UPDATE ON THE HERTFORD HEATH NEIGHBOURHOOD PLAN – Sep 2021
You may have seen an update on progress on the Hertford Heath Neighbourhood Plan on 21 September 2021 from the Hertford Heath Steering Group, which provides a recap on how the neighbourhood plan has evolved.
The promoters of the Barclay Grange site (located off London Road) want to correct some of the factually incorrect/misleading statements within the Steering Group’s update.
Following the village-wide survey, the Steering Group advises that two sites were put forward – Haileybury and Barclay Grange. Whilst this is correct, it fails to mention that:
- The Steering Group used incomplete and out of date details which omitted the various community benefits which Barclay Grange would bring to the village in addition to its Section 106 contributions. You can read more about the proposed community benefits at https://barclaygrange.com; and
- Haileybury was in fact put forward as two individual smaller sites. Local people did not therefore know that these would be combined into one site when they submitted their consultation responses.
The Steering Group goes on to say that a “clear preference for the Haileybury site was expressed and the Parish Council endorsed this with their decision to proceed with the Haileybury site”. In light of the fact that people did not know that Haileybury would be two sites combined, the ‘clear preference’ was not necessarily for both of those sites to come forward, but potentially for one or the other. The scoring matrix used by the Steering Group was also unclear. Despite Barclay Grange scoring higher than both of the separate Haileybury sites, once combined, the Steering Group allocated a higher score to Haileybury with no supporting explanation.
The Steering Group advises that policies for the neighbourhood plan were worked up and thereafter it was approved and progressed to a formal Regulation 14 consultation stage. It does however fail to record that this work was undertaken prematurely, without having considered whether the Haileybury site might result in significant environmental impacts. As part of this consultation, Historic England made clear that this site would likely result in significant environmental effects to local heritage assets and as such a Strategic Environmental Assessment (“SEA”) was required. This ought properly to be carried out prior to preparing policies and carrying out consultation, because the findings could impact these.
The SEA Report has now been made available, which you can view at https://www.hhnp.co.uk/resources/down/sea. We have commissioned experts to review this, but even on a high level review, we have identified some very concerning omissions within this document. We have therefore written again to the Parish Council, setting out our very serious concerns about the legal compliance of the SEA Report. Briefly, these include:
-
- The SEA Report clearly identifies the prospect of significant effects on heritage assets resulting from the Haileybury site development but fails to clearly identify appropriate mitigation measures and whether they can possibly be effective;
- The SEA Report does not appear to have any regard to the master-planning for the Haileybury site and what effects the mitigation would have on understanding if this would result in fewer homes being built, and whether it can meet the Parish’s identified need for a minimum 84 new homes. As a result, another larger site may need to come forward to meet the numbers;
- The SEA Report does not consider all the reasonable alternatives set out within the Council’s Strategic Land Availability Assessment of March 2017 (SLAA 2017 & SLAA Update – ERP D SLAA sites.HH), which should include (for example) Amwell Place Farm. It was surprising that such alternatives were omitted since the Parish Council have taken advice on this. To exclude a site from the assessment, clear reasons need to be documented in the report to avoid it coming back as a future option; and
- The scope of the SEA is very narrow and is only focused on heritage and not the wider social-economic and environmental scope which is normal on an SEA. No engagement appears to have taken place with other consultees on the non-heritage-based scope, nor has advice been taken from the District Council. A full SEA would help inform the Parish Council and residents on the most sustainable option.
We have requested that the Parish Council instruct AECOM (who prepared the SEA Report) to abandon the current report and undertake a full SEA which is appropriately scoped. We await a response to our letter (Letter to HHPC).
You may recall that we wrote to you advising that by law the SEA Report would need to be advertised and that we consider for this to be meaningful, local residents should be given a further opportunity to comment on the neighbourhood plan proposals at the same time. We advised at that time that we had written to the Parish Council seeking clarity on their next steps but, despite chasing several times, they have refused to engage with our query.
Whilst the update indicates that the Steering Group will take consultee responses to the SEA Report into account, there is no reference to any intention of consulting with local residents – who of course will be the people affected by the proposals.
The update then advises that the neighbourhood plan is due to be presented to the Parish Council for approval and thereafter will be submitted to East Herts Council for the next consultation stage (Regulation 16). We understand that the Steering Group may be intending for this to take place at the next Parish Council Meeting to be held in early October.
