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Planning application 26/1236/OUTEI Dear Sir/Madam I object to the proposed development of up to 650 homes at Home Farm. This objection should be taken as my separate and individual submission in accordance with your agreed policy I recognise that more housing is needed, and I welcome in principle the idea of providing a school and open space if delivered. But those benefits do not remove the serious problems with this particular site. As this site is outside Radlett’s settlement boundaries, NPPF Policy S5: Principle of development outside settlements, applies and I am especially concerned that Hertsmere is being asked to approve the main access now, before a number of fundamental questions about the development have been properly answered where national decision-making policies must be read as a whole and Policy S5 must be taken into account. In particular I draw your attention to these aspects and the related decision-making policie . 1. Green Belt, countryside and footpaths NPPF policy GB8 on Green Belt development conditions is also relevant to the safeguards that would be required if permission were contemplated. I do not accept that this large area of open countryside can be treated as though its loss is unimportant simply because the applicant describes it as “grey belt”. The development would permanently change the open character of this part of Radlett. The applicant’s own landscape assessment identifies significant effects that would remain even after 15 years of new planting. The Council must apply the National Planning Policy Framework (NPPF) policies GB6 and GB7 (Green Belt development decisions), including the provisions relating to grey belt, not just accept the applicant’s preferred description of the land. The local footpaths, including the Hertfordshire Way, are heavily used and much enjoyed. They give residents access to peace, rural views and countryside close to home. New paths through a housing estate are not a substitute for that experience. 2. Traffic, Watling Street and the proposed access My greatest practical concern is the traffic. Watling Street is already a busy road, and the proposed signal-controlled junction will have to serve a substantial new neighbourhood. The assessment needs to show convincingly what happens at peak times, including when other planned developments are added. It is not enough to assume that many new residents will choose to walk, cycle or take the bus. Radlett station is around 1.9 km from the site and is not fully step-free; existing bus services are limited. A proposed future bus service cannot be treated as though it is already available and dependable. The Council must be satisfied that the junction and surrounding road network can operate safely and acceptably, having regard to NPPF NPPF transport policies TR3 and TR6, before it grants outline consent for access. So I draw your attention to the Traffic Assessments in your possession, as submitted to you as the Planning authority by Aldenham Parish Council in their recent Regulation 18 Local Plan submission as being professional produced data directly relevant and so a material consideration as being relevant evidence requiring your explicit consideration before determination. 3. Common Lane must not become another estate road The connection towards Common Lane is a particular concern. The National Design Code, M.3.iii Services and utilities 53, requires that new development needs to take into account a range of practical requirements for streets and public spaces such as servicing requirements, access to utilities and reinstatement of road surfaces. If these are not considered they can undermine the quality of space. Therefore access should be for pedestrians and cyclists, with genuinely emergency-only vehicle access. There must be a physical and enforceable arrangement that prevents ordinary residents, deliveries, contractors or construction traffic from using it as a second access or shortcut that would undermine both National Design Code and NPPF TR3 requirements. I would not be reassured by a simple sign or a barrier that could routinely be opened. This protection needs to be designed into the permission at this stage as this is a fundamental issue of access. 4. Schools, doctors and other services The proposal refers to a one-form-entry primary school, with land reserved for possible expansion to two forms of entry. However, the school is not expected to open until approximately 350–400 homes are occupied. At the rate of 50 homes per year used in the applicant’s construction traffic assessment, that could mean a wait of seven or eight years from the first occupations. Where will those children go in the meantime? There is no new secondary school on the site, and local GP and other services are already under pressure. The Council should obtain much clearer Section 106 commitments about the size, funding and timing of facilities, rather than leave these matters to be resolved once hundreds of families have moved in. 5. Flood risk – the applicant’s own test The applicant’s Flood Sequential Test expressly concludes that Home Farm does not pass the Sequential Test and identifies another reasonably available site with a lower flood risk. That is a serious issue under NPPF policy F5 on the Sequential Test. The applicant argues that other planning benefits justify proceeding, but that is not the same as demonstrating compliance with the Sequential Test. Hertsmere should explain clearly how it proposes to address this failure before any permission is granted. 6. Water supply and sewage I am not satisfied that the effects on water supply and wastewater infrastructure have been properly resolved. The applicant’s estimated water use of 104.2 litres per person per day is considerably below Affinity Water’s reported average actual use of around 153.9 litres. Thames Water has also indicated that foul sewer reinforcement will be needed. With further housing and major commercial developments proposed nearby, the Council needs a realistic, cumulative assessment and a clear programme for any necessary upgrades before homes are occupied as enforceable conditions for this development. 7. Historic buildings at Battlers Green The historic buildings and setting at Battlers Green are an important part of the area’s character. I am particularly concerned about the effect of bringing a large modern housing estate so close to this attractive historic group, including Grade II* listed Battlers Green House. The issue is not simply whether the buildings themselves will be touched, but how their rural surroundings and the way they are experienced will change. The Council should give proper weight to that harm under its statutory duties towards listed buildings and NPPF policy HE6 on designated heritage assets. 8. Wildlife, ancient woodland and valuable farmland The development would remove approximately 41.7 hectares of best and most versatile agricultural land, including Grade 2 and Grade 3a land. That is a permanent loss which should be given real weight under NPPF policy N2(1)(b) on agricultural land. Hertfordshire’s ecology advisers have said that there is insufficient information to determine the wider application. Outstanding issues include ancient woodland, protected species and the loss of skylark breeding habitat. A claimed biodiversity net gain figure does not, by itself, answer those concerns. The Council must also consider the biodiversity and habitat requirements of NPPF policy N6, as well as the effects on the countryside under N2. The Council should require the necessary surveys, mitigation and compensation evidence before determining the application, having regard in particular to NPPF NPPF policy N6(2) on ancient woodland and veteran trees on ancient woodland and veteran trees. 9. Construction and the combined effect of other developments The Environmental Impact Assessment Regulations 2017 require the environmental effects of this EIA development to be properly assessed, including relevant cumulative effects. The impact would not end with the completed houses. Construction traffic, noise, dust and disruption could continue for years. There is also an unresolved difference between an earlier suggested five-to-seven-year build-out and the construction traffic assessment’s assumption of 50 homes a year, which would amount to 13 years for 650 homes. Residents deserve a credible programme and enforceable controls. Above all, this application cannot be considered in isolation. Other housing allocations, warehousing, energy infrastructure and the proposed A41 data centre may together place much greater demands on local roads, water, services and the countryside than any one scheme suggests on its own. For these reasons, I ask Hertsmere Borough Council to refuse the application. At the very least, the Council should not determine it until the outstanding transport, flood-risk, infrastructure, ecological and cumulative-impact questions have been properly resolved because of their obligation to consider national decision-making policies must be read as a whole. Yours faithfully

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