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My comments on your draft Local Plan “Planning for Growth” Dear Hertsmere Planning Department I am writing to oppose not only the ‘draft’ Hertsmere local plan in its entirety, but more specifically to oppose any development of any form or description, on site NS1: land at Coursers Road, Bowmans Cross new settlement. I oppose on all grounds, specifically regarding no. 5 individual place strategies and no. 9 Protecting the greenbelt. The greenbelt, including Bowman’s Cross, was created to prevent urban sprawl by keeping green buffers between settlements. They are the lungs of London and the surrounding areas, including London Colney and Colney Heath. Hertsmere’s plan is to build (initially) 2,500 ‘homes’ leading up to 6,000 homes on the site. The site is huge and covers the equivalent of 32,000 tennis courts and is around 4 times the size of the entire QE2 Olympic site in London. The site, despite being described, misleadingly, by Cllrs Cohen and Bright in a recent video as ‘poor quality’ is a high-grade swathe of lush green fields and habitat for all range of fauna and creatures including a colony of sparrows, bats, and birds of all description. In addition, there is ancient woodland dotted around the entire site which is rich in its natural beauty. It is a site used frequently by the public, as well as being home to farming and livery businesses who are unanimously opposed to this ruinous, misleading, and unworkable plan. The destruction of our green areas means a loss of natural habitats and is a threat to wildlife. 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. 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. It is stated frequently in the Draft Local Plan, and in public presentations, that it is a requirement for the Council to provide for housing need in full, as assessed by the Government formula (known as the ‘standard method’). 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, considering local circumstances and constraints. The National Planning Policy Framework (NPPF) allows councils to consider the presence of designated protected land, including the Green Belt, in determining (reducing) the appropriate housing targets. In addition, 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. Loss of farmlands means a loss of local produce. 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. The reuse of previously developed land is considered mainly in terms of the release of Green Belt land and some urban sites. This greatly underestimates the likely changes which are already affecting town centres, out-of-town-centres retailing, and commercial uses more generally. CPRE Herts estimates shows that only 46 hectares of brownfield (previously developed) land across the entire borough has been identified for redevelopment. The impact of the pandemic and projected social and economic trends is likely to create many more opportunities for the conversion of commercial and employment space to residential use. The expansion of permitted development rights which went into effect in 2020, further encourages conversion and change of use to residential purposes. I believe the opportunities for reuse and redevelopment accorded by all these changes are not sufficiently considered in the Draft Local Plan. Evolving changes in the nature of work, and the form and function of workspaces, are also not taken into account. A more positive house building strategy is needed as part of a detailed brownfield land review to realise the local enhancement of the existing built environment with benefits for existing and new residents. We are amid a climate crisis. How will we ever meet our carbon reduction commitments if we concrete over our green fields? With the recent COP 26 event, and the government finally realising they are upsetting their core voter bases, the PM and numerous cabinet Ministers are making clear signals toward a ‘pause’, or cessation, of the local plan process. Hertsmere have been urged to pause their local plan process numerous times but flatly refuse, instead choosing to produce a consultation portal that is purposefully difficult to navigate and comment upon, thus minimising, or silencing, ‘objections’ such as this. In addition, they have repeatedly refused to undertake their market research externally through an MRS (Market research society) registered company. This was clearly seen to be not fit for purpose when, in a previous so called ‘consultation, the Campaign for Colney response was omitted from the consultation findings document which, it was claimed, was an ‘oversight’. Pollution created by traffic from the 6000 new homes: In a recent meeting between the site promoters, Urban & Civic and a well-known political group, the possibility of 12,000 homes being built on the site was discussed. Despite asking Hertsmere most senior Councillor directly to refute this number, as of today he has refused to do so. Having come out of numerous lockdowns, the impact on residents’ mental health has been apparent to see, both locally and nationally. By destroying such rich habitats of nature, Hertsmere are doing little but exacerbating the mental health issues exponentially by continuing with this plan. HBC declared a Climate Emergency in 2019 and the Draft Local Plan is the key mechanism for the Council to implement the requirements of this declaration. Despite the requirements of the NPPF and the Planning and Compulsory Purchase Act 2004 and subsequent legislation, the proposed policies in the Local Plan fail to take account of the need for carbon reduction targets and sustainable transport provision, amongst