It is our very strong view that to proceed without further consultation despite the serious concerns we have raised about the legal competency of the SEA Report, could lead to East Herts Council dictating where housing is to be located in the area. This would be counter to the essence of a Neighbourhood Plan, which should give communities an opportunity to have their say. We therefore invite you to write to your local Parish Councillors requesting that this matter be considered properly with a full SEA Report being prepared and further consultation being undertaken, prior to any vote being held to submit the SEA Report and Neighbourhood Plan to East Herts Council.
Background
The consultation undertaken by the Parish Council in Autumn 2018 has helped shape the development of our proposals regarding the types of amenities or services which we know residents of the village would like to see.
We appreciate that some people may be sceptical and consider us just another developer who will not deliver on the commitment to provide what the village needs and wants. We want to reassure residents that we are committed to delivering a scheme which responds to local needs and the aspirations of the community. The delivery of the Hub would be built alongside the new homes and would be included in any future planning application and the subject of conditions or a planning agreement. This would be a legal lock to ensure the Hub building is delivered.
We remain committed to delivering what the village needs and want to develop a scheme that responds to the aspirations of the community, both for existing and future residents. We wanted to know what new businesses people would like to see in the village to inform the development of the plans.
In feedback given in 2018, most people suggested a general store. A total of 316 residents gave this response, with the next highest response being Post Office (188 responses). Other popular requests from residents were for a pharmacy (148), a medical facility (131) or a tea room/café (130).
Screenshot taken from Hertford Heath Neighbourhood Plan Steering Group Paper November 2018.
Is a new general store viable?
The response to the Neighbourhood plan gave a very clear indication that the local community is very supportive of a new community store. Our plans would offer to lease the space at a commercial rate which would make a new store commercially viable.
A new store would also provide an opportunity to incorporate a local post office which is common among many local community stores throughout the country. This could provide a service which the village has been lacking for a number of years.
In addition to the support expressed in the Neighbourhood Plan consultation, the size of the village also suggests that a second general store could be commercially viable. The village is one of the largest in Hertfordshire, with 2,672 existing residents (2011 census) and an additional 336 residents over the period to 2033 and is only served by one store. This is very unusual.
By providing a new general store, the number of trips made to neighbouring Hertford or Hoddesdon can be reduced and could improve the sustainability of the whole village. The village has had other shops in the past, but these closed many years ago. These premises were not fit for purpose and were converted back to their original residential use.
Our plans could deliver the new general store that local people want and need.
Could a medical facility be provided within Barclay Grange?
The suggestion of a medical facility capable of being a GP’s satellite surgery was an aspiration of the Neighbourhood Plan. We are aware that the East and North Hertfordshire Clinical Commissioning Group (CCG) is responsible for commissioning medical services for the area and we will discuss with the CCG on what, if any, deliverable services could be provided.
At this stage of the process, we are responding to the village aspirations and providing the offer. If this is not possible, the space would still be delivered and could be used for any number of purposes which the village would support, such as a community café or tearoom, a creche or nursery, or a meeting and storage facility for the Parish Council.
Our proposals are flexible and have the community in mind. If there is another village aspiration, we are keen to work with the community to adapt the offer to what is desirable and achievable.
Would a new Community Hub be a burden?
A concern was raised that the Community Hub could be a financial burden to the Parish. To ensure this is not the case, we would provide a lifetime tenancy on a peppercorn rent which would have no cost implications to the Parish Council. It would be space within a new building with low maintenance costs, which further ensures the financial stability of the Parish, whilst providing them with purpose-built facilities for its use. This is in contrast to the Village Hall which was built in the 1930’s which presents its own issues of being such an old building.
Pre-pandemic, the Village Hall was often fully booked with the many great community groups and events that happen in Hertford Heath. But the Village Hall lacks the necessary space to fully accommodate the Parish Council and our proposed Hub building would address this. Space would be provided for the Parish Council to store its equipment and files, along with meeting space that would free up capacity at the Village Hall, meaning more community groups could use it. This space can be put to an alternative community use if the Parish Council declines the offer.
Our proposals will deliver a new Community Hub that won’t be a financial burden for the Parish Council or those that use it.
Would Traffic calming measures be delivered?
