading west, it crosses the field, over Bell lane, to Darrs Lane which is the boundary for the Chilterns Area of Outstanding Natural Beauty (AONB). The development of 200 dwellings includes a secondary school with access from Darrs Lane. It runs alongside Bearroc Part 2, the recent development of 80 dwellings on Durrants lane.

Taken together, these developments comprise 560 dwellings and cover over 40 acres of Green Belt. This huge area fulfils the primary aim of Green Belt policy; to prevent the unrestricted sprawl of large built-up areas, and to prevent neighbouring towns and communities merging into one another. These 560 dwellings form a large crescent-shaped development which merges a large part of Berkhamsted with Northchurch.

5.2.2 Dacorum previously rejected this site as unsuitable for development

DBC’s 2013 review of Green Belt in Dacorum concluded that the parcel of Green Belt west of Durrants Lane strongly supports the fundamental purpose of the Green Belt: to prevent urban spawl. The site was further assessed in Dacorum’s Schedule of Site Appraisals (For Large Greenfield Sites) October 2017 and was rejected for its impact on the Green Belt. This appraisal concluded that “Durrants Lane forms a hard edge for the settlement and any loss of Green Belt further west may place undue pressure on the overall integrity of the wider Green Belt in the medium to long term”.

5.2.3 The impact on biodiversity

The Chiltern Beechwoods Special Area for Conservation is a site of European importance of biodiversity and wildlife conservation. In July 2018, the Chilterns Conservation Board submitted a request to Natural

England for a review of the designation and requested that National Park status be considered. DEFRA’s Landscapes Review 2019 (The Glover Report) strongly supported this request. The proximity of the developments will damage the nearby AONB and its prospects for becoming a National Park. Dacorum’s Local Plan should consider the economic and environmental benefits of a new National Park and put on hold any proposed developments that could impact on the AONB hold until the outcomes of the Glover Report.

5.2.4 The impact on physical and mental health

The loss of Green Belt will have a detrimental impact on local peoples physical and mental health which contradicts national and local policies. Very many local people walk up these lanes and along Shooters Way for exercise and fresh air. At various points, they stop to enjoy uninterrupted views across the valley and towards the AONB, and down into the built-up parts of Northchurch. The fields, hedges, wildflowers, groups of trees, ancient woodland and embankments combine to enhance the view and attract birds and wildlife which are pleasant to see and hear. This green fields, footpaths and lanes makes a significant contribution to people’s physical health and mental wellbeing. The loss of 40 acres of green fields will not be offset by the provision of a very small park.

The Darrs Lane site forms an important view from the other side of the valley. Although people adjacent to it in Northchurch enjoy the bucolic vista and the ability to exercise in the field, it is admired from the other side of the valley too. There have been recent discussions on social media about the single tree in the field - whether it is called the ‘wishing tree’ or the ‘Lonely tree’ - one resident reports that his little girl calls it ‘Arial’ — to desecrate this field will damage the sense of place of everyone in the surrounds and to see it destroyed will damage the sense of security, identity and wellbeing of all who see it - local photographers even sell photos of the view of this lonely tree field as it is so loved by the community. It is possible to walk some way up the field and look over towards Northchurch Common and Ashridge and not see the village of Northchurch at all, because of how it dips into the valley - the same will be true in reverse. To build an urban environment in this beautiful landscape is desecration that will detract from the beauty, ambiance and sense of place from those enjoying the countryside for miles around. Where once they saw the beautiful, lonely tree, they will soon see rooflines and asphalt. This will significantly damage the amenity and identity of the area, overwhelm the strong identity of the people of Northchurch, and damage their mental health.

5.2.5 The impact on heritage

Darrs Lane and Bell Lane are characterful rural lanes that are deep and high-sided from centuries of use. A Dacorum Heritage Trust study in 2010 concluded that the hedges in Darrs Lane, Bell Lane and parts of Shooters Way were over 800 years old. They need a 10-metre margin to protect them from damage. The proposed developments will damage or destroy these hedges.

The Thames Valley Archaeological Services 2016 report (a desk-based assessment of land off Durrants Lane), found that a rare surviving example of mediaeval to post-mediaeval plateau ridge and furrow had been recorded across the whole field that lies North of Grimm’s Dyke and adjacent to Bell’s Lane. This is an archaeological pattern of parallel ridges and troughs created by an historical system of ploughing, typical of the open field system, which suggests that Bell Lane has been in use since medieval times. There is a case that the lanes themselves merit conservation on the grounds of being an historic environment that adds rural character to Northchurch. Pre-historic artefacts were found on the proposed site and Roman finds reported in the vicinity. Darrs Lane and Bell Lane should be recognised as being an

environment of historic importance in the Local Plan and the ridge and furrow ploughing patterns should be preserved.

