EMERGING CORE STRATEGY
- OBSERVATIONS BY ST ALBANS CIVIC SOCIETY
The observations below address the Core Strategy consultation document as published by the Council in July 2009.
CORE STRATEGIC OBJECTIVES
SO1 Much of the document is panglossian in tone. The first strategic objective is characteristic. It is not meaningful in itself, and is immediately contradicted by SO3 and the proposals to release up to 180 hectares of GB land for development (see table below). The Society proposes that honesty is the best policy, and that SO1 should be re-worded along the lines:
"SO1 - in order to achieve the development goals set out in the plan, the Council will seek the release up to 200 hectares of Green Belt land. The usual presumption against inappropriate development will however continue to apply on the diminished extent of GB land elsewhere in the District."
Green Belt land release
as proposed in the 2009 Emerging Core Strategy document
Development
Area in hectares
reference / comment
Housing - dwellings
100
Para 10.23
- services
?? (say 10)
Para 10.23 (school / shops)
Traveller sites
?? (say 1)
Para 10.48 proposes 52 additional pitches
Employment - E1
14
Para 11.17ff
- Rothamsted & BRE
?? (say 5)
-x-
- E4 Roehyde
14
-x-
- E5 Porters Wood
?? (say 5)
-x-
Shopping - SH4
?? (say 10)
Para 12.13 expansion of Colney Fields
Transport
?? (say 2)
Para 13.34 mini-P+R
- Link Road
?? (say 2)
A414 – M10 link road
Education
?? (say 10)
Para 14.5 new secondary
?? (say 5)
New primary
??
OaklandsCollege – doubtful status !!
Leisure
- Westminster Lodge
?? (say 1)
para 16.11
- Colney Hatch
?? (say 1)
-x-
- Hotel HT2
?? (say 5)
Para 16.22
TOTALS
128 (plus 57 ??)
SO3 – conflicts with SO1 (see above)
SO5 – is it realistic to describe St Albans as a 'regional' hub? If the reference is to the Eastern Region, is St Albans really on a level with Norwich, Cambridge, Colchester, etc?
SO6 – this is meaningless. Would one additional affordable unit count as 'providing more affordable homes'?
SO8 – if the intention is to promote the city centre, why does the core strategy propose a major new educational facility in the Green Belt remote from the city centre (Oaklands College at Smallford - para 14.5). Government funding for the development of this site has now been withdrawn and this should be recognised in the document.
These are not policies, merely directions of travel. The Inspector will recognise that they are vague, and they offer all sorts of loopholes for developers.
There is also serious dislocation between the history of the local authorities (at both County and District levels) closing a whole raft of community facilities, and the apparent desire to provide new community facilities. Whilst some of the long-established facilities may have been life-expired, their closure and disposal is effectively responsible for much of the deficit. We draw little comfort from intentions to improve community facilities, when there has been such a practical legacy of decline.
SO10 – what precisely is a transport 'Node' and can St Albans sustain such concept?
CORE STRATEGIC POLICIES
P7.1 Where are the policies on which to comment? It follows that 7.2 should say “The emerging policies will be based on:”
Despite the absence of policy detail, we make the following comments on the material presented in the rest of the document.
HOUSING
P8.12 The proposed housing location (AoS1) is remote from the city and in an unsustainable location. The removal of 100ha of GB is also in complete contradiction with Policy SO1. If there has to be additional housing, it would make most sense to locate it between the M1 and Hemel Hempstead.
There is a dislocation between accepting the loss of playing fields at BeaumontSchool, Nicholas Breakspear and King Harry Lane, whilst advocating more playing fields elsewhere.
EMPLOYMENT
P11.6 There is very little employment land, one reason being that in recent years permission has been given for housing on a significant number of historic employment sites. Despite policies in the local plan, the Council has failed to protect this land for employment purposes.
RETAIL
P12.1 A serious omission is that there is no policy to prevent loss of A1 to A3. It is essential to stop further loss of small retail units, particularly in the city centre.
P12.22 This is a nice sentiment, but in the absence of a written policy it is impossible to assess its potential effectiveness.
For retail – the Society favours development in Drovers Way behind St Peter's Street. Aboyne Lodge school should be retained.
The Alma Road / London Road (Evershed's) site should be used for housing / school.
Civic Centre South needs a cultural, civic and amenity space, even cinema, galleries, bowling, entertainment for all ages.
Department store is an outdated and outmoded concept. The essential requirement is to protect the existing retail (but see above) and complement the specialist shops. It is important to avoid creating separate retail areas that would draw trade from the primary St Peter's Street frontage.
TRANSPORT
P13.25 The 'inner' bus route should link City Station, London Road (Maltings), Sumpter Yard (for Cathedral and Verulamium Park), Abbey Station and Westminster Lodge (for sports centre and car park).