It is very common that developments provide either funding for, or the construction of, highways improvements. Our development will bring improvements which will address various traffic issues on London Road, including the following:-
- Provision of a pedestrian refuge crossing/s on London Road adjacent to the Village Hall;
- Provision of traffic calming improvements on London Road through the village; and
- Provision of improvements to improve footway connectivity between Hertford Heath and Hertford (see further sub-section below).
Our planned pedestrian refuge crossing/s on London Road, by the Village Hall, would provide a safe way to cross the road and access walking routes into Hertford and the surrounding countryside. The crossing would allow those who park in our proposed car park to reach village amenities such as the playing fields, bus stops, allotments and the Village Hall. The crossing will also help knit our new development into the existing village. In addition, the crossing will also assist in calming traffic speeds along that stretch of the road.
Other traffic calming measures that could be implemented are narrowing the road at key points with kerb build outs and planters; installing vehicle activated signs to raise awareness of the speed limit; or introducing ramps or raised tables where appropriate. This list is not exhaustive, and the final decision would be reached in conjunction with the Parish Council and in agreement with Hertfordshire County Council Highways.
Our proposals offer real deliverable solutions to address current traffic issues in the village that couldn’t otherwise be provided.
Is delivering a new pedestrian crossing on London Road near the Foxholes viable?
We are aware that proposals to provide a pedestrian crossing between Hertford Heath and Hertford, which would improve road safety for schoolchildren and others walking between these settlements, have encountered land ownership issues in the past. We have engaged the services of a professional highway consultant to examine the technical feasibility of improving matters, and are confident that we can resolve these issues.
We have identified 3 potential options to improve footway connectivity between the settlements. The first option (Option 1 – 1.5m Refuge Crossing nr Foxholes Farm) involves the provision of a potential 1.5m wide pedestrian crossing refuge near the entrance to Foxholes Farm. This has been designed to accord with relevant highway design guidance and would allow schoolchildren and others to cross the road in a two-stage manner, which is safer and much more conspicuous to oncoming traffic. Localised road widening would be required to achieve this option, although no third-party land would be required.
The second option (Option 2 – 2m Refuge Crossing nr Foxholes Farm) is a variation of option 1 at the same location near Foxholes Farm, which would comprise a wider 2m pedestrian refuge, albeit the carriageway lane widths would be slightly reduced so that cyclists could not be overtaken when passing the potential refuge.
The third option (Option 3 – 2m Refuge Crossing nr Golf Course Entrance) shows a 2m wide pedestrian refuge located within the hatched road markings near the proposed golf course entrance. This option would require the construction of a new c.270m long length of footway within the verge on the south-western side of the road, which is public highway, to connect the pedestrian refuge crossing to existing footway infrastructure near Foxholes Farm.
All 3 options would have the added benefit of reducing speeding and dangerous overtaking manoeuvres along the more rural section of London Road.
Note that the provision of other forms of crossing (e.g. zebra / signalised crossings) have been discounted because these would not conform to prevailing highway standards and guidance for the higher speed section of London Road between Hertford and Hertford Heath.
The improvement schemes provided for in our proposals have been developed in response to the Draft Hertford Heath Neighbourhood Plan (HHNP) and meet the HHNP Infrastructure Objectives which call for the Parish “To achieve a list of infrastructure improvements including traffic management, a village parking area and better footpath and cycle links to connecting towns through negotiation and planning agreements.”
Any improvement measures would be agreed in conjunction with the Parish Council and Hertfordshire County Council. We are happy to meet with the Parish Council to discuss what these will be.
All options are achievable and deliverable without the use of third party land and the full cost of construction would be delivered through the development of Barclay Grange.
We are confident that a new pedestrian crossing is deliverable and desirable for the residents of Hertford Heath.
How will a village car park address problem parking in the village?
Our proposals include a village car park which would be located next to the Community Hub building, at the entrance to our site and adjacent to London Road. This car park would serve the community buildings, the village allotments, those accessing the trails and country walks to the west of the village and serve as overflow parking for events at the Village Hall or playing fields.
We appreciate that parking is a major issue in the village, especially during times when events are being hosted in the village. By delivering a car park on our site, we can address the worst of the problem and provide a capacity that the village currently does not have in the most accessible location directly off London Road. Having many smaller plots across the village is both undeliverable and undesirable for those living in the village.
Businesses in the village have investigated the installation of electric charging points and we are aware that one of these has been refused by the owners. The installation of a charging point has not yet been approved and it is unclear when it could be delivered without our proposals.
