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Hertsmere Local Plan FAQs

Giving Feedback To Hertsmere

Question 1:  Do I have to live in Hertsmere to provide feedback?

NO. Everybody who has a view on the Hertsmere Plan can provide feedback. You do not need to be a resident of Shenley/ Hertsmere. Please encourage everybody in your family and all your friends and contacts to provide feedback.

Question 2:  Can each member of my household provide individual feedback ?

YES. Every individual person can provide feedback. We encourage everybody in a household to provide their separate feedback. It is important that we have as many separate pieces of feedback about the Hertsmere Plan and the impact on Shenley. It really is a ‘numbers game’-the more separate pieces of feedback, the more Hertsmere Council will recognise that this plan is totally not acceptable for Shenley.

Question 3:  How can I provide feedback?

Please feedback your own views in your own words

  • You can view the document and leave comments about specific sites from 11 October to 6th December at: https://hertsmere-consult.objective.co.uk/portal/(Please note: You will need to create a login to comment online)
  • Paper copies of plan available to borrow at Shenley Stores
  • Feedback forms are available at Shenley Stores plus prepaid envelopes.
  • Alternatively, you can email your feedback comments to plan@hertsmere.gov.uk

Question 4:  Is the process used by Hertsmere Council to explain the plan and seek feedback appropriate?

NO. The process used by Hertsmere Council to explain the plan is not satisfactory and does not meet the needs of everybody in the community.

Section 2 page 11 of the local plan states that in the light of the COVID 19 pandemic “local planning authorities have been asked to promote effective community engagement by means which are locally practicable. …. The authority has acknowledged the need to ensure sections of the community that do not have internet access are involved and consider alternative and creative ways to achieve this”.

The process in which Hertsmere has sought to engage with the whole community, the provision of information about the local plan and the feedback mechanisms used have been deficient. In particular:

  • No Face to Face meetings: Face to face meetings, which could be organised on a small scale in line with COVID-19 regulations, have not been organised between the council and residents of Hertsmere. These face to face meetings were organised at the previous stage of engagement in 2018
  • No Zoom meetings: Video conferencing (e.g. “Zoom” meetings), a widely used medium throughout the pandemic, has not been used to organise meetings between the council and residents
  • Deficient ‘Planning for Growth’ leaflet: For those people without access to a computer, the “Planning for Growth” hard copy document distributed to households is highly deficient and does not provide any detail on the proposals in the plan nor explain how members of the public can get access to the details of the plan without using a computer.
  • Difficulties using consultation portal: Many residents have experienced difficulties in using the consultation portal. There have been delays in getting logins and registering your details, periods where the consultation portal has not been available and difficulty in providing feedback for specific sites or sections of the plan.
  • Pointed portal direction hinders people giving full feedback: The Hertsmere Local Plan website encourages people to provide feedback using the ‘Planning for Growth’ on-line questionnaire rather than directing them to the full consultation portal. There is a risk that by using the on-line questionnaire, people are not able to provide full feedback about the whole plan and individual sites. The free form text box is restricted to 250 words which is very small for a plan which is over 250 pages long !

We encourage people to request that Hertsmere:

  • Extends the consultation period,
  • Engages thoroughly with its residents through face to face and video conferencing type meetings
  • Take steps to ensure that everybody in the community can get access to information about the plan.
  • Updates the Local Plan website so that it is easier to find the consultation portal and the questionnaire is not used as a mechanism for collecting feedback

Questions About Hertsmere Local Plan

Question 5:  What is the Local Plan?

The Hertsmere Local Plan is a plan for development across the whole Borough of Hertsmere for the next 15 years. It has been written by Hertsmere Borough Council (HBC), and it allocates sites for where housing and employment will be built from 2023.   It is currently in its engagement phase before further assessment and then the Draft Plan will be submitted to a government-appointed inspector next year.  Once adopted, the new plan will be used to help shape growth in the Borough until 2038.
The Hertsmere Local Plan is available to the public via the Hertsmere Local Plan website. https://www.hertsmerelocalplan.com/  It is a large and complex document. There will be no referendum on this plan, so your comments are the only way to influence its final form.
YOU HAVE AN OPPORTUNITY TO GIVE FEEDBACK FROM NOW UNTIL 6th DECEMBER

Question 6:  What are the key plans that will impact Shenley?