P13.26 Park and Ride is another misapplied concept. If adopted in St Albans, it would drive trade away to nearby centres that do not have park and ride. Where it has been successful, research has shown that it furthers car-based transport, at the expense of public transport. Furthermore, the potential park and ride sites are all in the Green Belt.
LEISURE etc
P16.21 The Society endorses the unfavourable view of hotels that cater for M25 trade. However, it is difficult to see any material difference in this regard between the Council's preferred site near M25 J22 and a hotel near M25 J21A.
The Society has noted that the City Vision project is proposing hotel development in St Michaels. This conflict with the Core Strategy needs to be resolved.
BUILT AND HISTORIC ENVIRONMENT
P17.1 The Society considers this sentiment in this paragraph is hypocritical, in view of the recent disbanding and dismembering of the Conservation and Design Team. In the light of this, the Society questions how it is going to protect the existing heritage (P17.10).
P17.11 Should also mention urban common land (e.g. Bernard's Heath, and Harpenden Common).
P17.13 The need to protect the skyline of the city is mentioned, but this is inadequate and should be given greater priority within the document.
GREEN INFRASTRUCTURE AND COUNTRYSIDE POLICIES (Ch18)
P18.4 It should be made absolutely clear that there will be no development on or of existing public open spaces, not just those 'spaces with high value audit scores', whatever this may be.
P18.11 The Society notes the view that management of visitor numbers will be a critical issue if nearby settlements are not to be overwhelmed: this is an issue of concern to the Council. The Society is also concerned that the scheme may require considerable parking areas, interpretation buildings with retail elements (to make money!), toilets, signs, and proliferation of general urban paraphernalia.
P18.17/18 The absence of a policy, or even mention, of urban trees is a serious omission. As anyone who has viewed the city from the top of the Clock Tower will see, the existing trees make a significant contribution to the urban environment and are deserving of proper recognition and protection in policy.
OBSERVATION ON THE PRESENTATION OF THE DOCUMENT
The printed version has a host of unnecessary, irrelevant and distracting images. The layout, particularly where combined with tables, is poor. It looks more like a public relations exercise than a professional and carefully considered presentation of a document that will serve as a statutory reference for the next twenty years.
THE CONSULTATION QUESTIONNAIRE
The Society will complete a copy of the Questionnaire. However, we have to express dismay at the simplistic and largely meaningless wording of the questions, and the false choices that are presented in certain places.
* * * * * * * * *
St Albans Civic Society (28 September 2009)
- OBSERVATIONS BY ST ALBANS CIVIC SOCIETY
The observations below address the Core Strategy consultation document as published by the Council in July 2009.
CORE STRATEGIC OBJECTIVES
SO1 Much of the document is panglossian in tone. The first strategic objective is characteristic. It is not meaningful in itself, and is immediately contradicted by SO3 and the proposals to release up to 180 hectares of GB land for development (see table below). The Society proposes that honesty is the best policy, and that SO1 should be re-worded along the lines:
"SO1 - in order to achieve the development goals set out in the plan, the Council will seek the release up to 200 hectares of Green Belt land. The usual presumption against inappropriate development will however continue to apply on the diminished extent of GB land elsewhere in the District."
Green Belt land release
as proposed in the 2009 Emerging Core Strategy document
Development
Area in hectares
reference / comment
Housing - dwellings
100
Para 10.23
- services
?? (say 10)
Para 10.23 (school / shops)
Traveller sites
?? (say 1)
Para 10.48 proposes 52 additional pitches
Employment - E1
14
Para 11.17ff
- Rothamsted & BRE
?? (say 5)
-x-
- E4 Roehyde
14
-x-
- E5 Porters Wood
?? (say 5)
-x-
Shopping - SH4
?? (say 10)
Para 12.13 expansion of Colney Fields
Transport
?? (say 2)
Para 13.34 mini-P+R
- Link Road
?? (say 2)
A414 – M10 link road
Education
?? (say 10)
Para 14.5 new secondary
?? (say 5)
New primary
??
OaklandsCollege – doubtful status !!
Leisure
- Westminster Lodge
?? (say 1)
para 16.11
- Colney Hatch
?? (say 1)
-x-
- Hotel HT2
?? (say 5)
Para 16.22
TOTALS
128 (plus 57 ??)
SO3 – conflicts with SO1 (see above)
SO5 – is it realistic to describe St Albans as a 'regional' hub? If the reference is to the Eastern Region, is St Albans really on a level with Norwich, Cambridge, Colchester, etc?
SO6 – this is meaningless. Would one additional affordable unit count as 'providing more affordable homes'?
SO8 – if the intention is to promote the city centre, why does the core strategy propose a major new educational facility in the Green Belt remote from the city centre (Oaklands College at Smallford - para 14.5). Government funding for the development of this site has now been withdrawn and this should be recognised in the document.
