Main Modifications to the Pre-Submission Core Strategy – Comments

All comments that have been submitted to Dacorum Borough Council can be found at


BRAG’s submissions can obviously found at the above address but for convenience we reproduce them below:


MM2 – BRAG believes the paragraph can be further strengthened by adding “ only if and when there is a proven need for additional housing ”.


MM3 – BRAG broadly supports MM3 with the caveat that BRAG believes that not all local allocations are required to meet local housing needs and specifically LA4 (Berkhamsted: Hanburys, Shootersway) should not be included in Table 9.

BRAG is concerned that the wording: “The release date of any local allocation may be brought forward in order to maintain a five year housing land supply” is indeed a major modification that has not been well publicised. As worded, it is an open invitation to build on the Green Belt sites at any time during the planning period purely because other sites have failed to meet their commitments, or infrastructure has not been put in place. It makes MM2 and the first sentence of MM3 meaningless and leads to ongoing uncertainty for the residents.

[Footnote 13 has been omitted and so BRAG cannot comment on it.]


MM4 – BRAG supports.


MM6 – BRAG supports the management of travel demand by “carefully locating development so that it is accessible to all users’ and supports the addition of ‘managing public parking both on street and off the street”. Unfortunately the recently published Urban Transport plan for Berkhamsted does nothing to address this.



MM9 – BRAG supports regular review of office development and “managed release of office sites which are no longer attractive, viable or suitable for offices”. At a time when high street retailing faces a bleak future BRAG considers that we should be open minded about converting some unused commercial properties to residential use.


MM11 – BRAG supports.


MM12 – BRAG supports.


MM13 – BRAG suggests that ‘ after 2021’added so that it reads ” The management of local allocations after 2021, including possible release of a site earlier than intended ,”


MM14 – BRAG supports.


MM15 – BRAG supports.


MM18 – BRAG supports.


MM19 – BRAG supports.


MM25 – BRAG supports.


MM28 -BRAG does not support the Council’s commitment to an early partial review. BRAG has shown in its submissions and at the hearing that the Council’s figures are robust. Indeed, given that the 2011 Census proves that the decline in average household size has slowed considerably (referenced in MC61), updated projections indicate that the Core Strategy has a built in buffer of 12.7% above the actual projected housing need.

BRAG believes that an early partial review is not warranted, will prove a waste of time, money and resources. It will only serve to offer opportunistic developers another opportunity to promote their land outside the normal planning procedures, while dragging this process on for many more years exposing residents to prolonged stress of the uncertainty as to how their community will develop through the next 20 years.

The final line of 29.10 states “The outcome of the review cannot be prejudged “ but in 29.8 it states that “The purpose of the review is to reconsider housing need and investigate ways of meeting that need more fully”, which is prejudicial in that the wording suggests that the author believes that the Core Strategy as it stands doesn’t fully meet housing needs. This is wrong and at the very least that sentence should be stricken from MM28.

BRAG supports co-operation with neighbouring authorities (St Albans in particular) but believes a full Green Belt review is unnecessary. In brief, the only reason to change Green Belt boundaries is to allow development, but Green Belt was designed to check urban sprawl so the simple fact that some developers are asking for a review is proof enough that the current Green Belt boundaries are doing the job that they were designed to do.

There should be no assumption in a Green Belt review that some of the Green Belt is to be sacrificed and the importance of the Green Belt purpose “to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” should be fully recognised.


MC1 – BRAG supports including mention of windfall sites as these have made a positive contribution to housing supply in recent years and are likely to increase the available housing supply significantly over the planning period.

MC2 : BRAG objects to the deletion ‘ to ensure they are only brought forward if required .’ Local Allocations are Green Belt land and should only be used if absolutely required. BRAG considers that these words should be reinstated.

MC12 : BRAG supports

MC 14 : BRAG welcomes the addition of “More food is grown locally ” as this should be an on-going aim that cannot be achieved by building on productive farm land.

MC30 : BRAG broadly supports but doesnot agree with the partial review of the Core Strategy or the Green Belt review.

MC31 : BRAG supports.

MC32 : BRAG supports.

MC41 : BRAG supports.

