Your name

Your email

First Line of Address

Your Postcode

Subject

Message (Edit just as you wish)
Dear Sir/Madam Please find below my objections to planning application 22/1826/OUTEI Shenley Grange. This objection should be taken as my separate and individual submission in accordance with your agreed policy. 1. Inappropriate Development in relation to the current Hertsmere Local Plan. 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 ‘Any development opportunities in both Shenley and Elstree, identified as ‘service villages’, will be restricted to small scale infill opportunities where development may be acceptable, supports a local need and contributes to the sustainability of the local community.’ As such this application, for large scale, urban density development, contravenes the current Local Plan as well as the principles of sustainable development set out in the NPPF Clause 142. The proposal for 177 houses would increase Shenley’s population by approximately 10% and thus can in no way be considered ‘small scale’. There are also so many ‘reserved matters’ that it is not possible for a Planning Department to make an adequate assessment of full impact that this proposed development would have and so it must be rejected as speculative and inappropriate. 2. Unjustified Claim of Housing Need: Principle of Consistency 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. The recent Government announcement on flexibility on Housing Targets, especially in the context of Green Belts, is also now a material consideration 3. No Precedent from Shelved Local Plan Equally, any attempts to legitimise the site 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. 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 With regard to the ‘Very Special Circumstances’ referred to in paragraph 3 above, the National Planning Policy Framework (NPPF) policy states ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations. The applicant accepts that this development is inappropriate development and is harmful to the Green Belt by definition, that this harm should be afforded substantial weight and no specific NPFF exceptions apply. Specifically, they accept “There is harm to the Green Belt by virtue of the spatial and visual impacts on openness from the proposed development. Harm to openness is considered to be significant.’’ The main justification from the applicant, therefore, appears to be that it would meet housing need. However, as discussed in paragraph 2, it would be inconsistent in planning law to accept this claim given the recent decision on 22/0971/OUT. 5. Development is contrary to the Shenley Neighbourhood Plan. The applicant also acknowledges “that the development is not supported in principle in the Shenley Neighbourhood Plan (SNP) due to its location in the Green Belt.” Full weight must be given to the SNP which has force of law. The SNP designates the Spinney, which is adjacent to the development, a local green space, village and school amenity and important centre of biodiversity. As regards the proposed housing mix, despite the fact that it is a reserved matter, the proposals as described do not meet the SNP’s requirements on density, housing mix or design. 6. Incompatibility with existing Shenley Conservation Area The Shenley Conservation Area Appraisal notes that “in contrast to the more built-up east side, much of the west side of London Road remains attractively overgrown and secluded by a continuous barrier of hedges and trees behind which once hid the small regency estate known as Shenley Grange.” Development on the West side of London Road is therefore characterised by a loose layout of occasional one-off buildings on large plots stretching back to an informal boundary with the countryside. The suburban density proposed is therefore inappropriate and out of keeping with the conservation area context. 7. Irreparable Harm to Biodiversity As outlined in Herts and Middlesex Wildlife Trust’s major and 'in principle' objection: ‘This development would result in the destruction of the section 41 priority habitat, lowland meadow. This is an irreplaceable habitat and extremely rare in Hertfordshire. This site represents one of the largest areas of this habitat in the county. The habitat is consistent with the selection criteria for a local wildlife site and so should be considered as such. This is an absolute objection. No avoidance, mitigation or compensation has been put forward. Net gain has not been calculated, because it is not possible to compensate for the loss of this habitat. The application is therefore not consistent with NPPF, the Hertsmere SADMP, BS42020 and the Environment Act and in accordance with these documents, must be refused.’ The Trust’s objection must be given full weight and demonstrates that the developer’s proposal for a ‘bespoke off-site solution’ in Section 7.8.4 is completely unacceptable. 8. Serious Traffic Issues around Shenley School The developer’s traffic survey was conducted at the end of the summer school term, including on days when no pupils were at the school. In addition, the primary issues around the proposal single site entrance to Shenley Grange are not the increased traffic volume per se but the immediate very local impacts of several hundred cars entering and leaving directly opposite a primary school during rush hour. It is totally inappropriate in terms of traffic congestion, person safety and clean air requirements to create a busy and dangerous junction opposite a school location. It is clear these latter material public safety considerations have not been considered in any adequate manner by the applicant. 9. Unsustainable in context of local and national planning policy 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 in Shenley Parish. 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 taken out of the green belt merely upon the promised provision of some ‘affordable’ houses and 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. 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