These are not policies, merely directions of travel. The Inspector will recognise that they are vague, and they offer all sorts of loopholes for developers.
There is also serious dislocation between the history of the local authorities (at both County and District levels) closing a whole raft of community facilities, and the apparent desire to provide new community facilities. Whilst some of the long-established facilities may have been life-expired, their closure and disposal is effectively responsible for much of the deficit. We draw little comfort from intentions to improve community facilities, when there has been such a practical legacy of decline.
SO10 – what precisely is a transport 'Node' and can St Albans sustain such concept?
CORE STRATEGIC POLICIES
P7.1 Where are the policies on which to comment? It follows that 7.2 should say “The emerging policies will be based on:”
Despite the absence of policy detail, we make the following comments on the material presented in the rest of the document.
HOUSING
P8.12 The proposed housing location (AoS1) is remote from the city and in an unsustainable location. The removal of 100ha of GB is also in complete contradiction with Policy SO1. If there has to be additional housing, it would make most sense to locate it between the M1 and Hemel Hempstead.
There is a dislocation between accepting the loss of playing fields at BeaumontSchool, Nicholas Breakspear and King Harry Lane, whilst advocating more playing fields elsewhere.
EMPLOYMENT
P11.6 There is very little employment land, one reason being that in recent years permission has been given for housing on a significant number of historic employment sites. Despite policies in the local plan, the Council has failed to protect this land for employment purposes.
RETAIL
P12.1 A serious omission is that there is no policy to prevent loss of A1 to A3. It is essential to stop further loss of small retail units, particularly in the city centre.
P12.22 This is a nice sentiment, but in the absence of a written policy it is impossible to assess its potential effectiveness.
For retail – the Society favours development in Drovers Way behind St Peter's Street. Aboyne Lodge school should be retained.
The Alma Road / London Road (Evershed's) site should be used for housing / school.
Civic Centre South needs a cultural, civic and amenity space, even cinema, galleries, bowling, entertainment for all ages.
Department store is an outdated and outmoded concept. The essential requirement is to protect the existing retail (but see above) and complement the specialist shops. It is important to avoid creating separate retail areas that would draw trade from the primary St Peter's Street frontage.
TRANSPORT
P13.25 The 'inner' bus route should link City Station, London Road (Maltings), Sumpter Yard (for Cathedral and Verulamium Park), Abbey Station and Westminster Lodge (for sports centre and car park).
P13.26 Park and Ride is another misapplied concept. If adopted in St Albans, it would drive trade away to nearby centres that do not have park and ride. Where it has been successful, research has shown that it furthers car-based transport, at the expense of public transport. Furthermore, the potential park and ride sites are all in the Green Belt.
LEISURE etc
P16.21 The Society endorses the unfavourable view of hotels that cater for M25 trade. However, it is difficult to see any material difference in this regard between the Council's preferred site near M25 J22 and a hotel near M25 J21A.
The Society has noted that the City Vision project is proposing hotel development in St Michaels. This conflict with the Core Strategy needs to be resolved.
BUILT AND HISTORIC ENVIRONMENT
P17.1 The Society considers this sentiment in this paragraph is hypocritical, in view of the recent disbanding and dismembering of the Conservation and Design Team. In the light of this, the Society questions how it is going to protect the existing heritage (P17.10).
P17.11 Should also mention urban common land (e.g. Bernard's Heath, and Harpenden Common).
P17.13 The need to protect the skyline of the city is mentioned, but this is inadequate and should be given greater priority within the document.
GREEN INFRASTRUCTURE AND COUNTRYSIDE POLICIES (Ch18)
P18.4 It should be made absolutely clear that there will be no development on or of existing public open spaces, not just those 'spaces with high value audit scores', whatever this may be.
P18.11 The Society notes the view that management of visitor numbers will be a critical issue if nearby settlements are not to be overwhelmed: this is an issue of concern to the Council. The Society is also concerned that the scheme may require considerable parking areas, interpretation buildings with retail elements (to make money!), toilets, signs, and proliferation of general urban paraphernalia.
P18.17/18 The absence of a policy, or even mention, of urban trees is a serious omission. As anyone who has viewed the city from the top of the Clock Tower will see, the existing trees make a significant contribution to the urban environment and are deserving of proper recognition and protection in policy.
OBSERVATION ON THE PRESENTATION OF THE DOCUMENT
The printed version has a host of unnecessary, irrelevant and distracting images. The layout, particularly where combined with tables, is poor. It looks more like a public relations exercise than a professional and carefully considered presentation of a document that will serve as a statutory reference for the next twenty years.
THE CONSULTATION QUESTIONNAIRE
The Society will complete a copy of the Questionnaire. However, we have to express dismay at the simplistic and largely meaningless wording of the questions, and the false choices that are presented in certain places.
* * * * * * * * *
St Albans Civic Society (28 September 2009)