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My comments on your draft Local Plan “Planning for Growth” Dear Hertsmere Planning Department Dear Sir/Madam I strongly object to the Local Plan for Hertsmere, which will cause irreversible harm to the borough, and I object to the de-classification and development of greenbelt land in ANY location in Hertsmere and on ALL sites named in this Draft Plan (in no particular order) namely: 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, HEL180, HEL199, HEL219/252, HEL509 I request that I am given the opportunity to attend any public meetings arranged by Hertsmere Borough Council in respect of this plan and that I am informed of the dates and times of any such meetings and that they are publicised widely. In his speech on 6th October 2021, The Prime Minister clearly stated that new homes would be built on brownfield sites and not green fields. This is now backed up by the Budget announcement prioritizing brownfield re-development, with recent research by CPRE identifying brownfield sites, in England alone, which could accommodate 1.3 million new homes, a 10% increase on 2020 figures. I want Hertsmere Borough Council to uphold this pledge and preserve the borough’s greenbelt. The draft plan is flawed and based on out-of-date data and in continuing with this plan it is over-provisioning housing. HEL521 BUSHEY HALL FARM SITE The proposed plan for this site would have devastating effects, bringing with it increased traffic and air pollution, further water stress, through increased demand, driving over abstraction of the chalk aquifer and threatening the nearby River Colne. The biodiversity of the area would be negatively impacted by the destruction of habitat, whilst increased traffic and development will amplify surface water run-off, creating a greater risk of flooding and pollution of the nearby River Colne, which is one of Hertfordshire’s rare chalk streams. There are many reasons why site HEL521 should not be included in the Local Plan and were previously identified in previous iterations of the plan but are now largely being ignored, but with no material changes to the site which would support its inclusion for development. Many of the following reasons apply to ALL the sites listed above. Air Pollution Clean air must be a priority in the battle to reverse climate change. With Hertsmere declaring a climate change emergency, the destruction of green spaces, fundamental to the sequestering of carbon from the atmosphere, must be prevented at all costs. Clean air, free from increased traffic pollution must also be the right of all residents of Hertsmere. Increased traffic in the area, from both private and commercial vehicles, entering and leaving the industrial area via Bushey Mill Lane will negatively impact air quality in North Bushey. Amenity space HEL521, like many of the sites listed above, has a public right of way, used daily by local residents to access the local walking routes across Otterspool and beyond. These routes will be negatively impacted by large-scale increases in development, losing their purpose as valued open space in otherwise built-up areas. North Bushey itself has few green spaces or parks accessible without a car; our nearest large public parks, with family amenities, being King George’s in Bushey and Cassiobury in Watford. Flooding The impact of large-scale development on climate change cannot be overstated, especially where it replaces green spaces and the resultant increases in CO2 directly affect the warming of the planet. With warmer climate comes an increase in storm rainfall, which is responsible for the huge increases in UK wide flooding witnessed every year. Part of the HEL521 site is within the local flood plain and the roads around North Bushey, Little Bushey Lane, Watford, the River Colne and Hilfield Brook all suffer from the impacts of significant flooding as a result. Developing this land, which, when considering the overall local topography, sits at the bottom of a hill in the river valley, will negatively impact the flood plain, potentially increasing flooding in the immediate area or pushing it along stream to other areas of the Colne, such as the Radlett Road Park and Watford. Any flooding would have the additional negative impact of polluting the Colne with surface water run off from the new industrial area and proposed housing, which will have brought with it an increase in cars, lorries and other industrial vehicles. Hilfield Brook also carries the overflow from the Hilfield Reservoir, which in turn discharges into the Colne and with increases in rainfall it could reasonably be expected that the reservoir will be more often at capacity. Any building on land at its lowest point will be subject to risk of flooding, making HEL521 a wholly inappropriate site for development. Lack of local infrastructure Small roads already busy with traffic and parked cars, often at a standstill during busy times cannot accommodate the large increases in traffic these developments will bring. HEL251 is situated in an area protected by width restrictions, to reduce and discourage large vehicular access from the Bushey Mill Lane and Park Avenue entrances, meaning large vehicles must enter from Hartspring Lane. With the entrance for the new industrial area located in Bushey Mill Lane, just after the width restriction, lorries will be tempted to use the ‘Buses only’ central area of this width restriction in order to avoid having to travel along Park Avenue and up Bushey Mill Lane from the southern end. Likewise, an increase in commercial traffic along Park Avenue is unacceptable as, since the conversion of the ‘Smith’s’ building into flats, the parking along the road has made it impassable, in places, to more than one car at a time travelling in opposite directions. These roads cannot adequately deal with such an influx of traffic. Neither is the area served well by public transport links, there are few and irregular bus routes in and out of North Bushey, and the nearest train station is located a 30-minute walk away, meaning the majority of residents are reliant on private cars or taxis to access local facilities such as shops, supermarkets, medical services, and entertainment. The local two form entry primary school is already oversubscribed. Loss of Greenbelt The Greenbelt has a unique role to play in capturing and sequestering carbon from the atmosphere long term. We cannot fight Climate Change without it. In our battle for clean air, the Metropolitan Greenbelt is our most valuable asset and must be preserved without question. Inherent to the concept of the Greenbelt is its permanence. It has a crucial role to play in separating settlements, which otherwise would result in an urban sprawl. In this case, the 22 acres of land at HEL521 is the final buffer between Bushey and Watford and its removal will take with it the unique local character of the area. Overall, the combined size and scale of the plan’s proposals will remove a total of 1025 hectares of greenbelt from Hertsmere and I object to this entirely. Noise and light pollution Site HEL521 is bordered by the A41, M1 and A4008; noise pollution from these roads would be significant for any housing planned on the site, as is light pollution from