The Dacorum Borough Council Local Plan

Tring in Transition has played a significant role in discussing and shaping the DBC's Local Plan as it relates to Tring.



DBC Local Plan

TinT made substantial comment on the draft Local Plan in November 2017. Many of our points were echoed, and some amplified, by Tring Town Council in their response. The main points that we made are set out below the DBC timetable for final consultation version of the Plan.


DBC Timetable

  • Pre-Submission Plan for public Consultation - May-June 2020

  • Submission of Plan to the Government - November 2020

  • Public Examination of the Plan - January-April 2021

  • Planning Inspectors report Issued - November 2021

  • Adoption of the plan - February 2022


Examples of TinT Comments on Draft Local Plan (approx 1/3rd of the content submitted)

In Tring, Dunsley Farm should be developed first to comply with NPPF requirement of presumption in favour of sustainable development. The other Tring proposed sites will significantly increase car dependency as compared with Dunsley Farm as they are significantly further from the town centre, and too far for walking to be a realistic option.

For publicly owned land, e.g.Dunsley Farm, we recommend a 50% mix of affordable housing and starter homes (which are out-with Govt definition of affordable homes) on the grounds that public assets should be used to deliver development outcomes that are most needed by the public, and to deliver homes affordable by essential workers (often paid below the national average wage of £27k)


Considering that the environmental/climate impact of the developments enabled by the local plan will last for several generations and could be enormous, we feel it would be better for DBC to be vastly more ambitious in their target setting, to the benefit of the climate, the local population, and achieving NPPF requirement for presumption of sustainable development, climate change mitigation, and moving to a low/zero carbon future.


The National Planning Policy Framework states that Local Authorities should recognise that it is the responsibility of all communities to contribute to energy generation from renewable or low carbon sources, and that they should have a positive strategy to promote energy from renewable and low carbon sources.


Specifically we would recommend DBC to draw up and implement a Low Carbon Plan and Climate Change Action Plan, with information on these in chapter 5 of “How Local Authorities Can Reduce Emissions and Manage Climate Risk” (Committee on Climate Change May 2012) at

https://www.theccc.org.uk/archive/aws/Local%20Authorites/1584_CCC_LA%20Report_bookmarked_1b.pdf

We would strongly recommend a review of policies on climate change, house building/design, renewable energy etc to take the opportunity to integrate the key opportunities from this report.


We would recommend through planning conditions that a 19% reduction in CO2 emissions over Part L Building Regulations 2013 be required on all new build houses (thus to the level of the former Code for Sustainable Homes Level 4.


We would recommend renewable electrical energy requirements for proposed developments from solar PV and solar thermal for water heating (with energy storage once this becomes cost effective), with the existing power grid only being used as a back-up at peak times once or twice a year; together with alignment of new houses to face south/south west at either front or rear to maximise solar gain (thus reducing gas usage for space heating).


Paras 8.4.6 to 8.4.8. District heating. Welcome focus on renewable energy to power district heating. The AECOM report referenced (Hertfordshire Renewable and Low Carbon Energy Technical Study) is supported although dated 2010, thus in need of updating. See also the 2015 DECC Research Report:

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/424254/heat_networks.pdf


We would recommend fossil fuel specifically not used for district heating. As indicated in the Plan, and in the AECOM Report, district heating is best suited to blocks of flats (unless done on a “continental/European” scale).

We are seriously concerned about the ambiguity of para 9.3.4 which brings into question DBC’s approach to future Green Belt areas and to the type of development abutting the Chilterns AONB. “We are updating our evidence base to understand the types of open space we need to protect and whether we need to apply new provision standards. Our general approach will be to meet national standards but we will also consider if any local variation is appropriate.” This ambiguity needs to be resolved with complete clarity and policy before final consultation prior to Plan submission. In addition, the general principle on biodiversity should be no net loss of overall green cover.

There is real potential to make real achievements in climate change mitigation/carbon reduction in transport.


We recommend that the Plan aligns with relevant parts of the Govt BEIS Clean Growth Strategy: Leading the Way to a Low Carbon Future October 2017 https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/651916/BEIS_The_Clean_Growth_online_12.10.17.pdf

and with

https://www.theccc.org.uk/archive/aws/Local%20Authorites/1584_CCC_LA%20Report_bookmarked_1b.pdf especially box 3.5 on page 44, and the content of page 48.