Key plans for Shenley area:

  • Extra housing: 2,000 more in our Parish, including 350 more in Shenley Village centre at London Rd and Harris Lane, with the whole village to be taken out of green belt, enabling denser development.  (note: The “old village” is currently green belt, so this is a real threat to the future of the whole village).
  • Development in Cowley Hill (800+) and Radlett Lane (200).
  • “Windfall” extra 45 homes in Shenley, but no information about where these will be built.
  • New village/town – Bowman’s Cross to be built near Willows Farm: 6,000 houses (some within Shenley parish boundary) – with likely traffic impact on Shenley
  • New Media Quarter at Well End: likely traffic increase
  • No plans to upgrade infrastructure in Shenley

Question 7:  Can I have some pointers for providing my feedback?

Some considerations relevant to Shenley that you may wish to cover in your feedback:

  • Plan sustainability: In HBC’s Local plan it states that for sustainable development homes should only be built where there is ability to walk to railway station or catch a bus that runs every 3-5 mins and where there is good access to schools and GPs and where development does not add to traffic issues.  Shenley does not have this, hence the proposals don’t meet the Council’s own sustainability criteria.
  • The plan’s objectives include protecting green belt from inappropriate development and protecting open spaces, but also include building a minimum of 12,160 homes, many on green belt land which they are planning to take out of the green belt.  We feel this inexplicably high figure is based on an inexplicably high estimate of the housing need for the borough (see more detailed answer Question 8 below).
  • Shenley Parishes Housing Needs: Aecom, the Government (and Hertsmere’s own ‘delivery partner’) estimated Shenley’s housing need over the next 15 years to be approx. 220 homes, yet HBC’s Plan is for 350 new homes in the village and 2,000 across the parish.
    HBC only have the opportunity to propose taking land out of the green belt during the process of producing a local plan. Hence it is important to challenge not only the sites proposed but the overall estimates of the figures and te plan to remove the rest of the village from the green belt.
  • Shenley Sites out of Green Belt: Hertsmere are proposing to take the London Road/Harris Lane sites and the main village out of the Green Belt, allowing for denser housing than desirable for a rural area.  This conflicts with aims of the Shenley Neighbourhood Plan to maintain the rural feel of Shenley. HBC don’t have to take land out of the greenbelt to allow less dense redevelopment;  land could be left in the greenbelt to limit future growth.
  • Infrastructure provision: Hertsmere have not shown that they can or will deal with the infrastructure issues that will be created by the proposed developments.  There is no planned increase in medical provision for increased population. No provision for additional primary or secondary school places.
  • Transport/traffic issues: Hertsmere does not have the remit to develop roads or provide public transport – that’s Herts County Council – so there are no plans in place to improve roads/transport infrastructure.
    Borehamwood is a Zone 6 station so people commute to Borehamwood.  Anything built North of Shenley will cause more through traffic of people heading to Borehamwood to commute to London.
  • The new Media Quarter will create a significant amount of new traffic on roads through Shenley. We also have lorry restrictions that we have been told are not enforceable, so what is there to stop the studio lorries going through Shenley and down the lanes to Well End?
  • Brexit & Covid: We have left the EU and things have changed in the past two years (eg. Covid and working from home levels) yet Hertsmere’s Plan has not changed since 2018.
  • Shenley Neighbourhood Plan – Policy SC3 Housing Mix & Choices & Codes & Principles: How will Hertsmere ensure that development meets the requirements of the Shenley N’hood Plan in terms of standards and style of new buildings? (eg. “rural character”) and also that new homes meet local needs (size/affordability)?  A key finding from the Neighbourhood Plan consultation was that 98% Shenley residents wished to maintain the rural character of the village and protect our precious countryside.
  • Loss of precious countryside, rural approach to village, village “feel”, rural views.  Loss of wildlife habitats. Ecosystem/Environmental.

Question 8:  Can I have some pointers for feedback about specific sites?

