The TRDC Local Plan Public Consultation. It's the time to have your Say!
Before reading on read our Local Plan Fact or Fiction sheet here....
| local_plan_fact_or_fiction.pdf |
Simple guide to responding to the consultation
If you go online to view the TRDC consultation documentation and consider registering with TRDC and responding through the *TRDC Online Consultation Portal https://www.threerivers.gov.uk/egcl-page/new-local-plan then fine - go ahead - good luck. If you find the going difficult you can skip the questions we don’t address here. However, you may prefer to respond by email: localplanconsult@threerivers.gov.uk or write to: Economic & Sustainable Development, Three Rivers District Council, Three Rivers House, Northway, Rickmansworth, WD3 1RL. (Remember to include your name & address & site numbers).
Beware: the consultation is divided into two parts; part 1 is TRDC Preferred Policy Options & part 2 is Sites for Potential Allocation. In reality, we believe most Croxley Green residents will only want to look at and comment on a few of the potential development sites in and around Croxley Green.
HOWEVER, The CGRA considers it vital that residents comment on key TRDC Preferred Policy Options because we all want to see sensible planning for new homes where the space is available. The Local Plan and all your comments have to go to the Government’s planning inspector for approval. Thousands of responses from local residents will make TRDC and the inspector stand up and take notice.
For the majority of residents, responding to the consultation will be a daunting task BUT to help you consider and comment on Policies we have summarised (below) comments on six TRDC Policy areas / TRDC online questions that we consider need strengthening.
Part 1.TRDC Preferred Policy Options
Question 1. Do you agree with the Council’s proposed stance of not complying with the Government’s Standard Method for calculating the District’s housing need figure (due to the constraints of the District), which means that the Council would not fully meet the residual housing target?
Suggested response: We note TRDC has decided not to comply with the Government’s Standard Method for calculating housing need (by initially planning for a figure that is 1,700 dwellings below the Government target). Whilst we support this approach we believe TRDC has not gone far enough and that the housing requirement should be reduced considerably a) in accordance with more up to date Office of National Statistics data and b) because, as recently as May 2021, the Ministry of Housing Communities & Local Government stated that: “ Local Housing Need is simply a measure of need and we recognise not everywhere will be able to meet their housing need in full - for example, where available land is constrained due to Green Belt and an area therefore has to plan for fewer homes.” Three Rivers is a district of which 76% is Green Belt. This considerable constraint has to be factored into any algorithm calculating Local Housing need before reference is made to any review of the quality of Three River’s Green Belt.
*THIS IS THE IMPORTANT POINT. Our MP is extremely quiet on this - he represents us but doesn’t want to rock the government boat. Consider sending your response to him so he can lobby the government at: https://www.gaganmohindra.org.uk/contact
*Do repeat your concerns to your local district Councillors so that they can send the message up their chain of command: https://www.threerivers.gov.uk/egcl-page/ward-councillors
Question 2. Do you think the Preferred Policy Option for meeting the presumption in favour of sustainable development is the right approach? Should we have considered alternative options?
Suggested response: There is a need for infrastructure requirements to be in place to support new development before it commences. The TRDC assessment states current infrastructure can’t support many of the listed sites and that enhancing local infrastructure to support development isn’t feasible. Each site needs to be re-evaluated to ensure infrastructure can, feasibly, be provided.
TRDC has declared a Climate Emergency; however, there is no reference to climate change in the ‘Vision for Three Rivers’. The Vision has to be amended as the Climate Emergency has to be given prominence over everything the Council does.
A major Strategic Objective for TRDC should be to protect and enhance Green Belt and rural areas.
Question 5. Do you think the Preferred Policy Option for Affordable Housing the right approach?
Suggested response: The Council fails to acknowledge the real need, demands and preferences in Three Rivers for social housing and starter homes, which should be income-related. The definition of “affordable” housing is meaningless in a high-cost area such as Three Rivers and there should be a more detailed statement of the need for social housing and starter homes.
Local circumstances mean that TRDC needs to ensure that smaller sites (less than 10 dwellings) will have a crucial role in the delivery of affordable housing.
Question 16. Do you think the Preferred Policy Option for Flood Risk and Water Resources is the right approach?
