Borough of Broxbourne · 1.7.2 The Council has proposed an acceptable change to deal with the...

Borough of Broxbourne Local Plan Second Review 2001-2011

Report of the Public Local Inquiry into Objections and other Representations May 2005

Borough Of Broxbourne Local Plan Second Review 2001-2011: Inspector�s Report

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TABLE OF CONTENTS

Chapter Page

Glossary 2

1 Introduction & Sustainability 3

2 Green Belt & Countryside 16

3 Housing 65

4 Employment 103

5 Retailing & Town Centres 118

6 Greater Brookfield 128

7 Community, Leisure & Tourism 142

8 Heritage and Design 149

9 Transport 164

10 Implementation, Proposals Maps 177

Report Appendices Al


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Glossary AIC At Inquiry Changes ASR Area of Special Restraint CD Core Document Dph Dwellings per hectare EIA Environmental Impact Assessment EA Environment Agency EIP Examination in Public FD First Deposit GOE Government Office for the Eastern region HMWT Herts and Middlesex Wildlife Trust HCC Herts County Council LDDs Local Development Documents LDFs Local Framework Documents LPA Local Planning Authority ODPM Office of the Deputy Prime Minister PDL Previously developed land PIC Pre Inquiry Change PPG Planning Policy Guidance PPS Planning Policy Statement RSS Regional Planning Guidance RTS Round table session AM Scheduled Ancient Monument SSSI Site of Importance for Nature Conservation SPG Supplementary Planning Guidance TPO Tree Preservation Order UCO Use Classes Order # paragraph


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1. INTRODUCTION & SUSTAINABILITY

1.1 INTRODUCTION Objections - First Deposit 933/08 K Fedorowicz 1001/042 Hertfordshire County Council 1006/03 Epping Forest District Council Objections - Second Deposit 1364/03 Landmatch Ltd Issues

(a) Plan proposes too much development in the Borough.

(b) The Plan should refer to the review of the Development Plan.

(c) A different typeface should be used for policies.

(d) Council should publish a further revised deposit plan

(e) Plan policies contain too much scope for interpretation.

Inspector's Reasoning and Conclusions

1.1.1 The purpose of the Plan is to direct development and set out land use policies in accordance with the strategic framework contained in Regional Guidance and the Hertfordshire Structure Plan, taking local needs into account. I deal with a variety of objections about the quantum and location of development throughout the report. In general, I am satisfied the Plan provides broadly the correct balance between the need to provide for a range of development proposals and to protect the natural resources of the Borough.

1.1.2 Although the reference to procedures in paragraph(#) 3 of the plan was correct at the time of writing, I concur with the Council that this section should be re-worded to reflect the current statutory position following the commencement of relevant parts of the Planning and Compensation Act 2004. I leave the presentation of the final document to the Council.

1.1.3 I agree with the Council that inviting representations on the second deposit version of the Plan did not prejudice the validity of objections to the first deposit. Although there were some significant changes, which hindered the clarity of the whole, in the circumstances the process followed allowed the Plan to proceed at as expeditiously as possible, certainly faster than preparing another completely revised deposit.

1.1.4 I consider that the policies of the Plan leave scope for interpretation in the usual way for documents covering a relatively wide area such as a Borough.


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RECOMMENDATIONS

INT.1 No modification, other than to update the background text concerning the Development Plan system.

1.2 SUS1 SUSTAINABLE DEVELOPMENT FRAMEWORK Objections - First Deposit 1001/55 Hertfordshire County Council 1011/1 English Heritage 1010/3 The Countryside Agency (E. England Region) Objections - Second Deposit 1296/1 Tesco Stores Ltd 1000/142 Government Office for the East of England 1001/68 & 69 Hertfordshire County Council 1016/11 Network Rail Issues

(a) Important aspects relating to sustainable landscapes are not mentioned

(b) Chapter should provide better coverage in relation to built environment

(c) Plan does not include sustainability objectives for each chapter as stated in para 1.3.2

(d) Policy SUS1 duplicates structure plan policy and is unnecessary

(e) Policy is more appropriate as a general objective of plan and supporting text needs more explanation

(f) Plan not accompanied by a sustainability appraisal.

(g) The benefits of rail freight are not mentioned.


1.2.1 I note that the Plan does contain full coverage of those issues relating to the built and natural environment in other chapters, notably Chapters 2, 7 and 8. I see no need for additional duplication in this section, which is rightly restricted to general principles and other detailed matters not covered elsewhere.

1.2.2 Although the sustainability principles of Structure Plan Policy 1 provide the fundamental basis for the Plan, I see no real need for the Policy SUS1 in the form proposed. The Structure Plan policy, which is part of the Development Plan, will continue to be applicable to any development proposals. Although not harmful, the wording of the policy is set out as a general objective rather than a policy with specific criteria which have to be met. If retained as supporting text it could continue to provide a context for Policy SUS2. As the Council suggest, I consider #1.3.2 should be amended to clarify that


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sustainability objectives are reflected in the objectives for other Plan chapters.

1.2.3 I note that an Environmental Appraisal accompanied the first deposit Plan, which raised no objections. I consider that this complies with the government advice in PPG12 current at the time of preparation, and reflects in broad terms the requirements of both updated government policy, RPG9, the sustainability objectives of the Structure Plan and a raft of other guidance.

1.2.4 I see no need for specific mention of rail freight as a sustainable mode of transport in this chapter, but deal with the point in my discussion of objections to Chapter 9.

RECOMMENDATIONS

SUS.1 Modify the plan by deleting Policy SUS1 but include the wording as an overall Plan objective in the supporting text, with reference to sustainability objectives in other chapters of the Plan.

1.3 SUS2 SUSTAINABLE DEVELOPMENT PRINCIPLES

Objections - First Deposit 1010/2 The Countryside Agency (E. England Region) 1296/2 Tesco Stores Ltd 1001/43 Hertfordshire County Council Objections - Second Deposit 1296/22 Tesco Stores Ltd 1000/109 Government Office for the East of England Issues

(a) Policy title should be more widely defined

(b) Policy should not rely directly on SPG.

(c) No justification for sustainability checklist threshold for large scale developments, which is too low

(d) Policy should be cross referenced to other parts of the Plan

(e) Policy is unreasonably restrictive in current wording


1.3.1 I note that Herts CC do not object to the items contained within the sustainability checklist in #1.16. While the list may need to be updated in due course I see no reason why the current version should not be included within the Plan. Any revisions to accord with County-wide guidance could be incorporated into SPG at a later date, at which time they would be material


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considerations in the determination of development proposals.

1.3.2 Policy SUS 2 does not impose an absolute requirement on developers to produce a full assessment against the checklist, but to have considered its contents. As the supporting text indicates, it would not be reasonable to expect for example detailed assessments against all items in support of proposals for residential developments just above the policy threshold. On balance I consider the threshold sets a reasonable limit on the scale of proposals for which some sustainability statement should be required, and that the wording of the policy would not allow the Council to impose a lengthy string of requirements unilaterally, without taking into account the scale of development proposed. However, I agree that the supporting text should be modified to refer to potential delays in processing, rather than failure to consider, applications without such statements.

RECOMMENDATIONS

SUS.2 Modify the Plan in accordance with PIC 001

1.4 SUS3 ENERGY Objections - First Deposit 1299/2 Terence O'Rourke Plc Issues

(a) Paras. 1.6.6 - 1.6.8 would benefit from specific reference to PPG22


1.4.1 Changes to the 2nd deposit of the Plan meet this objection.

RECOMMENDATIONS

SUS.3 No modification

1.5 SUS4 WASTE AND RECYCLING

Objections - First Deposit 102/3 Mr & Mrs C West 1008/7 Environment Agency 1009/6 English Nature


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Issues (a) Policy omits reference to the Landfill directive

(b) Plan lacks reference to practical measures to implement this policy


1.5.1 The 2nd Deposit was changed to meet the objections of English Nature and the Environment Agency (EA). Practical ways of dealing with waste are not the direct concern of a land-use plan, but the point about adequate provision for waste vehicles is covered in Chapter 9 � Transport.

RECOMMENDATIONS

SUS.4 No modification.

1.6 SUS5 MINERALS Objections - First Deposit 1102/3 Goff's Oak Community Association Issues

(a) Policy omits reference to the impact on neighbouring properties


1.6.1 Criteria for deciding applications relating to minerals extraction, including residential amenity considerations, are contained in the Herts Minerals Local Plan, to which # 1.8.1 of the Plan refers.

RECOMMENDATIONS


1.7 SUS6 POLLUTION Objections - First Deposit 1104/01 Spitalbrook Village Green Conservation Group Objections - Second Deposit 1001/70 Hertfordshire County Council


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Issues

(a) Difficulty of implementing policy in face of potentially conflicting development objectives

(b) Reference should be added to Structure Plan Policy 56


1.7.1 The policy was revised in the 2nd deposit to provide more guidance about the factors to be taken into account when considering developments that may pollute the environment, but inevitably some judgement of the effects would have to be exercised.

1.7.2 The Council has proposed an acceptable change to deal with the suggested reference to Structure Plan Policy 56.

RECOMMENDATIONS


1.8 SUS7 AIR QUALITY

Objections- First Deposit 1009/9 English Nature 1006/5 Epping Forest District Council Objections- Second Deposit 1006/13 Epping Forest District Council

Issues

(a) Policy lacks focus and clarity and does not explain what it means in practice.


1.8.1 The 2nd Deposit was changed to meet the objections of English Nature but I consider that it requires further clarification for development that would lead to an unacceptable decrease in air quality.

RECOMMENDATIONS

SUS.7 Modify the Plan by adding this additional sentence to the end of Policy SUS 7:

�DEVELOPMENT THAT WOULD LEAD TO NATIONAL AIR QUALITY GUIDELINES BEING EXCEEDED WOULD NOT BE PERMITTED�


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1.9 SUS9 NOISY DEVELOPMENT (FORMERLY BE24)

Objections - First Deposit 1009/57 English Nature Issues

(a) Policy omits reference to noise impacts on wildlife


1.9.1 I agree with the Council that the difficulties of measuring the impact of noise on wildlife preclude revisions to the policy to take such matters into account.

RECOMMENDATIONS


1.10 SUS12 LIGHT POLLUTION AND FLOODLIGHTING (FORMERLY BE27)

Objections - First Deposit 1101/50 CPRE - The Hertfordshire Society 711/1 Mr F. Scott 1009/59 English Nature Issues

(a) Policy requirements could be more specific

(b) Policy should refer to impact on wildlife


1.10.1 The 2nd Deposit was changed to meet the objections of English Nature and the CPRE. I agree with the Council that the suggestion to set definitive light levels within the policy would be unnecessarily prescriptive and that detailed matters of lighting affect should be assessed at development control stage.

RECOMMENDATIONS



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1.11 SUS13 DEVELOPMENT ON CONTAMINATED LAND (FORMERLY BE28)

Objections- Second Deposit 1006/14 Epping Forest District Council 1009/60 English Nature Issues (a) Alteration to improve clarity of policy

(b) Text and policy omits reference to as yet unidentified landfill sites


1.11.1 I consider that the 2nd deposit and proposed change address the objections satisfactorily.

RECOMMENDATIONS


1.12 SUS14 HAZARDOUS SUBSTANCES (FORMERLY BE29)

Objections - First Deposit 86/1 Heath and Safety Executive Issues

(a) Policy and proposals map lack detailed information


1.12.1 The 2nd deposit provides the information sought by the objector.

RECOMMENDATIONS



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1.13 SUS15 WATER SUPPLY, WASTE WATER TREATMENT AND WATER CONSERVATION (FORMERLY SUS12)

Objections- First Deposit 1015/4 Thames Water Property 1253/11 The House Builders Federation Objections- Second Deposit 1015/13, 24 Thames Water Property Issues

(a) Supporting text omits useful references to support policy

(b) Policy covers measures more properly addressed through building regulations

(c) General policy on water supply and wastewater treatment facilities is still required


1.13.1 Although not critical to its success, I see no reason why advice on water conservation could not be added to the bibliography of the Plan as the Council suggest.

1.13.2 I agree with the Council that the Plan should require measures to ensure that existing water supplies are adequately protected, consistent with general government policy for sustainable development that conserves as much as possible natural resources.

1.13.3 I see no need for a general policy to facilitate water and sewerage facilities development, much of which can be undertaken using statutory powers; other proposals should be considered by the planning process in the normal way.

RECOMMENDATIONS


1.14 SUS16 GROUND AND SURFACE WATER PROTECTION (FORMERLY SUS11)

Objections- First Deposit 102/5 Mr & Mrs C West


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Objections- Second Deposit 1009/80 English Nature

Issues

(a) Policy wording needs minor clarification

(b) Policy should identify specific sites for groundwater protection


1.14.1 The suggested wording in PIC004 clarifies the Plan and meets the objection from English Nature. I consider the policy is worded in a way which would adequately protect all important ground water sources throughout the Borough, and there is no need to specify individual sites.

RECOMMENDATIONS

SUS.13 Modify the Plan in accordance with PIC004

1.15 FD POLICY SUS9 - RISK FROM FLOODING AND WATER RESOURCE ISSUES

Objections- First Deposit 1008/8, 9 Environment Agency 1009/10 English Nature 1104/2 The Spitalbrook Village Green Conservation Group 1253/9 The House Builders Federation 522/1 J. Valentine 770/1 Mr & Mrs D. J Lacey 784/1 W.E Cook 1320/2 Mr & Mrs Campbell & Harris 102/4 Mr & Mrs C West 355/1 R. Simmonds 357/1 Mrs J. Payne 1015/3,5 Thames Water Property 1104/1 The Spitalbrook Village Green Conservation Group

Issues (a) Para 1.11.3 should be replaced by a general policy on water supply and waste water treatment facilities

(b) Evidence should be provided how Council's aims in para 1.11.3 would be implemented where utility company has a conflict of interest

(c) Policy omits reference to flooding risks which impact outside the Borough area


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(d) Policy should restrict any development which increases flood risk

(e) Policy should be strengthened to reflect advice in PPG25


1.15.1 All the objections relate to the first deposit version of the Plan, which subsequently underwent significant changes which included the insertion of two new policies, SUS17 and 18. These revisions, which generally reflect government policy in PPG25, appear to have addressed concerns such as the impact of new development on flooding outside the Borough. I deal with detailed comments about the wording of the policies below.

RECOMMENDATIONS


1.16 SUS17 FLOOD RISK ASSESSMENTS

Objections- Second Deposit 1009/93 English Nature 1006/1 Epping Forest District Council 1104/12 The Spitalbrook Village Green Conservation Group 1000/110 Government Office for the East of England

Issues

(a) Policy lacks clear guidance on whether permission will be granted and is contrary to national guidance by requiring a prior environmental assessment

(b) Policy wording needs minor clarification

(c) Floodplain map does not correctly state areas of flood risk


1.16.1 The Council has proposed a change which meets the thrust of these objections, to provide a strengthened policy which should enable the Council to prevent developments that would create unacceptable increases in flood risk, without mitigation, in accordance with the sequential approach identified in PPG25.

1.16.2 I deal with the issue of floodplain definition of the Spitalbrook in the Meadway area in my discussion of objections in chapter 7. I accept that the Proposals Map indicates Areas of Flood Risk in accordance with the best information from EA and others at the time of publication, but note that the policy provides for these areas to be updated through SPG throughout the life of the Plan.

RECOMMENDATIONS

SUS.15 Modify the Plan in accordance with AIC02


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1.17 SUS18 FLOOD PREVENTION

Objections- Second Deposit 1006/15 Epping Forest District Council 1015/9,15 Thames Water Property Issues (a) Para 1.14.7 should be expanded to accord with para 23 of PPG25 (b) Policy wording needs minor clarification


1.17.1 I consider the wording of #1.14.7 adequately reflects the broad thrust of PPG25. PIC006 corrects a grammatical error.

RECOMMENDATIONS

SUS.16 Modify the Plan in accordance with PIC006

1.18 SUS19 SURFACE WATER DRAINAGE (FORMERLY SUS 10)

Objections- First Deposit 1253/10 The House Builders Federation Objections- Second Deposit 1006/16 Epping Forest District Council

Issues

(a) Plan does not address practical issues regarding maintenance and adoption

(b) Policy would be more logical if clause (II) and (III) reversed


1.18.1 Paragraph E15 of PPG25 encourages LPAs to adopt policies promoting sustainable drainage systems, which by their nature imply continued effective operation. I consider the spirit of the policy accords with this advice, although it should be re-worded in a more positive form as recommended below, re-ordering clauses as desirable.

RECOMMENDATIONS

SUS.17 Modify policy SUS19 to read as follows:


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DEVELOPMENT WHICH IS LIKELY TO CREATE RUN-OFF AND SURFACE WATER WILL ONLY BE PERMITTED WHERE:

A. SURFACE WATER DISPOSAL SOLUTIONS, THAT ARE SUSTAINABLE AND PROTECT THE ENVIRONMENT, ARE PROVIDED AS AN INTEGRAL PART OF THE DEVELOPMENT. WHERE NECESSARY, DISCHARGE RATES FROM SITES WILL BE RESTRICTED AND MEASURES TO ATTENUATE AND DISPOSE OF WATER IN ACCORDANCE WITH BEST PRACTICE WILL BE REQUIRED;

B. THE RUN-OFF WOULD NOT INCREASE THE RISK OF UNACCEPTABLE

FLOODING OF WATERCOURSES, LAND OR PROPERTY;

C. EXISTING LAND DRAINAGE SYSTEMS WOULD NOT BE ADVERSELY AFFECTED; AND

D. THE EFFECTIVE MAINTENANCE OF WATERCOURSE CHANNELS WOULD

NOT BE PREVENTED.

1.19 SUS20 BIODIVERSITY

Objections- First Deposit 1104/3 The Spitalbrook Village Green Conservation Group Objections- Second Deposit 1104/11 The Spitalbrook Village Green Conservation Group

Issues

(a) Policy is inadequate to protect the Borough's biodiversity.

(b) Policy is unclear and too weak in practice.


1.19.1 I agree that the policy is rather vague but it does provide a useful statement of intent and a checklist of important considerations that potential developers should take into account in drawing up any proposals. However I do not consider that these largely administrative considerations are appropriate for a Policy and the wording should be placed in the Plan�s supporting text. As the Council point out, many of these matters are covered in more detail, and with more force, in Policies GBC19-21, which I discuss below.

RECOMMENDATIONS

SUS.18 Delete Policy SUS 20 as an upper case Policy and place within the supporting text.

Borough of Broxbourne Local Plan Second Review 2001-2011: Inspector�s Report

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2. GREEN BELT AND COUNTRYSIDE

2.1 REVISIONS TO GREEN BELT BOUNDARY INTRODUCTORY TEXT First Deposit � Objections 254/01 R. Barnes 813/02 New River Action Group 1001/050 Hertfordshire County Council 1009/024 &104 English Nature 1010/05 The Countryside Agency (E. England Region) 1101/52,54,55 CPRE Hertfordshire 1102/088 Goffs Oak Community Association 1264/012 Higgins Homes Ltd Second Deposit � Objections 1101/67 CPRE Hertfordshire 1264/011,46 Higgins Homes Ltd 13/3,4 Mrs J Liddard

Issues

(a) Object to presumption in para 2.1.1 that development needs cannot be met without use of Green Belt land

(b) Introductory text (paras 2.1.1 - 2.1.4) fails to mention landscape value issues and has factual inaccuracies

(c) Chapter objectives (para 2.2.1) need to be strengthened and recognise role of A10 as a �Green Corridor�

(d) Para 2.3.4 fails to make clear how Green Belt boundaries have been defined in earlier plans

(e) Para 2.4.1 makes no reference to East Cheshunt which has suffered over development

(f) Plan incorrectly states that only development needs can be taken into account in altering Green Belt boundary

(g) Plan should include a policy on riding and livery stables.

(h) Chapter policies should have more specific protection for character of countryside and historic monuments.


2.1.1 In my discussion of objections to the housing chapter of the Plan I note that the Structure Plan requirement for new dwellings in the period to 2011 would be more than met, even if no green belt land were released into that use. However, the Plan does include other proposals, such as commercial development at Essex Road, Hoddesdon, to meet other needs that would be compromised without some loss of green belt. I agree therefore that the statement in #2.1.1 should not be revised.

2.1.2 I am satisfied that the Plan contains no inaccuracies, following corrections at


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2nd deposit stage. I agree with the Council that there is no need for the introductory remarks to include more detail, noting that #2.1.4 refers to the areas of high landscape value.

2.1.3 Higgins Homes� objections concerning the A10 corridor have to some extent been addressed by the revised deposit, which deleted Policy GB2 regarding Areas of Special Restraint (ASRs) and the designation of such land west of Hoddesdon. I address objections to the deletion of the ASR below, together with a number of other objections regarding the potential release at some future date of other green belt in the West Cheshunt area, primarily to meet future housing needs. For the present, the Plan proposes no significant changes to the amount of development in the A10 corridor compared with the previous Local Plan, apart from the new St Mary�s School site. I consider that the supporting text need not refer to any special measures to protect this part of the green belt above any other; I endorse the Council� revised approach that all areas of the green belt should be treated equally and be subject to review during the LDF process.

2.1.4 As PPG2 states, green belt boundaries are intended to have a high degree of permanence and I consider that explanations of the history of designations would add very little to understanding of the current Plan and the policies it contains.

2.1.5 If �East Cheshunt� is the area east of the A10 this is already developed; again, the Plan cannot put back the clock to reverse past development, but rightly concentrates on policies to protect remaining areas of green belt. Other parts of the Plan, including Chapter 8, set out policies for the protection of open spaces within the urban area.

2.1.6 In general I consider that the policies of Chapter 2, read as a whole, are sufficient to give guidance on a range of development proposals, including those for outdoor recreation which may be acceptable in principle, taking into government and strategic policy.

RECOMMENDATIONS

GBC.1 Modify the Plan in accordance with AIC03, 04

2.2 GBC1 REVISIONS TO GREEN BELT BOUNDARY - GENERAL OBJECTIONS

First Deposit � Objections 102/06,16 Mr & Mrs C West 192/08,11 Mr M Kousoulou 265/01 Ms S.J. Storey 371/01,02,03 Mr D. Shields 865/02 Mr & Mrs Hilton 1104/09 The Spitalbrook Village Green Conservation Group


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Issues

(a) Plan should impose stricter control over developers where land is released

(b) Council should undertake an urban capacity study before releasing Green Belt sites - there may be sufficient brownfield land to meet structure plan requirements. Object to all the proposed revisions to the boundary of the Metropolitan Green Belt on this basis.

