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Local Plan Consultation: We are submitting our response: have you?

Readers may recall our guide to the Local Plan and advice on how to respond shared to our community in July. The draft of a new Local Plan is now open for public consultation and you can have your say until 5pm on 25th September. Read more to see a flavour of our submission.

A community effort

Thank you to our incredible volunteer team who have incorporated community feedback and local expertise to draft a substantial 20+ page response on behalf of Sustainable St Albans. We share below an extract – our response to the ‘general comments’ section – which may help to inspire your own thoughts. Don’t forget that the deadline to share your feedback is 5pm on Monday 25th September.

Our General Comments on the Local Plan

Sustainable St Albans are encouraged to see action to reduce carbon emissions and support nature recovery reflected so strongly in the draft local plan; there is a climate crisis and a crisis for nature, and to tackle these requires concerted, bold, and urgent action.  We are sure that SADC will come under pressure from other respondents to water-down these commitments; we urge SADC to stand firm and ensure the local plan does deliver for climate and nature, as well as for local people and the economy. 

Our key recommendation is to ensure that the intentions of Chapter 2 are then implemented throughout the policies in every other chapter, to prioritise actions in every section.  For example: 

  • in the economy section, priority should be given to those businesses and organisations which will help with the climate crisis, nature loss, and community solutions, such as repair businesses and cycle shops,
  • in the heritage section, SADC should be as encouraging as possible about the weight given to the public benefit of energy efficiency/generation, when weighed against any harm to heritage,
  • in the housing section, building densities and height constraints should be relaxed, because more dense housing is lower carbon to build and operate, per dwelling,
  • in the transport section, SADC could require or strongly encourage solar canopies/roofs or green canopies/roofs on any new car parks, and could ensure the parking standards in Appendix 2 set maximum car parking limits and (higher than currently suggested) minimum cycle parking,
  • in the design section, planning conditions for extensions should require retrofitting measures for the main house to be delivered at the same time as the extension. 

Embodied and whole life carbon needs to be included, and is currently missing. For major developments, there should be a requirement for a calculation of both embodied and whole-life carbon, against an agreed benchmark, and then significant reductions against this benchmark found. (This is feasible, it is done already by the GLA.)

We recommend changes in the wording at various points to talk about the principle of minimising carbon and using the  ‘best technology currently available’, rather than naming particular technologies in the text, because this will change over time. Existing technologies can be given as examples, but not definitive lists. Similarly, the quality standards/benchmarks should be able to be ratcheted up over time, and take advantage of any relaxation in legislation, for example updates to the NPPF.

We strongly recommend that wherever tree planting is mentioned it is combined with tree care, to ensure the trees do not die, and also that other nature-based solutions are considered, such as using hedges rather than fences, and soil improvement. 

Biodiversity net gain should not just be a mathematical exercise, of calculating a % increase in generic habitat. It should have a clear link to those species which Hertfordshire is home to and where numbers are falling. Specific actions should be prioritised which create the habitats / wildlife corridors required for the recovery of these species. 

We support the concept of the offsetting fund, but it needs development, and there must be a very clear requirement to minimise emissions first and only offset as a last resort. (See GLA example here). We suggest changing the name, so as not to legitimise offsetting. We believe the funds raised should be used for community projects, e.g. allowing local community centres, parish halls, and faith buildings to implement energy efficiency / generation measures. Community solar / wind farms and community growing could also be supported, and sustainable travel measures. Developers should not be allowed to simply pay for tree planting. Any tree planting that does take place must have clear plans for long-term care. The implementation of the fund needs to be properly resourced, so that grants are made to well-chosen projects, in a timely manner. SSA would be willing to work with the Council to develop the policies governing this offsetting fund. 

If the reference point leading to 888 new homes per year reduces, and to meet the current target requires building on green belt land, we hope that SADC will use the freedom to avoid building on green belt, and instead set a target which meets genuine local need.

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