5.2.6 The lack of infrastructure planning

Although the report says that “a masterplan will be bought forward”, there is no evidence of planning for infrastructure. For example, there is no traffic management plan for these sites. Previous assessments of these sites have raised significant difficulties that have caused them to be rejected for future development. Both Bell Lane and Darrs Lane have sections which are not wide enough for two vehicles to pass and are unsuitable for increased traffic. Where these two lanes meet the High Street, road traffic is heavily congested and dangerous for pedestrians to cross, particularly children from the three nearby schools (and the proposed secondary school in Darrs Lane.) The bottom of Darrs lane is a bottleneck with an S- bend and insufficient parking spaces for customers visiting Tesco Express. The proximity of houses, means there is no opportunity to improve or expand Darrs Lane at this point. The suggestion that access to this school will be from Darrs Lane indicates that no consideration has been given to how cars and coaches will enter and leave the school.

5.2.7 Impact on the semi-rural character of Northchurch

Widening the surrounding lanes to accommodate increased traffic would alter the rural nature of Northchurch. Darrs lane and Bell Lane are attractive, narrow, hedge-lined country lanes which typify the lanes in Northchurch. Any road-widening would alter the country lane appearance to the detriment of the rural character of this part of Northchurch and the adjacent AONB.

Preservation of the Beechwoods in the Darrs Lane site would support the creation of a new National Park. Dacorum Borough Council is required to undertake a Habitats Regulation Assessment (HRA) involving a Screening Exercise to determine whether Dacorum’s Emerging Strategy for Growth has aspects within it that will impact adversely on the Chiltern Beechwoods Special Area for Conservation. However, the development proposals include the Beechwoods together with consideration of compensatory measures. This implies that Dacorum have reached a conclusion about the Beechwoods without the Screening Exercise. Therefore, Dacorum has not complied with its duties under the Conservation of Habitats and Species Regulations 2017 to determine if a plan or project may affect the protected features of a habitats site before deciding whether to undertake, permit or authorise it.

5.3 BK07 Lock Field

5.3.1 Lock Field forms part of a green, open and culturally important corridor

Lock Field is a triangular stretch of Green Belt that is surrounded by significant parts of heritage and countryside. To the south of Lock Field, the Northchurch Conservation Area sits at the bottom of a valley that rises towards Northchurch Common. Above the Conservation Area and on either side of Lock Field are the canal and the two Northchurch allotment sites. The importance of Lock Field is highlighted on page 52 of Dacorum’s 2017 Conservation Area Appraisal which states that views to the north towards the river and canal “form part of the character and significance of the conservation area”.

The Landscape Considerations on DBC’s Draft Strategy (page 317) highlight Lock Field’s “relationship to the Grand Union Canal, its setting and the associated views; the long-distance views of the AONB and the tree lined Ashridge horizon.

Taken together, the Conservation Area, the canal, Lock Field, the allotment sites and the hill rising to Northchurch Common provide a culturally important, green corridor. This thin strip of land provides a rich habitat for wildlife and allows wildlife to move, within an urban environment, from the canal to Ashridge and Northchurch Common. The proposed development would block this green corridor causing significant harm to wildlife.

The importance of preserving this corridor, in terms of its visual impact, was recognised in Dacorum’s 2017 Northchurch Conservation Area Appraisal which proposed extending the conservation area “to encompass the canal, tow path, lock gates, lock keeper’s cottage and open space between the River and Canal:

1.) “As the Grand Union Canal is an important historic influence on the wider area from the latter 18th/early 19th centuries, the area forms a key amenity link to the Grand Union Canal tow path which creates a pedestrian/cycle route to Berkhamsted to the east and Dudswell and Tring to the west. The section of the Grand Union Canal from Brentford to Berkhamsted was completed in 1798, and the link to Birmingham was opened in 1805. The building is a component of a nationally significant canal development which linked London and Birmingham by 1905 and which remained commercially operational until the 1960's. The setting of the building alongside the lock chamber to the north of Northchurch remains unchanged, enhancing the clearly legible functional relationship between the 2 structures. The lock cottage stands alongside the lock chamber of one of 2 operational locks. The lock retains wooden gates of traditional design to both ends of the chamber, which is brick lined below massive stone copings. The building is of distinctive architectural form and character and remains clearly identifiable as a canal-related structure.”

2.) The open area to the north east of the current conservation area boundary is open space which is visually connected to the existing conservation area and leads to the tow path and canal and a definable boundary.”