(c) Plan should avoid further releases of Green Belt land to contain urban sprawl

(d) Plan presumes Areas of Special Restraint (ASRs) identified in First Deposit plan automatically justifies their exclusion from the Green Belt in this review. This applies to Park Plaza, Canada Fields and NHS/MAFF site.

(e) No development should be allowed to encroach on the Green Belt - eg Canada Fields


2.2.1 PPG2 stresses that a key aspect of the green belt is its permanence and states that its boundaries should be changed only in exceptional circumstances. Policy 7 of the Structure Plan sets out three requirements where limited peripheral development may be permissible in the green belt:

• where planned regeneration opportunities have been fully explored;

• where such development can provide demonstrable sustainability benefits;

• and where it is planned in the context of the town as a whole.

In applying these policies to a number of objection sites, I have looked at housing need, the location of sites in relation to public transport and other facilities and any relevant site specific factors.

2.2.2 In my discussion of housing issues in Chapter 3 of this report I concluded that the Council has identified a supply of new dwellings well in excess of the number needed to meet the Structure Plan requirements for the period to 2011. I have dealt also with arguments about the need for a ten year supply, noting that the extent of housing requirements beyond the Plan period is not known at present. At this stage therefore there is no need to provide for future housing growth (apart from existing commitments and plan proposals) within the green belt and outside of the urban areas. The sequential test of PPG3 indicates that greenfield sites should be considered only after previously developed land in urban areas

2.2.3 The Plan does contain policies such as GBC2 which provide the basis for strict control of development in the green belt through the development control system. The ASRs (released from the green belt in earlier plans) have all been the subject of planning permissions; in two instances, development is now well under way. The revised Plan does not propose releases of green belt land for housing that are not already committed, except in one instance (see section 2.33 below).

2.2.4 Although disputed by the objector, the Council states that it has carried out a detailed urban capacity study. I am satisfied from papers concerning discussion of the Housing Chapter that some study of opportunities in the built up areas of the Borough has taken place, although it is accepted that


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this will need continual review. I discuss a number of site specific objections concerning proposed releases of green belt in the sections below. In all those instances where residential proposals have been mentioned or advanced, I have recommended no modification of the Plan, based on my conclusions about housing need set out in full in Chapter 3 of my report. I have not repeated this point about housing need in detail when dealing with individual sites. In broad terms, I accept that the Council has sought to restrict such releases to the minimum necessary. The Council has agreed to review all green belt land in determining future housing strategy at an early opportunity, when revised requirements are known following approval of regional guidance in the form of RSS14.

RECOMMENDATIONS

GBC.2 No modification, but see 2.33 revisions to green belt boundary:

GBC1 (D) LAND AT ST MARY�S SCHOOL

GBC1 REVISIONS TO GREEN BELT BOUNDARY - PROMOTION OF ALTERNATIVE SITES

Hoddesdon

2.3 GBC1 LAND NORTH OF HERTFORD ROAD

First Deposit � Objections 01258/02 Hubert C. Leach Issues

(a) Land north of Hertford Road Hoddesdon would be a logical addition to the area of Special Restraint West of Hoddesdon, identified in the First Deposit Plan


2.3.1 This triangular parcel of land, extending to about 10.7 ha, is located between Hertford Road and the north-western edge of Hoddesdon. Although the land suffers from problems of trespass and activity normally associated with the urban fringe, it nevertheless retains a predominantly rural character, comprising areas of grazing land and a wooded former gravel pit, albeit with two suburban features of a covered reservoir and car park in the central area of the site.

2.3.2 The site adjoins the urban area and abuts, but lies outside, the Accessibility Corridor shown on the Proposals Map. Two schools at Westfield Road and Roselands lie within 500m of the site boundary, but other facilities such as local shops are about 1km away from the main part of the site. I note that the development potential of the site is constrained by a TPO on the


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woodland in the former quarry and that development on the western part of the land would be highly visible from higher ground to west. I acknowledge that the line of the A10 would create a clear firm boundary to the green belt but applying the principle of that argument could lead to pressure for significant further development alongside the A10 elsewhere to south.

2.3.3 None of the factors discussed above need preclude the site from future consideration should releases of green belt be required when the Plan is reviewed as part of the LDF process. However, I consider that neither they, nor the problems of vandalism and public access to which the objector refers, in themselves create the very special circumstances needed to justify removing the site from the green belt. I have concluded that allocating this site for housing or as an ASR at the present time would be in clear conflict with local and national policies to secure the long term protection of the green belt.

RECOMMENDATIONS

GBC.3 No modification

2.4 GBC1 LAND AT 305 WARE ROAD

Second Deposit � Objections 01386/01 Hertfordshire Partnership NHS Trust Issues

(a) Land at 303 and 305 Ware Road should be released from Green Belt and allocated for housing.


2.4.1 I have dealt with another objection concerning land at 303 Ware Road below, where I concluded that there were no exceptional circumstances to justify the release of the land from the green belt. In summary, I recognised that the Council has provided more than enough housing land to meet strategic requirements to the end of the plan period, beyond which future needs remain uncertain.

2.4.2 Similar arguments apply to this site, and the others in this section of my report. The objectors themselves think that the site should be considered with the land at 303 Ware Road. Both sites have been part of the green belt for many years. I note that the inspector reporting on the 1993 Local Plan inquiry confirmed this designation.

2.4.3 Looking at the nature and density of development on the ground, the single storey nursing home is already quite well-developed. The Council�s figures of 1200m2 of building on a site of 0.54ha do not take account of other hard surfaces for parking and circulation. I consider therefore that the objectors� argument that the site contributes little to the openness of the green belt has some force. Nevertheless, the buildings on site are single storey, and there are some trees and shrubs which help the site to provide a transition


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to land at Belmont View care home to the north, and the Hailey Hall School to the west; these are both institutions in relatively large grounds with a rather different, more open character. However, while I note the objectors� comments about the obsolescence of the buildings, neither this point, nor the physical characteristics of the land are sufficient to justify release of the land from the green belt at this time, in the absence of any strong housing need. In such circumstances I consider there are no exceptional circumstances to justify release of green belt land.

RECOMMENDATIONS


2.5 GBC1 LAND NORTH OF COCK LANE

First Deposit � Objections 01285/01 Mr G Baldwin Issues

(a) Land north of Cock Lane at South Lodge should be released from Green Belt and allocated for housing.


2.5.1 Government policy in PPG2 and Structure Plan Policy 7 indicate that the objector has to demonstrate exceptional circumstances to justify the release of the land from the green belt. The site forms part of an extensive swathe of open land to the south of the Hoddesdon link and is part of the important gap between Hoddesdon and Broxbourne. Any development would breach the primary green belt policy objective of retaining openness and could intrude visually into the park landscape. In the absence of any Borough-wide housing need (see section 2.1 above) I consider there are no exceptional reasons to change the green belt boundary here.

RECOMMENDATIONS


2.6 GBC1 LAND AT ADMIRALS WALK LAKE, HODDESDON

First Deposit � Objections D H Turner Consultancy FD/GBC/01304/04 Issues

(a) Seek the release of land at Admirals Walk Lake, which should be released


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from Green Belt and allocated for housing.


2.6.1 The site forms part of an extensive area of open land which runs along much of the eastern side of the Borough. This wider area, much of which lies within the Lea Valley Regional park, provides a clear break between the settlements on either side of the valley. Green belt designation prevents the urban area from encroaching into the countryside. While the railway line forms a well-defined boundary to the green belt in many places, some parts of this important open land, including the objection site, extend further west. Any residential development here would breach the primary green belt policy objective of retaining openness.

2.6.2 I note that the land lies just outside, but very close to, the 1 in 100 year floodplain. I share the Council�s concerns that the land may be susceptible to flooding, in the absence of a full risk assessment. The development of the site would undoubtedly have some impact on the setting of the New River and the proposed green chain. However, I accept that these detailed matters may be capable of resolution if the principle of release from the green belt were to be agreed at some future date.

2.6.3 The site has reasonable, but not exceptional, access to public transport and a variety of services. Any enhancement of recreational facilities on the greater part of the site formed by the lake and its surroundings could be achieved without other development. As with all other such sites, the Council has agreed to review the position once future housing requirements are clarified by RSS14. In the absence of any Borough-wide housing need (see section 2.1 above) I consider there are no exceptional reasons to release this land from the green belt.

RECOMMENDATIONS


West Cheshunt

2.7 GBC1 LAND AT LIMES NURSERY

First Deposit � Objections 1262/03 George Wimpey UK Ltd

Issues

(a) Land at Limes Nursery, Goffs Oak should be released from Green Belt and allocated for housing.


2.7.1 I deal with a number of general points concerning proposed releases of green belt land in West Cheshunt in section 2.36 below. As with other green belt sites, in the absence of housing need, objectors would have to


23

demonstrate exceptional circumstances to justify changes to green belt boundaries in favour of residential (or any other commercial) development. I have dealt with the argument advanced by several objectors that general problems of dereliction in the area, at nursery and glasshouse sites in particular, need to be addressed. None of these horticultural sites fall within the definition of PDL as set out in PPG3.

2.7.2 Limes Nursery lies to the north of Hammondstreet Road between two residential estates developed after release from the green belt in the 1994 Local Plan. The land contains a number of glasshouses, some vacant but some still in horticultural production. It performs the green belt functions of separating the built up areas of Cheshunt and Hammondstreet, and although partly developed with glasshouses and some small outbuildings, prevents these settlements from encroaching into the countryside.

2.7.3 I appreciate the difficulties that the Council faced in preparing the 1994 Local Plan in deciding which areas of derelict nurseries to address first. I accept that circumstances have changed since; the financial position of previously viable production areas may have deteriorated and new problems may have arisen. However, the Council has agreed to review all green belt land in determining its future housing strategy when revised requirements are known once regional guidance in the form of RSS14 is approved. I consider that how to address current problems in the glasshouse industry should be one of the key tasks in such a review, which would include a revised sustainability analysis of all sites. In the meantime, despite the unsightly appearance of some parts of the site, there are no exceptional circumstances to warrant removing it from the green belt.

RECOMMENDATIONS


2.8 GBC1 LAND AT LAUREL PARK, NEWGATESTREET ROAD

First Deposit � Objections 1295/04 Leach Homes

Issues

(a) Land at Laurel Park, Newgatestreet Road should be released from Green Belt and allocated for housing.


2.8.1 Similar comments apply to Laurel Park as to The Limes and a number of other sites in the West Cheshunt area. National policy in PPG2 and Structure Plan policy requires objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and


24

sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known.

2.8.2 The site comprises about 5ha of land immediately west of the furthest extremity of residential development at the Hammondstreet estate. There is a clear edge to the housing area and I consider there are no strong reasons to alter the green belt boundary here on grounds of physical features in the landscape. The site does not lie close to a wide range of facilities and in my view is certainly not in a particularly sustainable position. In the absence of housing need, I have found no other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS


2.9 GBC1 LAND AT THE ROUGHS OFF HAMMONDSTREET ROAD

Second Deposit � Objections 1276/04 Meux Trust Issues

(a) Land at �The Roughs� off Hammondstreet Road should be released from Green Belt and allocated for housing.


2.9.1 Similar comments apply to this site as to a number of other sites in the West Cheshunt area. National policy in PPG2 and Structure Plan policy requires objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known.

2.9.2 The site mainly comprises open farmland located between the Hammondstreet estate and Cheshunt Common. It does not lie close to a wide range of facilities and in my view is certainly not in a particularly sustainable position. In the absence of housing need, I have found no other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS



25

2.10 GBC1 LAND NORTH OF HAMMONDSTREET ROAD AND DARNICLE HILL

First Deposit � Objections 1286/01 Mr B Monk

Issues

(a) Seek the release of land North of Reservoir (Darnicle Hill/Newgatestreet Road junction), West Cheshunt should be released from Green Belt and allocated for housing.


2.10.1 Similar comments apply to this site as to a number of other sites in the West Cheshunt area. National policy in PPG2 and Structure Plan policy requires objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known.

2.10.2 The site comprises a small open field located to the north of the covered reservoir, clearly outside the residential boundary of the Hammondstreet estate. It does not lie close to a wide range of facilities and in my view is certainly not in a particularly sustainable position. In the absence of housing need, I have found no other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS


2.11 GBC1 LAND AT SMALLACRE NURSERY, NORTH OF CROUCH LANE

First Deposit � Objections 1264/029, 041 Higgins Homes Ltd Issues

(a) Land at Smallacre Nursery, West Cheshunt should be released from Green Belt and allocated for housing.


2.11.1 Similar comments apply to this site as to a number of other sites in the


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West Cheshunt area. National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known. For the reasons set out in section 3.2, I agree with this approach. As explained in section 2.36, I have suggested that some of the text regarding West Cheshunt should be amended. However, I see no need for any special protection of the A10 corridor at this stage.

2.11.2 Turning to this specific site, much of Smallacre Nursery is covered with vacant glasshouses in various states of dereliction, and some other outbuildings, together with a dwelling house. The adjoining site appears to be used for storage and some car breaking. Although some of the buildings and storage areas do not contribute much to the openness of the green belt, the site and its surroundings remain essentially rural in character. While substantial further development in the vicinity may improve the availability of services, at present the site does not represent a particularly sustainable location for new housing compared to other parcels of green belt land. In the absence of housing need, I have found no other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS


2.12 GBC1 LAND AT GRANGE BROOK, RAGS LANE

First Deposit � Objections 1268/01 Snowgold Developments Ltd Issues

(a) Land at Grange Brook, Rags Lane should be released from Green Belt to facilitate provision of community facilities.


2.12.1 National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. The objection site comprises some paddock land and associated outbuildings on the north side of Rags Brook valley. The site forms part of a small gap which separates Hammond Street from St James and fulfils the important green belt functions of maintaining openness and preventing the coalescence of these two settlements.

2.12.2 The Council has given evidence of two sites in the locality where community facilities to serve new communities in West Cheshunt have been permitted. I have no grounds to suppose that these proposals would be inadequate to


27

meet local needs, given what appears to be limited commercial demand to come forward with such schemes. In the absence of a strong community need, I have found no other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS


2.13 GBC1 LAND ADJACENT TO SOPERS ROAD, CUFFLEY

First Deposit � Objections 1284/02 Mr B Barrett Issues

(a) Seek the release of land adjacent to Sopers Road, Cuffley to be allocated for Employment use.


2.13.1 National policy in PPG2 and Structure Plan policy requires objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. The site is an area of open land immediately east of the Sopers Road commercial estate, and forms part of the important green wedge between Cuffley and Goffs Oak. It thus fulfils two of the important green belt functions of maintaining openness and preventing the coalescence of these two settlements. The existing boundary forms a firm edge to the built-up area of Cuffley which would be broken in an obtrusive manner if changed in the way sought by the objector.

2.13.2 Although much of employment in Broxbourne is focussed on the Lea Valley corridor further to the east, there is no sound evidence that employment needs would not be met by existing provision and two substantial new allocations of land at Park Plaza and NE Hoddesdon. Residents of Cuffley would naturally look towards Welwyn-Hatfield District as well as Broxbourne and the adjoining estate appears to function adequately. In the absence of a strong employment need, I have found no other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS



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2.14 GBC1 LAND NORTH OF CUFFLEY HILL - (FAIRMEAD NURSERY AND R/O 90A-102 CUFFLEY HILL)

First Deposit � Objections 1259/01 Mr D Thrussell 1283/01 Mr & Mrs Pedersen Issues

(a) Land on urban edge of Goffs Oak should be released from Green Belt and allocated for housing.


2.14.1 Similar comments apply to this site as to a number of other sites in the West Cheshunt area. National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known. For the reasons set out in section 3.2, I agree with this approach. As explained in section 2.36, I consider the text regarding West Cheshunt should be amended to reflect the need to address continuing problems of dereliction as soon as possible.

2.14.2 The site comprises primarily a rectangular parcel of overgrown land behind dwellings fronting Cuffley Road and a nursery/gardening materials business bounded to the east by the rear of dwellings in Robinson Avenue. The larger uncultivated area contains a number of trees of some amenity value which have been the subject of a Tree Preservation Order (TPO). The site does not constitute PDL and remains essentially rural in character, preventing the encroachment of Goffs Oak into the countryside. Despite the ribbon of housing along Cuffley Road, it contributes to the openness of the vulnerable gap between Cuffley and Goffs Oak. I accept that the site lies in a relatively sustainable location for new housing, being within walking distances of schools, shops and other services. However, in the absence of any special housing need in West Cheshunt, I have found no exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS


2.15 GBC1 LAND AT DOVERFIELD , GOFFS OAK

First Deposit - Objections 1295/05 Leach Homes


29

Issues

(a) Land at Doverfield, Goffs Oak should be released from Green Belt and allocated for housing.


2.15.1 Similar comments apply to this site as to a number of other sites in the West Cheshunt/Goffs Oak area. National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known. For the reasons set out in section 3.2, I agree with this approach.

2.15.2 The site comprises undeveloped open land behind dwellings fronting Doverfield and Bollards Close. The site does not constitute PDL as defined in PPG3 and I agree with the Council that it relates to the rural area immediately to the south, preventing the encroachment of Goffs Oak into the countryside. I accept that the site lies in a relatively sustainable location for new housing, being within walking distances of schools, shops and other services. However, in the absence of any special housing need, I have found no exceptional reasons to justify releasing the site from the green belt

RECOMMENDATIONS


2.16 GBC1 CROSS NURSERY, NEWGATESTREET ROAD

First Deposit � Objections 1263/01 Mr C Sarno Issues

(a) Land fronting Newgatestreet Road should be released from Green Belt and allocated for housing.


2.16.1 Similar comments apply to this site as to a number of other sites in the West Cheshunt area. National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land


30

in determining its future housing strategy when revised requirements set out in RSS14 are known. For the reasons set out in section 3.2, I agree with this approach. As explained in section 2.36, I consider the supporting text regarding West Cheshunt should be amended to reflect the need to address continuing problems of dereliction as soon as possible.

2.16.2 A substantial part of the objection site is covered with vacant glasshouses in various states of dereliction, and some other outbuildings. Although some of the buildings and storage areas do not contribute much to the openness of the green belt, the site and its surroundings remain essentially rural in character. It fulfils the green belt functions of preventing Cheshunt from sprawling into the countryside, and maintaining the gap between Goffs Oak and Hammondstreet. The site does not constitute PDL as defined in PPG3 and at present it does not represent a particularly sustainable location for new housing compared to other parcels of green belt land. In the absence of housing need, I have found no other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS


2.17 GBC1 LAND BY OAK BUNGALOW, NEWGATESTREET ROAD

First Deposit � Objections 0533/01 H.A Pritchard Issues

(b) Land fronting Newgatestreet Road should be released from Green Belt and allocated as an ASR for future housing.


2.17.1 Similar comments apply to this site as to a number of other sites in the West Cheshunt area. National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known. For the reasons set out in section 3.2, I agree with this approach and see no need to designate particular parts of the green belt as ASRs to meet future needs at this time. As explained in section 2.36, I support the broad thrust of the revised supporting text regarding West Cheshunt.

2.17.2 The objection site comprises primarily open grassland that slopes away from the road to the west. Notwithstanding the presence of sporadic


31

development along both sides of Newgatestreet Road to the north, it fulfils the green belt functions of preventing the outward spread of the wider urban area into the countryside, and maintaining the gap between Goffs Oak and Hammondstreet. The site does not constitute PDL as defined in PPG3 and in my view it does not represent a particularly sustainable location for new housing compared to other parcels of green belt land. Goffs Oak is about 1 km away and there is no bus service along Newgatestreet Road. In the absence of housing need, I have found no other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS


2.18 GBC1 LAND AT PRIMROSE COTTAGE, ST JAMES

First Deposit � Objections 1271/01 Mr N. O'Dwyer Issues

(a) Seek the release of land at Primrose Cottage to provide a better defined Green Belt boundary


2.18.1 National policy in PPG2 and Structure Plan policy states that an essential feature of green belt boundaries is their permanence. The objector argued that the small site containing an historic cottage site was part of St James village and that the green belt boundary was anomalous at this location. I appreciate that the cottage was built at St James well before much of the residential development permitted in the last decade or so. However, the land has also been designated as green belt since 1994 when the previous Local Plan was adopted.

2.18.2 The site is not comparable with the unsightly land at Whitehaven but I consider it forms a part of the developed area, being located at the heart of the village not far from the church and diagonally opposite the public house. In my view it has a different character from the sporadic development further to the north, which lies outside the confines of recent suburban housing. The fence and hedge around the site would form a defensible boundary to the settlement. Any proposals for further development on the site, such as an extension to the dwelling, should be treated on their own merits with regard to normal planning considerations such as visual amenity. Given the nature of the site, which already contains residential development, I consider this very minor adjustment to the extent of the green belt would not prejudice the purpose and general thrust of green belt policy.


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RECOMMENDATIONS

GBC.18 Modify the Plan by amending the green belt to exclude the area shown on the plan in Appendix 1 of Doc C141/1271/01/P

2.19 GBC1 LAND AT PENDINE NURSERY AND ST JAMES NURSERY

First Deposit � Objections 0867/03 Mr C. I. Maxen 0932/01 Mr M. Maxen 1282/01 Mr P Thrussell 1288/02 Sworders Agricultural Second Deposit � Objections 0867/04 Mr C. I. Maxen Issues

(a) Land at Pendine Nursery and St James Nursery should be released from the Green Belt as land is derelict and should be redeveloped


2.19.1 Similar comments apply to this site as to a number of other sites in the West Cheshunt area. National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known. For the reasons set out in section 3.2, I agree with this approach. As explained in section 2.36, I consider the supporting text regarding West Cheshunt should be amended to reflect the need to address continuing problems of dereliction as soon as possible.

2.19.2 The land fulfils the green belt functions of preventing St James from sprawling into the countryside. Pendine is more open, whereas St James nursery is now mainly covered by coppiced woodland. Both sites play a vital role in maintaining the fragile gap between the built up areas of Goffs Oak and St James. I consider inclusion of the sites within St James would not create any more logical green belt boundary than that shown on the Plan.