MC42 : BRAG supports in principle but the current Urban Transport Plan, which is out for consultation, is a very poor document that is unlikely to address current problems let alone problems generated by future developments.

MC57 : BRAG considers that the new sentence ” The availability of such accessible shops and services is vital, and the Council will support their provision and retention where it can ” adds nothing to the paragraph and could be misinterpreted by prospective developers. Any additional shops and services must be shown to be viable in the long term.Delete this additional sentence.

MC61 : BRAG supports. It is important to reflect that the trend of declining household size has slowed significantly as this directly impacts on future housing need projections.

MC62 : BRAG supports

MC65 : BRAG opposes the deletion of “ small scale ” and is concerned about the reason the council has deleted these words. Reinstate the words “ small-scale ”

MC179 : BRAG supports, in particular, the pledge to protect “ the green swathe between the town and the A41 ”. However, to further strengthen the paragraph BRAG suggests after “ including the landscape setting of the castle” the phrase “ and other heritage sites ” is added.

MC180 : BRAG opposes the deletion of “ The development is in a sensitive ridge top and edge of town location, adjacent to existing housing ”. BRAG supports the principle of funding improvements to the Shootersway/Kingshill Way and Durrants Lane/High Street junctions but the current Urban Transport Plan doesn’t offer a satisfactory solution in particular for the Shootersway/Kingshill Way junction. Until an adequate solution is proven then SS1 and any development (in particular the unnecessaryLA4) along Shootersway should be held back.

MC181 : BRAG fully supports “The priority is to deliver the school playing fields” and sees no reason for the word “first” to be struck out. However, BRAG welcomes the addition of “the playing fields to be relocated first.” It is important that the school and community have continuous use of playing fields, so the relocation of the playing fields prior to any housing construction is a critical condition of the development agreement.

MC182 : BRAG does not believe that LA4 is required and should not be included in the Core Strategy. However, given that LA4 is included, BRAG queries why the word “funding ” has been struck out. BRAG also believes that it should be made clear that nodevelopment can take place until appropriate improvements have been made to Shootersway/Kingshill Way junction. Unfortunately, the current Urban Transport Plan is promoting an inappropriate solution.

MC204 : This is another inference that Local Allocations may be used before 2021. Make it clear that this is not the case. BRAG objects to the word ‘ site ’ being replaced with ‘Local Allocation’


In addition to the submissions above BRAG wrote directly to Strategic Planning specifically about the proposed review of Green Belt Boundaries:


I write to express BRAG’s  concern at the proposal to conduct a review of the Borough’s Green Belt boundaries as part of the partial review of the Core Strategy.


In the first instance we question the need for such a review and its purpose. There is a clear risk that the very existence of a review at this early stage raises expectations that changes to Green Belt boundaries will take place.


If the review does proceed, we are concerned as to the manner in which it is undertaken.  To be clear, all five core purposes of Green Belt have to be considered and none omitted as has happened in Green Belt reviews elsewhere.


The five core purposes of Green Belt as laid out in PPG 2 and confirmed in the NPPF are exactly what is required for Berkhamsted. Furthermore the Government position as set out in the NPPF is that Green Belts are in place and they have pledged to protect them (whilst seeming to be less enthusiastic about the creation of new Green Belt).


Where our concern arises is in the somewhat ambivalent references in the NPPF to reviews of boundaries and the need to meet the requirements for sustainable development. There seems to be an inherent conflict within the NPPF and we would be grateful if you would clarify the Council’s position on this.


If a review has to be undertaken we are concerned as to the basis and method. For instance a desk-top review might conclude that there is scope to improve the physical definition of some boundaries, perhaps by substituting a road such as the by-pass for a rear fence line behind some houses. It would also not take into account topography and the potential impact of development on ridge tops. There are other factors such as adverse noise and environmental impact that may not be considered as not specifically referred to in the five core purposes of Green Belt.


BRAG remains very supportive of Dacorum’s overall approach to the Core Strategy, in particular the commitment to retain the ‘green swathe’ between the Town and the A41 (MC179, RR, 21.6),  but seeks reassurance in relation to the existing Green Belt.


Yours sincerely,


Antony Harbidge

BRAG Chairman


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