many other concerns, and a carbon reduction pathway is needed to meet national obligations for net zero emissions by 2050. Campaign for Colney agree with the CPRE Hertfordshire that there is a need for more housing in Hertsmere as elsewhere, especially truly affordable housing for local people and key workers, but the projections used in the Local Plan are excessive and out of date. C4C also believe vehemently that housing should always be brown field first, which is an avenue that Hertsmere have been negligent in their exploration of. The Draft Local Plan identifies the Southwest Herts Local Housing Needs Assessment (LHNA) as the source of data for assessing housing need for Hertsmere. However, the LHNA uses out-of-date projections from 2016 Office of National Statistics projections. We firmly believe that the latest projections, currently available for 2018 and shortly to become available for 2020, as required by technical guidance, should be used. These show a projected decrease in new households in the Borough for the plan period, and therefore a reduced number of houses which should be planned for. The Council has also failed to take account of the National Planning Policy Framework (NPPF) as revised in July 2021, paragraph 11, footnote 7, which permits local planning authorities to restrict the scale of development due to planning constraints including protection of Green Belt and other designated areas and sites. Housing demand has actually fallen according to government data. The housing proposed, which is loosely proposed as 40% ‘affordable’, is, in reality, nowhere near affordable. The average salary in the UK of £29,600, whereas the average home, at the time of writing, in London Colney costs £415,000 (with huge increases in value year on year). With a 20% Affordable Homes discount this equates to £332k. With a 10% deposit of £33,200, this leaves a mortgage of £298,800. Therefore, on a X4 mortgage, you would need to earn £74,700pa minimum. The average UK salary is £29,600. Those starting off their careers will arguably be on below average income. Without the ‘affordable’ discount, the picture is even more stark: A minimum of £41,500 would be required for a deposit leaving an outstanding mortgage of £373,500. The household income would therefore have to be a minimum of £93,375 at current figures. If you are a young person attempting to get on the housing ladder locally, you have no chance whatsoever. With an 80kpa income placing you in the top 5% of UK earners, the only buyers would be investment vehicles, HNW individuals or property investors and developers. This entire site, which will generate (at current rates) over £10M annually through council tax revenue, not to mention new homes bonuses for Hertsmere BC, and is nothing more than council cash cow. The rhetoric of ‘affordable new homes for in need groups including families’ is little but a red herring. Families are not in need of homes. The planning think tank ‘Smart Growth UK’ are unequivocal, stating that the only shortage areas for housing are the demographics of ‘Single people and the elderly’. Hertsmere continue hell bent in their plan to not only desecrate this site but continue with wanton abandon in their refusal to ‘consult’ with local boroughs. The only face to face interaction, to our knowledge, regarding this plan, since the C4C group was formed in 2017, was a brief meeting of 20 minutes between the C4C founder, Brett Ellis and Oliver Dowden, Hertsmere MP, in 2018, where Mr Dowden admitted ‘if it were up to me, id say no more homes anyway’. He continues to refuse to oppose the plan despite being the self-appointed ‘defender of the green belt’. Cllrs, including Bright and Cohen have been invited to numerous events in London Colney but have refused to attend any. Despite their refusals, they have included the new London Colney Summerfield’s medical centre in their plan as a primary healthcare resource for new Bowmans cross residents. They have continually misled residents about the site, have refused to hold consultation events in the St Albans borough and, when they did hold face to face consultations, in Hertsmere, their planning department openly told mistruths to the public. When highlighted by C4C, one presenter stormed off and refused to engage with the numerous objections made. There are arguably clear conflicts of interest. Years have been spent opposing this site, and other green belt sites being developed on, in the borough. It is apparent that the vast majority of the Hertsmere housing quota is being ‘dumped’ away from the voter bases as again politics are put above residents’ concerns. There is an ongoing refusal to listen to objection, as the refusal to hold face to face consultations, despite continuing with face-to-face council meetings shows. Promotional literature and videos are clearly biased toward this site being of ‘poor quality’ as the surrounding infrastructure, already choked with traffic, will be strangled should the development goes ahead. In a recent meeting, even Urban and Civic raised serious concerns as to site access. I oppose this plan, in its entirety, in the strongest terms. I object to building on all sites, namely BE1, BE3, BE5, BE6, HEL152, HEL197, HEL218, HEL369, HEL388, HEL601, HEL212, HEL274, HEL175, B3, B2, B1, HEL235, HEL337b, HEL337c, B4, HEL386, HEL502, HEL505, HEL521, PB2, PB3, HEL162, HEL177, HEL216, HEL318, HEL375, R1, R3, HEL214, HEL220, HEL222, HEL231, HEL348/349, HEL390, HEL228a, HEL228b, HEL320, HEL385c, NS1, HEL345, HEL179, HEL 180, HEL199, HEL219/252, HEL509, Media Quarter. Yours sincerely

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