2.19.3 Neither site constitutes PDL as defined in PPG3. Although the sites are within reasonably close distance of the facilities at Goffs Oak they do not represent particularly sustainable locations for new housing compared with some other parcels of green belt land. In the absence of housing need, I have found no other exceptional reasons to justify releasing the site from the green belt


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RECOMMENDATIONS


2.20 GBC1 LAND AT PYLON FARM, LAUREL BANK FARM AND LONGMEAD TO THE NORTH OF ST JAMES VILLAGE

First Deposit � Objections 0215/04 RSG Properties Ltd 0030/07,08 Mr & Mrs Clarke 1295/02,03,06 Leach Homes Second Deposit � Objections 0636/04 Mrs J.E Petts 01361/01 Aitch Group 01365/01 St James Road Ltd Issues

(a) Land at Laurel Bank Farm, Longmead and Pylon Farm St James Road, Goffs Oak, should be released from Green Belt and allocated for housing.


2.20.1 Similar comments apply to this site as to a number of other sites in the West Cheshunt area. National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known. For the reasons set out in section 3.2, I agree with this approach. These sites would fall within the remit of such a review.

2.20.2 As I have explained in section 2.36, I consider the supporting text regarding the wider West Cheshunt area as defined by the Council should be amended to reflect the need to address continuing problems of dereliction on nursery sites in the area as soon as possible. I have noted the planning history of the area, including the outcome of the previous Structure Plan strategy and the releases of green belt through the 1994 Local Plan. I appreciate that circumstances have changed since some nursery sites were originally identified for new housing development, and that similar problems remain to be tackled. However, I have to deal with the objections in the current policy context whereby the sites remain within the green belt.

2.20.3 I acknowledge from the survey material produced at the hearing that the quality of agricultural land at Longmead Nursery is moderate to poor in parts. However, that does not justify releasing green belt land on its own,


34

since the argument could be applied to a number of sites, and the openness of substantial areas of the green belt prejudiced as a result. The problems of security mentioned by the objector are not uncommon on the urban fringe and are certainly not exceptional circumstances. The site fulfils the green belt purposes of preventing the encroachment of the built up area of St James into the countryside, and is part of a gap which stops the coalescence of the settlement with the housing estates at Hammondstreet to the north. There is little evidence of former buildings on the site, which was used for horticulture in the past; it does not therefore constitute PDL as defined in PPG3.

2.20.4 Very similar arguments apply to Pylon Farm, which contains one dwelling and some outbuildings but is largely open land in the gap between St James and Hammondstreet. The site of Laurel Bank Farm contains more buildings and hard surfaced storage areas but I have no evidence that the land has an established use for anything other than agriculture; the site is therefore not PDL as defined in PPG3. Although not particularly prominent, any release of land from the green belt and subsequent development would not in my opinion lead to any more defensible green belt boundary than exists at present; it would merely add to the encroachment of built form into the countryside. I consider inclusion of the site within St James would not create any more logical green belt boundary than that shown on the Plan.

RECOMMENDATIONS


2.21 GBC1 LAND AT TWELVE ACRE POULTRY FARM

First Deposit � Objections 1303/01 Mr D J Llewellyn Issues

(a) Land at �Twelve Acre Poultry Farm� Rags Lane should be released from Green Belt and allocated for housing.


2.21.1 Similar comments apply to this site as to a number of other sites in the West Cheshunt area. National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known. For the reasons set out in section 3.2, I agree with this approach but I see no need to make judgements about the merits of


35

potentially competing sites in this report.

2.21.2 The land is predominantly open farmland and fulfils the green belt functions of preventing St James from sprawling into the countryside and joining up with Hammondstreet to the north. I consider inclusion of the site within St James would not create any more logical green belt boundary than that shown on the Plan.

2.21.3 The site does not constitute PDL as defined in PPG3. At present it does not represent a particularly sustainable location for new housing compared to other parcels of green belt land. In the absence of housing need, I have found no other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS


2.22 GBC1 CLARAMOUNT NURSERY (LAND WEST OF BURTON LANE AND NORTH OF GOFFS LANE)

First Deposit � Objections 1269/01 Owners of land at Goffs Lane/Burton Lane Second Deposit � Objections 1269/05 Owners of land at Goffs Lane/Burton Lane Issues

(a) Land West of Burton Lane should be released from Green Belt and allocated for housing.


2.22.1 Similar comments apply to this site as to a number of other sites in the West Cheshunt area. National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known. For the reasons set out in section 3.2, I agree with this approach. As explained in section 2.36, I consider the supporting text regarding West Cheshunt should be amended to reflect the need to address continuing problems of dereliction as soon as possible.

2.22.2 The land is predominantly open paddock land and fulfils the green belt function of preventing urban development encroaching into the countryside.


36

The site does not constitute PDL as defined in PPG3. At present it is not particularly close to any services and facilities and does not represent any more sustainable a location for new housing than other parcels of green belt land. In the absence of housing need therefore, I have found no other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS


2.23 GBC1 LAND AT TUDOR NURSERIES

First Deposit � Objections 01270/042 Persimmon Homes (Essex) Ltd Issues

(a) Land at Tudor Nurseries should be released from Green Belt and allocated for housing.


2.23.1 Similar comments apply to this site as to a number of other sites in the West Cheshunt area. National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known. For the reasons set out in section 3.2, I agree with this approach but as with other sites I make no comment as to its relative suitability for new housing, nor do I consider any matters of detail such as design or access arrangements. As explained in section 2.36, I consider the supporting text regarding West Cheshunt should be amended to reflect the need to address continuing problems of dereliction as soon as possible.

2.23.2 A substantial part of the objection site is covered with glasshouses; some aluminium-framed are in horticultural production, while older timber- framed structures have been vacant for three growing seasons. The south-eastern part of the site is open rough grassland. I understand that cost pressures and strong competition continue to affect nursery businesses and that the whole site may become vacant at some time before the end of the Plan period. Nevertheless, the existing horticultural use is appropriate in the green belt and the site as a whole fulfils the green belt functions of preventing urban development encroaching into the countryside and maintaining the gap between Cheshunt and St James. At present, dereliction is not a serious problem at this location. The site does not constitute PDL as defined in PPG3 and at present it does not represent a particularly sustainable location for new housing compared with other parcels of green belt land. In the absence of housing need, I have found no


37

other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS


2.24 GBC1 LAND AT 424 GOFFS LANE, 454 GOFFS LANE AND LAND EAST OF BURTON LANE AND NORTH OF GOFFS LANE

First Deposit � Objections 0005/01 Mrs P Parrish 0518/01 Earl & Lawrence Second Deposit � Objections 01379/01 Mrs E.T Russell Issues

(a) Release land at 424 Goffs Lane to allow for modest infill development

(b) Land at 454 Goffs Lane, Cheshunt should be released from Green Belt as a valeting business is run from this property.


2.24.1 Similar comments apply to the larger of these sites as to a number of other sites in the West Cheshunt area and Tudor Nurseries in particular, which is included within it. National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known.

2.24.2 The smaller sites are part of a ribbon of residential development along both sides of Goffs Lane which stretches almost unbroken between the western edge of Cheshunt and Goffs Oak. This area has been included with the green belt since the 1994 Local Plan, and the properties are subject to normal restrictions on development which seek to preserve the openness of the vulnerable gap between the settlements, fulfilling the fundamental purpose of green belt policy. If such restrictions on substantial extensions or infilling were relaxed the character of the green belt would be compromised at this critical point and the effectiveness of the policy undermined. The existence of a small business run from an objector�s house is not a reason of significant importance to affect one of the key features of the green belt, its permanence.


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2.24.3 Therefore I find no exceptional circumstances to justify changing the green belt boundary here.

RECOMMENDATIONS


2.25 GBC1 LAND SOUTH ANDREWS LANE

Second Deposit � Objections 1281/03 David Wilson Estates Issues

(a) Land south of Andrews Lane should be released from Green Belt and allocated for housing.


2.25.1 Similar comments apply to this site as to a number of other sites in the West Cheshunt area. National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. As Section 3.2 shows, there is no housing need, since an adequate supply of land will be provided through existing commitments, estimated windfall and sequentially preferable sites outside the green belt. The Council has agreed to review all green belt land in determining its future housing strategy when revised requirements set out in RSS14 are known. For the reasons set out in section 3.2, I agree with this approach but make no comment about the relative merits of potential competing sites to inform that process.

2.25.2 The land is predominantly open grazing land. It fulfils the green belt function of preventing the outward spread of urban development at St James and the coalescence of that settlement with Cheshunt. The site does not constitute PDL as defined in PPG3. At present it is not particularly close to any services and facilities and does not represent any more sustainable a location for new housing compared with other parcels of green belt land. In the absence of housing need therefore, I have found no other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS



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2.26 GBC1 LAND NORTH OF ANDREWS LANE ( PEAKES WAY AND RAGS LANE)

First Deposit � Objections 1297/01 Mr D. McGregor & M Francis 1272/08 Mr A J Salter Issues

(a) Land north of Andrews Lane should be released from Green Belt and allocated for housing.



2.26.2 The land is predominantly open grassland. It fulfils the green belt function of preventing the outward spread of urban development at Cheshunt. The site does not constitute PDL as defined in PPG3. At present it is not particularly close to any services and facilities and does not represent any more sustainable a location for new housing compared with other parcels of green belt land. In the absence of housing need therefore, I have found no other exceptional reasons to justify releasing the site from the green belt.

RECOMMENDATIONS


2.27 GBC1 LAND AT EVEREST SPORTS GROUND

Second Deposit � Objections 1293/036 Colin Buchanan and Partners Issues

(a) Land at Everest Sports Ground, off Andrews Lane should be released from Green Belt and allocated for housing.


40



2.27.2 The land is predominantly open grassland, last used as a sports ground for Everest Double Glazing. Although it is largely surrounded by housing estates on three sides, it fulfils the green belt functions of preventing the outward spread of urban development at Cheshunt and forms part of the important gap between St James and the western edge of the main urban area of the Borough. The site does not constitute PDL as defined in PPG3.

2.27.3 However, it lies just outside the accessibility corridor and is within reasonable distance of a range of schools community facilities and shops. The objectors argued that it would be suitable for residential development primarily of much needed affordable housing, including special needs dwellings and those for key workers. Community facilities, a shop and open space are also proposed. Whilst there is a clear need for such housing in Broxbourne, such a development would not comply with government policy in PPS1 and PPG3 to create mixed sustainable communities. The developments already in the housing pipeline will provide substantial numbers of affordable units, in accordance with local and national policy. As far as I am aware, none of these policies advocate providing an even greater oversupply of dwellings on green belt land solely to meet affordable housing needs. Structure Plan dwelling targets include allowances for affordable housing, which should be provided within mixed developments in the normal way. In the absence of general housing need therefore, I consider the need for affordable housing does not constitute an exceptional reason to justify releasing the site from the green belt; if so, it could be repeated many times over throughout the sub region.

RECOMMENDATIONS


2.28 GBC1 LAND TO WEST OF PARK PLAZA

Second Deposit � Objections 1276/02 Meux Trust


41

Issues

(a) Release land to West of Park Plaza from Metropolitan Green Belt to meet regeneration and employment needs


2.28.1 National policy in PPG2 and Structure Plan policy require objectors to demonstrate exceptional circumstances before green belt boundaries should be changed. The site comprises open fields to the west of the A10 which form an important open gap between Cheshunt and the northern edge of Enfield. It fulfils the important green belt functions of preventing the encroachment of urban development into the countryside and the coalescence of these two settlements.

2.28.2 The objector argued that the site would support the development of a business cluster in combination with the Park Plaza scheme to the east of the A10. However, the Plan does identify two significant areas of employment land at Park Plaza and NE Hoddesdon to meet future needs. I have no firm evidence of any shortfall in employment land up to the end of the Plan period. I agree with the Council that the objector�s comment about the likelihood of a business cluster developing at Park Plaza is purely speculative at this stage.

RECOMMENDATIONS


Proposed GBC1 Revisions to Green Belt Boundary

2.29 GBC1(A) - LAND ADJACENT TO THE NORTH BANK OF THE RIVERS LYNCH AND LEE AT HODDESDON

Objections - First Deposit 0813/07 New River Action Group

Objections - Second Deposit

1009/081 English Nature

Issues

(a) Concerned about the impact on wildlife.

(b) Release from Green Belt is contrary to Council�s policies HD17/HD19 - landscape and green chains


2.29.1 I note that these objections have been overtaken by events, in that a


42

resolution to grant outline planning permission has been passed, subject to completion of a Section 106 agreement. A development brief provides for the impact of the scheme on wildlife interests to be mitigated.

RECOMMENDATIONS


2.30 GBC1 REVISIONS TO GREEN BELT BOUNDARY - GBC1(B) LAND AT HERTFORD REGIONAL COLLEGE

Objections - First Deposit 0064/01 Mr & Mrs M Briggs 078/01 Miss Grencastle 0562/05 The Wormley Society 0616/07 Ms C. Haigh 0635/03 Mr S. Ribbons 0813/08 New River Action Group 0823/01 Mrs D.M. Weston 0862/02 Mrs S. White 1101/48 CPRE - The Hertfordshire Society

Objections - Second Deposit 1009/081 English Nature 1374/01 Mrs J Currant 1377/01 Mrs V Jones 1378/01 M.I Richardson 1380/01 Mr & Mrs Stickler 1381/01 Mr & Mrs Wade 1385/01 Mr & Mrs Benn

Issues

(a) Object to removal of Green Belt/green wedge status as will encourage urban sprawl and increase problems with parking, traffic congestion and disturbance to neighbouring properties

(b) Oppose any development on educational land as this may be needed to meet Borough's growing population

(c) Council's proposal goes against previous public inquiry decision involving development at the college

(d) Land forms a lung of Green Belt adjoining the Lea Valley Park

(e) Policy should state that no housing or commercial buildings are to be built.

(f) Proposed Green Belt release fails to provide protection for the New River

(g) Land fulfils the purposes of Green Belt as stated in PPG2

(h) Land should be reserved for recreational use for local sports or students.

(i) Land represents the only remaining east-west wildlife corridor


43


2.30.1 From my site inspection I can well understand the pressing need to allow the repair, rebuilding and refurbishment of some buildings on site, many of which date back to the 1960s. There is comprehensive detailed evidence of leaking roofs and the poor general state of the building fabric, which is not in dispute. Improvements to the accessibility of the buildings for those with disabilities are urgently required, and there is a pressing need to provide a significantly better teaching environment.

2.30.2 Furthermore, the college wishes to expand the range and type of courses available at the site; although it is run jointly with other premises at Ware, the College tries to operate the units as independently as possible, to avoid unnecessary travelling between the two sites. The ability to expand the educational provision at Turnford would help to address local skill shortages and meet future education needs resulting from further housing growth as a result of likely proposals in RSS14 for development in the A10 corridor. I agree with the Council and objector that this site, in a central location within the Accessibility Corridor is best placed to provide these improved facilities.

2.30.3 I appreciate that green belt policy constraints would impair the ability of the College to meet its aspirations and improve its facilities for the local community. I accept that future requirements cannot be met within the existing building footprint and that some additional land is needed. Removing the site from the green belt would help these processes. Leaving the site as it is with restrictions on new buildings is not a viable option. The redevelopment of the college has more support at all levels of government than it did in 1997, when the Secretary of State considered earlier proposals for the site, which included about 3 ha of new housing. Policy 13 of the Structure Plan places greater emphasis on educational needs, as does the Council�s own Community Plan. PPS1 stresses the need for social inclusion and states that Development Plans should address accessibility for all members of the community to education, in a sustainable way.

2.30.4 Since 1997 the nature of the surrounding environment has also changed significantly, with the development of a major housing site at Canada Fields. Critically, this development has significantly reduced the extent of open green belt land between Cheshunt and Turnford. In my view the site provides very little sense of being a major green wedge or gap between the built up areas. When travelling along the Great Cambridge Road through to High Road, Turnford, the only green space on either side of the route is the site known as the Wilderness (see section below). The large roundabout to the south west of the site is an urban feature, and the view from the car park of the public house opposite is almost entirely taken up with buildings and hard surfaces in all directions. The college buildings occupy much of the frontage of the objection site itself, and a small green area has been lost to a day nursery building and car park. The railway line forms a natural defensible boundary to the east, with hedgerows preventing any real visual link to the open land off the Lea Valley Regional Park beyond.

2.30.5 The land is almost entirely enclosed by urban form and in my view has ceased to perform the green belt functions of preventing the coalescence of settlements and encroachment onto the countryside. Part of the site may have some local significance as open land but I consider any strategic contribution to the openness of the wider green belt has been lost. Without


44

prejudice to future proposals, the policy calls for a planning brief to specify open space to be retained. The council has dropped its �green wedge� policy, in accordance with government advice in #25 of PPS7 and this no longer applies.

2.30.6 The site would be subject to Policy EMP10, which does not allow for housing development. The Plan more than provides enough housing to meet Structure Plan requirements up to 2011. Any future proposals would have to be considered when RSS14 requirements for the period beyond 2011 have been published and in comparison with other competing sites.

2.30.7 The issue of traffic generation was covered in the previous inspector�s report, which concluded that congestion would not be an unacceptable problem. However, the current position may be different and a proposed change to Policy EMP10 quite rightly puts forward a criterion requiring a green travel plan to be formulated to accompany any scheme. The site is well located in the major public transport corridor and is as good a location as most others to help reduce the need to travel by private car.

2.30.8 Taking into account the pressing need for redevelopment of some college buildings and the very limited contribution of the site to the green belt as a whole, I consider that there are exceptional circumstances in this case to justify its release, subject to the requirements of Policy EMP10.

RECOMMENDATIONS


2.31 GBC1 REVISIONS TO GREEN BELT BOUNDARY - GBC1(G) LAND AT 303 WARE HODDESDON (DELETED FROM FIRST DEPOSIT PLAN)

Objections - First Deposit 0102/09 Mr & Mrs C West 0216/04 Mr J. Piner 0218/04 Mrs C. Piner 0306/02 Mrs J. Gant 0308/01 Mr & Mrs S. Gibbs 0426/01 D. Carter 0449/04 Mr M. Richardson 0452/05 Mrs T Richardson 0454/04 Mrs T Trick 0456/02 L. Roger 0457/02 Mr & Mrs J. Brookman 0473/03 Mr M. Reynolds 0477/02 T J A Jordan 0488/02 Mr & Mrs D. Butler 0500/03 Mr & Mrs A Mitchell 0527/03 Mr & Mrs M. Taylor 0644/02 Mrs A. Marsh


45

0660/02 Mrs F. Matthews 0690/01 Mrs Y Read 0691/01 M.J Glossop 0693/02 Mr W.C Pelling 0698/03 Mr S. Maniscalco 0702/02 Mr K Trick 0872/05 Mr A. LeBaigue 0904/03 Mr & Mrs Sawyers 0938/02 Mr P.J. Whiting 0940/04 Mrs N. Whiting Second Deposit � Objections 0013/01 & 05 Mrs J Liddard

Issues

(a) Object to need for the separate release of 303 Ware Road from Green Belt.

(b) Site could be developed if footpath retained.

(c) Objections to deletion of site from Second Deposit Plan.


2.31.1 All the objections to the 1st deposit would be met by the deletion of the site as a housing allocation from the 2nd deposit.

2.31.2 Originally the site was included in the residential allocation of land known as the Hailey site (previously owned by MAFF) to the south. This land is being developed in accordance with government policy in PPG3 at a relatively high density compared with surrounding housing areas to the east and south. Given significant change that has taken place on the adjoining site, and the relatively well-developed nature of the land at 305 Ware Road (which is not really built at a low density typical of rural areas, see 2.4.2) I can appreciate the logic behind an argument in favour of a re-aligned boundary at this location. From my inspection, the footpath that separates these two sites would form no more logical a boundary than the northern fence/hedge of the garden to the bungalow on 303 Ware Road.

2.31.3 There is no real dispute that the site lies in a sustainable location, as acknowledged by the allocation of the adjoining MAFF site for a substantial number of new dwellings. If any green belt land were needed, this site would appear to have several advantages, and in those circumstances could be said to meet requirements of Structure Plan Policy 7. There is no reason why the site could not provide a small amount of affordable housing.

2.31.4 On other matters, I can appreciate the Council�s initial desire to service the site via the land to the south. However, it has been agreed that satisfactory access can be obtained independently. At present there is no access to the public, so no land used for general recreation would be lost. I consider that the site would be a logical extension to the developed area of Hoddesdon, given its sustainable position.


46

2.31.5 However, the Council now say that the Plan provides enough housing land to meet Structure Plan requirements to 2011, a conclusion with which I agree (see Chapter 3). In these circumstances there are no exceptional circumstances to justify changing green belt boundaries, as required by PPG2 and Structure Plan Policy 7. The Council has agreed to review the suitability of this and other green belt sites to meet longer term needs when it undertakes an early review of the Plan, following approval of strategic guidance in RSS14.

RECOMMENDATIONS


2.32 GBC1 REVISIONS TO GREEN BELT BOUNDARY - GBC1 (C) (GBC1 (E) IN FIRST DEPOSIT) LAND AT CHESHUNT SCHOOL

Objections - First Deposit 0282/04 Friends of Cheshunt Park 0616/05, 6 Ms C. Haigh 0933/06 K. Fedorowick

Issues

(a)This land should be retained for school expansion - consider A10 is a better natural boundary

(b) Improving facilities of school should not be based on selling land for housing


2.32.1 The proposed revision of the green belt boundary at the school reflects what has already happened on the ground and does not involve any allocation of more land for housing. It would possibly allow for expansion of facilities within the school complex and an area between the existing buildings and the A10. I consider that the new boundary would provide a robust and defensible line that would meet the important green belt policy objective of preventing further encroachment into the countryside. It would define a secure and permanent long term boundary in accordance with the thrust of government policy in PPG2.

RECOMMENDATIONS



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2.33 GBC1 REVISIONS TO GREEN BELT BOUNDARY - GBC1(D) LAND AT ST MARY'S SCHOOL

Objections - Second Deposit 1015/01 Thames Water Property 1101/065 CPRE - The Hertfordshire Society 1295/08 Leach Homes 1371/01 Residents Association Focus Team 1376/01 Councillor M Greensmyth

Issues

(a)Proposal does not meet the 'exceptional circumstances' for release from the Metropolitan Green Belt as required by PPG2

(b)More sustainable development sites should be allocated for housing development before Green Belt sites are considered.

(c) Site has a flooding history


2.33.1 I deal in full with the merits of the Plan proposals for the relocation of St Mary�s School in Chapter 4. In summary, I consider that there are insufficient planning reasons to justify the release of either the existing site or the Bury Green Farm site at this time, pending the start of any scheme as a result of the planning permission on the proposed site. In the absence of any housing need and the ability of the Plan to meet requirements on sequentially preferable sites outside the green belt, I concluded the financial advantages of redeveloping the existing site to help fund the relocation did not constitute exceptional circumstances to justify green belt release. If the existing school buildings become redundant, the site could be assessed as to its suitability to meet future development needs, including housing, when the LDF or LDD is being prepared.

