Your name

Your email

First Line of Address

Your Postcode

Subject

Message (Edit just as you wish)
OBJECTION TO PLANNING APPLICATION 22/2149/OUT ORGAN HALL FARM Dear Sir/Madam Please find below my objections to planning application 22/2149/OUT Organ Hall Farm. This objection should be taken as my separate and individual submission in accordance with your agreed policy. 1. Inappropriate Green Belt Development in relation to the current Hertsmere Local Plan. a. The current Local Plan 2012-2027 Core Strategy sets out where and what type of development should take place in the Hertsmere Borough Council (HBC) area and states explicitly in respect of Borehamwood (2.35); “The Council continues to have a five-year land supply of housing sites and it is not envisaged that any strategic housing development in the Green Belt would need to be considered within the plan period“ b. As such, this application for large scale Green Belt development, contravenes the current Local Plan, as well as the principles of sustainable development set out in the NPPF Clause 142 2. Unjustified Claim of Housing Need: Principle of Consistency a. When recommending the refusal of planning permission for application 22/0971/OUT, Harris Lane Shenley on 20.10.22, the planning officer reported that HBC has over-delivered every year against housing target numbers and therefore arguments suggesting development is needed to meet the 5-year land supply must be disregarded. To uphold the principle of consistency in planning law it would therefore be inappropriate to consider unmet housing need as a valid justification for this development. b. The recent Government announcements on flexibility on Housing Targets, including 5-year land supply, especially in the context of Green Belts, is also now a material consideration. 3. No Precedent from Shelved Local Plan a. Equally, ongoing attempts to legitimise this site ( and indeed other such sites) with reference to it being mentioned in the failed, Section 18 consultation on the Draft Hertsmere Local Plan (2021) have no validity. As the Planning Officer confirmed during the HBC Planning Committee Meeting of 20.10.22, the draft Local Plan was rejected demonstrating that HBC had failed to establish a strategic need for changes to Green Belt boundaries. b. As it is only via the Local Plan process that changes to Green Belt boundaries can be proposed, no applications to develop on Green Belt land can therefore considered / granted while we are awaiting the development of the next Local Plan unless very special circumstances can be proven. 4. Inappropriate Development in the Green Belt a. The developers have underestimated the value of this site in checking the unrestricted sprawl of urban areas, and in preventing the neighbouring towns of Borehamwood and Radlett from merging together. b. The proposed site is exceptionally poorly located, tenuously connected to the outskirts of Borehamwood, with no attempt to integrate with the existing development. The site is not an infill, but an outward extension to the urban area of Borehamwood, eroding the valuable countryside space between Radlett and Borehamwood and does not achieve a continuation or extension of existing development. c. As such this application manifestly is contrary to at least three of the purposes of the Green Belt: 1). to check the unrestricted sprawl of large built-up areas; 2). to prevent neighbouring towns merging into one another; 3). to assist in safeguarding the countryside from encroachment; d. When Borehamwood was extended to the north-west after WW2 and further extended in the mid-1970s, there was a clear demarcation line established which bordered the Green Belt following a line to the north west of Rossington Avenue, Berwick Road and the Campions. This boundary was only broken when the Council gave consent for the development of the same applicants recent advent Organ Hall Farm site (20/0525/FUL). However it should be noted that this application was only considered acceptable by reason of "very special circumstances" where it was resolved that the site did fall under the definition of Previously Development Land. This does not apply to this current application 5. Harm to Biodiversity a. The application site supports a rich diversity of wildlife, both mammals, amphibians and birds and includes muntjac deer, heron, toads and bats, and is used by the local community in both Radlett and Borehamwood for exercise and enjoyment. b. In particular this site contains kingfishers, a schedule 1 protected bird species under the Wildlife and Countryside Act 1981, which lays out penalties for disturbing the birds. Kingfishers are territorial, inhabiting the river banks year round, and are particularly vulnerable to changes in the river and its environs. Human presence nearby can cause nesting birds to fail to return properly to feed their young, and cause fledglings to die. 6. Traffic Issues a. Eroding the buffer between Borehamwood and Radlett would cause an already stressed and gridlocked local road system to falter even more, require substantial new utilities infrastructure, increase pollution and erode the trust residents have put in the Council to preserve our towns and villages. b. Morning rush hour queues on Theobald Street typically extend for over a mile in length at peak times currently. In addition, the existing Station Car Park is already inadequate to cope with the number of daily users and as is parking within Borehamwood town centre which currently has limited availability. c. No direct, dedicated, upgraded access for pedestrians and cyclists to Elstree and Borehamwood station is proposed and so additional housing in this development will inevitably add to existing traffic. A medical centre would be largely inaccessible except by use of more private cars. d. All in all this site would produce substantial increase in vehicle journeys causing additional air pollution resulting from vehicle exhausts, resulting in considerable carbon dioxide and particulate pollution, which are all contrary to local development policies 7. Flooding, sewage and infrastructure a. The Organ Hall site is crossed by two Main Rivers (as defined by the Environment Agency) and both of these streams are bounded by areas of National Flood zone 3. Insufficient efforts have been made by the developer to keep all new building well clear of the flood zone. In particular, the proposed Care Home and buildings on plots 108, 109, 114 and 115 are very close. b. The existing sewage disposal infrastructure is incapable of coping with any additional load. The main sewer crossing the application site and to which the Organ Hall Farm development (The Grain Yard) has been connected, regularly overflows and deposits raw sewage into the adjacent Tykes Water and along the green lane (BOAT) in Radlett. c. Building on this site will inevitably impact on the flood zone itself, as well as secondary sewage overflow, to the detriment not only of future occupants of this development, land and residents downstream from the development and demonstrate that the overall infrastructure for these ongoing ribbon developments at this location is wholly inadequate. 8. Unsustainable in context of local and national planning policy a. HBC has published three draft Supplementary Planning Documents, which provide detailed advice or guidance on our current planning policies. They include details on how HBC intend to promote sustainable transport and parking through prioritising brownfield developments and how they intend to ensure developments over a certain size result in an increase in biodiversity. These are now interim guidance in the determination of planning applications on or after 15th September 2022. This development is neither brownfield nor would it result in an increase in biodiversity b. 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 developed upon, merely on the promised provision of someaffordable houses. This would therefore promote a pattern of unsustainable development and harm to the Green Belt, in clear contravention of ALL key provisions in the NPPF and the current Local Plan. 9. Erroneous claim of care home needs HBC accepted in June 2020 that there was a 300 space surplus in care home space provision in this local area ( as demonstrated by the very same applicants in 20/0225/FUL). So it is not feasible that within two years there is a sudden urgent requirement for care home spaces in the same area as this application less than 1.5 miles away. This applicant cannot have this both ways! Thank you for your time in considering these objections and for your commitment to upholding the principles of sustainability and consistency in planning. Yours sincerely,

I agree to the Privacy Policy