Given the Govt intention to have no petrol/diesel cars by 2040, we would strongly recommend the installation of electric charge points at the front of all new houses (or, as a minimum, at 20% of new houses with passive provision (cabling and power supply to enable easy conversion to use later by adding a socket) at the remainder), and at new employment units.


We recommend the provision of more electric charging points at all car parks, with dedicated parking spaces, given the Govt target of ending the sale of new conventional petrol and diesel cars and vans by 2040, i.e. by just after the end of the Local Plan. Charging points in public areas should be supplied with electricity from a 100% renewable energy supplier. Free parking should be provided for electric vehicles.


We would ask DBC as a local taxi and private hire vehicle (PHV) licensing authority to require zero emission capability by taxis/private hire vehicles licensed by DBC by 2032, for which these firms will need prior notice.


We would ask DBC to liaise with Herts County Council on requiring bus operators to have low carbon buses from early date.


Improvements to the rail link between Dacorum and London Euston need DBC to meet with the new rail franchise provider about:

  • reducing overcrowding at peak times by following Chiltern Railways example of some years ago by scrapping first class so opening that up to standard fare passengers. Overcrowding will worsen with the proposed housebuilding.

  • poor quality of some stations”; Tring station has neither toilet facilities nor any provision for passengers who cannot negotiate steps/or who need a wheelchair to reach the platforms. These two issues need resolving very soon.

Accepting the identified need to develop the Plan, we would recommend the provision of off-road cycle paths between large developments and stations (eg Pitstone and Tring Station), and between towns (eg by upgrading the canal towpath along Grand Union Canal between Marshcroft Lane, Tring and Berkhamsted Waitrose car park because the main road between Tring and Berkhamsted has several narrow sections which are dangerous for cyclists). Also an off-road cycle path along the proposed new east link road from Bulbourne Road to connect to the existing cycle path at Station Road. We would also recommend the provision of further cycle storage at stations heavily used by cyclists, eg Tring.

At all new public buildings including shops we would recommend the provision of cycle racks.

Residential road safety for children, pedestrians and cyclists. We would recommend 20 mph speed limits and traffic calming, such as chicanes, on all new residential roads.

On larger residential sites we would recommend that the main access road(s) are sufficiently wide to enable buses to be able to pass each other. Pull ins should be provided at all bus stops along with real time information (rather than timetabled times) on bus arrival times.


All new residential sites should have pavements wide enough to enable cycle/pedestrian sharing.


Wildlife corridors. Most Tring sites have existing wildlife corridors (please see next paragraph for specifics). These green corridors (bushes/trees/hedges/ ditches/banks/scrub) need to be continuous to allow free movement of creatures (including birds, butterflies, bees, insects, spiders) providing rich biodiversity including wild flowers and food sources for these creatures and pleasure to people walking and cycling. Pockets of unconnected open space are of limited value, especially if kept manicured.


Provision for biodiversity. This could include green roofs or walls for insects and birds, wood piles for beetles, nest boxes for birds, and in ecological networks can increase permeability of wildlife in new development through biodiversity enhancements.


Grand Union Canal forms a strategic wildlife corridor along northern boundary of Tr-h1 (see Adopted Core Strategy 2013 Tring Place Strategy). We recommend that the trees/bushes/hedges/scrub along this boundary be retained with a buffer of 10 metres.

Tr-h1 and Tr-h2 have urban wildlife corridors along Marshcroft Lane. The banks/ditches/scrub etc along this corridor should be retained wherever possible. If any are removed/destroyed then biodiversity offsetting should be undertaken on the development sites concerned. Options include new hedges of locally indigenous shrubs; orchard of traditional Hertfordshire apples and plums; wildlife ponds.


Tr-h3 has an urban wildlife corridor along Bulbourne Road. Any removal of this corridor, eg hedging removal should be subject to biodiversity offsite on site, eg as continuous a hedge as possible to connect with existing hedges using indigenous shrubs, eg guelder rose, spindle, field maple.