RECOMMENDATIONS

GBC.33 Modify the Plan by retaining the site within the green belt.

2.34 GBC1 REVISIONS TO GREEN BELT BOUNDARY - GBC1 (E) (GBC1 (F) IN FIRST DEPOSIT) LAND AT WHITEHAVEN, BURTON LANE

Objections - First Deposit 0282/03 Friends of Cheshunt Park 0616/08 Ms C. Haigh


48

Issues

(a) Land should be retained as Green Belt for informal recreation

(b) Insufficient facilities in the area to support further releases of Green Belt land for housing.


2.34.1 The revision to the boundary here reflects what has happened on the ground, where the site has recently been developed with housing.

RECOMMENDATIONS


2.35 GBC 2 AREAS OF SPECIAL RESTRAINT (DELETED FROM SECOND DEPOSIT PLAN)

Objections - First Deposit 1264/05,030 Higgins Homes Ltd 1298/02,03 Berkeley Strategic Land Ltd 0872/04 Mr A. LeBaigue 0451/02 Mr & Mrs Eley 01001/092 Hertfordshire County Council 01101/037 CPRE - The Hertfordshire Society 1102/10,12,85,88 Goff's Oak Community Association 1250/01-03 Woodhall Properties Ltd 1258/03 Hubert C. Leach 1270/016,17 Persimmon Homes (Essex) Ltd 1272/07 Mr A J Salter 1277/04 Landmatch Ltd (formerly Lafarge Aggregates) 1293/03,04 Colin Buchanan and Partners 1294/015 Bellway Estates Objections - Second Deposit 1258/012 Hubert C. Leach 1264/034 Higgins Homes

Issues (a) Plan fails to identify Areas of Special Restraint (ASRs) to meet development

needs following deletion of policy in Second Deposit. (b) Plan fails to consider other land outside West of Hoddesdon suitable to be

identified as ASRs (c) Land West of Hoddesdon acts as a landscape buffer to the A10 and should not

be identified as an ASR


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(d)One of the few areas of open space in this section of Hoddesdon and vital to the community (e)Most of the land serves Green Belt purposes set out in PPG2

(f)No case for releasing land on the grounds of housing need, or to look beyond the current local plan period

(g)Landowner supports designation but seeks a larger area for release from Metropolitan Green Belt that that defined on Proposals Map.

(h)Insufficient infrastructure in Hoddesdon to support development.


2.35.1 The objections to the 1st deposit were met by the Council�s decision to remove the ASR from the Plan, following revised calculations concerning housing land availability. I have already referred to my conclusion that the Plan identifies more than enough potential new housing to meet the requirements of the approved Structure Plan for the period up to 2011. While accepting this point, Landmatch and Hubert C Leach Ltd argued that the ASR designation should be re-instated to meet future housing needs in the period beyond 2011.

2.35.2 PPG2 states that where Local Plans are being revised, green belt boundaries should not be changed unless alterations to the Structure Plan have been approved or there are other exceptional circumstances which necessitate such a revision. However, it also says long term releases should be identified to avoid the need for future changes, and reduce uncertainty about green belt protection. Local planning authorities should satisfy themselves that boundaries will not need to be changed at the end of the plan period, which may involve safeguarding land at the edge of the urban area. Regional or strategic guidance should provide a framework to inform this process.

2.35.3 In this case the current Structure Plan (Policies 5-8) does not provide for any green belt releases in Broxbourne. RSS14 has been published in draft form, identifying Broxbourne as falling within the A10 and Harlow growth corridor, but at present there is no clear guidance about the numbers of dwellings needed within the Borough beyond 2011. I deal with other arguments about the need for a 10 year supply in section 3.2. When the land was first identified as an ASR in the 1st deposit to meet development needs beyond the Plan period, this designation may not have conflicted with Structure Plan policy at a time of a possible shortfall of housing land. Circumstances have changed since, particularly with regard to the capacity of some large sites and within the urban area overall.

2.35.4 I appreciate the Council�s difficulty in knowing how much land to designate as an ASR; much will depend on the future housing policy context and the scale of need over several years. This is a large site of about 40ha, capable of accommodating a minimum of 1200 dwellings at the densities recommended in PPG3. I consider that it would not be difficult to imagine a scenario whereby a residual greenfield housing requirement (taking account of revisions to projected capacity within the urban area) would be significantly less than this number for the period to 2011-16 or even to 2021.


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2.35.5 I recognise that the Council thought at 1st deposit stage that this was the best site if any green belt land were needed for release. The objectors argued that circumstances had not changed since then, and no other surveys or other evidence had been adduced to show that the original analysis was wrong. However, in response to other objections concerning a number of sites in West Cheshunt, the Council has agreed that a review of all green belt land should take place once regional guidance about housing targets has been finalised and an urban capacity study completed.

2.35.6 At the inquiry there was no dispute that the original ASR was located in a sustainable location; most parts of the ASR lie within about 1.5km of Hoddesdon town centre, with the retail and other facilities it provides. It is reasonably close to the accessibility corridor. The A10 would effectively constrain any spread of development to the west and would provide a clear, firm boundary to the green belt. The character of the landscape is somewhat different from the land west of the A10, which rises up to the west and contains substantial areas of woodland. Although the objection site is visually quite self contained, it does form part of a larger area between the A10 and Hoddesdon which provides an open setting for the town. There are no other obvious constraints (such as access problems or potential loss of wildlife) to the development of the site in the long term.

2.35.7 Nevertheless, from evidence to the inquiry and my own assessment of objection sites, I consider that other land may equally be suitable, depending on the scale of need for greenfield land. I consider it reasonable for the Council to decide to undertake an early review of housing provision to take account of factors raised by other objectors and updated strategic guidance. In the absence of such guidance or any sub-regional policy clearly proposing a need for an ASR, I consider there are no exceptional circumstances to justify the removing the land from the green belt within this Plan period.

RECOMMENDATIONS


2.36 GBC2 DEVELOPMENT WITHIN THE METROPOLITAN GREEN BELT (FORMERLY GBC3)

Objections - First Deposit 0254/02 R. Barnes 1251/03 Fitzpatrick PLC 1270/014 Persimmon Homes (Essex) Ltd 1288/01 Sworders Agricultural 1102/10,12,85,88 Goff's Oak Community Association 1316/01 Mr & Mrs B. Smith


51

Objections - Second Deposit 168/03 Mr R.E Henbest 595/01, 04 Goffs Oak Community Association 635/05 Mr S. Ribbons 867/01 Mr C. I. Maxen 1006/17 Epping Forest District Council 1373/01 R Petts

Pre-Inquiry Changes 1277/019 Landmatch Ltd (formerly Lafarge Aggregates)

Issues

(a) Policy should include a specific allocation for provision of a cemetery at Box

Wood, Hoddesdon on land west of the A10, thereby adding strength to the

Council's position as set out in para 2.5.2.

(b)Disagree with para 2.5.3 that the issue of derelict glass houses has been

resolved and the view that a balance has now been achieved. Text fails to

describe true condition of remaining dereliction.

(c)Council's interpretation of Structure Plan Policy 54 from the 1986 Structure Plan

is incorrect.

(d)Paragraph 2.5.3 should include a commitment to strongly resist further

development in the West Cheshunt area rather than merely resist.

(e)In respect of PIC011, failure of the suggested new text to reflect the resolution

to grant planning permission (ref. 7/1122-02) for a cemetery on land north of Lord Street and west of the A10 (T) at Hoddesdon.


2.36.1 In response to a number of objections about sites in West Cheshunt, the Council has proposed a change to the wording in #3.5.1-3.5.5 of the Plan. In essence this states that while development will be resisted in the West Cheshunt area during the life of the Plan, all areas of green belt will be reconsidered as to their suitability for development, including new housing, when the Plan is reviewed as part of the LDF process. The Council intends to undertake such a review following approval of RSS14, which will identify future housing requirements for the period to 2016 and beyond.

2.36.2 Given the change in emphasis of the Plan the more detailed explanation of this general policy for the West Cheshunt area compared with any other parts of the green belt is in some ways an anachronism. Many of the factors listed in revised #3.5.3, such as sustainability principles and the threat of coalescence, would apply in general to all areas of green belt. Some of the physical attributes of the area, and the desire to protect certain parts for landscape reasons, should be taken on board in any future review of policy in any event.

2.36.3 I have much sympathy with the objectors� point that the issue of dereliction


52

on a number of former glasshouse sites has not been addressed fully. While the new housing schemes undertaken following the proposals set out in the 1986 Structure Plan and the 1994 Local Plan have dealt with what were identified as the worst problems at that time, the process of change and decline in certain areas of production in West Cheshunt has continued. It became clear from my visits that a number of sites suffer from extensive areas of broken glass, unsightly old infrastructure such as concrete bases, heating pipes, water tanks, and hard surfaces and from overgrown scrub. I consider that the Plan does not address these common issues of safety and unsightly appearance properly.

2.36.4 The previous Local Plan contained Policy WC9, which sought to address problems of dereliction on those sites not considered suitable for housing, through a number of measures, including use of CPO powers and Derelict Land Grant. I have no evidence of any specific positive actions to implement this policy, but clearly from my visits to the area it has not been fully effective. Following revisions to policy GBC17, the 2nd deposit plan contains no specific provisions which address the issue of improving derelict land. The Plan does however contain policies that protect countryside areas and monuments of special character (HD1 and HD3).

2.36.5 As I have acknowledged elsewhere in section 3.2 of the report, Structure Plan housing requirements to 2011 will be met and there is no need to identify further releases of land for housing during the life of this Plan. I consider therefore as a general principle that the very special circumstances required to justify a change to green belt boundaries on the grounds of housing need do not exist. However, given the outstanding problems in the area, I do not think that West Cheshunt should be afforded any better protection than other parts of green belt. I therefore support the Council�s approach that all areas of the Borough should be subject to early review when RSS14 housing requirements are finalised. The Council has given a clear commitment to undertake such a review as a matter of urgency; this would create the opportunity to address the issues of future housing needs and continuing dereliction at the same time, and to put forward comprehensive proposals for the whole West Cheshunt area. I deal with individual objections elsewhere in this chapter.

2.36.6 In these circumstances, I consider that the proposed revisions to #3.5.1-5 are acceptable in principle. However, I find it difficult to accept that the rural character of the area remains at locations where substantial housing development has taken place. While not the subject of a formal recommendation for deletion, I suggest however that some parts of #3.5.2 should be re-written to provide recognition of the need to re-survey the area and address remaining derelict sites through positive measures if further housing development is considered inappropriate at the review stage.

2.36.7 The wording of the Policy GBC2 accurately reflects government policy in PPG2 that cemeteries are not inappropriate in the green belt. However, The Plan would be unnecessarily complex if it were to identify a number of sites for particular proposals such as cemeteries. In this case, although planning permission has been granted for such a use at two locations, off Hertford Road and at Lord Street. If both are acceptable, it would not be right for the Proposals Map to identify one site in preference to another. I agree with the wording change proposed in PIC11, which usefully reflects draft Structure


53

Plan Policy concerning general sustainability principles.

RECOMMENDATIONS

GBC.36 Modify the Plan in accordance with PICs 10 & 11 and AIC06, subject to some revision of #3.5.2 on the lines suggested in # 2.36.6 above.

2.37 GBC5 REMOVAL OF AGRICULTURAL OCCUPANCY CONDITIONS (FORMERLY GBC6)

Objections - First Deposit 1009/082 English Nature

Issues

(a) Policy should be cross - referenced to policies GBC7, 8 and 9 (now GBC6, 7 and 8) to avoid abuse of restricted occupancy dwellings.

(b) There may be a need for accommodation for other acceptable uses in the Green Belt


2.37.1 PIC12, which I support, has addressed the first objection. The Council has suggested a further change which would enable them to retain agricultural occupancy conditions to serve a different purpose from the one originally in place. I consider such a policy would not comply with government policy regarding the use of conditions set out in Circular 11/95. In essence applying the policy would be akin to imposing a new condition retrospectively on an existing dwelling.

RECOMMENDATIONS

GBC.37 Modify the Plan in accordance with PIC 12

2.38 GBC6 PROPOSALS FOR NON AGRICULTURAL USES OF GREEN BELT LAND (FORMERLY GBC7)

Objections - First Deposit 1009/19,20 English Nature Objections - Second Deposit 1000/0105 GOE


54

Issues

(a) Policy needs to be cross-referenced with GBC7-GBC9 and reference made to sustainability


2.38.1 The 2nd deposit usefully makes cross reference to other policies.

RECOMMENDATIONS

GBC.38 Modify the Plan in accordance with PIC15

2.39 GBC7 BUILDINGS REQUIRED IN ASSOCIATION WITH PREDOMINANTLY OPEN USES OF GREEN BELT LAND (FORMERLY GBC8)

Objections - Second Deposit 1101/069 CPRE - The Hertfordshire Society Issues

(a) Policy fails to recognise problems associated with the establishment of stables.


2.39.1 I consider that the policy as a whole provides a sufficient basis to ensure that new equestrian development in the green belt meets the requirement in PPG2 that it should be small scale and should protect the visual amenity of the countryside in which it is set. I agree with the Council that criterion (ii) of the policy gives further guidance on this issue.

RECOMMENDATIONS


2.40 GBC10 TRAVELLING SHOWPEOPLE (FORMERLY GBC11)

Objections - First Deposit 0805/01 John Manning Amusements 0227/01 David Manning's Amusements 1001/061 Herts County Council Forward Planning Unit


55

Issues

(a) Plan fails to provide for a group of showpeople who do not have a permanent site but have resided in the Borough for over 40 years.

(b) Para 2.5.11 should also refer to smaller site at 579 Goffs Lane

(c) Broxbourne should identify as part of this policy a new permanent gypsy site to replace that which is proposed for development at Halfhide Lane.


2.40.1 The objection concerning a site at Goffs Lane has been met by changes to the 2nd deposit.

2.40.2 The Council has put forward a suggested change which adds a clause to the policy supporting the provision of a travelling showpersons� site in NE Hoddesdon. The objector agrees to this change. Taking into account the wording of the policy clause which protects existing and any newly permitted site, I consider that the Plan would comply with the guidance in Circular 22/91 about meeting travelling showpeople�s needs by giving as much assistance as possible in finding suitable sites.

RECOMMENDATIONS

GBC.40 Modify the Plan in accordance with AIC08

2.41 GBC14 RURAL DIVERSIFICATION


1000/0111 GOE 1001/071 Herts County Council Landscape Unit

Issues

(a) Policy should be revised to give greater certainty as to what will be permitted

(b) Policy omits reference to local landscape character

(c) Policy should follow the example of The Hambleton District Plan


2.41.1 The substance of these objections has been met by PIC 16, which in my view clarifies the policy and usefully adds a reference to fostering local landscape character.

RECOMMENDATIONS



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2.42 GBC15 RE-USE OF EXISTING BUILDINGS

Objections - First Deposit 1100/017 Herts & Middlesex Wildlife Trust 01010/04 The Countryside Agency (E. England Region) Objections - Second Deposit 1009/083 English Nature Issues

(a) Policy should have a stronger emphasis favouring re-use for economic purposes

(b) Title of policy should refer to re-use of �rural� buildings.

(c) Policy omits reference to protection of bats being present in buildings.

(d) Policy does not adequately take into account the impacts of ancillary operations


2.42.1 I note the Council�s comments about the proximity of Broxbourne to London and the variety of employment opportunities provided within and close to the Borough. However, rural diversification may continue to be an issue within Broxbourne due to the changing nature of the glasshouse business in the wider Lea valley. In any event, such an argument could apply to substantial areas of the Metropolitan Green Belt, not just to Broxbourne. PPS7 re-iterates the preference for the employment use of rural buildings originally contained in the superseded PPG7 and in PPG2. Retention of such buildings in employment rather than residential use may also help to conserve the visual amenity of the green belt, by minimising visual clutter and suburban paraphernalia within the curtilage of conversions. Other criteria of the policy would allow for the re-use of rural buildings for holiday accommodation, community purposes, affordable housing or general housing if the specific circumstances of the building or its location provided sufficiently good reasons.

2.42.2 The Council has agreed to the inclusion of �rural� in the policy heading.

2.42.3 As the Council point out, bats are a species protected by other legislation. I see no need for a specific clause in this policy to require any additional measures.

2.42.4 Clause (I)(b)(iv) deals with the potential impact of �other features� (in addition to hard surfaces), which could encompass service connections.

RECOMMENDATIONS

GBC.42 Modify the Plan in accordance with AIC09 and by inserting the following clause after (i) in part (b) of the policy:

�IN THE CASE OF PROPOSALS FOR RESIDENTIAL USE, BUSINESS, COMMUNITY or TOURIST USES, OR CONVERSION TO AFFORDABLE HOUSING, HAVE BEEN SHOWN TO BE EITHER INAPPROPRIATE IN PLANNING TERMS OR OTHERWISE IMPRACTICAL�


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2.43 GBC16 LANDSCAPE CHARACTER AREAS (FORMERLY GBC17)

Objections - First Deposit 0695/01 Ms J. Crew 1001/91,93 Hertfordshire County Council 1009/023 English Nature 1010/06 The Countryside Agency (E. England Region) 1264/06,07 Higgins Homes Ltd 01269/02 Owners of land at Goffs Lane/Burton Lane Objections - Second Deposit 1001/074 Hertfordshire County Council 1000/0106 Government Office for the East of England 1001/072 Hertfordshire County Council 1267/05 Rialto Homes plc - Canada Fields 1269/07 Owners of land at Goffs Lane/Burton Lane 1293/05 Colin Buchanan and Partners Issues

(a) Policy should include two additional areas - land West of Hoddesdon and Cheshunt South Reservoir.

(b) Policy should reflect updated landscape areas identified by appraisal undertaken on behalf of Herts County Council.

(c) Policy should include updated references to Turnford and Cheshunt Pits.

(d) Landscape character areas need to be reviewed to correct discrepancies and be shown on proposals map.

(e) Policy confuses 'landscape character' and 'appearance'.

(f) Objections to application of this policy to specific sites being promoted for development


2.43.1 The council has proposed changes to include descriptions of 8 landscape character areas, all of which lie within the green belt, and to combine Policies GBC16 and 17. These meet the thrust of most of the objections and would create a more logical policy context for landscape enhancement, where possible.

2.43.2 I deal with objections concerning Cheshunt South Reservoir, which is essentially a site within the urban area, in chapter 3 below.

RECOMMENDATIONS

GBC.43 Modify the Plan in accordance with PICs 019 & 017


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2.44 GBC17 LANDSCAPE ENHANCEMENT (FORMERLY GBC18)


1000/0102 GOE

Issues

(a) Policy could be omitted as repeats intention of GBC16


2.44.1 The policy has now been combined with GBC16 above.

RECOMMENDATIONS


2.45 GBC18 PROTECTION AND ENHANCEMENT OF PUBLIC RIGHTS OF WAY (FORMERLY GBC19)

Objections - First Deposit 1001/035 Hertfordshire County Council

Issues

(a) Policy would benefit from reference to County Good practice guide


2.45.1 This objection has been met by a change to the 2nd deposit

RECOMMENDATIONS


2.46 GBC19 PROTECTION OF INTERNATIONALLY IMPORTANT WILDLIFE SITES.

Objections - First Deposit 1009/026 English Nature


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Objections - Second Deposit 1000/0112 GOE Objections - Pre-Inquiry Changes 1253/016 The House Builders Federation Issues

(a) Policy should be worded more positively to give greater certainty as to what will be permitted.

(b) Policy should refer to sites of international importance


2.46.1 The Council accept the points made in the objections. I consider the revised wording, with minor changes as recommended below, would clarify the Plan.

RECOMMENDATIONS

GBC.46 Modify policy GBC19 to read as follows:

�DEVELOPMENT THAT WOULD HARM THE NATURE CONSERVATION OR GEOLOGICAL INTEREST OF AN INTERNATIONALLY IMPORTANT WILDLIFE SITE WILL NOT BE PERMITTED UNLESS:

(a) IT IS REQUIRED IN CONNECTION WITH THE MANAGEMENT OR CONSERVATION OF THE SITE; AND

(b) THERE IS A CLEAR NEED TO SUPPORT THE DEVELOPMENT IN THE PUBLIC INTEREST; AND

(c) THERE IS NO LESS ENVIRONMENTALLY DAMAGING SOLUTION

2.47 POLICY GBC20 PARKS AND GARDENS OF HISTORIC INTEREST FROM FIRST DEPOSIT.

Objections - First Deposit 1001/056 Hertfordshire County Council Objections - Second Deposit 1001/073 Hertfordshire County Council

Issues

(a) Object to deletion of this policy from First Deposit


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2.47.1 The Council proposes to re-introduce the policy within Chapter 8 of the Plan (Heritage and Design). This would be appropriate.

RECOMMENDATIONS

GBC.47 Modify the Plan in accordance with AIC051

2.48 GBC20 PROTECTION FOR SITES OF WILDLIFE AND NATURE INTEREST � GENERAL (PREVIOUSLY GBC21)

Objections - First Deposit 1006/18 Epping Forest District Council 1008/018 Environment Agency 1101/038 CPRE - The Hertfordshire Society 1104/04 The Spitalbrook Village Green Conservation Group 1264/10 Higgins Homes Ltd

Objections - Second Deposit 1104/013 The Spitalbrook Village Green Conservation Group 1264/35 Higgins Homes Ltd 1006/020 Epping Forest District Council 1009/077 English Nature 1000/0113 Government Office for the East of England

Issues

(a) There should be a requirement for an environmental assessment as part of the policy.

(b) Policy should include reference to international wildlife sites and geological/geomorphological value.

(c) Policy lacks clarity and should be strengthened.

(d) Policy needs to be simplified as text is repetitive


2.48.1 I have considered the Council�s proposed changes to this policy in PIC021, which seek to meet the objections. While the revised wording improves clarity, I see no need to re-introduce the clause about protected species, which are dealt with satisfactorily by other legislation. Similarly, as GoE point out, separate regulations set out the circumstances in which statutory EIA is required, whatever the Plan says. While government advice is to


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avoid a narrow interpretation of these regulations, it would not be reasonable to impose a blanket requirement on all development proposals which may affect wildlife sites and the certainty sought by some objectors is unrealistic; each case should be considered on its merits. The revised clause on this matter should be re-worded therefore.

