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Dear Sir/Madam Please find below my objections to planning application 22/1526/FULEI. Please note that this objection should be taken as my separate and individual submission in accordance with your agreed policy. The applicant submitted a new 58 page Environmental Statement (ES) Addendum on 15 September 2023, with 12 further appendices. In the context of the scale and scope of this submission, I submit this objection which is new to any previous objection I have made. It should be considered my individual new submission in line with your policies and precedent. 1. Failure of Community Involvement This ES addendum is in response to consultation after the initial proposal. In the addendums Review of Other Consultee Comments they make no mention of the over 1800 public comments most of which relate to the topics covered in the ES. The applicant has ignored the scale and scope of the valid comments of local residents by not addressing them in their ES addendum. Whilst this is profoundly disrespectful to local residents, in planning policy terms it also fundamentally undermines the addendum’s validity. Councillors must, under national planning guidance, take into account public views where they relate to relevant planning matters, and this is also a failure by the applicant to deliver HBC’s requirements for Community Involvement. Without any comment from the applicant these valid comments of local residents must be given full weight in the planning determination. 2. No consideration of alternatives In their ES addendum the applicants states that their position of alternatives to this site ‘remains as set out within the main ES (Chapter C, paragraph C5.9- C5.10), that no other locations have been considered by the Applicants in respect of the development as the Proposed Development is an extension of the existing development at SSES.’ This is then contradicted in the accompanying non-technical summary where the application states ‘The EIA Regulations require that consideration is given to any alternatives to the Proposed Development that may have been studied by the applicant, along with a consideration of what may happen at the site should the development not go ahead.’ This latter statement is the correct as the Regulations clearly state ‘A description of the reasonable alternatives (for example in terms of development design, technology, location……’ The applicant continues to admit they have failed to look for alternatives, simply saying their justification is to build adjacent to their existing premises. There is no justification in law for planning permission to be granted simply because an applicant wished to build on greenfield Green Belt next door to their existing holding. 3. Significant adverse effect on Landscape. After the applicant’s initial ES many comments were received. which have required the applicant themselves to increase the adverse effect on Landscape to ‘significant’, this in ’in relation to the removal of the historic hedgerows within the Site, which cannot be avoided or mitigated any further due to the nature of the Proposed Development.’ The proposed site is criss-crossed by historic hedgerow that even the applicant agrees are classified as ‘important’ under the Hedgerows Regulations 1997. These Regulations ‘make provision for the protection of important hedgerows in England and Wales. Before removing any hedgerow, including a stretch of hedgerow, to which these Regulations apply the owner (or in certain cases a relevant utility operator) must notify the local planning authority (regulation 5). The hedgerow may then not be removed if the local planning authority serves a hedgerow retention notice’ This ‘significant’ deleterious effect on Landscape further carries significant weight against justification for Very Special Circumstances. Hertsmere Borough Council have it in their direct power under the Hedgerows Regulations 1997 to stop the removal of these hedgerows and should use these powers without delay. 4. Visual Assessment Hertsmere Borough Council asked for photographs to be from the Mops and Brooms public house to assess the visual impact of the proposed northern studio. The applicant has provided a photograph from down the sloping garden, taken off centre to pace a tree in the eye-line, and away from the seating area. This claims to show no visual impact from the proposed northern studio. However photographs taken from the seating area of further up the garden show the existing southern studios. As such the northern extension, on rising ground toward the Mops and Brooms public house. will be even more visible, both to users of the garden as well those on the terrace and through the windows. Furthermore at night the existing building is illuminated and clearly visible and the proposed northern studio will have an even greater impact at night. The result of this request from Hertsmere Borough Council for photographs from the Mops and Brooms public house should be that planning weight now be be given to the reality of the impingement of these views by proposed northern studio, both during the day and when illuminated at night. 5. Loss of Local Biodiversity There is no dispute that this proposal will result loss of biodiversity at this site. Such environmental harm resulting from this development should be avoided, adequately mitigated, or, as a last resort, compensated under the required planning/biodiversity hierarchy. The applicant has chosen this last resort, by moving the biodiversity away from Borehamwood and its surrounding areas to a inaccessible site south of the M25 near Potter Bar. Use of last resort off-site offsetting measures away from the immediate locality is not a right for developers but an indication of the weight of significant harm that further undermines the justification for Very Special Circumstances. The fundamental contradiction in proposed justification at the heart of this application, local jobs versus strategic traffic issues. This is further highlighted in this ES Addendum. In their initial proposal’s publicity the applicant declared this site would create ‘More than 2,000 ADDITIONAL JOBS LOCALLY throughout construction and operation.’ However, as it is well recognised, including in the ES Addendum Employment & Skills Plan in Appendix 3 ‘In the UK, studios do not usually employ cast, crew, or facilities to make films or TV productions. Almost all crew are self-employed, meaning they work contract to contract’ These persons travel in from all over the UK. The applicant cannot not use both issues as justification for Very Special Circumstances; if employment is local then the major traffic mitigation measures on the strategic road network are not needed, but if national road network traffic mitigations are needed this will be because employment is not local. 6. Significant issues with national and especially local traffic. The concern with the strategic (national) road network as shown in part by the protracted concerns from National Highways and Barnet Council, particularly over significant congestion at the Newark Green Roundabout that are further described in this ES Addendum. The effect of the wider local road network has not been fully addressed by these submissions. It is not the concern of National Highways, and has not been addressed in a realistic way by the applicant who have only provided a very localised ‘Transport Study Area’ (Fig 4.1 in the non technical ES). These wider local traffic concerns also are unlikely to be addressed by Hertfordshire Highways.At present they have made no submission, and there is little confidence from residents, and indeed Hertsmere’s own Councillors, that their assessments represent the real world in respect of the effect of such developments of the local road network. However useful conclusions can be drawn from the applicants previous own ‘Figure 2.1: Summary trip distribution (October 2022). There will be significant congestion at the Newark Green Roundabout. It is clear to any local resident driving traffic through Barnet, through Elstree to Borehamwood, through Shenley and through South Mimms and Ridge. In view of these deficiencies from the applicant and Hertfordshire Highways then Hertsmere Borough Council should conclude (in the absence of evidence to the contrary) that this application will cause significant and permanent deleterious local traffic effects across the locality and this should carry significant weight against Very Special Circumstances. Yours sincerely

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