  • S1 Land off London Road: Potential for 240 homes (140 homes + 100 senior care housing). Hertsmere propose taking this site out of the Green Belt, allowing for denser housing than desirable for a rural area. Exit to part of the site is right next to the Spinney, which needs to be protected. This is in centre of village – so would change/impact the village’s character and rural feel.
  • HEL390 Land off Harris Lane: up to 50 homes Increased traffic around playing fields and narrow roads of Rectory and Mimms Lane, causing potential risk to children and other users. No road improvements included.  Land will be taken out of Green Belt, so could lead to high density housing, not in keeping with the Shenley Plan, and would spoil the village’s rural edge and landscape views.
  • BE3 Land between Cowley Hill and Well End Road 800 homes: listed under the Borehamwood section but is in Shenley Parish. It has potential for 800 homes. Could also have a significant impact on the traffic through Shenley, especially when combined with the new Media Quarter in the same area.
  • R3 Land along Radlett Lane just before Radlett. Potential for 195 new homes. One access point is right next to a sharp bend on Radlett Lane, which could be dangerous and disrupt traffic flow.
  • NS1 Bowman’s Cross 6000 homes: An area of Green Belt Land within Shenley Parish to be a New Garden Village with leisure, educational and employment/business facilities. Initially 2400 homes proposed, with capacity for up to 6000 homes.  With no new transport infrastructure provisions in place, this could have a significant impact on the traffic and congestion in and around Shenley, as residents are likely to travel through Shenley to Borehamwood to commute to London.
  • E6 Media Quarter close to Cowley Hill site BE3: Sky Studios Elstree development (Site A) has 12 sound stages – up to an additional 34 sound stages proposed in this area. Is this many needed or will they end up becoming houses?  40+ sound stages will have potential huge impact on commuter traffic through Shenley.

Question 9:  Why are the Local Plan housing targets so high – 12,160?

Hertsmere say the Government say they have to have 12,160 homes but this is not true.  The Government has repeatedly stated that its formula for assessing housing need is a starting point, but each local Council is responsible for the preparation of housing targets for its Local Plan taking into account local circumstances and constraints.  The National Planning Policy Framework (NPPF) allows councils to take into account the presence of designated protected land, including Green Belt, in determining (REDUCING) the appropriate housing targets.   Hertsmere can get their target housing number reduced.

Lobby Morris Bright, Harvey Cohen, Oliver Dowden and Michael Gove to get the numbers reduced.

Question 10:  Do we need all these proposed houses in Shenley?

NO. The Shenley Housing Needs Assessment report completed by Aecom in May 2018 for the Shenley Neighbourhood Plan states that the estimated unconstrained housing need for Shenley for the next 15 years was 220 homes. Given a high percentage of Shenley Parish is in the Green Belt, the amount of housing on a ‘constrained’ basis would be significantly lower.

The Hertsmere Local Plan’s proposals to build 350 homes in the village with over 2000 in the wider Parish, is totally inconsistent with the housing need for Shenley village.

We encourage people to request Hertsmere to reduce the overall housing numbers for Hertsmere and Shenley Parish.

Question 11:  Why are Hertsmere proposing to take Shenley Village out of Green Belt?

Hertsmere says in the Plan (P.42) “A large part of the village is designated as a conservation area, the largest in Hertsmere.  There is a high density of listed buildings and structures within the village” and yet they propose to ‘Inset the village’ from the Green Belt?

On P.144 they say:  “Three quarters of the borough is designated as Green Belt acting as a highly effective buffer to the outward growth of London and preventing the coalescence of settlements.  The protection of the Green Belt shapes the character of the borough with large areas of Green Belt retaining a verdant open and genuinely rural character, despite their proximity to large built up areas.

Much of the countryside remains in use for agriculture, woodland and sport or recreation and the Local Plan continues to restrict development in the Green Belt to these and a limited range of other activities defined by National Planning Policy as ‘appropriate’ in the Green Belt.

The above is particularly true of Shenley.  It is a historic rural village.  If the majority of it is taken out of Green Belt it will make it vulnerable to dense rural development.  Shenley Parish Council does not want Shenley Village taken out of Green Belt.

We have just had this reply from Hertsmere Planning department to our Question ‘What parts of the village do you propose to take out of Green Belt?’:

“The area proposed to be removed, or ‘inset’, from the green belt relates to the whole of Shenley village as well as the Grange and Harris Lane sites. The simplified version of our draft policies map below hopefully illustrates this.