Suggested response: The key role of our three rivers and tributaries as chalk stream habitats is not covered in Polices. These are ‘priority habitats’ under Section 41 of the Natural Environment & Rural Communities Act 2006 and should therefore be emphasised in polices and cross referenced to Policy Options on Green & Blue Infrastructure and Biodiversity.
Question 17: Do you think the Preferred Policy Option for Green Belt is the right approach? If not, please identify how this option could be changed.
Suggested response: We want TRDC to uphold Green Belt policy and to resist the inflated housing numbers (as per Q.1 response) especially as our Green Belt is the London Metropolitan Green Belt and its primary purpose is to “check the unrestricted sprawl of large built-up areas”, which is London. We want to see TRDC taking account of Green Belt reviews in adjoining local authorities to secure a strategic and consistent approach.
Question 28: Do think the Preferred Policy Option for Parking is the right approach? If not, please identify how the option could be changed.
Suggested response: We believe parking standards have been inadequate for the actual levels of car ownership in new residential developments. As a result, the completion of large-scale schemes has been followed by multiple problems of congestion and road safety. We therefore suggest that the proposed standards for the C3 Use Class are too low and too complicated. The minimum per dwelling standards should be raised as follows: I bedroom dwellings-1 space; 2 & 3 bedroom - 2 spaces; 4 or more bedroom -3 spaces.
Part 2. Sites
We have provided information on sites included in the draft Plan, as well as on the massive Little Green Lane /Rousebarn Lane site that was removed from the draft Plan just prior to publication. We consider this site will come back into consideration so its vital you comment on this site too (do this by email to localplanconsult@threerivers.gov.uk (remember to use the site number and to include your name and address).
Remember, the allocation of thousands of new homes in a Local Plan requires infrastructure support but:
● The draft Plan provides no details as to where new infant, junior and senior schools will go (they will go on Green Belt when already 80% of new development is due to be allocated on Green Belt).
● There is already huge pressure on water supply and a much needed new reservoir for the area (more Green Belt?) is 40+ years away from being online.
● Our Rivers are used as open sewers in times of high rainfall and at other times convenient to privatised water companies. In addition, it appears our old network of sewage works and collapsing sewers aren’t coping with current usage and demand.
● No new roads planned but a significant increase in vehicles and parking requirements can be expected.
● No details of extra medical provision in an area already experiencing very high doctor / patient ratios.
Do consider these practical points when considering the following sites:
If you go online to view the TRDC consultation documentation and consider registering with TRDC and responding through the *TRDC Online Consultation Portal https://www.threerivers.gov.uk/egcl-page/new-local-plan then fine - go ahead - good luck. If you find the going difficult you can skip the questions we don’t address here. However, you may prefer to respond by email: localplanconsult@threerivers.gov.uk or write to: Economic & Sustainable Development, Three Rivers District Council, Three Rivers House, Northway, Rickmansworth, WD3 1RL. (Remember to include your name & address & site numbers).
Beware: the consultation is divided into two parts; part 1 is TRDC Preferred Policy Options & part 2 is Sites for Potential Allocation. In reality, we believe most Croxley Green residents will only want to look at and comment on a few of the potential development sites in and around Croxley Green.
HOWEVER, The CGRA considers it vital that residents comment on key TRDC Preferred Policy Options because we all want to see sensible planning for new homes where the space is available. The Local Plan and all your comments have to go to the Government’s planning inspector for approval. Thousands of responses from local residents will make TRDC and the inspector stand up and take notice.
For the majority of residents, responding to the consultation will be a daunting task BUT to help you consider and comment on Policies we have summarised (below) comments on six TRDC Policy areas / TRDC online questions that we consider need strengthening.
Part 1.TRDC Preferred Policy Options
Question 1. Do you agree with the Council’s proposed stance of not complying with the Government’s Standard Method for calculating the District’s housing need figure (due to the constraints of the District), which means that the Council would not fully meet the residual housing target?
Suggested response: We note TRDC has decided not to comply with the Government’s Standard Method for calculating housing need (by initially planning for a figure that is 1,700 dwellings below the Government target). Whilst we support this approach we believe TRDC has not gone far enough and that the housing requirement should be reduced considerably a) in accordance with more up to date Office of National Statistics data and b) because, as recently as May 2021, the Ministry of Housing Communities & Local Government stated that: “ Local Housing Need is simply a measure of need and we recognise not everywhere will be able to meet their housing need in full - for example, where available land is constrained due to Green Belt and an area therefore has to plan for fewer homes.” Three Rivers is a district of which 76% is Green Belt. This considerable constraint has to be factored into any algorithm calculating Local Housing need before reference is made to any review of the quality of Three River’s Green Belt.
