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Dear Sir/Madam Please find below my objections to planning application 22/0971/OUT 1. Not in line with Shenley Neighbourhood Plan The proposed development is not in line with Shenley Neighbourhood Plan. The Shenley Neighbourhood Plan received overwhelming support in the referendum. 96% of respondents to the Shenley Neighbourhood Plan want HBC and Shenley Parish Council to protect the green belt, the rural feel of the village and Shenley's open spaces and countryside views. This site is a green belt field at the rural edge of the village in a location which is used and enjoyed by the whole community, and as such should be protected. An urban density development of this site would ruin the rural edge of the village, harm the rural village character, and set a precedent for destruction of green belt land in Shenley and beyond. 2. The report on the Green Belt commissioned from Arup by Hertsmere Borough Council during the Local Plan Consultation period 2020-2021 specifically rejects changing the green belt boundary for this site: Arup refer SPECIFICALLY to this site (SH5 in their report) and conclude: “It is recommended that no alternations are made to this section of the Green Belt boundary”. This is not least because removing green belt protection would contravene provisions a), e) and f) of Clause 143 of the NPPF in that there is a lack of distinctive physical features which would prevent further urban sprawl back towards London Road across Pursley Farm (which was also put forward for development during the Local Plan consultation). As noted in section RC-3 (Parts of SA-27 and SA-28) of the Green Belt Stage 2 Assessment report (page 86), “the eastern boundary of SA-27 is weaker and less readily recognisable, comprising the Catherine Bourne watercourse which is very small in scale and partially culverted;” . There is no information in the Local Plan to explain how the boundary of the housing estate would be strengthened to protect further encroachment into the Green Belt.” 3. Contravention of the National Planning Policy Framework (NPPF) The National Planning Policy Framework (NPPF) is designed to guide Councils and Planning Authorities in decisions concerning green belt land. Its main thrust is the preservation of such land for the enjoyment of future generations, ensuring a pattern of sustainable development and the prevention of urban sprawl. Site 22/0971/OUT is NOT a sustainable site under NPPF provisions in Clause 142. Neither Harris Lane nor Shenley are ‘well-served’ by public transport. The only bus serving Shenley is the 602 which runs only once an hour and does not serve Borehamwood & Elstree station – the preferred destination of most commuters. The site is also unsustainable because Hertfordshire County Council have firmly declared they will not increase GP or primary school places in Shenley, nor will they invest in any road improvements. As things stand: • There are no more GP places available in the Shenley GP practice • There are no more primary school places available in Shenley Primary School • There are no employment vacancies/planned increase in employment for Shenley meaning that any new residents will have to commute – mainly by car • Harris Lane is single file traffic only and suffers greatly from congestion already at the London Road end at peak times. The NPPF also uses the term ‘sustainable patterns of development’. If this site is released from the green belt, it would act as a precedent for any green belt field in an unsustainable location to be taken out of the green belt merely upon the promised provision of a few ‘affordable’ houses and would therefore promote a pattern of unsustainable development in clear contravention of ALL key provisions in the NPPF. In any case, the government’s own commentary on the NPPF declares that unmet housing need is NOT a very special circumstance capable of outweighing the harm caused by inappropriate development in the Green Belt. The NPPF considers all unsustainable development inappropriate and therefore this application cannot be approved without contravening the terms of the NPPF and government housing policy. 4. Site 22/0971/OUT is NOT an appropriate location for affordable housing and would result in inappropriate development. The NPPF states that “Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances”. Application 22/0971/OUT’s only claim to ‘exceptionalism’ rests on the provision of a very small amount of ‘affordable housing’. However, any such housing built here would not be ‘affordable’ in real terms. The land itself is among the most expensive in the Parish so would result in the LEAST affordable, ‘affordable’ housing in the Parish. If the goal is to provide affordable housing, then a sustainable site, well served by frequent public transport, with available GP and primary school places should be sought. Preferably this should be done as part of the Hertsmere Local Plan process where such considerations can be evaluated on a holistic basis. 5. Application 22/0971/OUT would do considerable harm to an area of tranquillity, which is also a well-used and prized community amenity. The NPPF also states that “planning policies and decisions should also ensure that new development is appropriate for its location taking into account the likely effects (including cumulative effects) of pollution on health, living conditions and the natural environment… In Clause 185, it states that these policies should: …identify and protect tranquil areas which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason.” Harris Lane is such a ‘tranquil area’ which has ‘remained relatively undisturbed by noise’ (including traffic) and is therefore prized for its ‘recreational and amenity value’. Development on this site would spoil the precious and beautiful rural edge of the village, ruin the tranquility and attractive open views opposite the playing fields and deprive the community of the quiet enjoyment of Harris Lane and Harris Lane playing fields. Because the area opposite the park has only 4 houses, the traffic is infrequent, making it a safe as well as beautiful spot for cyclists, horse-riders, joggers, walkers and dog walkers. This amenity value is special to the whole community – who enjoy coming and going from the playing fields in safety as well as walks along Harris Lane (more suitable in the winter when the fields are boggy) all year round. It also provides a pleasant route to access local lanes and footpaths. Approving this application would diminish the wellbeing of a diverse range of Hertsmere residents whose amenity value derives from the absence of noise, the absence of danger from traffic and the absence of the built environment. 6. Development on this site would harm the biodiversity and ruin a valued and beautiful landscape. The NPPF states that “planning policies and decisions should contribute to and enhance the natural and local environment protecting and enhancing valued landscapes, sites of biodiversity … and recognising the intrinsic character and beauty of the countryside”. This site provides valued landscape views for people living in and using Harris Lane. This site is a large area of natural grassland surrounded by trees and hedgerows. It is home to many species, including protected species, such as bats. The developer claims that destroying this area of natural grassland will have ‘net biodiversity gains’ but there is no evidence given to support these claims. It seems unlikely that biodiversity could be improved by digging up and concreting over 70% of the field and increasing human habitation, vehicles and the accompanying noise and pollution. 7. Lack of support for development of this site was already registered during the Hertsmere Local Plan Consultation in 2021. The failure of the Hertsmere Local Plan (now shelved) to meet with public approval demonstrated that HBC’s strategic policies failed to establish a need for changes to Green Belt boundaries. Thousands of residents, including children, objected to the number of houses proposed and the threat posed to precious green belt land. Developers are seeking to exploit the absence of a Local Plan to target green belt land site by site. This, or any other application to develop on green belt land should not be considered/granted while we are awaiting the development of a Local Plan that will consider all potential sites across Hertsmere and decide which are both suitable and sustainable. In addition, HBC has not updated its brownfield register, so any claim that this site is required to accommodate housing need must be disregarded as unsupported by evidence. In line with government policy, Hertsmere Borough Council (HBC) should seek to maximise brownfield and other suitable, sustainable sites. HBC has also over-delivered in each and every year against its housing supply targets. There are a number of developments already underway in the Parish, and a further application for 180 houses on Shenley Grange currently under consideration. There is therefore is no case to suggest that this development is needed in respect of the 5 year land supply. Hertsmere Borough Council will not be able to demonstrate the NPPF requirement that it has ‘fully examined all other reasonable options’ for meeting its identified need until a new local plan has been developed and assessed. Hence, this application should not be considered/granted while we are awaiting the development of a new Local Plan. Your time in considering the matters raised below is much appreciated; as Planning officers and Councillors you are entrusted with weighty decisions which leave a legacy that will be remembered for years to come. Yours sincerely

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