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Resident representation on Regulation 18 Consultation Document April 2026 Hertsmere Local Plan Dear Sir/Madam This is my separate and individual representation in response to important wider elements of the draft Local Plan beyond individual or grouped site allocations and you are required to take account separately of any representation from any person in accordance with the Planning Authority’s obligations, including under its Statement of Community Involvement and under the Town and Country Planning (Local Planning) (England) Regulations 2026. Overall I do not consider there is a need for the scale of development proposed. Based on local knowledge and experience, on the record of the Local Planning Authority in delivering sustainable development, and on the draft Plan’s supporting information, I consider that the scale and number of sites proposed across Hertsmere is neither sustainable nor deliverable. 1. The draft Hertsmere Local Plan is not yet supported by clear evidence of a quality that shows that a genuinely sustainable strategy including infrastructure and transport can actually be delivered in practice. Key supporting documents still identify major uncertainties around transport impacts, flood risk, school places, healthcare, water and wastewater capacity, viability and the timing of strategic infrastructure, while the Sustainability Appraisal itself accepts uncertain or negative effects in important areas such as climate mitigation. Since a Local Plan must be justified, effective and deliverable to pass examination, the present gaps in infrastructure, viability and delivery evidence create a serious risk that the Plan will be found unsound unless the Council can show, before submission, how its preferred strategy can realistically be implemented over the Plan period. 2. Bowmans Cross is correctly identified as a strategic new settlement but the draft Plan unrealistically limits delivery to around 500 homes in the plan period, despite evidence that the location can accommodate at least 4,000–7,500 dwellings overall. Earlier plan work and current promoter’s material consistently envisage a substantially larger first phase, with comprehensive, infrastructure‑led masterplanning. Increasing plan‑period delivery to at least 2,500 homes would make more effective use of agreed Green Belt release, strengthen the housing trajectory and flexibility, and in particular secure greater contemporary affordable housing and infrastructure benefits, thereby better meeting residents consistent feedback and improving the Plan’s soundness. 3. Housing design, Green Belt protection and affordability 3.1. I support the ambition of Policies HQD1–5 but question whether they will be effective without stronger delivery mechanisms, given Hertsmere’s mixed record on applying Neighbourhood Plan design codes and securing high-quality public realm. In Shenley and Radlett, and shortly in Borehamwood, existing neighbourhood plans, design codes and checklists already have set clear local expectations that must be given substantial weight as part of the development plan. The Plan should therefore be modified so HQD1–2 explicitly require compliance with Neighbourhood Plan design codes, design‑led masterplanning, independent design review, robust use of conditions and obligations, and ongoing monitoring of design and public‑realm. 3.2. The draft Local Plan’s approach to Policies H10 (New Homes in the Countryside/Green Belt) and H3 (Optimising Delivery from Small Urban Sites), together with Chapter 19 (Delivery and Monitoring), is currently too loose and risks undermining the settlement‑focused spatial strategy. As drafted, they could enable incremental and cumulative development in the countryside and Green Belt, and over‑intensification of small urban sites, with any resulting shortfall then used to justify further Green Belt release. The Plan should be amended so these policies are clearly subordinate to the spatial strategy, tightly defined, and supported by monitoring that prioritises delivery on allocated and brownfield sites. 3.3. Housing Policy H4 Delivering Genuinely Affordable Housing. The 30% requirement is not justified, not consistent with national policy, and will not be effective. The AECOM LHNA (March 2026) identifies affordable need at 58–70% of total need, and the Reg 18 text concedes the LHNA evidences a higher figure than 30%. The December 2024 NPPF permits contributions up to 50%, and sets 50% as the default on major Green Belt sites — which dominate Hertsmere. Selected sites now in the Green Belt will be removed from the Green Belt under exceptional circumstances in the Local Plan, so Policy H4 must be amended to require 50% affordable housing on all major sites, Green Belt or not, with the majority delivered as Social Rent, or it will be found unsound at examination. 4. The draft Plan must be strengthened so that on site infrastructure provision is the unambiguous default for both SCI3 (sports, recreation and play) and SD4 (greenhouse gas emissions). National policy expects infrastructure needs from new development to be met through facilities and for climate measures integrated into each site, with separate financial contributions only to address clearly justified residual impacts. Heavy reliance on off-site payments is less justified, less effective and harder to monitor, and may fail the legal tests for planning obligations. Unless policies are revised to prioritise on-site delivery, the Plan risks being found unsound at Regulation 19 examination. 5. The draft Plan’s borough-wide “car lite” approach is not yet convincingly justified or deliverable. While reduced car use is supported in principle, the evidence base does not show that strong parking restraint is realistic across all settlements, particularly rural and semi-rural areas. The Plan is unclear about how parking at retail sites and railway stations would be reduced, what alternatives would be in place first, and how town-centre vitality and commuter access would be protected. Policy TR3 and Chapter 7 should be amended to adopt a spatially differentiated, evidence-led approach that aligns transport, parking and economic objectives. My representation relates to the plan as consulted. Should there be any changes to the planning status of sites or to the supporting evidence base, it would be unreasonable to refuse acceptance of any further representation I may choose to submit. I request this as my separate and individual representation is taken in account as a response to Regulation 18 Consultation Document April 2026 Hertsmere Local Plan and made available to the Planning Inspectorate in due course. Yours faithfully

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