HERTSMERE BOROUGH COUNCIL DRAFT LOCAL PLAN

The Letchmore Heath Village Trust exists to protect and sustain quality of both the village and the lives of those who live there.

In addition to comments already submitted in respect of proposed development at Little Simpsons in Letchmore Heath (HEL 509), the Letchmore Heath Village Trust has the following objections to the Draft Local Plan:

1. Unacceptable loss of Green Belt
2. Residential overdevelopment in Hertsmere
3. Lack of proper detail and planning for requisite infrastructure
4. Industrial creep inside the Green belt

1. UNACCEPTABLE LOSS OF GREEN BELT

Proposals to build on Green Belt are unacceptable. The Prime Minister at his recent party conference stated that the new focus will be on boosting construction on brownfield sites, which have been previously developed and are less controversial locations for housebuilding and that green fields would not be built upon. The many objections to the Solar Plant development on Green Belt land and our Councilors’ overwhelming rejection of the application indicate clear local support for the Prime Minister’s position.

Taken together, HEL179, HEL180, HEL199, HEL219/252/HEL345 and HEL509 together with other unspecified proposals would mean over an additional 130 houses in Aldenham Parish villages. This is completely contrary to the stated aims of Green Belt policy which include safeguarding the countryside from encroachment, preserving the setting and special character of historic areas and checking unrestricted sprawl. These proposals also detract from the stated opportunities and benefits of the Green Belt which include providing opportunities for access to the open countryside for the urban population, the retention of attractive landscapes and the enhancement of landscapes, near to where people live as well as securing nature conservation interests and the retention of land in agricultural, forestry and related uses.

We strongly object to building on Green Belt particularly in an area which is so close to London. We do not believe that housing development on the Green Belt passes the “ very special circumstances” test – namely both a vital need for the specific development proposed, and that it could not be carried out equally successfully somewhere else, outside the Green Belt.

Residents are already bracing for either an appeal against the Solar Plant decision or a new proposal for a smaller scale solar plant. Whilst either would be very strongly opposed, any success by the applicants would cause further loss of Green Belt unaccounted for in the Local Plan.

2. RESIDENTIAL OVERDEVELOPMENT OF HERTSMERE

As an individual example, the proposed additional housing for Radlett is excessive. In percentage terms the number of new dwellings proposed for Radlett versus existing households is higher than Potters Bar, Shenley, Bushey and Borehamwood and is nearly 4 times more in percentage terms than South Mimms which has a similar number of existing households.

Collectively, it is likely to be unnecessary for so many houses to be built in Hertsmere as

a) The planning white paper itself proposed a new centralised system under which the government assesses housing need, land constraints, and other factors, and passes them on to planning authorities to implement as a mandatory target. It has been widely reported that this element of the white paper will be dropped when the reforms are finally published.

b) Additionally, the Housing Secretary has stated that he is revisiting the way housing targets are calculated. He has said “I think that some of the assumptions there are probably out of date”. The existing target formula focused more growth in high value and rural areas both of which are found in Hertsmere e.g. Radlett and Aldenham Parish villages.

Accordingly, the number of new homes set out in the Draft Local Plan will have to be reviewed and/or paused. The Council should proactively approach the Housing Department for urgent clarification on these issues before mandating any particular number of new dwellings in the Local Plan.

3. INFRASTRUCTURE ISSUES

The current infrastructure in Hertsmere cannot cope with building on the scale proposed in the Draft Local Plan and the Plan itself does very little to address this issue apart from vague references. As an example, Hertsmere acknowledges that “existing pressures on key services within Radlett such as transport, education and healthcare can be partly attributed to the wider catchment area that its facilities serve.” Yet, there are scant proposals for improving these services.

Transport

• the proposals will cause horrendous traffic congestion on many key roads across the borough, e.g. A41 and A414 and will also cause unacceptable additional congestion on already overused country lanes- eg the roads around Letchmore Heath and Round Bush
• the Plan contains many references to sustainable transport strategies but no material detail. Without that detail, how can Hertsmere be confident that any new development can be supported by sustainable transport?
• there seems to be an assumption that given the right infrastructure people will walk or cycle to work whereas the reality is that given its proximity to London many Hertsmere residents simply don’t work locally and can’t walk or cycle to work.
• Welwyn Hatfield BC and St Albans DC both share boundaries with Hertsmere’s proposed new development of thousands of homes at Bowman’s Cross and have raised concerns over transport difficulties. Welwyn’s draft response said Hertsmere should consider the potential infrastructure implications, adding: “This should include implications on the A414 of bringing forward such a significant site. There is a lack of detail in the consultation document of the proposed sustainable transport links and whether the necessary supporting services and facilities can be provided …”

Schools
The plan is overly optimistic about the availability of school places throughout Hertsmere

• The proposed residential development of Radlett and the Aldenham villages is substantial but no new secondary schools are proposed. Only a minor class expansion of primary school provision is proposed. The Council seem to suggest that a new secondary school proposed for Bushey will be sufficient but much new housing is proposed there too and there seems to be a naïve assumption that Radlett parents will continue to use private schools although this cannot be assured and is unlikely anyway in the case of the affordable home occupants.
• Regarding the proposals at Bowman’s Cross, Welwyn are concerned about a section of Hertsmere’s report mentioning Chancellor’s School, which is in their borough and which Hertsmere is anticipating its own students will attend. Welwyn has made it clear that the school will be required to meet demand from their own emerging Local Plan and have voiced their concern about the lack of school provision by Hertsmere.

Medical
There are plenty of references in the Plan to post pandemic requirements but no reference to the increased pressure on medical facilities which is daily headline news. Even, if as hoped, this eventually subsides, any extra capacity provided will be quickly absorbed by the increased population of Hertsmere residents. Specific new medical facility proposals need to be included and these need to be in place before material residential development starts.

Utilities
These are already under heavy strain, with constant piecemeal repairs, just to serve existing settlements. There is no specific proposal in the plan to address this issue.

4. INDUSTRIAL CREEP INSIDE GREEN BELT

Taken as a whole, there is a good deal of industrial proliferation proposed to land on the doorstep of the Aldenham parish villages including Letchmore Heath. Full implementation of this plan, particularly when taken in context of the proposed residential development of the villages, would spoil the unique look and feel of the villages, replacing open agricultural land with a more industrial vista.

• The designation of the Bio Products Laboratory space as a Rural Employment Area combined with the additional homes proposed to front Dagger Lane will exacerbate existing traffic issues there and take away loss of Green Belt status which has been the only protection against overbuilding of industrial units in that area.
• We are concerned that Elstree Aerodrome is to become a Special Policy Area losing its Green Belt status and particularly that operational-related development will be supported. Any development should not increase the airborne operations and the consequential environmental/noise impact that would result nor should it materially increase the use of the approach roads – particularly Dagger Lane.
• The above combined with the proposal that Lismirrane Industrial Estate loses its Green Belt status and will be allocated another 5.2 hectares of land creates too much industrialization in our rural vicinity.

For the reasons set out above, the Letchmore Heath Village Trust strongly opposes the current Draft Local Plan

LHVT.
 
19 November 2021