surrounding street lighting and mist significantly from the floodlights at TopGolf. The close proximity of industrial units will exacerbate this further, adding to the noise and light nuisance already affecting existing residents of the area. Local residents also suffer significantly throughout the year, but particularly at nesting times, from the dreadful noise and guano issues caused by huge flocks of gulls, who use the industrial units as nesting sites. Increased numbers of industrial units on the HEL251 site will exacerbate this well publicised problem, which severely impacts the lives of local residents and for whom an increase in potential nesting sites would be untenable. Over-development According to the Government’s own figures housing demand is falling and this has been highlighted by the CPRE. The data used is out of date and exaggerates future requirements. North Bushey does not need or want further housing or industrial development on areas of its last remaining greenbelt, thereby changing its nature forever. Families choose to live here for the community’s character and its semi-rural feel, whilst maintaining close links to London. Water Stress It is well publicised that the chalk aquifers that supply the majority of the area’s water are already hugely over-abstracted and under severe stress, causing nearby chalk streams in other boroughs, such as the rivers Ver and Misbourne, tributaries of the River Colne, to run dry. Within the next few years, Affinity Water, who own site HEL521, will have fitted water meters to all properties in North Bushey in an effort to reduce consumption. Large-scale developments, both residential and commercial will negate any gains made from domestic water-metering, as will the construction process. If high volumes of water continue to be abstracted from the aquifer, the rich biodiversity supported by the chalk streams they feed will be lost forever. Of the 210 chalk streams classified globally, 76% are in England and 10% of these are in Hertfordshire. Herts Wildlife Trust have recently stated that urgent action is needed to protect these rare habitats, as they continue to come under severe pressure from pollution and over-abstraction of water for domestic and commercial use. Wildlife The greenbelt in Hertsmere is the natural habitat of a vast range of flora and fauna. On site HEL521 alone there have been sightings of grey herons, red kites, kestrels, buzzards, sparrowhawks, foxes, owls, bats and many other small birds. Alongside these, a wide variety of wild-flowers and grasses, established hedgerows and mature oak trees support an immense number of insects, including many species of butterfly and grasshopper. Elsewhere in Hertsmere badgers, muntjac deer, rare tree sparrows, moles, voles, field mice, skylarks and snakes are amongst some of the species whose habitats would also be permanently destroyed. Many of these species are protected or on red endangered lists. In addition to my comments regarding HEL521 and ALL other sites in the proposed draft plan, I would like to make specific additional comments on the following sites: R1 LAND NORTH OF WATFORD ROAD, INCLUDING KEMPROW. The Watford Road is already an extremely busy thoroughfare and this site, next to a primary school will expose children to higher levels of pollution. The site comprises farmland which should maintain its agricultural use. There are listed buildings in the area, a tree preservation area, 2 local wildlife sites and a public footpath. HEL345 ALDENHAM GLEBE The Roundbush Garden Centre has been based here for 60 years, with the family having worked the land for 100 years. I object to this site being proposed for housing of any kind. This is also within the conservation area of Roundbush. There are listed buildings in the area and the land is part of the greenbelt. B1 HARTS FARM AND FIELDS The development at Harts Farm will generate some 1200 additional cars on the already congested Little Bushey Lane. In a recent traffic study, figures demonstrated an increase of 12% in three years, with a 32% increase between 09:00 – 09:30. The site itself and surrounding roads have been identified as flood plain by the Environment Agency, ranging from medium to high risk. Little Bushey Lane already floods as does the new development at Rossway Drive, a further 350 houses on the site will exacerbate this risk. Additionally, the nearest bus route, which has a limited evening and Sunday service, is a ten-minute walk away. This lack of accessible public transport makes any development entirely car dependant, which will intensify the pressure from traffic on the surrounding roads, especially when considered in conjunction with sites B2 and HEL521 (see below), which are in close proximity, with proposals for a further 750 homes, 80 homes and a large extension to the Otterspool Way Industrial area. B2 LAND NORTH OF FARM WAY – COMPASS PARK This land makes an important contribution to the gap between Bushey, North Bushey and Watford. Maintaining an unspoilt rural character, any development would significantly reduce the gap between these areas, contributing to urban sprawl. The increase in traffic levels in recent years already impacts the area negatively. Little Bushey Lane, Aldenham Road and Bushey Mill Lane are especially busy at certain times, with traffic queuing from the Aldenham Road traffic lights, in all directions, with waiting times often exceeding 20 minutes. An increase in housing and commercial buildings both here and at sites B1 and HEL521 will add exponentially to the traffic and worsen the already poor air quality experienced in the area. New housing and commercial development on these sites will potentially bring thousands of vehicles to the area. As with all the other sites, there is insufficient infrastructure and additional homes will put greater strain on this. The two nearest secondary schools are oversubscribed as they also serve neighbouring towns. There is no public transport on Little Bushey Lane and the nearest bus routes are on Aldenham Road or Farm Way. The nearest train station is a 30 minute walk away. Development on this, and sites B1 and HEL521, will result in additional cars on already heavily congested roads, leading to increased emissions. Like sites HEL521 and B1, flooding in the area is already a problem. During heavy or continuous rain, the surface water pours off the fields onto Little Bushey Lane, causing pools of water to form. The existing sewers are unable cope with this volume of water, causing untreated and polluted water to be discharged into local waterways, which form part of the areas rare chalk stream habitats. Documentation shows that Farm Way and Bournehall Avenue are at risk of flooding and Homefield, Springcroft and Finch Lane have flooded in previous years. As these roads are below the level of the fields, and any development would severely increase the risk of flooding to existing homes. Thank you for giving due consideration to my comments and I hope that any decisions made regarding the Local Plan will take all of these important factors into account and carefully assess the impact that development of this scale will have upon the unique character of Hertsmere. Yours faithfully,

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