NPPF, paragraphs 133-147, states that the fundamental aim of the Green Belt is to prevent urban sprawl by keeping land permanently open. In relation to the openness and purposes of the Green Belt, the development at Lock Field would "significantly reduce the openness of the Green Belt, to its considerable detriment

5.3.2 Lock Field is a potential community amenity

If Lock Field is removed as a development area, Northchurch Parish Council would seek to purchase this Green Belt as a community amenity for people to visit and enjoy. Residents have demonstrated a high demand for recreational and exercise areas. Northchurch Recreation Ground had to be temporarily closed due to surface damage as a result of people exercising and paths at Northchurch Common and Northchurch cricket ground have been damaged by the amount of people exercising there. The Lock Field Site would be highly valued by the local community as a nature reserve with some gravel and brick pathways to enable exercise and enjoyment of nature.

5.3.3 Risk of flooding

During heavy rain on 31st January 2021 and a Flood Alert on 7th February 2021. the Lock Field site was the subject of a surface water run-off flood warning. The National Flood Warning Service shows that part of the site is at Medium Risk, meaning that each year that section has a chance of flooding between 1 and 3.3%. The proposed development will require flood prevention measures

5.3.4 Impact of increased traffic flows

The Local Plan has no masterplan to assess the impact on infrastructure or traffic. Northchurch Parish Council has had more complaints from residents about road safety traffic in New Road in the vicinity of this site than anywhere else in Northchurch. Residents are fearful that traffic from the Lock Field site will increase the likelihood of a pedestrian being injured. Vehicles often speed down the hill towards the canal bridge. The canal bridge is the primary cause of danger and it is just above the bridge that traffic will enter and leave the estate. It is not possible to prevent these additional vehicles adding to what is already a very dangerous location.

The Transport Study proposes moving the stop line on the north of the single-track bridge up the hill beyond the new Lock Field access road; and lengthening the footpath on the south side. This would lengthen the single-track section over the canal bridge and cause further congestion on either side of the bridge.

In 2017, a development company circulated proposals for a residential development on Lock Field. At the time, the primary concern for residents was the danger from road traffic leaving the estate by the canal bridge. The canal bridge is only wide enough for one vehicle. Private houses on either side of the canal prevent any widening. The pavement outside the school is very narrow and lined on both sides by parked cars. The narrow pavement gives little room for error and parents with buggies are forced into the road, particularly by the canal bridge. Cars approaching from either side, sometimes accelerate to get through the gap first. An unsupervised child crossing the road will appear from between parked cars and give an approaching driver very little time to brake. At this point, many drivers are accelerating towards the canal bridge with eyes focussed on approaching traffic. To protect children, Northchurch Parish Council pay for a crossing patrol.

5.3.5 Impact on air quality

According to the 2020 Dacorum Local Plan (2020-2038) Emerging Strategy for Growth Interim Sustainability Appraisal Report Appendices: “The main source of air pollution within Dacorum Borough is generated from road traffic”

The section of Northchurch High Street running from St. Marys School to Darrs lane is one of three areas in Dacorum identified as vulnerable to pollution from nitrogen dioxide (NO2). This stretch of road is narrow and the tall houses trap NO2 from queueing vehicles. Although the air quality has improved in the past two years, any increase in traffic from additional residential developments may make the problem return. The main users of this part of the High Street are junior school children and the elderly who are both particularly vulnerable to lung damage.

Northchurch has a high percentage of elderly residents: about 30% are aged over 60. In February 2021, Asthma UK and the British Lung Foundation published a new report explaining the health risks:

“Exposure to air pollution increases the chance of a person dying early, developing lung

cancer and cardiovascular disease. Emerging research has even shown links with air pollution and cognitive decline, including dementia.5”

The report revealed that 59% of older people are living in areas where fine particulate matter (PM2.5), the most worrying type of pollution that can penetrate deep into the lungs, is above the levels recommended by the World Health Organisation (WHO).

In conclusion the air pollution caused by increased vehicle journeys is likely to cause significant harm to the health of Northchurch residents, particularly to the young and old.

5A. Question 5A – Are there any other sites that you think should be included in the Plan?

5A.1 Growth Area BK13: Gossoms End / Billet Lane, Berkhamsted

Developers own this 1.48-acre site and have planning consent for a retail food store, 30 flats and a carpark. However, they no longer wish to build a retail store on this site and Berkhamsted already has three, large, retail food stores. This site could provide many low-cost residential apartments, like the adjacent Turner Court Apartments, with a small grocery store below. Unlike a retail store, which would attract many out-of-town shoppers in cars, residential apartments would provide low-cost accommodation, that local people could afford, within walking distance on level ground of the town centre and train station. Improving the canal path would encourage residents to make that journey on foot. In contrast, the proposed developments in Darrs Lane and shooters Way encourage car journeys. This site should be included in the Local Plan as suitable for residential development.

