Dacorum Councillors

Draft Local Plan 2020-2038 Consultation

Berkhamsted Residents Action Group (BRAG) has detailed knowledge of Berkhamsted and has been pro- actively involved in the planning strategy for the Town for the last 10 years. We were actively involved and worked alongside the Planning team on the preparation and examination of the 2013 approved and still current Plan. Since the decision to draft a new Plan rather than review the current Plan (as proposed by the Planning Inspector) we have had a dialogue with the Planning team on the appropriate assessment of the Borough’s housing need and their review of the Green Belt.

It is against this background and on the basis of the points made below that we ask you as Councillors to defer the consultation on the draft new Plan, though we stress that the points made are relevant to the whole of the Borough, not just Berkhamsted.

• In approving the current Plan, the Inspector stated an interim review would be required. It was not necessary to start the Plan process again and open the floodgates for potentially much greater housing need targets.
• Consultation on possible housing need targets took place in 2017 but there has been no reference to the results of this consultation.
• Against this background the Planners have produced their own assessment of housing need which is much higher than previously felt appropriate. Given the development/land constraints the Borough faces, we question why?
• The consultants’ review of the Borough’s Green Belt was seriously flawed and biased. BRAG provided a detailed critique which was adopted by Berkhamsted Town Council and provided to the Dacorum planning department
• The ‘need’ to build over much of the Borough’s Green Belt is not proven and does not appear to have been challenged by either the Council or Planners. The “exceptional circumstances” are driven by a central Government algorithm producing numbers which may not exist in reality and given a recent statement by the Minister and the campaign by MP’s for a rethink, could, indeed should, be revised. Even the Government’s White Paper (paragraph 2.29) indicates that the formula should take into account land constraints such as Green Belt, but the methodology used and the targets set in the proposed plan do not. It is therefore premature to go out to public consultation on what is almost certainly a false premise.
• As well as this uncertainty over the Borough’s housing need targets this is not an appropriate time to hold a public consultation. We cannot hold members’ meetings to consider views and responses. There may be restrictions on holding public displays of the draft Plan proposals. At over 500 pages there is a lot to absorb and there has to be a serious question as to whether a proper democratic consultation can take place on a matter so significant to the future of the Borough.

In view of the above and the current climate of uncertainty we ask that you seek a deferral of the proposed consultation. According to the Local Government Association “A councillor’s primary role is to represent their ward or division and the people who live in it” – rubber stamping the proposed plan for consultation fails to fulfil that primary purpose in favour of developer demand and mythical Government targets.

BRAG Committee 9^th November 2020