*THIS IS THE IMPORTANT POINT. Our MP is extremely quiet on this - he represents us but doesn’t want to rock the government boat. Consider sending your response to him so he can lobby the government at: https://www.gaganmohindra.org.uk/contact
*Do repeat your concerns to your local district Councillors so that they can send the message up their chain of command: https://www.threerivers.gov.uk/egcl-page/ward-councillors
Question 2. Do you think the Preferred Policy Option for meeting the presumption in favour of sustainable development is the right approach? Should we have considered alternative options?
Suggested response: There is a need for infrastructure requirements to be in place to support new development before it commences. The TRDC assessment states current infrastructure can’t support many of the listed sites and that enhancing local infrastructure to support development isn’t feasible. Each site needs to be re-evaluated to ensure infrastructure can, feasibly, be provided.
TRDC has declared a Climate Emergency; however, there is no reference to climate change in the ‘Vision for Three Rivers’. The Vision has to be amended as the Climate Emergency has to be given prominence over everything the Council does.
A major Strategic Objective for TRDC should be to protect and enhance Green Belt and rural areas.
Question 5. Do you think the Preferred Policy Option for Affordable Housing the right approach?
Suggested response: The Council fails to acknowledge the real need, demands and preferences in Three Rivers for social housing and starter homes, which should be income-related. The definition of “affordable” housing is meaningless in a high-cost area such as Three Rivers and there should be a more detailed statement of the need for social housing and starter homes.
Local circumstances mean that TRDC needs to ensure that smaller sites (less than 10 dwellings) will have a crucial role in the delivery of affordable housing.
Question 16. Do you think the Preferred Policy Option for Flood Risk and Water Resources is the right approach?
Suggested response: The key role of our three rivers and tributaries as chalk stream habitats is not covered in Polices. These are ‘priority habitats’ under Section 41 of the Natural Environment & Rural Communities Act 2006 and should therefore be emphasised in polices and cross referenced to Policy Options on Green & Blue Infrastructure and Biodiversity.
Question 17: Do you think the Preferred Policy Option for Green Belt is the right approach? If not, please identify how this option could be changed.
Suggested response: We want TRDC to uphold Green Belt policy and to resist the inflated housing numbers (as per Q.1 response) especially as our Green Belt is the London Metropolitan Green Belt and its primary purpose is to “check the unrestricted sprawl of large built-up areas”, which is London. We want to see TRDC taking account of Green Belt reviews in adjoining local authorities to secure a strategic and consistent approach.
Question 28: Do think the Preferred Policy Option for Parking is the right approach? If not, please identify how the option could be changed.
Suggested response: We believe parking standards have been inadequate for the actual levels of car ownership in new residential developments. As a result, the completion of large-scale schemes has been followed by multiple problems of congestion and road safety. We therefore suggest that the proposed standards for the C3 Use Class are too low and too complicated. The minimum per dwelling standards should be raised as follows: I bedroom dwellings-1 space; 2 & 3 bedroom - 2 spaces; 4 or more bedroom -3 spaces.
Part 2. Sites
We have provided information on sites included in the draft Plan, as well as on the massive Little Green Lane /Rousebarn Lane site that was removed from the draft Plan just prior to publication. We consider this site will come back into consideration so its vital you comment on this site too (do this by email to localplanconsult@threerivers.gov.uk (remember to use the site number and to include your name and address).
Remember, the allocation of thousands of new homes in a Local Plan requires infrastructure support but:
● The draft Plan provides no details as to where new infant, junior and senior schools will go (they will go on Green Belt when already 80% of new development is due to be allocated on Green Belt).
● There is already huge pressure on water supply and a much needed new reservoir for the area (more Green Belt?) is 40+ years away from being online.
● Our Rivers are used as open sewers in times of high rainfall and at other times convenient to privatised water companies. In addition, it appears our old network of sewage works and collapsing sewers aren’t coping with current usage and demand.
● No new roads planned but a significant increase in vehicles and parking requirements can be expected.
● No details of extra medical provision in an area already experiencing very high doctor / patient ratios.