6. Question 6 – Do you have any comments on the Sustainability Appraisal that accompanies the Plan?

6.1 The Plan is not compatible with the objectives of the Sustainability Appraisal (SA)

Dacorum’s Local Plan Interim SA Report November 2020 4.5 (page 24) assesses the compatibility between SA Objectives and Local Plan Objectives. In relation to Local Plan Objective: “Delivering Dacorum’s future with homes for everyone”, it concludes:

“This objective is potentially incompatible with a number of the SA objectives:

• The level of housing development required in the Borough will require development of greenfield land. Development of greenfield land is not compatible with biodiversity (SA1) due to landtake, potential habitat fragmentation and urban pollution issues. Development on greenfield land would also result in soil sealing (SA6).

• Providing new homes in the Borough will put direct pressure on water resources (SA2) which are already identified as ‘over-abstracted’.

• Housing development will result in increases in greenhouse gas emissions from new housing and associated activities (SA4). It will also contribute to background emissions through an increase in the number of vehicles on the road thereby reducing air quality (SA5). The objective also has uncertain compatibilities with several the SA objectives:

• Parts of the Borough lie within areas of flood risk and there is the potential for new housing sites to lie within these zones (SA3).

• Housing development on greenfield sites is potentially incompatible with the SA objectives on historic environment (SA8), and landscape / townscape (SA9).”

Similarly, the report details potential incompatibilities between SA objectives and two Local Plan Objectives: ‘Generating a vibrant economy with opportunities for all’, and ‘Enabling the delivery of infrastructure’.

The Local Plan should remove the word “potentially” and acknowledge that Local Plan Objectives are not compatible with sustainability.

6.2 The Sustainability Appraisal does not meet the need in Dacorum for social housing

The proposed developments contain insufficient social housing to meet local needs. For example, a semi-detached house in the Bearroc 2 site, adjacent to the new Northchurch developments, is priced between £500,000 and £800,000. This is beyond the means of people in Dacorum who need housing.

7. Question 7 – Do you agree that the Evidence Base that accompanies the Plan is adequate, up-to-date and relevant?

7.1 The Evidence Base in not up-to-date and relevant

Dacorum’s target of 922 dwellings is based on out-of-date projections carried out in 2014. Subsequent household projections in 2016 and 2018, by the Office for National Statistics (ONS), have been much lower, with significant declines in London, the South East, and the East of England. For example, in 2014 the ONS projected growth, over 25 years, at 23.1%. In 2016 this projection fell to 17.3%, and in 2018 it fell to 16.2%. Within these projections, increases in the East Midlands, North East, North West, and South West were balanced by significant declines in London, the South East, and the East of England.

In Dacorum, the reduced projections led to a fall in the annual requirement for dwellings from 922 in 2014 to 430 in 2018. The trend for working from home rather than commuting to an office, has further reduced the demand for dwellings near train stations within commuting range of London. Future projections for housing requirements in Dacorum are likely to be even lower. So, Dacorum’s Local Plan is based on projections that are out of date and that do not reflect current demand.

Other planning authorities have declined to use these outdated projections. For example, in October 2020, Buckinghamshire Councillors voted to withdraw their Local Plan and are working on a revised plan to "reflect the considerable effect Covid-19 has had on areas such as shopping habits and town centres as well as changes to planning law". Dacorum’s councillors should follow the example of their Buckinghamshire counterparts, withdraw their Local Plan, and produce a new plan based on current projections.

8. Question 8 -Do you think that the Plan is consistent with the National Planning Policy Framework (NPPF) and supporting guidance?

8.1 When calculating housing need, the Plan does not take account of the Green Belt

The Campaign for the Protection of Rural England (CPRE) Hertfordshire states that Dacorum’s Plan is not consistent with the NPPF as it does not take account of such constraints as Green Belt and AONB when calculating housing need.

“We do not believe that the Plan is consistent with the NPPF. DBC state that they aim to “minimise” development on Green Belt land and the impact on the Chilterns AONB. We believe that DBC have ignored this aim in order to meet an unnecessary and inflated housing target that they themselves have chosen. The proposed developments in Northchurch are Green Belt and the Darrs Lane site borders the Chilterns Area of Outstanding Natural Beauty.”

