Planning and Economic Development
Claire May MSc MRTPI
Your Reference:
Head of Planning Policy & Projects
Our Reference: HLP/DTC
Three Rivers District Council
Contact: Mark Silverman
Three Rivers House
Extension: 4300
Northway
Date: 31 January 2020
Rickmansworth
Herts, WD3 1RL
Dear Ms May
Hertsmere Local Plan
Hertsmere Borough Council is currently progressing work on its own Local Plan which will cover
the period from 2018 to 2036.
As part of the duty to cooperate process, we have been actively engaging with all of our
neighbours and stakeholders to consider how Hertsmere will meet its own identified housing and
employment needs. The standard national methodology for assessing housing need has resulted
in an annual requirement of 750 homes per annum (incorporating a 5% buffer, as required by the
NPPF) or 13,500 homes over the plan period. By comparison, our current Local Plan which was
adopted 2013, has an annual housing requirement of 266 homes. That Plan is now more than
five years old and therefore deemed to be ‘out of date’ in determining our future strategic growth
requirements.
We recognise that there is an agreement in principle to progress a joint plan for the South West
Herts Housing Market Area, which would involve a comprehensive and comparative assessment
of Green Belt land. Clearly this will not be in place in time to inform our new Local Plan and there
remains a need for Hertsmere to bring forward this new plan without delay.
Following
a Call for Sites, we have consulted on a Potential Sites for Housing and Employment
document which identified and summarised the site proposals initially put forward by landowners
and developers. Hertsmere’s current housing and employment land capacity is considered to be
solely that which can be developed on previously developed land and includes all sources on land
not covered by Green Belt designation. We also recognise that there is greater emphasis in the
NPPF on making effective use of land (chapter 11) and maximising densities (chapter 13) as a
preliminary requirement prior to assessing where Green Belt land might be taken and whether
exceptional circumstances exist for doing so. Given these requirements and to ensure that
previously developed land is maximised, we have set out to:
1) Review the housing densities and capacities of all potential sites located within major
settlement boundaries, and applying a significant uplift in the average density of residential
development in accordance with paragraph 123 of the NPPF.
2) Assess the utilisation of local vacant housing stock as a source of untapped brownfield housing
supply.
3) Review the achievability and deliverability of Hertsmere’s own land assets.
4) Contact owners/occupiers of major brownfields sites who have not yet submitted any of their
land holdings.
Our Housing and Economic Land Availability Assessment (HELAA), published in 2019, points to a
capacity of less than 2,500 homes on previously developed land. This includes an allowance for
windfall development and existing commitments. We are hopeful that around two-thirds of our
employment requirement of over 25ha of employment can be accommodated within land which
has previously been safeguarded for such purposes in our current Local Plan.
There is therefore a very significant shortfall between the potential housing capacity of
Hertsmere’s previously developed land and the level of identified need, as well as a clear deficit of
land required to meet employment needs over the plan period. As an authority with almost 80%
of its area designated as Green Belt, we are therefore asking you whether your authority is able to
accommodate some of the growth shortfall identified within Hertsmere. A similar request has also
been sent to all neighbouring authorities and other authorities within our HMA.
We are intending to arrange a Duty to Co-operate workshop in due course to discuss our
emerging plan and potential cross boundary issues arising, and will be in contact again with more
details about this event. In the meantime, I would be grateful for a response to this letter at the
earliest opportunity.
If you have any queries relating to the above request, please do not hesitate to get in contact.
Yours sincerely
Laura Wood
Planning Strategy Manager