Local Plan Map Interactive Map of Shenley
Local Plan Map Interactive Map of Shenley showing village removed from Green Belt

 

We recommend that you look at Hertsmere’s Local Plans Green Belt Review ‘Inset Village Boundary Assessment – Final Report March 2021.

The Shenley section starts at Page 45.

What is particularly relevant is that they split the proposed areas for ‘inset’ (to be taken out of Green Belt) into segments and Harris Lane is SH5.

Arup’s recommendation for SH5 is:

Green Belt Boundary Assessment     P.58

“Description of Green Belt segment

SH5 represents the remainder of the eastern section of the Stage Green Belt Assessment sub-area RC-3 which is not covered by the village envelope.  This section of Green Belt is comprised of two open fields to the east of the village envelope.

The area is delineated by dispersed trees and hedgerows to the north-east and south-east.  The south-west and north-west, the area is bound by the curtilage fencing of residential properties along Birchwood, Newcombe Road, Harris Lane and Anderson Road; and by a small section of Harris Lane.

Recommended boundary

It is recommended that no alterations are made to this section of the Green Belt boundary”

Yet again Hertsmere are ignoring advice from a Green Belt report!!

The Grange site is not included in the Arup report but they clearly didn’t know it was definitely going to be chosen as the main Shenley Village strategic site in March.

See Figure 4.43 Shenley Proposed Inset Green Belt Boundary in the report.

Question 12:  Hertsmere are proposing to release 12% of the Borough’s Green Belt land for housing and development. Does the Local Plan have suitable protection polices for the Green Belt? 

NO. Council for the Protection of Rural England (CPRE) indicates that it is abundantly clear that Hertsmere Borough Council (HBC) has a strong traditional economic growth agenda which is seen as beneficial in economic and social terms, without considering the impact of the amount of Green Belt land in the borough.  Policy proposals are presented in term of opportunities for further development, effectively without the major constraint of the Green Belt. It estimates that 1025 hectares of land within the Green Belt are proposed for development: circa 961 hectares for housing and circa 64 hectares for employment and commercial space. This is c12% of the Green Belt land in the borough.

Key weaknesses of the local plan with respect to the Green Belt and the protection of it include:

  • No assessment of the impact of the loss of the Green Belt

There is no evidence in the local plan or supporting studies that the council has given sufficient consideration to the environmental and health and wellbeing implications of losing this huge amount of countryside and green space, which is equivalent to more than 2500 football pitches.

Specifically, policy SG7 (page 58) of the local plan states “Development that contributes to the reduction of health inequalities in Hertsmere, ……and enables people of all ages to choose healthier behaviours and live more healthy, active and fulfilling lifestyles, will be supported.

The proposal to take 12% of land out of the Greenbelt would be contrary to policy SG7 “Health and Wellbeing”.

  • Failure to identify that the high percentage of Green Belt land in borough is a positive attribute

The fact that all the open countryside in the Borough is designated as Green Belt is not identified in the Draft Local Plan as a positive attribute for the Borough. CPRE’s view is that this is clearly intentional and effectively ignores the contribution that open countryside makes to the quality of life for local people, providing an imbalanced Draft Local Plan.

  • Recent government statements regarding protection of the Green Belt

The Government has repeatedly pledged to protect the Green Belt, and the Prime Minister recently stated at the Conservative Party conference that housing would not be built on greenfield sites. With its Draft Local Plan, Hertsmere Borough Council has chosen to ignore these Government statements.

  • Lack of protection of Green Belt as a Strategic Objective for the Local Plan

All of Hertsmere outside the built-up areas is designated as Green Belt which also includes designated environmental sites which are key characteristics of the district and contribute greatly to the quality of life and well-being of residents.

The proposed Draft Local Plan would allocate approximately 12% of the Green Belt in Hertsmere for development, and this will have a very significant impact on the character and appearance of the Borough. With all the open countryside of the Borough being Green Belt, it is unacceptable that its protection is not regarded as a specific Strategic Objective for the Local Plan. A basic characteristic of the Green Belt is its permanence, and it should be a principal constraint to development and a huge asset for the Borough to be protected and enhanced for the benefit of everyone, both residents and visitors alike.