Do consider these practical points when considering the following sites:
Rousebarn Lane Site
Site ref. CFS21. Assessed by TRDC as suitable, available, achievable and developable but withdrawn by TRDC Councillors just prior to consultation on the grounds it would cause particular harm to the existing community and residents’ quality of life without providing compensating benefits to the community. However, its removal means TRDC falls some way short of the target set for completing its Local Plan. Therefore, it could feasibly be put back into the final Plan.
The site is in the Parish of Sarratt whose Parish boundary with Croxley Green runs a long Little Green Lane. It has a Right of Way running west to east connecting Dell Wood to Cassiobury Park woods. It is a section of the nationally acclaimed Croxley Green Boundary Walk.
So how would 800 new homes be accessed by road?
Can you envisage how Little Green Lane would have to be significantly widened to allow for the extra connectivity and increase in vehicles /traffic? Existing residential roads off of Little Green Lane would become through roads for the new development.
Can you imagine Rousebarn Lane remaining as a no through Lane with no vehicular access to Chandlers Cross and on to Watford / M25 / M1 junctions?
A further primary school would be needed? Would this be onsite or would a further release of Green Belt be required.
Does the site fulfil the requirements of Green Belt? Well, the Green Belt assessment of the site undertaken for TRDC scores it as only Moderate High impact on the Green Belt. Perhaps your view on the relatively low score given in respect of preventing neighbouring towns from merging and impact on adjacent Green Belt differs from the assessment (as per below extract)?
Remember - this site is not within the borders of Croxley Green Parish and if developed the boundary of Croxley Green would need to be extended. Would the powers that be merely seek to extend the boundary for this site or extend the boundary generally to the north and east to accommodate future development?
So how would 800 new homes be accessed by road?
Can you envisage how Little Green Lane would have to be significantly widened to allow for the extra connectivity and increase in vehicles /traffic? Existing residential roads off of Little Green Lane would become through roads for the new development.
Can you imagine Rousebarn Lane remaining as a no through Lane with no vehicular access to Chandlers Cross and on to Watford / M25 / M1 junctions?
A further primary school would be needed? Would this be onsite or would a further release of Green Belt be required.
Does the site fulfil the requirements of Green Belt? Well, the Green Belt assessment of the site undertaken for TRDC scores it as only Moderate High impact on the Green Belt. Perhaps your view on the relatively low score given in respect of preventing neighbouring towns from merging and impact on adjacent Green Belt differs from the assessment (as per below extract)?
Remember - this site is not within the borders of Croxley Green Parish and if developed the boundary of Croxley Green would need to be extended. Would the powers that be merely seek to extend the boundary for this site or extend the boundary generally to the north and east to accommodate future development?
Red Cross Centre
Site ref: CG65
The Parish Council considers this building to be a community asset that should not be developed for commercial purposes.
The Parish Council considers this building to be a community asset that should not be developed for commercial purposes.
Sycamore Road Site
Site CFS19
This is the amenity green adjacent to the flats at Sycamore Road. The freeholder of the flats has wanted planning permission to build more dwellings on this amenity site for many years but prior planning applications have been rejected by the TRDC Planning Committee, primarily because this is a much needed amenity space for flat owners. The planning application referred to below in TRDCs description was rejected.
This is the amenity green adjacent to the flats at Sycamore Road. The freeholder of the flats has wanted planning permission to build more dwellings on this amenity site for many years but prior planning applications have been rejected by the TRDC Planning Committee, primarily because this is a much needed amenity space for flat owners. The planning application referred to below in TRDCs description was rejected.
Station Car Park
Site CFS20
We presume development of this site would be to provide flats over and above the station, platform and car parking areas.
Transport for London have been seeking to maximise land use at other stations, notably at Canons Park and Rayners Lane stations but the primary issue has been the paucity of car parking provision.
Car parking is a big issue in the centre of Croxley Green and the likelihood of reduced station parking and minimal parking for new flat owners will have a significant impact for residential parking for new and existing residents
We presume development of this site would be to provide flats over and above the station, platform and car parking areas.
Transport for London have been seeking to maximise land use at other stations, notably at Canons Park and Rayners Lane stations but the primary issue has been the paucity of car parking provision.
