Official bodies from across the county have branded the St Albans Local Plan (LP) unsound, illegal, and incompliant.

Representations were submitted as part of the second consultation on the St Albans district council (SADC) document, which outlines where 15,000 new houses would be built in the district before 2036

The consultation ran from September 4 to October 17 and attracted 1,777 comments.

Proposals have proved controversial, notably the placement of large housing developments on Green Belt land near the village of Redbourn and on the controversial Strategic Rail Freight Interchange (SRFI) site in Park Street.

Network Rail (Infrastructure) threw its support behind SRFI, objecting to the LP on various grounds: “The apparent allocation of the whole of the site is in direct opposition to the outline consent for the SRFI and can only be viewed as an attempt to frustrate the development of the latter.

“Given the support of the Secretary of State to the proposal following lengthy consideration of the merits of the scheme, and its strategic importance in serving the north of London and the weight given to meeting targets for creating sustainable patterns of freight delivery we cannot see any justification given for the allocation of the whole site at Park Street.”

It also asked SADC to close the Cottonmill Level Crossing if services on the Abbey Flyer line are made more frequent.

Local campaigners have been working to keep the crossing open since at least 2015, arguing it is not dangerous and will cut the ward in half.

NHS Property Services raised concerns about policies aimed at preventing the loss of clinical facilities: “Where such policies are overly restrictive, the disposal of unneeded and unsuitable healthcare facilities for best value can be prevented or delayed.

“This has a direct impact on the provision and quality of healthcare facilities and services, as it can prevent or delay the reinvestment of capital in modern and fit-for-purpose facilities and require ongoing revenue to be spent on maintaining inefficient parts of the estate.”

It said many redundant healthcare buildings are purpose built and therefore not suitable for any other use.

The submission added: “It is important to note that there are separate, rigorous testing and approval processes employed by NHS commissioners to identify unneeded and unsuitable healthcare facilities.”

Herts county council (HCC) Growth and Infrastructure Unit has suggested a number of problems with how care, community protection, ecology, highways, libraries, waste planning, rights of way, and education are dealt with.

It says new school buildings should not be placed on Green Belt.

Gorhambury Estates has asked for assurance the historic landmark will not be compromised if East Hemel Hempstead is developed, for example a clarification on the scale, location and lighting proposed to the east of the M1.

The West Hertfordshire Hospitals NHS Trust said it would like the St Albans LP to include a general plan for a new hospital within the next five to 10 years.

Their submission stated: “It is noted that the emerging LP document for St Albans does not include a hospital focus, making no reference to the existing hospital or the provision for a new hospital across the district.

“This oversight for hospital provision does not recognise the value of the employment and clinical benefits to the local population.

“An open policy within the LP, or an ability to trigger a review of the plan once the trust is in a position to develop a site, should be included as a minimum.”

It says this is necessary to provide appropriate and sustainable growth across the district.

Planning portfolio holder at SADC, Cllr Mary Maynard, said the planning policy committee will meet to discuss all these representations on December 12.

She stressed that none of the neighbouring authorities have threatened to object on duty to cooperate grounds: “That is very good, it means all the hard work of the planning team is paying off and we are now understanding each other’s plans.

“They are bringing up issues and concerns, obviously, but we would expect that and it is why we do it.”

She added: “It is beginning to bring everything together.”