Hertsmere Borough Council (HBC) Local Plan – RSGB Response November 2021
HERTSMERE LOCAL PLAN 2022-2038
RSGBA comments on Hertsmere draft Local Plan – 2nd November 2021
The Society has now responded to the consultation on Hertsmere’s draft Local Plan which you can read below. We urge you to respond as well, perhaps taking some comments from our letter. It is important that as many as people do respond as numbers count in such exercises!
We are commenting from the point of view of an association representing Radlett and surrounding villages but we have naturally considered the whole plan and its impact on Hertsmere in general.
We have three key objections:
- This plan represents an unwarranted and serious attack on the Green Belt, totally at odds with the country’s policy
- The plan is lamentably short of consideration of, and provision for, necessary infrastructure improvements to facilitate the proposed huge increase in population
- The whole plan seems to be one of significant development with little control, based on minimal evidence of the real demand for new housing and in particular with no consideration of the vastly changed world of work we find ourselves in post-pandemic.
We develop these and other points below.
- Green Belt
The Green Belt is a key principle that manages our environment; that tries to ensure development is managed; that the countryside remains open and permanent; and that communities remain distinct. The law says that Green Belt usage is only to be permitted in ‘very special circumstances’. We see no explanation in this Local Plan of what those circumstances are to justify such extensive development on so many Green Belt sites. It certainly seems contrary to statements by the Prime Minister at Conservative Party Conference. More recently Levelling-up Secretary of State Michael Gove said: “Making the most of previously developed land is a government priority and it will help protect our cherished countryside and green spaces.”, effectively stressing the need to protect the Green Belt. Overall, the Plan takes away a substantial part of Hertsmere’s Green Belt to meet a housing need that we do not believe has been properly substantiated.
The Borough’s 2018 plan identified a range of possible sites, against which we commented in considerable and careful detail. At that time, we identified a number of sites that could be used – for example what is now designated HEL214 “South of Theobald Street” (75 homes) and HEL231 “Starveacres” (90 homes). We understand the need for controlled expansion of Radlett and occasional small breaches in the Green Belt – and HEL214 in our view was acceptable.
The new large development site R1 “North of Watford Road” (350 homes) has suddenly entered consideration, we assume purely because of being put forward by the landowner. What justification is there for turning such a substantial area of productive farmland over to housing? Its position means that those living there and wanting to access Radlett’s centre will almost all drive: where is the consideration of the necessary road and parking improvements to enable this – and where is the commitment to make proper provision for these?
Meanwhile, objections to R3 “South of Shenley Road” (195 homes) have been made frequently and extensively over the years. It has been turned down for development in the past for many reasons, including geology and access, and we do not see that any new factors have emerged to justify its reinstatement.
Both of these developments breach a cardinal Green Belt principle of preventing communities becoming joined together – R1 effectively absorbs Kemprow and High Cross; R3 makes significant moves towards Shenley.
We also note that there is a special policy in the draft plan – E5 – which will apply to the Elstree Aerodrome. This appears to open the way for an extension of the airport into two additional fields, currently classed as Green Belt, with the Aerodrome’s “permitted development” rights.
There is a current proposal for a large ‘Solar Farm’ on land between Radlett and Elstree airfield. This would also be a major erosion of the Green Belt. Taken together, these would have a massive impact on the Green Belt around Radlett and would make a nonsense of the protection it is supposed to receive.
The Local Plan does make mention of expansion of the Red House doctors’ practice and of primary schools; but there is a great deal more to infrastructure than these aspects, important as they are. In any event, the discussion about possible expansion of primary school provision is weak, making no clear commitment to a new school, just general talk of one or two new classes.
Secondary school provision is needed – not in Bushey but in Radlett, if the sort of expansion suggested in this plan goes ahead. There seems to be an assumption that Radlett parents will use private secondary schools – so there is no local need for a state secondary school. This does not square with the apparent drive of the plan to bring affordable housing, and so lower income people to the village. Such people will not be sending their children to private schools. In any event, local schools are at capacity – and more people driving to them will simply create more congestion in places such as Letchmore Heath and the A41 roundabout.
But where the plan fails is to give any consideration to real infrastructure:
- Provision of water, gas, electricity – where current supplies are under strain. What consideration has been given to capacity and what commitment to improving them if development is to happen?
- Provision of waste and sewage – again, current systems are showing signs of being overloaded with similar considerations.
- Roads and traffic – the main roads in Radlett are already congested with regular jams on Watling Street and Watford Road/Park Road. Where is the plan for relieving this in the face of a supposed 28% increase in housing?
- Trying to drive out of Radlett, there are already incessant jams at the A41 roundabout (going West), at Elstree lights (going South) and within Borehamwood itself (going Southeast). The new junction arrangements at Harper Lane (going North or East) have been helpful but there is no capacity to expand significantly without more jams (or accepting that another bridge is needed). How does the Plan address these?
- It may be that the plan assumes that new residents will walk or cycle; leaving aside the naivety of this view in the face of all current evidence, the plan has no provision for extra cycleways or improved walkways.
- What of the parking requirements? Electric charging points? Proper cycle storage facilities for the people who might be tempted to cycle due to the impossibility of driving down?
- What of further public transport – will the Council be organising this to mitigate the car traffic?
- Radlett used to have a Fire station and a Police station; will the proposed population expansion bring a concomitant commitment to reinstate these?
- Does this plan have any consideration of safer streets?
There is a certain irony about the current proposals for redevelopment of Radlett’s filling station site. Recent events have demonstrated how valuable this is and although we are supposed to be using less petrol, does the Plan need to reconsider this redevelopment with so many more people/cars coming to Radlett?