The ‘Green Hertsmere’ Vision heading in Section 3 of the Draft Local Plan makes no mention of the Green Belt and ‘Distinctive Hertsmere’ states simply that “the strategic green belt (sic) will be protected’. This is clearly not true. A single line in Strategic Objective 13 (Section 3) refers to the Green Belt and policies referring to the Green Belt comprise six pages in a 245 page document. The minimal treatment of this major land designation is a significant failing of the Draft Local Plan.

We encourage people to request that Hertsmere:

  • Includes a strategic objective in the local plan with regard to the protection of the Green Belt and set out specific policies to achieve this objective.
  • Takes account of recent Government statements to significantly reduce the development in the Green Belt-including the reduction of the overall housing and employment sites proposed in the Green Belt
  • Commissions detailed Ecological & Biodiversity reports to assess the impact of taking [12%] land out of the Green Belt. These reports should assess the impact across the borough and not just be focussed on individual specific sites. It should be recognised that when a specific site is taken out of the Green Belt, there is a consequential impact on other  parts of the Green Belt both adjacent to and further afield from the specific site.
  • Commissions a detailed report to assess the benefits of the high level of Green Belt land in Hertsmere on the health, well-being and quality of life for residents. This should focus, not only on formalised green spaces including parks and village greens but the benefits of open countryside, network of paths, wildlife, flora and fauna and open views.

Question 13:  Hertsmere say that the new development proposed across the borough will be sustainable. Is this true?

It is Hertfordshire County Council (HCC) who provides the major infrastructure for Hertsmere, roads, hospitals, schools, doctors surgeries, ambulance etc.

There is no major infrastructure planned or budgeted for in Hertsmere.  HCC are focussed on providing infrastructure for the new Harlow extension, 10,000 homes.

This is a problem for the whole of the Borough but particularly for Shenley Parish.

No infrastructure improvement to our rural roads despite 10,000 traffic movements through Shenley daily (2017 data!!).  How will Shenley roads cope with the vast increase in traffic Hertsmere’s development proposals will entail?  Will we end up with 20,000 traffic movements daily??

Hertsmere say there will be new schools and community facilities for the bigger developments proposed but for Shenley Village no new school, Shenley Primary School will not be expanded.

Question 14:  Has Hertsmere obtained a transportation study to assess the impact of the Local Plan on Shenley and the wider borough ?

NO. The sustainable transportation report commissioned by Hertsmere was not completed/ available for residents to review during the consultation period.

We encourage people to request that Hertsmere extends the current consultation period to allow people to review the transportation study when it is available.

Question 15:  The proposed development on Cowley Hill 800 homes is huge – how can this be justified?

  • It is up a steep hill that already has flooding issues – having another 800 homes could have big issues
  • It is Green belt and has a working farm which provides food source – why would Hertsmere want to take this away?
  • Approval was given for development at the Cowley Hill Stables – this will have an impact
  • Huge amount of wildlife in the area will be effected with these developments

800 homes in Cowley Hill – This is proposal will mean very big area of Shenley Parish Green Belt will be lost.   Local residents are aware of the issues including flooding in the area.  Residents need to ask Hertsmere why this development is proposed when there is no sustainable transport plan in Hertsmere’s Local Plan and there is a flooding issue.  There is no major infrastructure planned for Hertsmere.  Hertfordshire County Council are focussing on infrastructure for the Harlow extension, 10,000 homes!

We believe that:

  1. Additional cars from this and other possible developments in the area would severely impact journey times from Shenley to Elstree/Borehamwood Station.
  2. Residents on this site would potentially look to use Shenley amenities, causing additional traffic pressure.
  3. Access via Potters Lane would add additional congestion to this very narrow road.
  4. Additional cars from this and other possible developments in the area heading to Watford/St Albans/M25 could easily cause additional traffic through Shenley.
  5. It is likely to lead to additional traffic congestion in area.
  6. Building here would go against sustainable building principles in NPFF – building within 5 minute walk of a train station. The site is approx. 2 miles from the nearest station.  Not only that there is no bus service every 3-5 minutes to a train station or local services

Infrastructure issues (schools, doctor’s surgeries etc.)