Car parking is a big issue in the centre of Croxley Green and the likelihood of reduced station parking and minimal parking for new flat owners will have a significant impact for residential parking for new and existing residents
Cockaygne Site (Adjacent to Loudwater Lane North Croxley)
The following site is deemed undeliverable by TRDC:
Site: PSC51
Availability (ownership/legal issues)
The site has multiple owners (14 different titles). Representations from some of the landowners confirm that they are not willing to promote their land for development. There is no evidence that the site is available for development. The site is considered to be unavailable.
Achievability
The site was promoted for the previous Local Plan. The site has not been resubmitted for consideration to this Local Plan. Subsequently there is no evidence that the site is achievable.
Site: PSC51
Availability (ownership/legal issues)
The site has multiple owners (14 different titles). Representations from some of the landowners confirm that they are not willing to promote their land for development. There is no evidence that the site is available for development. The site is considered to be unavailable.
Achievability
The site was promoted for the previous Local Plan. The site has not been resubmitted for consideration to this Local Plan. Subsequently there is no evidence that the site is achievable.
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Want some background information (in simple CGRA words) to guide you?
What is the Local Plan?
Our District Council is consulting with us on its proposed policies and sites for new homes and businesses that meet a criteria of availability, deliverability and sustainability. The Council is required to adhere to a figure for new homes that is set by the Government. This figure is for 12,624 new homes to 2038 (630 new homes per year).
What is the main, underlying, problem?
This figure should be adjusted down for local considerations and local constraints. The government, via ministerial statements, has stated this but it isn't enshrined in the National Planning Policy Framework “NPPF” that Council officers are bound to work with. It’s a classic non-workable equation where the Government stresses its desire to save, save, save Green Belt whilst also setting a 300,000 annual build, build, build target for new homes. The Government states it doesn’t want to force new homes to be built on green space (note - it never seems to refer to Green Belt) but it's a fact that our district is 76% Green Belt and the Council’s register of available brownfield land can only fit in about 1,500 homes. The CGRA acknowledges that steady sustainable growth with new homes, business and infrastructure growing hand in hand is required (and has been ongoing) but the threefold leap in the Government’s target for our area is unsustainable and will serve to destroy the very essence of why we all love living around here.
The Target?
The ONS figures that fit into a government algorithm that equates to the 300,000 homes pa for England target are from 2014 and based on the 2011 Census. You may think this is out of date and that significant factors over the past couple of years merit downward adjustment of the target but…. that’s party politics.
Affordable homes?
Affordable housing provision (costing, say, 20% of market cost) is a misnomer in an area with some of the highest land and property prices in the country. It doesn’t follow that building swathes of new homes (whether they be 2,3,4 or 5 bedroom homes) in the district will bring the prices down, making them in any way affordable.
The figures don’t add up!
The Council states at the outset of its consultation that it is not possible for it to provide the Government’s target for additional homes without causing disproportionate harm to existing communities as a result of building on much-needed accessible open space. However, as things stand, when the Council’s Plan, with a figure lower than the Government’s figure, is sent for examination, the Government’s Planning Inspectorate will seek to ensure the Government’s figure is met. The Inspector will look at the Council’s workings and propose which Green Belt sites should be inserted to the Plan to make the Plan “sustainable”,”sound” and add up.
Why you should be worried?
The reality is that what we’re being consulted on now is nowhere near what is going to be in the final version of the Plan and the Council has options that include significantly increasing the size of our individual communities or even shoehorning in a new, 3,000 to 5,000 home community somewhere into our small district. Really? Yes, one of the 70+ documents provided by TRDC is the TRDC Green Belt Study - New settlement analysis: https://www.threerivers.gov.uk/download?id=50012
Almost every site offered up by landowners and developers remains “on the table” for inclusion in a Local Plan that seeks land for homes at a rate that is more than 3 times the rate of the prior Local Plan. Over 85% of this is likely to be on Green Belt.
What can residents do?
First - respond to the consultation in a way that grabs the attention of our Council and can be used by the Council to push back against a) an Inspector who will scrutinise the Local Plan and b) Central government which has set the figure for housing need:
https://www.threerivers.gov.uk/egcl-page/new-local-plan
Second - sign the online petition - Build the Homes We Need whilst Protecting Three Rivers Green Belt:
https://www.change.org/p/three-rivers-district-council-build-the-homes-we-need-whilst-protecting-three-rivers-green-belt?utm_content=cl_sharecopy_29615169_en-GB%3A4&recruiter=1213377546&utm_source=share_petition&utm_medium=copylink&utm_campaign=share_petition
Third - reiterate concerns highlighted below under “what do we want” with your MP:
https://www.gaganmohindra.org.uk/contact
Fourth - repeat your concerns to your local district Councillors so that they can send the message up their chain of command:
https://www.threerivers.gov.uk/egcl-page/ward-councillors
What can the Resident Association do?