- Demand for housing
Both the Radlett proposals and the overall Hertsmere plan project huge increases in housing. The Radlett section posits a 28% increase in stock; increases for Hertsmere as a whole are very significant. We question the whole basis for this expansion. Is there really proven demand for this housing? Given the combination of a net exit of EU workers and reducing birth rates, the UK population is projected to decline. In any case, such a large increase for Hertsmere seems somewhat contrary to the Government’s ‘levelling up’ agenda and spending on projects such as HS2: surely if more housing is needed (and we question how much is needed) it should be built away from the Southeast?
The risk with expanding the Radlett and Hertsmere housing stock is that it changes Hertsmere significantly and just draws residents from London, creating vacancies there. Or does it just provide investment opportunities for those, often from outside the UK, who wish to invest in UK property? The Plan makes much of the potential for expansion of Elstree’s film/TV industry – is that where the new Radlett residents will work? If so, how do they get there? Or are many of the new workers likely to be remote workers…in which case they do not need to live in Hertsmere.
More generally, we see no sign that any consideration has been given to the changes in working and commuting patterns in the wake of the pandemic. How does that affect the demand for housing? What scope is there for meeting housing demand from converting or redeveloping redundant office or retail spaces? Hertsmere needs to assess this and factor it into planning to manage the risk of being left with significant brownfield sites in a few years’ time. Surely this needs to be done before setting out plans for new housing?
Those of us who live in and around Radlett are well aware of its attractions; we accept that there has to be some increase in our housing stock. But that increase needs to be controlled and in keeping with what makes Radlett attractive in the first place: there is no point in a huge expansion that fundamentally changes the place and so damages the attractiveness that will bring people here to fill the houses. How is a 28% expansion justified?
We have no doubt that Radlett needs more smaller houses and we agree that sites such as HEL214 should focus on smaller houses. But there is another way that the Council can encourage small housing: by not approving so many huge mansion projects, or blocks of luxury apartments, both often involving destroying an existing house, but instead allowing small houses on these sites.
- Other aspects
Earlier this year, the Radlett Plan was approved in a full democratic poll. We see no evidence that any real consideration has been given to this within the Hertsmere Local Plan. This is unacceptable.
The Plan does talk about new development needing to be carbon-neutral, which is appropriate, but we would argue that the likely increase in traffic generated by the housing plans make this ambition unrealistic. We have already mentioned the lack of attention to greener forms of transport. In addition, the Plan says nothing about tree planting and other forms of environmental improvement.
Finally, we think that to allow only a six week period for consultation and comment for such a major proposal is so unacceptable as to be potentially wrong in law. We note that the Council have extended the period by two weeks but this is still well short of the normal 12 week period allowed for consultation, a period that many organisations extend for major projects. Is the Council simply trying to push this Plan through without allowing time for proper debate with and involvement of the people who will have to live with its impact?
The Radlett Society & Green Belt Association
2 November 2021
Hertsmere Borough Council (HBC) Local Plan – Update October 2021
HERTSMERE LOCAL PLAN 2022-2038
Hertsmere’ draft Local Plan for 2022-2038 is currently open for public consultation until 22 November. This Plan is based on their vision for developments in Hertsmere for the next 16 years and beyond. Over this period they aim to build a total of 12,160 new homes – at an average rate of 760 a year – with the majority in Borehamwood and Bushey plus in a new community of Bowmans Cross near London Colney.
Radlett currently has 3,360 homes and the Plan will add a further 940 (so an extra 28%) over the next 16 years. So at an average rate of of 58 new homes each year. A further 130 new homes will be built in the nearby villages of Letchmore Heath, Aldenham (including Wall Hall) and Patchetts Green.
Most of the new homes will be built on six sites including two new “sustainable neighbourhoods” known as R1 “North of Watford Road” (350 homes) and R3 “South of Shenley Road” (195 homes) plus HEL214 “South of Theobald Street” (75 homes), HEL220 “Porters Park Golf Club” (40 homes), HEL 272 “Cobden Hill” (10 homes) and HEL231 “Starveacres” (90 homes).
The Plan identifies a need for new infrastructure including a possible new site for an expanded Red House surgery on site R3 plus a new 2FE primary school on R1 and the ability to expand Newberries School to 2 FE into R3. There is no plan for a secondary school although a new one is planned for Bushey for Radlett students.
In line with Hertsmere’s commitments on meeting the challenges of Climate Change all new developments must be net zero carbon and, for example, be designed to deal with higher winds and heavier storms expected in the next few decades. The design codes detailed in the Radlett Neighbourhood Plan will be applied to all new homes being built here. New roads must be lined with trees and trees planted for every new home or other buildings. All new developments will be required to provide easy walkable access to local amenities.
The draft Local Plan is at https://www.
Look under “Resources”
You can send your comments to Hertsmere via their website or by email to [email protected] Or you even write a letter!
Hertsmere Borough Council (HBC) Local Plan – Update July 2019
Some further sites have been added to the proposals and a further request for comments issued. The details are in the following email – New sites put forward to help Hertsmere grow
Please have a look at this and send in your comments
Hertsmere Borough Council (HBC) Local Plan
HBC published an updated Local Plan and various exhibitions of it and the proposals were held around the area in November, including one at the Radlett Centre on the 20th November 2018.
Response to the plan were required by midnight on Thursday 20th December 2018. Further details of the plan and how to respond are given on the HBC website here (https://www.hertsmere.gov.uk/Planning–Building-Control/Planning-Policy/Local-Plan/New-Local-Plan-Planning-for-Growth.aspx)
The RSGBA has now sent its response to HBC and a copy of it is available here RSGBA LOCAL PLAN RESPONSE TO HBC
We strongly encourage you to give your own views of this plan to HBC