  1. This site is approx. 1.5 miles from the edge of Shenley village, residents on this site would potentially look to use Shenley amenities: local shops, surgery, etc. The Gateway Surgery in Shenley would have to accommodate many more patients.  As this site is adjacent to housing in Borehamwood, a more practical solution would be to look to the Borehamwood surgeries, but we understand that the nearest surgery in Brook Road Borehamwood has also closed its Books (?  is this the case? )
  2. What plans are there for additional capacity for intensive care units, maternity units, cancer units and other critical healthcare services to support the greatly increased population in the area? What about schools capacity/provision?  These issues are of great concern to our community.
  3. The area can barely cope with the repercussions to services and roads from the current spate of building under the Local Plan in place at present.

Maintenance of Green Belt:

  1. This area forms an essential gap between Borehamwood and Well End.
  2. Developing this site would go against the Local Plan Core Strategy objective of preventing urban sprawl and the coalescence of towns.
  3. In Stage 1 of HBC’s Green Belt review the conclusion was ‘Development would not be suitable as the site formed part of a parcel identified as making a strong contribution to the wide Green Belt, particularly with regard to preventing encroachment into the countryside. Cowley Hill is identified as one of a number of durable boundary features with the parcel as a whole largely comprising open fields with long views and an unspoilt rural character’. We agree with this conclusion strongly.   The Stage 2 Green Belt review recommends that the southern part of the sub area within which the site is located could be considered further.  They think with a change of policy 787 homes could be built.   We completely disagree for sprawl and coalescence reasons. 

Question 16:  Houses that have recently been built are not affordable – shouldn’t people be bombarding MP Oliver Dowden and MP Michael Gove about this?

We agree people should be writing not only to Hertsmere but also MP Oliver Dowden and MP Michael Gove to make sure that Hertsmere do what they say they will do in the Draft Local Plan.

P.62  says:  The Local Housing Needs Assessment (LHNA) indicates a need in the period 2020-2036 for a total of 503 dwellings per annum in the affordable/social rent and affordable home ownership sectors.  A target of 4,260 (minimum) affordable dwellings over the period of 2022 to 2038, equating to 35% of all dwellings will contribute towards meeting this need.  This includes 40% of homes on all qualifying site allocations and 35% (the affordable housing requirement prior to the new Local Plan carrying weight) of anticipated commitments on qualifying sites.

Table 12 P.53
Affordable Housing Need by type
                                                                Annual Need 2020-2036          Annual %
Affordable/Social Rent                                 356                                         71%
Affordable home ownership                        147                                          39%
Total                                                               503                                        100%

The adopted Shenley Neighbourhood Plan Policy SH2 Housing Mix & Choices highlights the need for smaller affordable housing however the Cowley Hill Stables development doesn’t support this

This all sounds good but Hertsmere do not have a good track record for delivering the type of houses actually needed.  If they had there would not be such a shortage of affordable housing currently – Affordable social/rent and affordable home ownership.  Far too many large executive homes have been built recently particularly in Shenley Parish.

Question 17:  Is the Local Plan consistent with the Government’s levelling up agenda ?

NO. As set out at the Conservative Party Conference recently, there is now increased focus on the ‘levelling up’ agenda with higher levels of investment in housing, employment sites and infrastructure in the North, making better use of brownfield sites and minimising the development on the greenbelt areas in the South East.

The Hertsmere local plan with its focus on using historical data to estimate its housing need and proposals to build on 12% of its Green Belt is inconsistent with the critical ‘levelling up’ agenda.

We encourage people to request that Hertsmere Borough Council should put its local plan on hold and seek further clarification from central government, to support the reduction in housing and employment sites in the local plan.

Question 18:  Could there be impact on local amenities in Shenley including the Harris Lane playing fields and Spinney Woodland path?

 YES. Both the Harris Lane playing fields and the Spinney woodland path are vital community assets enjoyed by many people in our community.

The proposed development off Harris lane threatens the safety of the road for children and young families and will significantly affect the availability of parking

With regard to the Spinney, extreme care needs to be taken to protect this environment from the nearby development.

Question 19:  Shenley Neighbourhood Plan – doesn’t this come into this?

The Shenley Neighbourhood Plan is now in force which was why Cowley Hill stables was called into the Secretary of State as the recent planning application approval by Hertsmere Borough Council goes against the NPPF, the current Local Plan and the adopted Shenley Neighbourhood Plan.

Shenley Parish Council has asked the Secretary of State (SOS) to call the application in and it is also consulting solicitors.  Shenley Parish Council will robustly defend the adopted Shenley Neighbourhood Plan.