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Dear Sir/Madam 24/1211/OUT | Outline permission (with all matters reserved except for means of access) for the erection of up to 195 new homes (50% affordable), safeguarded land for the expansion of Newberries Primary School and provision of a new medical centre, along with associated access, landscaping and parking. | Land South Of Shenley Hill Radlett Hertfordshire. This application is essentially the same as previously made in respect of rejected application 22/1539/OUT (ref 1), the rejected appeal to the same (ref 2), and the subsequent failed High Court case ref (3). Hence I agree with the thousands of previous objections that remain valid and it would be perverse not to take into account these previous issues, which I provide as part of my current objections (ref 1,2,3) as being material to this application. This objection focuses on further claims made in 24/1211/OUT and should be taken as my separate and individual submission in accordance with your agreed policy. GREEN BELT Application 24/1211/OUT ignores the findings of the Planning Inspectorate and the High Court on the weighting given to Openness and Green Belt purposes for 22/1539/OUT. The Planning Authority should be confident in standing by their own previous decisions on Green Belt weighting and those of the Inspectorate and High Court rather that giving any credence to rehashed further third party consultants paid for by the applicants, and as such for the financial interests of the applicants. GREY BELT The reasons the applicant has attempted to override the findings of the Planning Authority, Inspectorate and High Court are a misleading attempt to invoke grey belt status for this land and in doing so, justify the development. The applicants submission selectively quotes national planning proposals to make such a specious argument. References to the actual grey belt proposals highlights that this land at Shenley Hill is “not previously developed,” the Inspectorate’s “strong effect or impact against the Green Belt purpose” of “Assist(ing) in safeguarding the countryside from encroachment” and the Inspectorate’s finding in respect of Green Belt purpose “to prevent towns merging into one another” that “is important to spatially preserve open land between such settlements if the policy is to continue to be an effective planning tool in the Metropolitan Green Belt.”. As such this application completely fails to make the proposed required case to be grey belt. More plainly Government Ministers have: “been very clear about building on the grey belt,”. They make it clear that grey belt is “areas people wouldn’t recognise as green: disused car parks or petrol stations. This land south of Shenley Hill is manifestly greenfield Green Belt , and has never been a “disused car park” or a “petrol station”, or anything similar. To claim otherwise is highly misleading. CLAIMED BENEFITS Application 24/1211/OUT again ignores the findings of the Planning Inspectorate and the High Court on the weighting given to various claimed benefits for 22/1539/OUT. There are no substantive changes: • to market housing so the Inspectorate’s “substantial” weighting remains. • to affordable housing so the Inspectorate’s “ very substantial” weighting remains. • to economic benefits so the Inspectorate’s “Limited ” weighting remains. • to Enhancements to Plantation RIGS so the Inspectorate’s “Limited ” weighting remains. • to Biodiversity Net Gain so the Inspectorate’s “Limited ” weighting remains. The application includes at least 50% affordable housing which is proposed as a minimum requirement in new national planning policy, but makes no mention of the connected requirement that an appropriate proportion must be Social Rent. Only limited benefit can accrue through meeting minimum requirements, and even the proposed new requirements are not being met. There is an absence of any weighting to a Medical Centre as the Doctors / Red House Surgery who serve Radlett have withdrawn their support. The Inspectorate gave limited weight to Safeguarded land for expansion of Newberries Primary School and it must be clear that in respect of Statement Of Common Ground – Education (SOCG) that HCC say “For the avoidance of doubt, this SOCG does not present any formal support for the application by HCC”. At this stage of the Local Plan it is too early to decide where any Schools might be provided, and this should be led by local need rather than developer wishes. TRANSPORT This application is for outline permission with all matters reserved except for means of access. As such traffic and road safety issues assume major importance. As is clear in the many objections to rejected application 22/1539/OUT the actual traffic impact of this proposal is a major concern. Residents and indeed local Councillors have lost confidence in the Highway Authority to assess and mitigate traffic impact in this and other proposals. Furthermore, a highly significant Road Safety issue became clear during the Appeal. The Highway Authority must have made a risk assessment to justify the motorway style crash barrier that currently runs by the access of the proposed application. Even worse, this crash barrier has suffered significant damage, which undoubtably confirms vehicle(s) having collided with it. This proposed access is quite simply unsafe and is a primary reason to reject this application. This new application is an opportunity for the Planning Authority to redress the parlous deficiencies in previous transport assessments, and should as it has the right to do so over the Highways Authority. PLANNING BALANCE It is clear from the information I have provided that this application does not achieve the planning balance to allow Very Special Circumstances to develop this Green Belt site. Therefore I strongly oppose these outline proposals in 24/1211/OUT and urge the Planning Authority to refuse the application. Yours sincerely References: 1. 22/1539/OUT Decision Notice: https://www6.hertsmere.gov.uk/online-applications/files/A1ADB235018B723ADA92A10949FE682E/pdf/22_1539_OUT-DECISION_NOTICE-1564850.pdf 2. https://acp.planninginspectorate.gov.uk/ViewCase.aspx?caseid=3320599 3. a. https://casetracker.justice.gov.uk/getDetail.do;jsessionid=4AE2B315187BECF987013945159AA6A7?case_id=CA-2024-001928 b. https://cornerstonebarristers.com/in-combined-judgment-high-court-addresses-a-smorgasbord-of-substantive-and-procedural-issues-in-planning-law/

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