What the CGRA can do that the District Council can’t (or finds hard to do for a variety of reasons - some of them party political) is to look at the bigger picture and help to sway opinion that will change the guidance that central Government provides to Local Planning Authorities / District Councils.
To start this, two years ago a Three Rivers Joint Residents’ Association “TRJRA” was formed by local Residents’ Associations. This pooling of “talent” helped to amplify the voices of local residents and led to action planning which we have been spreading throughout our community, to our Councillors, our MPs and neighbouring areas. Our voices are getting louder. Look at the recent Chesham / Amersham bi-election result. The swing away from the Government on a supposedly safe seat was huge and, according to many political commentators, was largely down to Government planning to build in our countryside.
What do we want:
It’s clear that council Officers are working from NPPF guidance text and that recent ministerial ambiguous missives have to be enshrined in “guidance” before they can be relied upon. So , we want the Government to utilise more accurate, up to date data, for the calculation of housing need and we want to see local constraints, such as Green Belt, factored into calculations of what can actually be delivered.
In short:
A. the 2014 ONS figures are used by the Government because they fit into the algorithm that produces the 300,000 per year new housing in the Tory manifesto. It’s crazy that year by year statistics are not being used as they should be to predict population growth - particularly in view of what has happened in the past couple of years.
B. Green Belt /AONBs etc should be properly identified as significant constraints to development. It’s ambiguous and disingenuous of the Government to say it absolutely wants to protect Green Belt on the one hand and, on the other, force local authorities to allow building all over it.
We need to ensure change happens. We need to be in the faces of district & county Councillors, MPs and Government. We need our Council to be talking to other home county authorities and stirring it with MPs and Government.
Resident Association Actions:
What is the Local Plan?
Our District Council is consulting with us on its proposed policies and sites for new homes and businesses that meet a criteria of availability, deliverability and sustainability. The Council is required to adhere to a figure for new homes that is set by the Government. This figure is for 12,624 new homes to 2038 (630 new homes per year).
What is the main, underlying, problem?
This figure should be adjusted down for local considerations and local constraints. The government, via ministerial statements, has stated this but it isn't enshrined in the National Planning Policy Framework “NPPF” that Council officers are bound to work with. It’s a classic non-workable equation where the Government stresses its desire to save, save, save Green Belt whilst also setting a 300,000 annual build, build, build target for new homes. The Government states it doesn’t want to force new homes to be built on green space (note - it never seems to refer to Green Belt) but it's a fact that our district is 76% Green Belt and the Council’s register of available brownfield land can only fit in about 1,500 homes. The CGRA acknowledges that steady sustainable growth with new homes, business and infrastructure growing hand in hand is required (and has been ongoing) but the threefold leap in the Government’s target for our area is unsustainable and will serve to destroy the very essence of why we all love living around here.
The Target?
The ONS figures that fit into a government algorithm that equates to the 300,000 homes pa for England target are from 2014 and based on the 2011 Census. You may think this is out of date and that significant factors over the past couple of years merit downward adjustment of the target but…. that’s party politics.
Affordable homes?
Affordable housing provision (costing, say, 20% of market cost) is a misnomer in an area with some of the highest land and property prices in the country. It doesn’t follow that building swathes of new homes (whether they be 2,3,4 or 5 bedroom homes) in the district will bring the prices down, making them in any way affordable.
The figures don’t add up!
The Council states at the outset of its consultation that it is not possible for it to provide the Government’s target for additional homes without causing disproportionate harm to existing communities as a result of building on much-needed accessible open space. However, as things stand, when the Council’s Plan, with a figure lower than the Government’s figure, is sent for examination, the Government’s Planning Inspectorate will seek to ensure the Government’s figure is met. The Inspector will look at the Council’s workings and propose which Green Belt sites should be inserted to the Plan to make the Plan “sustainable”,”sound” and add up.