Dacorum “are not obliged by the NPPF to prioritise housing targets over environmental or other concerns: paragraph 11, footnote 6 allows Dacorum to restrict the scale of development due to other planning constraints such as the impact on the Green Belt and AONB. In our view, the failure to do this means that their proposals are not consistent with the NPPF.”

8.2 When calculating housing need, the Plan does not give sufficient weight to the physical and mental health of local people

The ‘places vision’, emphasises growth over all other considerations and does not reflect the aspirations of local people.

Northchurch Parish Council has many formal and informal consultations with residents about what is important to them. In line with their views, our published mission is to make Northchurch “a safe,

healthy

and vibrant community by:

• Helping local people to improve their physical health and mental wellbeing

• Making our roads safer

• Protecting and improving access to the Green Belt and other open spaces

• Preserving the environment and increase biodiversity

• Preserving the historic identity of Northchurch

• Being open and accessible, and engage local people in decision making”

https://www.northchurchparishcouncil.gov.uk/

All our work is focussed on achieving these aims. For example, we have a 5-year project to increase biodiversity by changing a 400m stretch of closely mown verge into a wildflower verge. We are carrying out a major project to improve play and exercise facilities at our recreation ground. We have set up a committee dedicated to improving road safety. These efforts will be undermined by the loss of so many acres of Green Belt. By over-emphasising growth, the ‘places vision’ meets neither the aspirations nor the concerns of Northchurch residents.

9. Question 9 - Do you have any other comments on the Plan?

9.1 Inadequate public consultation

Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012, requires Dacorum Borough Council to notify residents and other persons carrying on business. Dacorum’s consultation process does not comply with these regulations. On the contrary, many people in Northchurch have either not heard of the consultation or have no means of responding.

Many homes in Northchurch did not receive Dacorum’s brochure. During the extended period of the consultation, residents from Northchurch and surrounding streets, including some parish councillors have told us that the brochure has not been delivered to their street including Granville Road, Cowslip Meadow, Lyme Avenue, The Meads, Darrs Lane, Northchurch High Street, Tring Road, Covert Road, Covert Close, Compass Point, New Road, Wharf Lane, South Bank Road, Chaucer Close, Kings Road Berkhamsted, Westfield Road, Durrants Lane, Pages Croft, Haynes Mead, Bridle Way, Edlyn Close and Winston Gardens. Additionally, the hard copy directs residents to the DBC website but does not provide the full information required for a resident to a return a meaningful response.

Northchurch has a high percentage of elderly residents who do not access information online or via social media and know little of nothing about Dacorum’s plans. Many residents to not have access to the devices that they need to consult the documents and are therefore excluded. Journeys to libraries are non-essential, unlawful and cannot reasonably be advised. In normal circumstances, Northchurch parish councillors would distribute leaflets detailing the plans for Northchurch to all our households, but Lockdown rules have prevented us doing this. One example from an elderly local man illustrates the difficulties face by elderly and disabled residents:

“I moved area in 1959 and took part in a consultation on building on the field behind Chaucer Close at that time by attending a meeting in Sunnyside Church Hall. But I have not received any information notifying me of the current consultation. I have no IT. I cannot travel to a library because I am disabled, and I live alone. I would like to participate in the consultation, but it is not possible because the current lockdown restrictions say I should only do essential journeys.”

Meaningful consultation would reveal that virtually everyone in Northchurch believes that Dacorum’s Plan does not recognise Northchurch and does not meet the needs or aspirations of local people. It will undermine their quality of life, harm their physical and mental wellbeing, and cause irreparable damage to the Green Belt. Northchurch Parish Council would like this plan to be withdrawn and replaced with a new plan based on an up-to-date assessment of housing needs that reflects the views of the people of Dacorum.

In conclusion the Local Plan:

• Is unknown to many residents due to lockdown restrictions

• Is deeply unpopular with those residents who are aware of it

• Uses out-of-date, 2014 housing projections which are much higher than current projections

• Prioritises housing targets above the Green Belt, climate change, sustainability, biodiversity and

public health

• Does not meet the need for social housing

• The population increase in Northchurch (over 50%) will cause overcrowding and congestion

• Will destroy 40 acres of Green Belt in Northchurch, and 21,000 acres across Dacorum

• Is not compatible with the Sustainability Appraisal

• Will damage the River Bulbourne

• Will harm the physical health and mental wellbeing of local people

• Fails to protect the distinct community, history and rural character of Northchurch

• Allows Northchurch to ‘sprawl’ into Berkhamsted

• Fails to maximise the use of brownfield land for housing

• Fails to provide the infrastructure needed to cope with increased demand

• Fails to provide each development with a traffic management plan