Currently, the only suggested alternative location for a car park is on the playing fields, which would only have limited use on match days and will reduce the already limited recreational space within the Village.
In addition, electric vehicle charging points will be located at the Barclay Grange site alongside 5 acres of open green space and a children’s play area.
The proposals for Barclay Grange will address current car parking issues within the village which is for the benefit of new and existing residents of Hertford Heath.
Working with you to deliver for Hertford Heath.
Our proposals are flexible and seek to take the community’s views into consideration, where possible, to meet your aspirations. We are keen to continue working with the community to provide what is desirable and achievable.
All of the community benefits, listed above, would be sperate from, and additional to, the standard developer contributions (section 106) paid to the local authority and Parish Council.
Why does Hertford Heath need more homes?
In 2018, East Hertfordshire District Council adopted its Local Plan. This is a document designed to plot the future growth of the District, including Hertford Heath. As part of this Plan, the village has been identified as being in need of new housing to support future growth. The decision of where these homes are to be built has been delegated to the Parish Council. A Parish Neighbourhood Plan was subsequently drafted to identify sites suitable for new homes within the village, which is currently being considered.
The Parish Council has chosen to allocate land to build 84 new homes in the village. Our development would provide the entire allocation on one site and address the village’s housing needs for the next 12 years. In addition to meeting local housing needs, the development would provide an array of benefits for local people, including much-needed highways improvements and an abundance of community facilities and green spaces for use by existing and future residents.
For the Neighbourhood Plan to accord with the EHDC District Plan, any release of Green Belt land should generate countervailing community benefits.
The plans for Barclay Grange offer a real solution to delivering the new homes the village needs. The proposals are about much more than bricks and mortar, but delivering community facilities that local people can be proud of.
What Happens Next?
We now intend to carefully consider the valuable feedback we have received thus far in response to our consultation exercise. This will help to inform our development proposals and shape the specific community benefits which are considered to be most valuable to local residents. One of the first steps will be to understand your preferences in relation to the identified highways safety options. We will continue to keep you up to date and whilst our most recent consultation exercise has come to a close, we will continue to engage to secure the right mix of community benefits for local residents. If you have comments on a preferred highways safety option (from the three options identified above), or indeed have any further commentary associated with the community benefits being proposed, please contact us at info@barclaygrange.co.m
Neighbourhood Plan
We will continue to promote Barclay Grange as part of the emerging Hertford Heath Neighbourhood Plan. The consultation exercise has reinforced our view that the proposals are preferable to the current options identified in terms of the sustainability of the site, as well as the socio economic and environmental benefits that it can deliver. Your feedback will help to demonstrate the value that the local community place on achieving new community facilities and public benefits from any new development in the village. Other proposals do not come close to matching the offer of Barclay Grange in this regard and we would welcome the support of the local community in making this clear to your Parish Councillors.
The Parish Council has instructed a company to produce a Strategic Environmental Assessment (SEA) that should assess the likely significant effects of the draft Neighbourhood Plan. As part of this assessment they are also required to consider any reasonable alternatives, which would include alternative sites to those currently proposed. Barclay Grange is one such site and we have written to the Parish Council to offer any assistance and information that they may require about our proposals in order to support with the assessment. We strongly believe that an objective and professional assessment that follows recognised methodologies will clearly identify the advantages of our site and proposals.
Where an SEA is required (as here), Government guidance states that this should be prepared and advertised at the same time as the consultation on the draft Neighbourhood Plan proposals. In this case, that did not occur, therefore the previous consultation on which the Parish Council place great reliance was not informed by this key information. We therefore fully expect that the Parish Council will carefully consider the outcome of the SEA once it is available to determine what implications it may have for the current draft of the neighbourhood plan.
By law the SEA report will also need to be advertised and we think that this will only be meaningful if people are given a further opportunity to comment on the neighbourhood plan proposals at the same time. To rely on the old consultation exercise that was not informed by the legally required SEA report would be deficient and would certainly not represent meaningful consultation. In our view this approach would substantially reduce the weight to be placed on the previous consultation exercise. We have written to the Parish Council seeking clarity on their next steps and await a response. We will provide further updates in due course.
To read more about the issues raised regarding how the Neighbourhood Plan consultation has been conducted, and to view a timeline of key milestones for this scheme and the Neighbourhood Plan, click here.