Tr-h5 has a local wildlife site. We would recommend retention of this site, and connection of it to existing hedges. Existing field hedges should be retained or have replacement hedges of indigenous shrubs.


Tr-h6 northern boundary is a canal which is a strategic wildlife corridor. This boundary should remain undisturbed by development, with additional planting to fill gaps, and have a 10-metre buffer zone.


“Climate change mitigation” should be extended to including “moving to a zero carbon future”, or, as a minimum, moving to a “low carbon future” as required by (NPPF “Achieving Sustainable Development”. )


“Renewable Energy” policy with targets is needed to comply with NPPF, inter alia including solar PV, solar thermal, heat pumps. Consider inclusion of option of using s106 contributions for renewable energy schemes, which should either be on the same site or, as a minimum, in the same town.


“Sustainability Offsetting” policy required, including definition of this previously undefined term. We would suggest calling it by the well-understood terms “carbon offsetting and biodiversity offsetting” rather than using a term that even experts we have consulted have never heard of.


“Water , sustainable drainage, sewage” policy needed


“New housing” policy needs to encourage co-housing, and for self-build, including using “natural materials”.


“Affordable Homes” needs to include policy on Starter Homes (currently excluded from Govt definition of Affordable Homes). It also needs to include process for monitoring build % agreement and actual build of affordable homes.


Building Regulations is no guarantee of good-quality houses, and makes only a 6% reduction in energy saving compared with its predecessor. We would recommend that new houses be required to achieve a 10% carbon reduction beyond Building Regulations Part L by energy efficiency measures.


Water. We would draw DBC attention to Building Regulations section 36, specifically “The potential consumption of wholesome water by persons occupying a dwelling to which this regulation applies must not exceed 125 litres per person per day.” The headline figure on page 65 of the Plan says “Household water use is 161 litres per head each day.” which is substantially higher than Building Regs allow for in new homes, and higher than current national average of 139 litres/head/day. We would recommend the target of 110 litres per person per day from the outset of Plan to take account of rain fall reduction/climate change during the life of the houses (see below)


We would recommend that to reduce water use and loss, new homes should be built with rainwater harvesting and grey water recycling. Taps and shower heads which reduce the water flow (eg the Ecocamel) should be used.


The report below demonstrates the water situation in Herts. West Herts has been drier than the East. Rainfall in Dacorum has been ‘notably low’ over the last 12 months but normal in East Herts. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/658516/Hertfordshire_and_North_London_Water_Situation_Report_October_2017.pdf


We live in a dry area and use more water than the national average, and substantially more than Building Regulations section 36 allow in new houses.


Sewage. Opportunities exist to use anaerobic digestion at sewage farms to create renewable energy and a useable by-product, ie fertilizer. Reed bed effluent and waste water treatment systems could be used where appropriate.


We would recommend the use of porous “hard surfacing” at new house developments, so that rain water soaks through into the ground below rather than running off as surface water. This may provide opportunity for local water collection and distribution, eg for garden/lawn watering, to reduce use of mains water, and would reduce impact on drainage systems.

Waste. We recommend a target of zero biodegradable waste to landfill by the end of Plan.

Sewage. Opportunities exist to use anaerobic digestion at sewage farms to create renewable energy and a useable by-product, ie fertilizer. Reed bed effluent and waste water treatment systems could be used where appropriate.


We would recommend the use of porous “hard surfacing” at new house developments, so that rain water soaks through into the ground below rather than running off as surface water. This may provide opportunity for local water collection and distribution, eg for garden/lawn watering, to reduce use of mains water, and would reduce impact on drainage systems.


Waste. We recommend a target of zero biodegradable waste to landfill by the end of Plan.


DBC should meet with AVDC to discuss option of moving the small/medium warehouses scheduled for Dunsley Farm to land adjacent to the Arla site at College Road North, where warehousing would be less intrusive and have equally good link to A41 dual carriageway. (Note: warehousing tends to create very few new jobs). This would enable additional housing at Dunsley Farm including sheltered housing and a residential home, lessening impact elsewhere in Tring.




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Copyright Tring in Transition 2019