2.48.2 As with Policy GBC19, it would be proper for the policy to retain the clause concerning a balancing of competing interests, subject to the deletion of a minor clause as GOE suggest.

RECOMMENDATIONS

GBC.48 Modify Policy GBC20 to read as follows:

(1) �DEVELOPMENT WILL NOT BE PERMITTED IF IT WOULD HAVE AN ADVERSE EFFECT ON:

(a) SPECIAL AREAS OF CONSERVATION

(b) SPECIAL PROTECTION AREAS (spas)

(c) SITES OF SPECIAL SCIENTIFIC INTEREST (SSSIs)

(d) LOCAL WILDLIFE SITES

(e) LOCAL NATURE RESERVES

UNLESS THE NEED FOR THE DEVELOPMENT OUTWEIGHS ITS NATURE CONSERVATION OR GEOLOGICAL VALUE.

(2) WHERE NECESSARY, ANY ENVIRONMENTAL IMPACT ASSESSMENT (EIA) SHOULD IDENTIFY THE EXTENT OF ANY HARM TO THE NATURE CONSERVATION OR GEOLOGICAL INTEREST OF THE SITE AND ANY REMEDIAL MEASURES TO MITIGATE THE IMPACT OF DEVELOPMENT, AND THE MEANS OF IMPLEMENTATION OF SUCH MEASURES THROUGH PLANNING CONDITIONS AND/OR PLANNING OBLIGATIONS

2.49 GBC20 SITE SPECIFIC ISSUES

First Deposit � Objections 030/03,04 Mr & Mrs R Clarke 0215/016 RSG Properties 0282/01 Friends of Cheshunt Park 0627/01 Miss B. Peters 0636/03 Mrs J.E Petts 1015/06 Thames Water Property 1250/014 Woodhall Properties Ltd 1256/01 The National Grid Company PLC 1269/04 Owners of land at Goffs Lane/Burton Lane


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Second Deposit � Objections 1015/01,017 Thames Water Property 1269/08 Owners of land at Goffs Lane/Burton Lane

Issues

(a) Contest the designation of wildlife site 80/046 covering land at Pylon Farm

(b) Whole of Cheshunt Park should be designated as a wildlife site

(c) Contest the designation of Cheshunt South Reservoir as a Wildlife site.

(d) Contest the designation of Rosedale Sports Ground as a Wildlife site.

(e) Contest the designation of land at Rye House substation as a Wildlife site - conflicts with operational needs.

(f) Contest the designation of Wildlife site 80/057 Tudor Villas (Claramount Nursery)


2.49.1 PPG9 states that local planning authorities should designate local wildlife sites only in those instances where there is substantive nature conservation value, and take care to avoid unnecessary constraints on development. All the designated local wildlife sites shown on the Proposals Map originate from surveys carried out throughout the county using standard criteria. I deal with specific points about the surveys for individual sites and their nature conservation value below.

Longmead Farm

2.49.2 There appears to have been some confusion about the designation of land at Pylon Farm and Longmead Farm as a local wildlife site, with the area in question being wrongly named. The area shown on the Proposals Map at Longmead Farm is primarily rough grass on clay soil with some limited remains of former glasshouses. The land does contain old hedgerows of some wildlife interest and evidence of less common plants in damp areas towards Rags Brook. However, from the evidence of the survey and my own site inspection I consider that the whole site does not have such value as to warrant any particular protection afforded by special designation of this sort.

Claramount Nursery, Goffs Lane/Burton Lane

2.49.3 Similar arguments apply to the Claramount Nursery site. The previous glasshouses have been demolished and most of this area has been grazed by horses for some time. The survey information on which the designation was based dates back to 1985. From what I saw of the paddocks on site there was very little that would justify the status of local nature reserve to the extent shown on the Proposals Map; some of the land is used as an all weather ménage with a rubber-based surface. I recommend that the notation be deleted.

Land at Rosedale Sports ground

2.49.4 This site was designated by Herts CC as a Local Wildlife Site in 1999 based on information from a survey in 1985. This identified the land as a


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meadow, supporting species-diverse neutral grassland, described by the surveyor as �rather weedy horse pasture with abundant centaurea nigra� (black knapweed). However, the main part of the site has been used as a rugby pitch for several years, which the objectors claimed had reduced its ecological value. The objectors� recent surveys, in 2001 and 2004 recorded about 39 grassland species, compared with the 40 or more suggested in Herts Wildlife Criteria as a typical number for species-rich grassland. I saw on my visit that the rugby pitches had substantial areas of disturbed grass and no longer had a tussocky structure. Knapweed was still present, although it was abundant only in local patches, and I find no reason to question the objectors� analysis that he site was typical of semi-improved grassland, rather than being species-rich. The smaller part of the site to the south, originally described as primarily rank grassland, has largely been overtaken by brambles and scrub and had very limited value as grassland.

2.49.5 The objectors also questioned the criteria used in the selection process for wildlife sites, with regard to the type and number of species at grassland sites in particular. I can appreciate the need for consistency of approach across the county in this respect but see no need to make comments about the number of different plant species required to justify wildlife site status elsewhere. The Council�s evidence showed that a relatively small proportion of such grassland (less than 3%) had been classified using the current criteria. Similarly, the inclusion of certain species as indicators of semi-improved grassland based on local characteristics in Hertfordshire is not a matter for comment in a report on objections to a Local Plan. However, the inquiry process is a legitimate arena in which such designations can be challenged, considering up to date evidence in individual cases. In this case, the undisputed most recent surveys from the objectors and the change in management regime since the original survey lead me to conclude that the value of the site as wildlife area has been much reduced and that the notation should be deleted.

Cheshunt South Reservoir

2.49.6 I deal with Cheshunt South Reservoir in section 3.19. In summary, I consider the site to be suitable for housing (at the end of the Plan period) subject to detailed proposals for retaining a significant area of open space, including a number of protected trees. This should help to retain substantial wildlife interest, and the bats that have been found at the site in particular. On balance however I consider it would be inconsistent to show an allocated housing area as a local wildlife site. However, parts of the undeveloped land may well warrant such designation once the form of any future development and the nature and extent of retained open space are known.

Cheshunt Park

2.49.7 The objectors have produced survey evidence from the Herts and Middlesex Wildlife Trust which indicates that some of the land north-east of Park Lane has areas of species-rich grassland. However, the proposed designation is not actively supported by the Trust in the form of an objection to the Plan on this point. From site inspection a substantial part of the grassland appears overgrown and the evidence about the quality of the whole area is not compelling. Other habitats a short distance to the north are protected by wildlife designation.


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Rye House Substation

2.49.8 I note National Grid�s concerns that the wildlife designation could preclude the effective use of the land at the substation should it be required to expand existing operations at the site. However, in the absence of any immediate plans to use the land and bearing in mind the company�s obligations to protect natural resources where possible, I see no need to remove this designation. The survey evidence shows its comparative value; any future proposals would be considered against Policy GBC20, which I have recommended should include a clause that enables the need for the development to be weighed in the balance with the nature conservation value of any land which would be lost.

RECOMMENDATIONS

GBC.49 Delete the local wildlife site notations at Longmead Farm, Claramount Nursery, Rosedale Sports Ground and Cheshunt South Reservoir; No modification to the designations at Cheshunt Park and Rye House Substation.

Borough of Broxbourne Local Plan Second Review: Inspectors Report

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3. HOUSING

3.1 HOUSING - GENERAL

Objections - First Deposit 0192/01,02,05 Mr M Kousoulou 0252/01 Mr A. Carter 0349/01 Warden Lodge Surgery 0562/03 The Wormley Society 0709/01 The Goffs Oak and Waltham Cross Trusts 01000/12,29,79 Government Office for the East of England 01013/03 South East Hertfordshire Primary Care Trust 01102/026,084 Goff's Oak Community Association 01103/03,04 Windmill Estate Residents' Association 01105/01 Abbey Road Surgery 01251/02 Fitzpatrick PLC 01264/014 Higgins Homes Ltd 01270/1,3,7,9. 10 Persimmon Homes (Essex) Ltd 01293/07 Colin Buchanan and Partners 01294/01-6,16 Bellway Estates 01320/01,03 Mr & Mrs Campbell & Harris Objections - Second Deposit 01001/75,78,79 Hertfordshire County Council 01270/044,045 Persimmon Homes (Essex) Ltd 01359/04 Weston Homes PLC Issues

(a) Introductory text has not correctly interpreted PPG3.

(b) Objections to detail and approach of the Council's urban capacity assessment.

(c) Chapter omits policies to allocate land for education and medical facilities, which would be necessary to permit additional housing development.

(d) Chapter should recognise the need for new places of religious worship

(e) Objections to the Council's calculation of windfall.

(f) Plan appears to provide housing in excess of the adopted Structure Plan

(g) Chapter should not provide for any housing development in the Green Belt.

(h) Chapter should take account of emerging regional guidance

(i) Housing allocations are insufficient to meet structure plan targets

(j) Chapter should clarify targets regarding use of previously developed land.

(k) Council's approach will lead to town cramming and puts open spaces at risk of development.


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3.1.1 I deal with a number of general points with regard to the Council�s approach to the supply of housing land in Section 3.2 below. The notes of the Housing Round Table Session (RTS) set out summaries of the main objections on this topic and the Council�s responses (see Appendix 1). The section considers overall housing numbers, the constituent parts of supply, including windfall provision on previously developed land (PDL). I also make a recommendation with regard to a number of objections concerning the timescale of the Plan, and its relationship to current and forthcoming regional guidance.

3.1.2 The Council�s studies appear to have included a comprehensive analysis of potential housing capacity on urban sites throughout the Borough. However, the Council acknowledge that not all circumstances can be predicted and that to preclude the redevelopment of industrial premises may not meet the guidance in PPG3. I therefore recommend the deletion of the last sentence of #3.1.6. In similar vein, the inclusion of a target for the proportion of new housing development on previously developed land would also accord with PPG3.

3.1.3 Other chapters of the plan address community needs for social infrastructure such as schools, medical facilities and places of worship, and the need to provide open space and protect the green belt. From my visits to the Borough and evidence from the Community Development Plan (CDP), I consider that any deficiencies in infrastructure are not so serious as to preclude the level of housing likely to result within the plan period. I note that new medical facilities are to be provided on the two largest housing sites at Canada Fields and at Ware Road Hoddesdon (The MAFF/Hailey site).

3.1.4 Other policies in the Plan, such as HD16, provide safeguards against �town cramming� proposals that would have an unacceptable impact on the environment. As PPS1 and PPG3 state, high density need not mean poor quality; I consider the Plan provides an adequate policy framework to ensure that the best use is made of urban land at the densities recommended by PPG3. The policy would however secure development of appropriate quality.

RECOMMENDATIONS

H.1 Modify the Plan in accordance with AICs 13 and 14.

3.2 H1 RESIDENTIAL LAND SUPPLY

Objections - First Deposit 0347/02 Ms P. Rowley 1101/039 CPRE - The Hertfordshire Society 01253/02 The House Builders Federation 01264/023 Higgins Homes Ltd 01293/09 Colin Buchanan and Partners 01294/018 Bellway Estates


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01304/03 D H Turner Consultancy Objections - Second Deposit 01270/043 Persimmon Homes (Essex) Ltd 01276/08 Meux Trust 01304/08,09,010 D H Turner Consultancy 01359/01 Weston Homes PLC Objections - Pre-Inquiry Changes 01277/020 Landmatch Ltd (formerly Lafarge Aggregates Issues

(a) Policy incorrectly interprets PPG3

(b) Estimates for windfall in First Deposit Plan are too low.

(c) Greater allowances should be made for non-implementation of allocated sites.

(d) Policy text should refer to requirements for Green Belt/reserve land

(e) Second Deposit policy amounts to an over-allocation of land and lacks a phasing mechanism.

(f) Object in principle to allocating housing when so many council houses sold.

(g) Council should clarify that previously developed land will exclude allotments and open space etc.


Housing numbers

3.2.1 All participants at the Housing RTS accepted that the Plan had identified enough housing land to meet the Structure Plan requirement for 5,400 dwellings in the period from 1991 to 2011. The Council�s revised Housing Topic Paper indicates a net gain of 4,157 completions up to March 31 2004, leaving a residual of 1,243 dwellings to be constructed in the 7 years to 2011. However, planning permission has already been granted for a further 1,631 dwellings, of which 1,134 are in schemes where construction has started and is likely to continue until completion in full. None of these figures has been disputed by those attending the Housing RTS.

3.2.2 Looking at the schemes which have not been started, past experience suggests that about 4.4% of the permissions would not be taken up for one reason or another. Therefore, I consider it reasonable to apply a non-completion rate of 5% to the remaining permitted schemes, resulting in a further net gain of 460 dwellings. It would seem prudent to make the same assumption with regard to the sites where resolution to grant permission is subject to the completion of satisfactory Section 106 planning obligations.

3.2.3 Another source of potential housing supply, known as windfall, is likely to come from new small sites (providing 10 dwellings or fewer) within the urban areas of the Borough where no permission exists at present. The number of dwellings from this source was the matter of some dispute at


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the RTS. Some objectors pointed out that in the immediate future constructions on such small sites would occur where permission already exists. That may be so, but the Council�s records show that the supply of permissions is constantly topped up. Over the last 6 years on average 40 dwellings per year have been permitted and constructed on sites containing a maximum of 10 dwellings. There is no firm evidence to suggest that the rate of completion is likely to drop. However, I consider it would be reasonable to assume that for the next two years the windfalls would come from existing permissions, to avoid double counting from this source.

3.2.4 Of the allocations, two have been carried forward from the 1994 Local Plan Review. One of these sites, at Hammondstreet Road, apparently has ownership constraints, and is not genuinely available at present, even though it has outline planning permission, but no reserved matters application has been received. Nevertheless, the position may change within the life of the Plan and the site must be considered a commitment.

3.2.5 Table 1 below therefore shows that about 2,300 dwellings are available in the 7 years to 2011. This represents a supply of about 8.5 years, at the Structure Plan projected rate of 270 dwellings pa. Several parties at the RTS argued that the Plan would not meet the policy guidance of PPG12, as clarified by Minister Keith Hill�s statement in July 2003, that plans should demonstrate a potential 10 year supply of housing land. However, the statement also indicates that plans should have a duration of at least 10 years from the date of adoption. That would be unrealistic in this case, since the Plan is intended to run to 2011 to tie in with known Structure Plan housing targets. Within the next year or so revised housing requirements up to and beyond 2011 are likely to be set by guidance in RSS14. Although this may lead to a step change in provision, Broxbourne is in the fortunate position of an over-supply with regard to current targets. Much of this housing is already committed and there is no danger of an immediate shortfall within the next 5 years through failure of anticipated windfall totals.

3.2.6 The Council pursued a review to 2011 on the understanding that the position regarding longer term housing supply may well change. A similar situation was accepted by the Inspector at the Uttlesford Local Plan Inquiry; other Districts nearby, such as Welwyn Hatfield and Epping Forest, have taken a similar stance. I consider the circumstances in other areas quoted by objectors in different regions and at Milton Keynes, which has been identified for growth in a rather different context, are not analogous to those in Broxbourne. For the purposes of this Plan, housing supply can be considered only in relation to the current adopted Structure Plan. I agree with the Council that it would not be sensible at this stage to plan for an increased housing requirement of unknown size.

3.2.7 It follows from my analysis of housing supply that there is no need for any release of green belt sites in the Plan period. I have not therefore undertaken any comparative analysis of the many such sites that were put forward in objections. However, as I discuss in section 3.19 below, I have found no overriding planning reason why the Cheshunt South Reservoir should not be allocated for residential development towards the end of the Plan period, subject to a number of safeguards, including the extent of the developed area.


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3.2.8 There will clearly be a need for a very early review of the Plan soon after adoption, particularly if new regional guidance proposes a significant rise in annual housing completions. The intention is for LDF procedures to be speedier than the current process, and I am confident that there will be no undue problems of housing supply in the interim.

3.2.9 Again, for reasons explained in 3.24, I have not recommended the existing St Mary�s School site as a housing allocation at this stage.

Table 1 Housing provision

Structure Plan requirement 5,400 Completions 4,157 Sites with permission - started 1,134 not started (inc 5% discount) 460 Sites subject to S.106 agreement (inc 5% discount) 135 Windfall Allowance (sites under 10 units) 200 Sites allocated in 1994 Local Plan 120 Sites in the Plan 2008 � Cheshunt Reservoir South 150 Total 6,356 3.2.10 The Council is required to meet Structure Plan housing targets, irrespective

of past sales of Council housing, to achieve a certificate of conformity and comply with statutory procedures.

3.2.11 The definition of previously developed land (PDL) is contained in PPG3 and clarification in the Plan is unnecessary. It does not include allotments and open spaces. Housing provision should be considered from a range of sources in accordance with government advice.

RECOMMENDATIONS

H.2 No modification to the main thrust of the policy. Update the supporting text to reflect the most accurate housing figures when the Plan is modified. Include Cheshunt South Reservoir as an allocation in accordance with recommendation 3.19. Delete the allocation at St Mary�s School.

3.3 H2 WINDFALL RESIDENTIAL DEVELOPMENT

Objections - First Deposit 01253/03 The House Builders Federation Objections - Second Deposit 01000/0114 GOE 01001/076 Hertfordshire County Council


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01101/070 CPRE - The Hertfordshire Society 01264/040 Higgins Homes Ltd 01293/038 Colin Buchanan and Partners 01304/011,012 D H Turner Consultancy 01359/03 Weston Homes PLC 01370/03 Hertford Regional College 01386/02 Hertfordshire Partnership NHS Trust Objections - Pre-Inquiry Changes 01253/017 The House Builders Federation

Issues

(a) Policy is unnecessary if plan has made a realistic and robust assessment of windfalls.

(b) Policy fails to take into account the emerging structure plan to 2016.

(c) Policy fails to include any assessment of suitability of sites with consent.

(d) Definition of oversupply is not provided.

(e) Policy is contrary to guidance as assigns a lower priority to windfalls and acts as an arbitrary restriction on housing land supply.

(f) Windfall allowance is too high and should be reduced if sites coming forward too quickly.

(g) Windfall calculation included in summary table 3 (para 3.3.7d) is not justified


3.3.1 The Council has put forward a revised policy, following discussion at the RTS. It continues to seek restraint of windfall development, to prevent oversupply in relation to the available infrastructure. The definition of such oversupply relates to an eight-year period of Structure Plan housing requirements, equivalent to 2160 dwellings. However, the policy continues to refer to �unreasonable� strain on facilities which cannot be overcome by �appropriate provision� through S. 106 planning obligations. I consider this still fails to provide much clarity concerning the shortfall of infrastructure, which is not quantified. The Council argued that the policy was not overly restrictive; where an Inspector supported a similar policy at Three Rivers Council. However, the strategic policy context of restraint in West Hertfordshire is somewhat different from that of Broxbourne, an area which has been identified as part of a possible growth corridor.

3.3.2 Even as re-worded, I consider that Policy H2 refers back to a time when additional housing development was being resisted within the urban area, a situation that is highly unlikely to exist from now on. Given the changes in government policy regarding the need to deal with problems of housing supply in London and the South East in general, I consider the policy does not fully reflect the spirit of guidance in PPG3 to secure the best use of PDL within the urban areas. As I have already said, other policies in the Plan provide satisfactory environmental safeguards against unacceptable forms of town cramming. The plan also includes policies which could be used to secure appropriate contributions towards community, leisure and other


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facilities, such as transport provision, fairly related to the nature of any proposed development. Further housing at sustainable locations within the urban area of the Borough would reduce the take-up of greenfield sites and should be welcomed in current circumstances.

RECOMMENDATIONS

H.3 Modify the Plan by deleting Policy H2

H3 - STRATEGIC HOUSING SITES

3.4 WARE ROAD, HODDESDON (H3-III IN FIRST DEPOSIT)

Objections - First and Second Deposit See Appendix 4 Issues

(a) Allocation is unjustified as Council is ahead of development targets. Seek deletion or inclusion in second half of plan period.

(b) Objections on grounds of over-development in North Hoddesdon and pressures on local medical and educational provision, change to 'semi-rural' character of area and neighbouring properties, height and density of development.

(c) Development area should be reduced and more open space retained.

(d) Council should continue to press for hospital or return the site to Green Belt if not required.

(e) Allocation ignores existing wildlife & recreation value - this site should be allocated for these uses.

(f) Allocation represents unsustainable development and is contrary to national guidance.

(g) Land at 303 Ware Road should not be released with this site.


3.4.1 The broad thrust of all these objections has been overtaken by events as the development at this site for 334 dwellings is well under way. This followed allocation in the previous Local Plan. The scheme will eventually provide 97 affordable homes, a new doctors� surgery and financial contributions towards expansion of schools. In these circumstances I see no good reason to recommend against the allocation of this site for housing, given the substantial scale of development to be completed.

3.4.2 I deal with objections concerning 303 Ware Road in section 2.31.

RECOMMENDATIONS

H.4 No modification


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3.5 CANADA FIELDS (H3-VI IN FIRST DEPOSIT)

Objections - First and Second Deposit See Appendix 4

Issues

(a) Objections on grounds of increasing traffic congestion in Brookfield area, lack of local community infrastructure and loss of open space.

(b) Allocation should be deleted as an area of flood-risk.

(c) Employment allocation should be retained, zoned for recreation or if not required for employment returned to Green Belt.

(d) Estimated development density is too low.

(e) Development of greenfield site is not sustainable and contrary to national guidance.

(f) Alternative sites in the Green Belt should be allocated rather than Canada Fields


3.5.1 As at Ware Road, Hoddesdon, development at Canada Fields is well under way, in accordance with 3 planning permissions, with substantial parts completed and occupied. Matters such as environmental assessment, transport and flood risk were considered in detail at application stage. Given the progress of the scheme towards completion, I therefore recommend the allocation be confirmed.