Why you should be worried?
The reality is that what we’re being consulted on now is nowhere near what is going to be in the final version of the Plan and the Council has options that include significantly increasing the size of our individual communities or even shoehorning in a new, 3,000 to 5,000 home community somewhere into our small district. Really? Yes, one of the 70+ documents provided by TRDC is the TRDC Green Belt Study - New settlement analysis: https://www.threerivers.gov.uk/download?id=50012
Almost every site offered up by landowners and developers remains “on the table” for inclusion in a Local Plan that seeks land for homes at a rate that is more than 3 times the rate of the prior Local Plan. Over 85% of this is likely to be on Green Belt.
What can residents do?
First - respond to the consultation in a way that grabs the attention of our Council and can be used by the Council to push back against a) an Inspector who will scrutinise the Local Plan and b) Central government which has set the figure for housing need:
https://www.threerivers.gov.uk/egcl-page/new-local-plan
Second - sign the online petition - Build the Homes We Need whilst Protecting Three Rivers Green Belt:
https://www.change.org/p/three-rivers-district-council-build-the-homes-we-need-whilst-protecting-three-rivers-green-belt?utm_content=cl_sharecopy_29615169_en-GB%3A4&recruiter=1213377546&utm_source=share_petition&utm_medium=copylink&utm_campaign=share_petition
Third - reiterate concerns highlighted below under “what do we want” with your MP:
https://www.gaganmohindra.org.uk/contact
Fourth - repeat your concerns to your local district Councillors so that they can send the message up their chain of command:
https://www.threerivers.gov.uk/egcl-page/ward-councillors
What can the Resident Association do?
What the CGRA can do that the District Council can’t (or finds hard to do for a variety of reasons - some of them party political) is to look at the bigger picture and help to sway opinion that will change the guidance that central Government provides to Local Planning Authorities / District Councils.
To start this, two years ago a Three Rivers Joint Residents’ Association “TRJRA” was formed by local Residents’ Associations. This pooling of “talent” helped to amplify the voices of local residents and led to action planning which we have been spreading throughout our community, to our Councillors, our MPs and neighbouring areas. Our voices are getting louder. Look at the recent Chesham / Amersham bi-election result. The swing away from the Government on a supposedly safe seat was huge and, according to many political commentators, was largely down to Government planning to build in our countryside.
What do we want:
It’s clear that council Officers are working from NPPF guidance text and that recent ministerial ambiguous missives have to be enshrined in “guidance” before they can be relied upon. So , we want the Government to utilise more accurate, up to date data, for the calculation of housing need and we want to see local constraints, such as Green Belt, factored into calculations of what can actually be delivered.
In short:
A. the 2014 ONS figures are used by the Government because they fit into the algorithm that produces the 300,000 per year new housing in the Tory manifesto. It’s crazy that year by year statistics are not being used as they should be to predict population growth - particularly in view of what has happened in the past couple of years.
B. Green Belt /AONBs etc should be properly identified as significant constraints to development. It’s ambiguous and disingenuous of the Government to say it absolutely wants to protect Green Belt on the one hand and, on the other, force local authorities to allow building all over it.
We need to ensure change happens. We need to be in the faces of district & county Councillors, MPs and Government. We need our Council to be talking to other home county authorities and stirring it with MPs and Government.
Resident Association Actions:
- the TRJRA has petitioned the district council for the district (on Change.org) rejecting the draft Local Plan as it will do too much damage to Green Belt.
- The TRJRA will submit a joint residents’ association submission on TRDC Local Plan related policies.
- There will be area specific responses from individual resident associations.
- We will work with our own district Cllrs to ensure everything can be done to create a Local Plan that takes local constraints into account.
- Get residents to respond to consultation. Lib Dems have muddied the water in withdrawing the big Rousebarn Lane green belt site from the Plan. The reasons for doing this are not that robust (in Planning terms) so this site is very much still in play. Developing the Croxley Underground station will potentially create vehicle parking issues requiring controls etc.
- Deliver consultation response postcards to every home in Croxley Green.
- Guidance on our website will refer to specific TRDC policies that we consider should be amended as well as to specific sites in and around Croxley Green (which are the primary cause of residents’ responses to Local Plan consultation).
CGRA Consultation response cards. Down load here.
| cgra-trpostcard-v1-draft_-_20210622.pdf |