RECOMMENDATIONS

H.5 No modification

H4 SHORT TERM HOUSING ALLOCATIONS 2001-2005

3.6 GENERAL OBJECTIONS

Objections - First Deposit 0166/03 Mrs J. Turner 0215/01-2,5,7,8-9 RSG Properties LTD 0218/05 Mrs C. Piner 0221/01 Mr D. Barnes 0253/01 Mrs W.A. Carter 0302/01 Mr & Mrs S. Blyth 0371/010 Mr D. Shields 0397/01 Mrs S. Stapley


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0449/01 Mr M. Richardson 0452/02 Mrs T Richardson 0454/02 Mrs T Trick 0518/02 Earl & Lawrence 0533/02 H.A Pritchard 0628/03 Mr D.J. Llewellwn 0867/02 Mr C. I. Maxen 0876/04 Mr P Smith and Miss Laverack 0932/02 Mr M. Maxen 0940/02 Mrs N. Whiting 01013/01 South East Hertfordshire Primary Care Trust 01101/041 CPRE - The Hertfordshire Society 01253/4 The House Builders Federation 01262/01,011,012 George Wimpey UK Ltd 01264/015,024 Higgins Homes Ltd 01269/03 Owners of land at Goffs Lane/Burton Lane 01270/06 Persimmon Homes (Essex) Ltd 01281/02 David Wilson Estates 01283/02 Mr & Mrs Pedersen 01288/03 Sworders Agricultural 01293/028,030 Colin Buchanan and Partners 01295/01 Leach Homes 01304/02 D H Turner Consultancy 01316/04 Mr & Mrs B. Smith


SD/H/01000/0141 Government Office for the East of England SD/H/01101/059 CPRE - The Hertfordshire Society SD/H/01264/037 Higgins Homes Ltd SD/H/01281/04 David Wilson Estates SD/H/01295/07 Leach Homes SD/H/01361/03 Aitch Group SD/H/01365/03 St James Road Ltd SD/H/01386/03 Hertfordshire Partnership NHS Trust

Issues

a) Seek inclusion of alternative sites for development currently within the Green Belt (these are itemised separately in the Green Belt Chapter) on the basis of uncertainties with allocations coming forward.

b) Allocations only required from 2006 onwards

c) Allocations ignore flooding impacts.

d) Allocations do not provide for low density development.

e) Allocations should be conditional on new infrastructure coming forward - concerns raised regarding over-development, lack of medical and educational provision.

f) Policy fails to give guidance on when sites should be released and should be tied more closely to structure plan targets.


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g) By promoting development on employment and educational land - policy is inconsistent with other policies in the Plan.

h) Plan is not required to make any Housing allocations as the Council have met its five year housing targets in the Structure Plan.

i) Affordable housing targets should vary by location.

j) It is not clear whether FD para 3.37 implies a development sequence in policies H3 and H4.


General

3.6.1 I deal with general points about the proposed numbers of new dwellings and their timing in section 3.2 above. In summary, the Plan identifies a more than adequate housing supply and there is no need to allocate any green belt land to meet current Structure Plan requirements. Although much residential development would be front-loaded, I see no need to delay its provision, particularly those sites which can provide much needed affordable housing, given the short lifespan of the Plan.

Infrastructure

3.6.2 I have noted the broad thrust of the Council�s response to several objections about the availability of infrastructure to service the residents of new housing. In some instances allocation of major new housing sites can help to address deficiencies in areas such as education and healthcare through provision of facilities from developer contributions. However, the adequacy of social infrastructure as a whole should be addressed through other mechanisms, including the Community Plan, but is not a sound planning reason to prevent new development in acceptable sustainable locations.

Density

3.6.3 I am satisfied that the estimates of housing provision on various sites is consistent with the policy in PPG3 to make the best use of land by building at a density of between 30-50 dwellings per ha on average. Having looked at all the sites, I consider that such densities could be achieved without any unduly adverse environmental consequences.

Flooding & Nature Conservation

3.6.4 My site inspections and the detailed information provided about the proposed allocations, including development briefs, have not revealed any overriding constraints with regard to liability to flood or loss of wildlife or special habitats.

Employment land

3.6.5 I deal with some objections to the loss of employment sites elsewhere. Two substantial new employment sites at Park Plaza and NE Hoddesdon are key elements of the Plan. Overall, I agree with the Council that the correct balance between employment and housing growth has been maintained.


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RECOMMENDATIONS

H.6 No modification

3.7 LAND AT HOLLYBUSH WAY


0009/01 Matthew Homes Ltd Issues

(a) This urban infill site should be allocated as part of this policy


3.7.1 The Council raise no objection as a matter of principle to the housing development of this small area of open space within the urban area at Rosedale. Any proposals for a small-scale scheme could be considered through the development control process in the normal way, and could include provision for a small area of playspace. However, there is no need to allocate a site of this size in the Plan; it could be treated as windfall.

RECOMMENDATIONS

H.7 No modification

3.8 LAND AT CHESHUNT HIGH STREET

Objections - Second Deposit 1359/02 Weston Homes PLC Issues

(a) This urban infill site should be allocated as part of this policy


3.8.1 I note that planning permission has already been granted for 14 dwellings on this highly sustainable site. These proposals have been taken into account by the capacity study carried out by the Council. Any revised scheme could be considered through the development control process in the normal way. I have dealt with Policy H2 regarding windfalls in section 3.3 above, concluding that there is no need for any particular restrictions on new housing that is well-located within the urban area, like this site, in the current strategic and national policy context.

RECOMMENDATIONS

H.8 No modification


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3.9 LAND AT FAWKON WALK (H3-1 IN FIRST DEPOSIT)

Objections - First and Deposit See Appendix 4

Issues

(b) Car parking use of this site should be retained.

(c) Loss of parking on this site will impact on the vitality of town centre. This conflicts with retail polices in the Plan and national guidance.

(d) Plan fails to allocate replacement car parking provision.

(e) Site will create unacceptable traffic impacts on town centre.

(f) Alternative unused sites exist which could be allocated for housing development.

(g) Dwelling estimate should reflect higher density development.


3.9.1 The proposals for new housing at the Fawkon Walk site are well-advanced, detailed planning permission having been granted in 2004. Work has now started on the site. On its merits, the site is very well located, being adjacent to the town centre and all its facilities. I consider it is a highly suitable location for a mixed use development including small dwellings and some affordable housing.

3.9.2 While I appreciate residents� concerns about the loss of free car parking, its retention was not within the control of the Council. The management of town centre parking should be considered as part of a package of measures to help maintain the vitality and viability of the centre. The loss of such parking need not have an adverse effect on the centre if combined with other measures. The development of the site complies with general government policy to encourage mixed-use proposals which avert the need to travel by car and would assist other retail policy objectives by helping to shift the balance of the town centre towards the south.

RECOMMENDATIONS

H.9 Delete the site from long term housing allocations

3.10 RYE PARK EDUCATION CENTRE (H3-2 IN FIRST DEPOSIT)

Objections - First Deposit FD/H/0102/013 Mr & Mrs C West FD/H/0192/010 Mr M Kousoulou FD/H/0215/06 RSG Properties Ltd FD/H/0257/02 P. Bloomfield


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FD/H/0267/01 Ms M.T. Gopper FD/H/0268/01 Mr & Mrs R. Attridge FD/H/0269/01 Miss T Rose FD/H/0626/01 Mr & Mrs M Reay FD/H/0832/01 Mr & Mrs I Hofmeister FD/H/0876/01 Mr P Smith and Miss Laverack FD/H/01262/05 George Wimpey UK Ltd Objections - Second Deposit

1365/010 St James Road Ltd

Issues

(a) Insufficient regard paid to traffic, parking & local flooding impacts.

(b) Allocation of land in educational use is contrary to plan objectives.


3.10.1 The proposal for the partial redevelopment of the site, which would retain the school, has been granted planning permission, after effects on traffic, parking and flooding had been considered satisfactory. I have no evidence that the scheme will not proceed and these objections have therefore effectively been overtaken by events.

RECOMMENDATIONS

H.10 No modification

3.11 FORMER MAFF BUFFER DEPOT (H3-4 IN FIRST DEPOSIT)

Objections - First Deposit FD/H/0102/012 Mr & Mrs C West FD/H/0631/02 Mr & Mrs N J Francis FD/H/01139/01 Mr T Shakerchi FD/H/01293/011 Colin Buchanan and Partners Issues

(a) Concerns raised regarding site access and surface water on neighbouring area.

(b) Adjacent vacant site should be included in this allocation


3.11.1 I note that the Council has resolved to grant planning permission for 54 dwellings on this site subject to a Section 106 planning obligation concerning the provision of affordable housing. A satisfactory access to Hertford Road already exists and I am unaware of any particular difficulties with surface water drainage.


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3.11.2 I deal with objections concerning the adjacent industrial site in section 4.2.

RECOMMENDATIONS


3.12 FORMER TW PUMPING STATION (H3-5 IN FIRST DEPOSIT)

Objections - First Deposit FD/H/0318/01 Mr A. Stanley FD/H/0717/01 S. Antaniello FD/H/01109/01 Mr & Mrs G. Ricotta FD/H/01111/01 Mr L. Genuardi FD/H/01113/02 Mr G. Genuardi

Issues

(a) Objections on grounds of impacts on surrounding area; particularly site access, traffic, parking and noise.


3.12.1 The objection has been met by the deletion of the site, which is a protected groundwater source.

RECOMMENDATIONS

H12. No modification

3.13 LEE VALLEY TRADERS, CHESHUNT (H3-7 IN FIRST DEPOSIT)

Objections - First Deposit 0335/01 Mr & Mrs D. Tormey

Issues

(a)Objections on grounds of overlooking and proportion of affordable housing


3.13.1 This objection has been overtaken by events, as the development of 25 dwellings (including 8 affordable units) and 51 sheltered apartments is under construction.


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RECOMMENDATIONS


3.14 ENFIELD FOUNDRY (H3-9 IN FIRST DEPOSIT)

Objections - First Deposit 1016/07 FD/H/Network Rail


1016/12 FD/H/Network Rail

Issues

(a)Policy should refer to operational needs of the railway.


3.14.1 The objector did not comment when a planning application for the site was submitted and approved, and a residential development of the site is close to completion.

RECOMMENDATIONS


H5 LONG TERM HOUSING ALLOCATIONS

3.15 GENERAL

Objections - First Deposit 0215/03,013,014 RSG Properties Ltd 0221/02 Mr D. Barnes 1013/02 South East Hertfordshire Primary Care Trust 1101/057 CPRE - The Hertfordshire Society 1253/05 The House Builders Federation 1259/02 Mr D Thrussell 1262/02 George Wimpey UK Ltd 1264/016,025 Higgins Homes Ltd 1270/04,038 Persimmon Homes (Essex) Ltd 1275/03 London Merchant Securities plc 1282/02 Mr P Thrussell 1283/03 Mr & Mrs Pedersen 1285/02 Mr G Baldwin 1286/02 Mr B Monk


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1304/07 D H Turner Consultancy Objections - Second Deposit 1101/060,061 CPRE - The Hertfordshire Society 1264/031 Higgins Homes Ltd 1269/06 Owners of land at Goffs Lane/Burton Lane 1276/06 Meux Trust 1304/014 D H Turner Consultancy 1365/06 St James Road Ltd Issues

(a) Council has not justified whether these sites will come forward in the plan period

(b) Alternative/additional sites in West Cheshunt and Hoddesdon area should be allocated


3.15.1 I deal with the three sites that remain as long term allocations in detail below. As I have already discussed in sections 3.2 and 3.6 above the Council has provided for more than enough housing within the Plan period to meet Structure Plan requirements. I have dealt with the merits of other competing sites in chapter 2 of the report and elsewhere in this chapter.

RECOMMENDATIONS


3.16 TOWN CENTRE ALLOCATION (H4-1)

Objections - First Deposit 0420/01 Hoddesdon Retail Association

Issues

(a) Proposals Map fails to identify a specific site


3.16.1 The Plan refers to a summary total of new dwellings expected in the town centres of the Borough rather than identifying specific sites. I consider this approach reasonable, in that predictions about which particular parcels of land or existing buildings which might come forward over the


81

next 6 years or so would be very uncertain. The general approach to encourage mixed- use developments including housing, in town centres accords with government policy in PPS1 and PPG3 to help regenerate established centres, where a variety of facilities and good public transport are normally available.

RECOMMENDATIONS


3.17 GATEWAY SITE ALLOCATION H4-2 (NOW DELETED)

Objections - First Deposit

0102/014 Mr & Mrs C West 0144/01 Paul Wallace 0215/010 RSG Properties Ltd 0311/01 Mr & Mrs P. Castle 0809/01 Mrs L. Morgan 0813/06 New River Action Group

Issues

(a) Concerns as land liable to flood and access constraints.

(b) Plan should clarify that adjacent allotment site is protected


3.17.1 The objections are met by the proposed deletion of the allocation.

RECOMMENDATIONS


3.18 CANADA FIELDS


0371/06 Mr D. Shields 0562/010 The Wormley Society 0823/03 Mrs D. M. Weston 1272/05 Mr A. J. Salter 1280/03 George Wimpey UK Ltd 1301/023 Standard Life Investments


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Issues

(a) Delete this site as within a flood risk area and allocate land in West Cheshunt for long-term housing.


3.18.1 The issue of potential to flood was addressed when planning applications for the site were considered and subsequently approved. The development is progressing and these objections have been overtaken by events.

RECOMMENDATIONS


3.19 CHESHUNT SOUTH RESERVOIR (H3-4)

Objections - First and Second Deposit

See Appendix 4

Issues

(a) Object to deletion of this site from Second Deposit Plan and allocation of sites such as St Mary�s School and MAFF Site, which are less sustainable.

(b) Allocation of this site and exclusion of housing sites in West Cheshunt fails to meet housing needs in this area.

(c) Cheshunt is already over-developed. Local community infrastructure is inadequate.

(d) Object to loss of open space, fishing, woodland and destruction of wildlife habitats.

(e) Protection sought given local wildlife site status. Allocation is contrary to wildlife policies in the plan.

(f) Development will increase congestion around the Brookfield Centre and adjacent residential areas.

(g) Development of site will increase flooding risks as it forms a natural defence.

(h) Loss of unique area of tranquillity for local residents.

(i) Site should be allocated for recreational uses


General principle

3.19.1 I have dealt with overall housing numbers in section 3.2 above, where I concluded that enough land has been identified to meet Structure Plan requirements to 2011. Therefore no need green belt land, including St Mary�s School, need be allocated at this time. I deal in full with the merits of the Plan proposals for the relocation of St Mary�s School in Chapter 4.


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In summary, I concluded that there are insufficient planning reasons to justify the release of either the existing site for housing or the Bury Green Farm site for a new school at this time. However, shortly before the inquiry closed a High Court challenge to the granting of planning permission for the development of a new school in the green belt was withdrawn. In the event that the proposed new school goes ahead, and the existing school buildings become redundant, the site could be assessed as to its suitability to meet future development needs, including housing, when the LDF or LDD is being prepared. Although the existing school lies in sustainable position, as a green belt site PPG3 indicates that it is sequentially less preferable to Cheshunt South Reservoir, which constitutes PDL within the urban area of Cheshunt.

Accessibility

3.19.2 The centre of the reservoir site is about 850m from the traffic signals at Greater Brookfield, which I consider to be a reasonably close walking distance to retail facilities of this type. New housing on the site would on average be no further from Brookfield Centre than Canada Fields, where proximity to the shops was used to justify residential development on that site. There is a regular bus service along Brookfield Lane, which would be available for future residents. Support for additional services could be provided through appropriate agreements at the planning application stage.

Traffic

3.19.3 Brookfield Lane is busy and there are acknowledged problems at the Brookfield Centre at peak shopping times, including Sunday lunchtime. These problems would need to be addressed and the Council has indicated that it intends to prepare a Masterplan for the Brookfield area as a matter of urgency to inform an early review of the Plan. However, the Council did not argue that original housing allocation had been withdrawn for traffic reasons. Traffic congestion is a general problem in the area and the trip generation from a site in a location within the urban area can in general terms be expected to be less than that from other more peripheral sites. A safe vehicular access point that meets all relevant standards can be achieved, together with other pedestrian and cycle links.

Environment

3.19.4 The site extends to 6.4ha. Many objectors at 1st deposit stage were concerned about the environmental impact of discontinuing the reservoir and building a substantial number of new houses. The water and the surrounding embankments, which contain a number of protected trees, have been home to a variety of birds and animals over many years. Of particular note is the presence of a number of bats of different species. Thames Water have offered to retain 40% of the site to meet residents� requests for open space, to satisfy the company�s operational requirements and to safeguard the trees. A significant water feature could be incorporated into any scheme, and the best trees retained, allowing for the loss of some of the older trees which I saw were in poor condition.

3.19.5 I can appreciate that residents would prefer not to have new residential development on a site where previously water was surrounded by a


84

wooded strip. However there is a very large area of parkland immediately to the north of the site and there is no real shortage of space for recreation in this part of Cheshunt. In summary, I consider that a high quality residential environment could be created that would have no unduly adverse effect on the amenity of residents living nearby and would retain significant wildlife interest, including the protected bats.

Timing

3.19.6 Development at the mid range of minimum densities advocated in PPG3 would result in about 150 dwellings. The Council argued that there was no need to allocate such a number of new dwellings, given the acknowledged over provision within the Plan period. However, I consider a known site of this size is too large to be considered as windfall. In the sub-regional policy context of a growth corridor and government initiatives to address housing shortages in South East England, I can see no sound reason to delay development to some time beyond 2011. I consider the site would be suitable for phased development at the back end of the Plan period, to come on stream after the two major sites at Canada Fields and MAFF, Hoddesdon have been completed.

Infrastructure

3.19.7 Such a programme should be consistent with Council initiatives to address traffic issues at Brookfield in the short term. The issue of school capacity, and the number of secondary places in particular, is being addressed by the County Council; whatever the outcome of a replacement school at St Mary�s, significant extra building is proposed in the Cheshunt area. As far I am aware there are no problems regarding the availability of other infrastructure. If any other special needs come to light, they could be assessed under the terms of other policies in the Plan, including CLT1 and CLT2 (see sections 7.1 and 7.2).

RECOMMENDATIONS

H.19 Modify the Plan by re-instating the site as a housing allocation for about 150 dwellings to be constructed in the period 2008-2011.

3.20 H5 DEPOT NORTH OF WINDMILL LANE (DELETED ALLOCATION H4-5)

Objections - First Deposit 0845/01 E. Lewington Issues

(a) Concerns regarding impact of extra traffic.


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3.20.1 The objection is met by the proposed deletion of the allocation.

RECOMMENDATIONS


3.21 LAND NORTH OF ELEANOR CROSS ROAD ALLOCATION (H4-6)


RSG Properties Ltd FD/H/0215/012 Network Rail FD/H/01016/06 George Wimpey UK Ltd FD/H/01262/06 Colin Buchanan and Partners FD/H/01293/029


Network Rail SD/H/01016/013 St James Road Ltd SD/H/01365/02

Issues

(a) Plan should not allocate a site currently in employment use.


3.21.1 This deep and narrow site extends northwards from Eleanor Cross road adjacent to the railway. Although it is used for industrial/storage purposes at present, as a concrete batching and palette storage plant, it is not a site of strategic importance for employment. The Council has determined to approve a planning application for 46 dwellings, subject to suitable measures to ensure affordable housing provision. I see no significant planning objection to residential development; in current market conditions I see no reason why it should not come forward towards the end of the remaining plan period.

RECOMMENDATIONS



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3.22 LAND WEST OF HODDESDON AND SECOND DEPOSIT TEXT (PARA 3.4.5)

Objections - First Deposit 0054/01 Mrs H Riches 0150/01 Mr D. Malyon 0152/02 Mr & Mrs Tomlinson 0379/02 Mr & Mrs D. Perkins 0695/03 Ms J. Crew 0992/01 G & A Saggers 1000/074 Government Office for the East of England 1001/031, 063 Hertfordshire County Council 1086/02 N.D & V.B Wakefield 01101/05 CPRE - The Hertfordshire Society 1250/013, 017 Woodhall Properties Ltd 1258/09 Hubert C. Leach 1262/010 George Wimpey UK Ltd 1270/040 Persimmon Homes (Essex) Ltd 1272/03 Mr A. J. Salter 1286/03 Mr B. Monk 1293/018 Colin Buchanan and Partners 1294/015 Bellway Estates 1298/09 Berkeley Strategic Land Ltd Objections - Second Deposit 0152/01 Mr & Mrs Tomlinson 1001/080 Hertfordshire County Council 1101/01 CPRE - The Hertfordshire Society 1250/015 Woodhall Properties Ltd 1264/039 Higgins Homes Ltd 1270/048 Persimmon Homes (Essex) Ltd 1281/01 David Wilson Estates 1293/039 Colin Buchanan and Partners 1304/015 D H Turner Consultancy 1364/04 Landmatch Limited Issues

(a) Objections to allocation of this land as an ASR in First Deposit Plan on environmental, technical and strategic grounds.

(b) Delete remaining references to land west of Hoddesdon in Second Deposit (para 3.45 and 3.45a) as this prejudges emerging structure plan alterations and regional guidance.

(c) Objections made by developers promoting other Green Belt sites.

(d) Objections by landowners to deletion of these policies from First Deposit.

(e) Plan should allocate strategic reserves.


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3.22.1 The broad thrust of many of these objections has been met by the deletion of the ASR designation from the Plan. I deal with objections to the removal of the ASR in section 2.35 above. Given the adequacy of housing land in the short term and the uncertainty about future needs beyond 2011, which should be resolved in the reasonably near future, I see no need for an ASR designation at this time.

RECOMMENDATIONS

H.22 Modify the Plan in accordance with PICs 10 & 11 and AIC06

3.23 WEST CHESHUNT AREA (PARAS 3.5.1 - 3.5.4)

Objections - First Deposit 0254/03 R. Barnes 0265/02 Ms S. J. Storey 1262/04 George Wimpey UK Ltd 1264/027 Higgins Homes Ltd 1270/039 Persimmon Homes (Essex) Ltd 1272/04 Mr A. J. Salter 1272/09 Mr A. J. Salter 1293/017 Colin Buchanan and Partners 1102/096 Goff's Oak Community Association 1250/04 Woodhall Properties Ltd 1102/032 Goff's Oak Community Association 1103/06 Windmill Estate Residents' Association 1250/05 Woodhall Properties Ltd 1270/02, 39 Persimmon Homes (Essex) Ltd Objections - Second Deposit 1262/13,14 George Wimpey UK Ltd 1276/07 Meux Trust 1281/05 David Wilson Estates 1361/02 Aitch Group 1293/035 Colin Buchanan and Partners

Issues

(a) Council's approach to limiting further development in this area is unjustified as does not provide sustainable long term approach or provide a satisfactory land-use strategy.

(b) Text fails to recognise alternative sites, which could meet housing need.

(c) Approach incorrectly states the process of permitting redevelopment of nursery land has been competed satisfactorily.


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3.23.1 I deal with a number of arguments about West Cheshunt in Section 2.36 above. In summary I see no need to allow the release of any green belt sites on grounds of housing need. However, I support the Council�s basic position that all areas of the green belt should be considered when the Plan is reviewed once strategic housing requirements for the period beyond 2011 are known. I have suggested some re-wording of the text concerning West Cheshunt and urge the Council to address remaining issues of dereliction in nursery areas.

RECOMMENDATIONS

H.23 Modify the Plan in accordance with AIC16, subject to some revision of #3.5.2 on the lines suggested in # 2.36.6 above.

All - Chapter Order

3.24 H6 EXISTING ST MARY'S SCHOOL SITE, CHURCHGATE, CHESHUNT

Objections - Second Deposit 0471/01 Mrs I. Beard 1015/011, 020 Thames Water Property 1101/062, 066 CPRE - The Hertfordshire Society 1104/014 The Spitalbrook Village Green Conservation Group 1264/047 Higgins Homes Ltd 1270/046, 049 Persimmon Homes (Essex) Ltd 1365/05 St James Road Ltd 1371/06 Residents Association Focus Team 1376/03 Councillor M Greensmyth Issues

(a) Object to policy as alternative urban housing sites are available - e.g. Cheshunt S. Reservoir which should come before Green Belt development.

(b) Proposal is unjustified as provides housing in excess of structure plan requirements.

(c) Alternative school locations should be considered which limit housing redevelopment in this location.

(d) Objections to principle of development in the Green Belt.

(e) The need for enabling development and Green Belt release is inadequately justified

(f) Object as there are other Green Belt sites which are more suitable.

(g) Site is liable to flooding and should not be used for development


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3.24.1 The Council�s revised proposals for the school site involve a housing allocation of about 3.2 ha for 75 dwellings, restricted for the most part to the area of the school buildings and hard surfaces, with a small area of playing field in the south-west corner of the site (as shown on AIC05). The allocation is a direct result of the proposal to provide a new, expanded school at Bury Green Farm, which I discuss in section 4.13. Planning permission for the new school has been granted and development was intended to be complete by September 2006. That may be optimistic, but following the withdrawal of a High Court challenge to the permission it seemed likely at the close of the inquiry that the scheme would go ahead in the near future.

3.24.2 The Council does not dispute that there is no pressing need for additional housing to meet Structure Plan requirements in the period up to 2011. It argued that there were exceptional circumstances to justify releasing this part of the green belt for housing, based on the nature of the site and particularly, the amount of development it contains. The site is previously developed land, in the context of PPG3, comprising a number of school buildings which range from one to three storeys high. However, a substantial part of the site comprises hard surfaced playgrounds, amenity and circulation areas, together with a small area of playing field. I agree with the Council that generally the area of the revised allocation does not read as or form part of open countryside. This comment applies to much of the land in the wedge of green belt which intrudes into the urban area from Dark Lane, most of which apart from the historic moat comprises playing fields and their associated pavilions, changing rooms and car parking. Nevertheless, the core area of school buildings contributes nothing to the openness of the green belt.

3.24.3 The Council argue that redevelopment with housing will prevent buildings becoming derelict and creating an adverse impact on the appearance of the green belt and the historic core of Cheshunt, including St Mary�s Church itself, immediately to the west. I consider this argument is over-stated, because the school buildings are rather tucked away from views from Churchgate. However, the buildings are not attractive and there would be considerable scope for a well designed housing development to improve the appearance of the area.

3.24.4 Originally, the sale of a larger area of school land for housing, including part of the playing fields extending westwards as far as Dark Lane, was put forward as an essential enabling development to allow relocation of the school to take place. However, circumstances have changed and the capital receipt from any sale for housing is now no longer such an important element of the overall package. This reduces the weight to be attached to the arguments that very special circumstances exist to remove the site from the green belt.

3.24.5 I have dealt with the merits of Cheshunt South Reservoir site in section 3.19 above. I conclude that it is a good, sustainable, well-located site, with no overriding environmental objections to residential development. Many of same points could be made about the St Mary�s School site, which also lies in a position close to a range of social and community facilities and some retail outlets; it also has good accessibility by public


90

transport. These advantages would make the site a very good location for a rebuilt and expanded school, especially in relation to its catchment area. Nevertheless the site lies within the green belt. The sequential approach of PPG3 indicates that it is not preferable to Cheshunt Reservoir South on planning policy grounds. I have therefore recommended that the site should not be released from the green belt and allocated for housing at this time, pending a definite start on the new school.

3.24.6 Local residents have raised concerns about flooding, which appears to be a serious issue in the locality. However, a residential development could lead to a reduction in the area of hard surfaces and construction of a balancing pond would help to improve the position. Foul water problems appear to result from off site, but could be improved by new works as part of a housing scheme.

RECOMMENDATIONS

H.24 Delete the allocation from the Plan

l - All Objecting Representations - Chapter Order

3.25 H7 PROTECTING THE AMENITY OF EXISTING RESIDENTIAL AREAS

Objections - First Deposit 1103/07 Windmill Estate Residents' Association Objections - Second Deposit 1000/0115 GOE

Issues

(a) Policy needs to be more positively framed and flexible


3.25.1 Amendments in the 2nd deposit Plan met objections from Windmill Estate residents and a further revisions suggested by GOE have been included in PIC 028.

RECOMMENDATIONS

H.25 Modify the Plan in accordance with PIC 028

- Al

- All Objectin - - Representations - Chapter Order


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3.26 H8 RETENTION OF EXISTING HOUSING STOCK

Objections - First Deposit 1000/08, 42 GOE Objections - Second Deposit 1000/92 GOE

Issues

(b) Policy needs to be more positively framed


3.26.1 Revisions suggested by GOE have been included in PIC 030.

RECOMMENDATIONS

H.26 Modify the Plan in accordance with PIC 030

3.27 H9 REFURBISHMENT OF EXISTING HOUSING STOCK

Objections - Second Deposit 1000/095 GOE

Issues

(a) Policy is unnecessary as already covered by H8


3.27.1 The Council has met the objection by proposed changes which combine Polices H8 and H9 of the first deposit.

RECOMMENDATIONS

H.27 Modify the Plan in accordance with PICs 029 and 030

All Objecting Representations - Chapter Order

3.28 FIRST DEPOSIT POLICY H9 DEVELOPMENT STANDARDS (NOW DELETED )

Objections - First Deposit 1002/018 Hertfordshire County Council (Property) 1253/06 The House Builders Federation


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1267/02 Rialto Homes plc - Canada Fields 1280/04 George Wimpey UK Ltd (formerly McLean Homes) 1294/014 Bellway Estates 1301/03 Standard Life Investments Issues

(a) Policy is over prescriptive and delegates decisions to SPG which is contrary to national guidance


3.28.1 The objections have been met by the deletion of the policy.

RECOMMENDATIONS


Representations - Chapter Order

3.29 H10 DESIGN QUALITY OF DEVELOPMENT


1001/077 Hertfordshire County Council Issues

(a) Reference omitted to a related policy on the deposit Structure Plan


3.29.1 Changes to the Plan at 2nd deposit stage and through PICs have strengthened the policy context seeking high standards of design in response to this and other objections by GOE. Policies HD13 and HD14 are particularly relevant in supplementing this policy, which relates to housing design alone.

RECOMMENDATIONS


Order

3.30 H11 CONVERSION OF EXISTING RESIDENTIAL PROPERTY TO SELF CONTAINED FLATS

Objections - First Deposit 1102/038 Goff's Oak Community Association 1294/012 Bellway Estates 1294/013 Bellway Estates


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Objections - Second Deposit 1000/116 GOE

Issues

(a) Policy is over-detailed, too prescriptive and prejudges many issues.

(b) Policy should include measures to ensure the maintenance of gardens


3.30.1 The objection from GOE has been met by deleting criterion (a) of the policy, which I consider would have imposed an arbitrary size limit on any conversions and could have prevented some proposals suitable for much- needed single person households. The remaining criteria would provide reasonable planning safeguards to provide for highway safety and to ensure a satisfactory environment for residents. The issue of garden maintenance is too detailed a subject for coverage in Local Plan policies.

RECOMMENDATIONS

H.30 Modify the Plan in accordance with PIC031

s - Chapter Order

3.31 H12 RESIDENTIAL CONVERSION OF NON RESIDENTIAL PREMISES


1101/042 CPRE - The Hertfordshire Society 1294/07 Bellway Estates Issues

(a) Policy lacks clarity and is too prescriptive.

(b) Policy is contrary to PPG3 as will restrict redevelopment of employment land


3.31.1 I consider the policy sets out guidelines which give reasonable scope for interpretation; in the absence of any preferable clearer alternative wording from the CPRE the criteria would provide suitable guidance in interpreting the policy. The need to provide some protection for employment and community uses is a legitimate planning concern and reflects current pressures on land use within the Borough. These matters are also addressed by Policies EMP1. EMP6 and CLT1, which should be retained in the Plan.

RECOMMENDATIONS



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- Chapter Order

3.32 H13 HOUSING DENSITIES IN NEW DEVELOPMENT ON UNALLOCATED HOUSING SITES

Objections - First Deposit 1101/043 CPRE - The Hertfordshire Society 1103/02, 08 Windmill Estate Residents' Association 1264/017,18 Higgins Homes Ltd 1270/24 Persimmon Homes (Essex) Ltd 1293/041 Colin Buchanan and Partners 1294/011 Bellway Estates 1304/01 D H Turner Consultancy 1305/01 GML Architects Objections - Second Deposit 1101/071 CPRE - The Hertfordshire Society 01264/038 Higgins Homes Ltd Issues

(a) Policy is too vague and lacks clarity as to what would be permitted.

(b) Policy fails to conform with minimum densities indicated by PPG3

(c) Policy promotes over-development of open spaces in the urban area.

(d) Policy fails to ensure densities are compatible with existing developments; definition and application of 'accessibility corridor' needs explanation.

(e) Accessibility corridor excludes land at Admirals Walk Lake.


3.32.1 The policy has been changed to provide some more clarity and specific guidance about density levels. I consider the policy would allow developers to maximise the potential of housing sites. The main thrust of the policy to make best use of urban land by developing at a minimum density rather than replicate that of surrounding areas accords with government policy in PPG3. The proposed change to omit �materially� from criterion (c) is consistent with this guidance. While future housing developments may be different in character from some traditional estates of primarily detached and semi-detached houses, building at higher density need not be at the expense of environmental quality. Other parts of the Plan help to safeguard against development that would degrade the Borough.

3.32.2 Turning to the Accessibility Corridor, I consider the basic principle of defining areas of better accessibility to public transport wherein higher residential density may be appropriate follows established good planning practice. It complies with the broad thrust of government policy in a number of statements, including notably, PPGs 3 and 13.

3.32.3 I consider the distances used by the Council to be a sound and commonly


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accepted basis to assess reasonable walking distances to public transport and other facilities. The use of high frequency routes at 4 buses per hour also accords with reasonable common practice. Similarly it is appropriate to take into account access on foot to town centres but to exclude uncommitted bus provision.

3.32.4 I agree that the notation of the exact boundaries of the corridor should be subject to frequent review to reflect changes in service provision. This could be achieved more readily by defining the corridor(s) in Supplementary Planning Guidance. The explanatory text and the policy itself should be amended accordingly. I consider that the corridor should be confined to a factual basis, and that all land within the defined criteria should be included. The policy makes clear that the accessibility corridor is a tool for assessment in general terms, not a boundary showing where development is permissible.

3.32.5 The definition of the corridor is a factual matter, based on the accepted criteria detailed in the Plan. I have already dealt with the merits of the proposed housing sites, including public transport accessibility, above. Given the projected surplus of housing supply within the plan period, the location of other competing development sites in relation to the area is a matter for a future review through the LDF procedures.

RECOMMENDATIONS

H.32 Modify the Plan as follows: In Policies H13 and T10, replace �ON THE PROPOSALS MAP� with �IN SUPPLEMENTARY PLANNING GUIDANCE�

- C

3.33 H14 RESIDENTIAL BUILDING HEIGHTS

Objections - First Deposit 0254/04 R. Barnes 1267/03 Rialto Homes plc 1280/05 George Wimpey UK Ltd 1294/020 Bellway Estates 1301/04 Standard Life Investments

Issues

(a) Policy is overly prescriptive and contrary to PPG3


3.33.1 The implications of PPG3 regarding the increased density of urban housing schemes are likely to lead to a re-appraisal of previous policy statements concerning the need to closely reflect the character and appearance of existing residential areas. The way such policies are interpreted is critical to the successful implementation of high quality, high density schemes that do not detract from their neighbours. Although this policy could be used in a flexible way, I consider it is not really necessary, since design


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matters for all developments, including new housing, are fully covered by Policies HD13 and HD14 in particular.

RECOMMENDATIONS

H.33 Delete the policy


3.34 H15 HOUSING MIX

Objections - First Deposit 0192/04 Mr M Kousoulou 1101/044 CPRE - The Hertfordshire Society 1253/07 The House Builders Federation 1294/010 Bellway Estates Objections - Second Deposit 01000/0117 GOE Issues

(a) Policy should be more specific in locations and requirements.

(b) Policy is contrary to PPG3 and Circular 6/98.

(c) Policy is largely a statement of intent and should be deleted.

(d) Housing mix should not be addressed through planning obligations.


3.34.1 The Council has suggested a PIC which makes substantial revisions to this policy. I consider that this would meet the broad thrust of the objections concerning compliance with government policy. As revised the policy could be used to foster the aim of securing a range of housing types and balanced communities. I agree with the Council that the wording goes as far as it reasonably can and that any more site specific requirements would not be feasible.

RECOMMENDATIONS

H.34 Modify the Plan in accordance with PIC 034.


3.35 H16 AFFORDABLE HOUSING

Objections - First Deposit 0225/01-06 Taywood Homes Ltd 0711/03 Mr F. Scott 1000/032 Government Office for the East of England 1002/04 Hertfordshire County Council (Property)


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1101/046 CPRE - The Hertfordshire Society 1253/013 The House Builders Federation 1258/010 Hubert C. Leach 1260/6,8,9,11-13 McCarthy & Stone Ltd 1267/04 Rialto Homes plc - Canada Fields 1272/02 Mr A. J. Salter 1277/06 Landmatch Ltd (formerly Lafarge Aggregates) 1278/02, 03 Martin Grant Homes (UK) Ltd 1280/06 1293/021 Colin Buchanan and Partners 1294/09 Bellway Estates 1301/05 Standard Life Investments 1304/05 D H Turner Consultancy Objections - Second Deposit 0010/02.03 British Telecom Plc 1000/093, 0118 Government Office for the East of England 1101/072 CPRE - The Hertfordshire Society Issues

(a) Lower threshold and target percentage are contrary to Circular 6/98 and not sufficiently justified.

(b) Policy lacks flexibility, is too prescriptive and unclear.

(c) Policy should not exclude key worker housing and discounted open market housing.

(d) Policy is insufficiently rigorous.

(e) Supporting text should clarify the role of the statement of need.

(f) Definition of affordable housing favours particular forms of tenure.

(g) Policy fails to give sufficient emphasis to negotiation


3.35.1 The minutes of the housing RTS contain a summary of the main points discussed at the session in March 2004 (CDH/60).

Definition of affordable housing

3.35.2 The definition of affordable housing in #3.8.1 and 3.8.11 of the Plan is quite broad; it specifically includes housing for sale intended to be accessible to those who cannot afford to buy on the open market. This would exclude the type of �low cost market housing� to which Circular 6/98 refers. The Council justify this approach by quoting from the Housing Needs Assessment carried out by Market Research UK in 2001 (CD/H/20). This document concluded that low cost market housing would be unlikely to meet the identified need, which was primarily for rented accommodation. However, the Plan does allow for affordable housing needs to be met through subsidised sale housing. The Council�s evidence to the RTS showed that shared ownership developments had formed a significant part of recent provision. Although the Council�s definition does not fully comply with Circular 6/98, I consider that it enables the main


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needs to be met; other market cost housing schemes may be able to add to the number of homes in the lower price range of market housing. The importance of providing the type of housing covered by the Council�s definition is recognised in emerging government policy, and the latest consultation paper �Planning for Mixed Communities� January 2005, in particular. On balance I see no need to alter the text of #s 3.8.1 or 3.8.11.

Needs survey

3.35.3 Some objectors have questioned the rigour and/or accuracy of the Housing Needs Survey undertaken for the Council by Market Research UK. From the published methodology, I consider the survey generally followed the format advised by the government. There is no doubt that there will continue to be a strong demand for housing of all types within Broxbourne. However, I consider that the detailed assessments are more likely to indicate respondents� preferred aspirations, rather than critical needs. In any event, the Plan does not expect to meet this level of demand, even though two major sites (at Canada Fields and the former MAFF site at Hoddesdon) are coming on stream with a significant affordable housing element. I note that the survey is based on information dating from 2001 which is rapidly becoming outdated; no doubt the promised early review of the Plan will incorporate new material to update expected requirements in this key area of housing provision.

Threshold

3.35.4 I note the Council�s arguments about the level of affordable housing need in Broxbourne. However, although the differential between average income and house prices may be greater than that in some (but not all) other Districts in Herts and Essex, that does not provide evidence of a comparable need to that in Inner London, as Circular 6/98 stipulates.

3.35.5 Similarly, the Council refers to relatively high levels of homelessness in the Borough compared with its neighbours. However, the Audit Commission�s report on its performance in providing affordable housing in accordance with corporate objectives does not make reference to levels of need comparable with Central London Boroughs. The Best Value Review of Housing and Homelessness was prepared in 2001, before some major schemes which will make a significant contribution to improved affordable housing provision came on stream.

3.35.6 I appreciate that the very recent consultation document published by the government �Planning for Mixed Communities� carries forward the same threshold as the draft revision to Circular 6/98 published in July 2003. Both documents indicate support for a development threshold of 15 dwellings or 0.5 ha, as sought by the Council. They represent a consistent thread of government policy in recent years, as part of a number of initiatives to increase the range and choice of housing and to provide more housing opportunities for those who cannot afford market housing. I appreciate the guidance may yet be subject to change and cannot be afforded full weight at present. In terms of the numbers of dwellings likely to come forward from a change to the threshold, data on permissions in Broxbourne shows that the reduced threshold would produce a limited, but welcome, number of additional dwellings. Small-


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medium sized sites are likely to be a significant element of windfalls in years to come. On the evidence presented to me, and in particular that concerning the level of need in Broxbourne compared with other districts in Hertfordshire, I consider that the Council has demonstrated reasonable grounds to justify imposing a threshold of 15 dwellings or 0.5ha as set out in emerging guidance.

Level of Provision

3.35.7 Following discussion at the RTS, the Council has proposed a change to the policy, which would allow it to negotiate for up to 40% of dwellings on new housing sites to be affordable. This would allow for more flexibility in addressing particular needs at different locations, for example on difficult brownfield sites, as the HBF seek. The original contribution level of 30% was never a hard and fast rule, as shown by the table in the Council�s evidence setting out details of affordable housing numbers achieved in recent years. I note that draft guidance in RSS14 suggests a minimum requirement of 30% of total annual supply. On some sites it may be financially realistic to expect a higher proportion of affordable housing in a range of tenures, including �low cost� key worker housing, for example.

3.35.8 The Council has produced evidence of a substantial level of available financial support for affordable housing in the Borough, to counter objectors concerns about deliverability. Future arrangements are not likely to constrain provision, which can be considered on a site by site basis. Emerging government guidance indicates that a substantial proportion of affordable housing should be sought on sites over 0.5 ha or 15 dwellings, irrespective of the availability of subsidy. The policy framework in the Plan allows for exceptional costs to be taken into account in deciding the level of affordable housing provision on each site.

3.35.9 I consider the reworded policy sets a clear intention which would help to maximise the contribution of this much needed form of housing but would still allow the circumstances of each individual site to be taken into account during negotiations.

3.35.10 The policy does not provide detail about what might constitute exceptional site development costs. However, it would be impossible to predict all possible problems and the inclusion of the criterion provides some scope to deal with proposals on a case by case basis as sought by some objectors. I support this more flexible approach.

Key workers

3.35.11 The Council has agreed to change the Plan to clarify that key worker housing falls within the remit of affordable housing provision as a whole.

RECOMMENDATIONS

H.35 Modify the Plan in accordance with PICs 035, 036and AIC021.

Representatio


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ns - Chapter Order

3.36 H17 SECURING PROVISION OF AFFORDABLE HOUSING

Objections - First Deposit 0225/07 Taywood Homes Ltd 1000/033 Government Office for the East of England 1253/014-015 The House Builders Federation 1260/014-020 McCarthy & Stone Ltd 1278/01 Martin Grant Homes (UK) Ltd 1294/08 Bellway Estates

Issues

(a) Criteria conflict with Circular 6/98: a policy cannot require transfer of land/buildings to an RSL

(b) Should not seek off-site provision if on-site unavailable

(c) Policy effectively precluded provision other than rent.


3.36.1 The Council propose to change the wording of this policy, which is necessary to procure the proper implementation of affordable housing, to meet these objections. The revised policy provides more flexibility by referring to �an affordable housing provider� and allows a variety of other mechanisms to secure affordable housing. I see no objection to the reference to the Council�s affordable housing strategy, to ensure the best fit between provision and needs as they evolve. Although the great need for rented housing cannot be disputed, the revised criteria would not preclude �low cost� housing, depending on the circumstances relevant to each particular site. I consider these changes accord with the thrust of government advice and should be supported.

RRECOMMENDATIONS

H.36 Modify the Plan in accordance with AIC022

- Chapter Order

3.37 H18 AFFORDABLE HOUSING: ENSURING CONTINUING BENEFITS

Objections - First Deposit 0225/08 Taywood Homes Ltd 1000/034 Government Office for the East of England 1253/08 The House Builders Federation 1260/02 McCarthy & Stone Ltd


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Issues

(a) Policy is over-restrictive, unreasonable and contrary to guidance in Circular 6/98.

(b) Policy covers matters outside planning control and cannot be justified.


3.37.1 The Council accepted that the original wording conflicted with Circular 6/98 regarding rent levels and has proposed a change to rectify the matter.

RECOMMENDATIONS

H.37 Modify the Plan in accordance with PICs 038 and 039


3.38 H19 RESIDENTIAL CARE HOMES

Objections - First Deposit 0337/05 Mr & Mrs D. Mort Issues

(a) Policy needs to be more specific and allocate sites.


3.38.1 In normal circumstances residential care homes do not require sites of such a size that allocation in a Local Plan is necessary to ensure adequate provision of these facilities. I agree with the Council that allocating specific sites is not feasible. However, the Plan does seek to preserve the existing stock of such homes and allows for new ones, subject to standard safeguards for environmental protection and highway safety.

RECOMMENDATIONS


Borough of Broxbourne Local Plan Second Review: Inspector�s Report

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4. EMPLOYMENT AND EDUCATION

4.1 EMP1 EMPLOYMENT AREAS

Objections - First Deposit 102/17 Mr & Mrs C West 254/5 R. Barnes 371/11-13 Mr D. Shields 1000/9 Government Office for the East of England 1001/47 Hertfordshire County Council 1006/7 Epping Forest District Council 1012/9 East of England Tourist Board 1251/1 Fitzpatrick PLC 1258/11 Hubert C. Leach 1294/19 Bellway Estates 1296/4 Tesco Stores Ltd 1300/1 B & Q plc Objections - Second Deposit 1000/96 Government Office for the East of England 1001/81 Hertfordshire County Council 1006/12 Epping Forest District Council 1300/5 B & Q Plc 1366/20 Bayfordbury Estates Issues

(a) EMP1 should restrict developments near bus routes and rail stations to those which maximise the number of employees using public transport.

(b) Chapter as a whole fails to give adequate recognition to leisure and tourism developments.

(c) Objectives in para 4.4.7 should contain reference to supporting major employers.

(d) Reference to employment use on land West of Hoddesdon needs to be cross-referenced elsewhere in the Plan.

(e) Object to entire range of Class B uses being permissible on estates in Waltham Cross.

(f) Policy omits uses other than that in Class B, eg sui generis uses, waste, retailing.

(g) Land off Hertford Road needs better transport links.

(h) Policy omits reference to the opportunity to improve landscaping of industrial estates.

(i) Policy would permit B2 and B8 uses at the Park Plaza site.

(j) Wording of policy could be improved.


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(k) Supporting text needs reference to cross-boundary local consultation.

(l) Additional criterion sought to support redevelopment of employment land for housing use.

(m) Policy overlaps with allocations in Greater Brookfield Chapter


4.1.1 Many of the objections at first deposit stage have been addressed by the changes to the Plan in the second deposit, and in particular the reference to leisure/tourism and the change to a criteria based policy. I consider the new wording would allow appropriate uses falling outside the definition of Class B of the Use Classes Order (UCO) within the employment areas. I have agreed that the ASR West of Hoddesdon should be deleted (see section 2.35). The new reference to policies for the large sites provides helpful clarification. Similarly, the Council has agreed to add a criterion concerning waste uses, which I support.

4.1.2 Bearing in mind my conclusions on housing need, where it is clear that Structure Plan requirements can be exceeded in the life of the Plan, I consider the policy provides a suitable safeguard against loss of land that should provide for the continuing employment needs of the Borough. An appropriate balance of uses should be retained, to help reduce commuting. Failure to protect employment land in favour of other , possibly higher value use, could frustrate reasonable employment objectives to improve the range and quality of premises.

4.1.3 Other general policies of the Plan and SPG should provide the means to ensure that new developments are constructed to high standards, with full landscaping.

RECOMMENDATIONS

EMP.1 Modify the Plan in accordance with PIC 042 and AICs 023 & 024

4.2 EMP1 � EMPLOYMENT AREAS - SITE-SPECIFIC ISSUES

Objections - First Deposit 1139/2 Mr T Shakerchi 1284/1 Mr B Barrett Issues

(a) Land off Hertford Road � should be re-allocated for housing.

(b) Employment allocation should include extending Sopers Road Estate in Cuffley (into Broxbourne)


4.2.1 The land at Hertford Road is in two parcels, separated by a public footpath.


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The larger area adjoins Merck Sharp and Dhome (MSD) premises and is used as a temporary car park at present. It was originally allocated for employment use because of its position next to a major employment site, and its suitability for any expansion thereof. However MSD has carried out an expansion programme within its own site and the land is not needed for any other employment purpose. The Council has removed the employment land notation, therefore in the Plan.

4.2.2 Bearing in mind the position of housing supply in relation to Structure Plan requirements (see section 3.2), I agree with the Council that there is no need to allocate the land for housing. Any proposals for residential or other uses could be considered as windfall if and when they arose.

4.2.3 I have dealt with the Sopers Road site in section 2.13.

RECOMMENDATIONS

EMP.2 No modification

4.3 EMP2 PARK PLAZA EMPLOYMENT SITE

Objections - First Deposit 471/8 Mrs I. Beard 635/1 Mr S. Ribbons 637/1 Ms L. Ribbons 1102/42 Goff's Oak Community Association 1276/1 Meux Trust Objections - Second Deposit 1016/14 Network Rail 1276/3 Meux Trust Issues

(a) Allocation is unjustified until occupiers come forward for this site.

(b) Object to allocation on traffic generation grounds.

(c) Policy should include scope for high quality B8 uses.

(d) Site should be expanded to land west of the A10


4.3.1 Outline planning permission has been granted for the development of this site, which is an integral part of the previously adopted Local Plan and Structure Plan strategies. All aspects of the proposal, including traffic and environmental impact, have already been taken into account and considered acceptable by the relevant authorities. These aspects included relocation of affected sports pitches.


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4.3.2 Widening the scope of employment uses would not meet the employment objectives which the allocation of this former green belt land were intended to meet, in terms of the likely numbers of jobs and the type of skilled employment that should be provided. The re-wording to a criteria based policy is an improvement which allows for some flexibility in the type of development that may come forward on the site.

RECOMMENDATIONS


4.4 EMP3 NORTH EAST HODDESDON KEY SITE

Objections - First Deposit 102/11 Mr & Mrs C West 813/9 New River Action Group 1000/11 Government Office for the East of England 1001/59, 60 Hertfordshire County Council 1006/8 Epping Forest District Council 1009/35 English Nature 1016/2- 3 Network Rail 1100/20 Herts & Middlesex Wildlife Trust 1274/1 The Highways Agency 1277/8, 11 & 13 Landmatch Ltd (formerly Lafarge Aggregates) 1293/22 Colin Buchanan and Partners 1340/1 Nazeing Parish Council Objections - Second Deposit 1000/97 Government Office for the East of England 1006/21 Epping Forest District Council 1364/5 Landmatch Ltd Issues

(a) Development brief should cover a wider area than the allocated sites.

(b) Reference in text to a lorry park should be deleted.

(c) Corrections sought to points in supporting text and clarity of policy wording.

(d) Employment area overlaps wildlife site 72/009, the status of which should be clarified

(e) Allocation conflicts with area of flood risk


4.4.1 This key employment site was agreed in the 1994 Local Plan and an outline


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planning permission had been approved in principle. The issue of flood risk has therefore been assessed fully and any disadvantages of the site balanced against other possible allocations. Any necessary flood mitigation measures can be dealt with at the detailed planning stage, through a development brief. As with EMP2, the policy has been re-worded to be criteria based. The boundary of the site has been amended to avoid the wildlife site and this has been reflected in the site boundary for the recent planning application.

4.4.2 I note that the reference to lorry parks has been deleted, to meet an objection. While the Council has sought to take on the comments of Railtrack, #4.6.13 reflects the current position with the railway crossing at Essex Road. The policy makes it clear that new development of currently open land should not take place until the first stage of the Essex Road improvement scheme is completed. I see no need for any further changes now that the general principles of the scope of development and transport infrastructure have been agreed.

RECOMMENDATIONS

EMP.4 Modify the Plan in accordance with PICs 044-046 and AIC 025

4.5 EMP4 ESSEX ROAD IMPROVEMENT SCHEME

Objections - First Deposit 1002/29 Hertfordshire County Council 1006/9 Epping Forest District Council 1277/7- 8 Landmatch Ltd (formerly Lafarge Aggregates) Objections - Second Deposit 1000/127 Government Office for the East of England 1001/84 Hertfordshire County Council 1006/11 & 22 Epping Forest District Council Issues

(a) Policy appears contrary to Circular 1/97.

(b) Policy needs more clarity in terms of implementation.

(c) Object to policy as will encourage HGVs into Essex.

(d) Objector seeks change of wording.


4.5.1 I note that revisions to the policy and supporting text are proposed to meet these objections.


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RECOMMENDATIONS

EMP.5 Modify the Plan in accordance with PIC 048

4.6 EMP6 LOCAL EMPLOYMENT SITES

Objections - First Deposit 10/1 British Telecom Plc Objections - Second Deposit 10/4 British Telecom Plc Issues

(a) Policy should include an exemption for telephone exchanges


4.6.1 I see no need to make an amendment to exclude two particular sites that could be dealt with by applying the criteria of policy if appropriate.

RECOMMENDATIONS


4.7 EMP7 INCOMPATIBLE EMPLOYMENT USES

Objections - First Deposit 1009/36 English Nature Issues

(a) Minor amendments sought to improve flexibility of policy


4.7.1 I agree that the inclusion of the suggested clause regarding environmental improvement would improve the policy.

RECOMMENDATIONS



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4.8 EMP8 HOME WORKING

Objections - First Deposit 1010/7 The Countryside Agency (E. England Region)

Issues

(a) Policy should be reworded more positively


4.8.1 I agree with the Council that the tone of paragraph 4.7.5 reflects the gist of the objection but the wording of the policy should be retained, to enable decisions on individual cases to be assessed on their own merits, taking into account local circumstances as appropriate.

RECOMMENDATIONS


4.9 EMP9 SMALL BUSINESS UNITS

Objections - Second Deposit 1000/98 Government Office for the East of England Issues

(a) Change wording, new text is unnecessary


4.9.1 I can see no reason not to �permit� small units in town centres, subject to normal planning standards. I consider it appropriate to apply this principle to conversions of larger buildings and the additional clause adds clarity in this respect.

RECOMMENDATIONS



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4.10 EMP10 HERTFORD REGIONAL COLLEGE & THE WILDERNESS

Objections - First Deposit 562/4 The Wormley Society 813/10 New River Action Group 862/1 Mrs S. White 1000/45 Government Office for the East of England 1275/5-6 London Merchant Securities Plc Objections - Second Deposit 1000/99 Government Office for the East of England 1009/102 English Nature 1101/73 CPRE - The Hertfordshire Society 1370/1 Hertford Regional College Issues

(a) Policy omits reference to need for east-west wildlife corridor.

(b) Object on basis of impact on Green Belt, New River and road traffic.

(c) Policy needs to clarify status of development brief.

(d) Policy appears to permit non-educational uses.

(e) Surplus land should be retained for recreational use by students


4.10.1 I have dealt with this issue regarding loss of green belt land in Chapter 2. From my site inspection I can well understand the pressing need to allow the repair, rebuilding and refurbishment of some buildings on the site, many of which date back to the 1960s. There is comprehensive detailed evidence of leaking roofs and the poor general state of the building fabric, which is not in dispute. Improvements to the accessibility of the buildings for those with disabilities are urgently required, and there is a pressing need to provide a significantly better teaching environment.

4.10.2 Furthermore, the college wishes to expand the range and type of courses available at the site; although it is run jointly with other premises at Ware, the College tries to operate the units as independently as possible, to avoid unnecessary travelling between the two sites. The ability to expand the educational provision at Turnford would help to address local skill shortages and meet future education needs resulting from further housing growth as a result of proposals in RSS14 for development in the A10 corridor. I agree with the Council and objector that this site, in a central location within the Accessibility Corridor is best placed to provide these improved facilities. Removing the site from the green belt would help these processes.

4.10.3 The main issue of dispute between the College and the Council concerns the acceptability of enabling development (almost certainly in the form of housing) on the site. The justification for removing the site from the green


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belt is underpinned by educational need, which outweighs the now limited value of the land in terms of the green belt functions it performs. The policy as drafted does not allow for residential development of the site. The Council argue that any such proposals should be considered after a detailed scheme for redevelopment of the college buildings has been finalised, bearing in mind future housing requirements set out by RSS14 and a comparative assessment of the ability of all other competing sites to meet those needs. As I concluded in section 3.2, the Plan provides for more than enough housing to meet current Structure Plan requirements to 2011. In these circumstances I consider the Council�s approach reasonable. Furthermore, other needs for community facilities or open space may arise for which the site should be considered if any land is surplus to education requirements.

4.10.4 I consider there is some inconsistency in the Council�s comment in the green belt topic paper that some enabling housing development may be acceptable if it is essential to the funding of new college facilities. In this event it could be argued that such housing would be allowed for financial, not planning reasons. As the policy does not specifically allow for such a possibility as currently worded any such proposal would have to be considered on its own merits if it came forward. In the absence of any detailed proven need at present I consider the policy should remain as drafted, subject to the changes in the PICs.

The Wilderness

4.10.5 The parcel of land known locally as The Wilderness lies opposite Canada Fields, sandwiched between the A1170 and the B176, Turnford High Road. The Council argued that the proposed release of the site from the green belt was entirely dependent on the proposals for the Herts Regional College and its future should be considered jointly with the college land. However, the two parcels of land are divided by a busy road and, I understand, are in different ownerships. Their physical characteristics are totally different and the college would have ample space within its own land to carry out the necessary improvements to its facilities. In my opinion the common feature shared by both sites is their minimal contribution to green belt policy objectives; the Wilderness, like the college, is surrounded by the built up area and neither prevents the outward spread of the urban area nor helps to prevent coalescence of settlements. The release of this particular site in these circumstances would not therefore set a precedent for any other releases of green belt land, even if it were eventually developed for housing.

4.10.6 The developable area of the site is constrained by a culverted stream and a wooded area covering the northern part of the land. This contains some trees subject to a TPO, although much of the vegetation in this area shows few signs of active management and is in poor condition. Adequate access can be obtained to the High Road, and the culvert would not prove an insuperable constraint. In principle therefore, I see no objection to some form of development.

4.10.7 The Council referred to the possibility that the community facilities mentioned as an acceptable use for the combined site could include affordable housing. However, no detailed proposals had been put forward. It is not disputed that there is no particular need for housing land to meet


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Structure Plan requirements during the Plan period and a residential allocation could not be justified on that ground. While I do not agree with the Council that the site should fall within the remit of the development brief for Herts Regional College, I consider that it may be suitable to meet other community needs or possibly to provide employment in some form. Alternatively, housing development towards the end of the Plan period would also be an acceptable option. For the present therefore I merely endorse its removal from the green belt but propose no other allocation, pending further thought on future development needs in this part of the Borough.

RECOMMENDATIONS

EMP.10 Modify the Plan in accordance with PICs 051-053, but remove The Wilderness from the EMP10 allocation at Herts Regional College.

4.11 PARAGRAPH 4.9.1 SCHOOLS AND EDUCATION PROVISION

Objections - First Deposit 1002/1 Hertfordshire County Council (Property) 1102/43 Goff's Oak Community

Issues

a) Policy should not judge the priority of education in relation to community needs b) School provision to meet recent development has been inadequate


4.11.1 My reading of the explanatory text is that it does not indicate any order of priority between educational and other community needs, but merely indicates the need for a balance to be struck when assessing competing demands, taking into account economic factors. I consider this approach pragmatic and reasonable.

4.11.2 The paragraph also recognises the importance of balancing provision for education with housing supply, without stating that such a balance has occurred or not. In fact, the Plan does allow for additional school provision to meet the needs of residents of new housing estates in West Cheshunt, particularly through the proposed relocation of an expanded St Mary�s School, which I discuss in section 4.13 below.

RECOMMENDATIONS



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4.12 PARAGRAPH 4.9.4-4.9.8 ST MARY�S SCHOOL, RESERVE SITES AT PARK LANE, CHESHUNT AND JONES ROAD, GOFFS OAK

Objections - First Deposit 0282/2,5,7 Friends of Cheshunt Park 0328/1 M.E.Thomas 0350/3 Mr & Mrs Redmond (Friends of Cheshunt Park) 0471/11 Mrs I. Beard 0620/2 Mr S Shepherd 1102/97 Goffs Oak Community Association 0933/01 K Fedorwicz Continued at Appendix 4 (a) Objections to these proposals on grounds of traffic, safety, loss of open spaces

and wildlife sites.

(b) Alternatives such as expanding other schools should be considered

(c) Object to impacts from development at Jones Road.


4.12.1 These sites no longer form part of the Plan, following the decision to put forward proposals for a replacement school at Bury Green Farm, discussed in section 4.13 below.

RECOMMENDATIONS


4.13 EMP11 REPLACEMENT OF ST MARY'S HIGH SCHOOL

Objections - Second Deposit 471/12 Mrs I. Beard 1001/82 Hertfordshire County Council 1015/21 Thames Water Property 1101/64 CPRE- The Hertfordshire Society 1371/7 Residents Association Focus Team 1376/2 Councillor M Greensmyth Issues

(a) Policy needs to take account of impacts on landscape character.

(b) Allocation of school on Green Belt is contrary to PPG2


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(c) Allocated site is unsuitable and unsustainable � traffic, safety, flooding impacts.


4.13.1 The background to the proposal to relocate St Mary�s School to a site in the green belt at Bury Green Farm is well known. Following additional housing development in the Borough over the previous decade, and the resulting demographic changes, the County Council decided in May 2000 to increase secondary education provision by expanding St Mary�s School from 4 to 6 or 7 form entry and to provide an extra 7th form entry at Goffs and Turnford schools. After investigation of a number of sites, including those listed in section 4.12 above, the County Council originally decided to pursue the relocation of the school to a site north of Park Lane in Cheshunt Park. Although the reasons for the replacement school and its expansion were broadly accepted by all parties, the proposed move to Cheshunt Park generated considerable opposition. An alternative proposal, the �Greater St Mary�s� scheme, involving expansion using Goffs Lane Recreation Ground and providing replacement playing fields in Cheshunt Park, was developed. However, this was dropped after the Bury Green farm site unexpectedly became available. The Council�s latest proposals involve allocating part of the existing school site, comprising for the most part the land occupied by buildings and hard surfaces, for 75 dwellings. I deal with objections to this part of the Plan in section 3.24 of my report.

4.13.2 There is no dispute about the strategy to create schools of roughly equal size and the need for radical improvement of the facilities at St Mary�s. I saw for myself that many of the existing school buildings are in poor condition, although with significant additional investment some of the structures could no doubt be renovated to a much higher standard. Without some additional land for new buildings, however, I appreciate that the remodelling of the school would be highly disruptive as parts of the buildings were being refurbished or demolished and rebuilt while the school continued to operate. However, evidence from the objectors indicates that rebuilding the school on an expanded site was a good, feasible option. Although these proposals also included sale of part of the existing site for housing, recent changes in proposed funding of the Bury Green Farm proposal do not rely on the sale of land for housing. Although this is the only scheme for which DfES funding had been approved, I heard no firm evidence that the previously agreed �Greater St Mary�s� scheme could not attract similar funding, even with the site of existing buildings remediated to create public open space; no relevant authority had been requested to fund such a scheme.

4.13.3 The Council said that the original proposals to help subsidise school improvements through capital receipts from the sale of housing land were no longer applicable. Nevertheless, I have no doubt that allocating land for housing at St Mary�s existing site would create significant value. It is clear from the evidence to the inquiry, including the Supporting Planning Statement by Vincent & Gorbing February 2003, that subsidy from housing redevelopment was an essential part of the new school package. A scheme to rebuild the school on site was rejected as poor value for money, even though the costs would have been lower than those for new buildings on a different site. Clearly, this was a sound judgement if substantial receipts


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from sale of the site for housing had been included in the calculations. However, achieving this financial benefit for the public would not comply with strict planning policy for the green belt; to allow a proposal in these circumstances could seriously undermine the policy to protect the green belt and weaken the chances of successfully resisting development proposals from other public or private interests. In summary, I can see no planning reason why the redevelopment of the school on its existing site, expanded to include part of some adjoining playing field areas, could not take place.

4.13.4 The Council argued that relocating the school at Bury Green Farm was the best option for a number of reasons. These arguments were based on a comparison of the Bury Green Farm site with part of the Goffs Lane playing fields, and assumed that the existing school site would be redeveloped for housing. In that event (with additional housing development) I acknowledge that a new school on the current site would intrude into a sensitive wedge of green belt. However, this area has the character of more of an urban green space, with tenuous links to open countryside further west. By contrast, as I discuss below, Bury Green Farm is clearly part of the wider countryside, and contributes to the important gap between Cheshunt and Enfield.

4.13.5 The loss of playing fields, and their replacement at Cheshunt Park about 2 km away, would be unfortunate (if not replaced on the existing school site) but would be offset by the considerable benefit of the proposed all weather pitch. While space for expansion of the Greater St Mary�s site to 7 form entry is more limited than the amount of green belt available at Bury Green Farm, the scheme met DfES space guidelines. Although traffic congestion is worse at Churchgate and Goffs Lane/ Dark Lane than Lt Ellis Way, the proposed site is much less accessible generally, as I discuss below.

4.13.6 Although the proposed extent of residential development on open green belt land has been reduced, housing on the existing site would spread over a wider area than that currently occupied by school buildings, through new development on the playground and land in the south west corner of the site. Also, the Plan proposals still entail a substantial volume of building on open farmland in the green belt at Bury Green. Thus, a much greater extent of green belt would be lost than if the school were redeveloped on its existing, albeit expanded, site. I have no doubt that a much reduced take of open green belt land could be achieved by using the existing school site.

4.13.7 Government policy in PPG2 states that very special circumstances must be demonstrated before inappropriate development should be allowed on green belt land. The Council point to the location of the site adjoining the urban area. Nevertheless, the land retains its open character; I consider it contributes to the setting of Cheshunt by providing a clear break between the urban edge and Lieutenant Ellis Way. The new school would be a significant encroachment onto open farmland and would erode the gap between Cheshunt and northern boundary of Enfield formed by the M25. Although Broom hills woodland would screen some long views of the school from the west, the buildings would be very prominent from a number of viewpoints to the east and south-east, particularly from Lieutenant Ellis Way, the A10 and the footpath along the New River.

4.13.8 Even allowing for the wider catchment of a church school, I consider the new school would be sited at a more peripheral location, just outside the


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very edge of the urban area. In general sustainability terms, pupils would be likely to have significantly further to walk or cycle. As the Council�s witness admitted, the Bury Green Farm site would have to be supported by a network of school buses. Measures to ensure safe crossing of the A10 for pupils from Cheshunt would be essential. Residents (and at one stage the Council) are seeking a potentially expensive footbridge and other measures. The Council�s evidence about the suitability for housing of the existing school site, which lies within the accessibility corridor, stresses its sustainability credentials, and the availability of a number of bus services. No such high frequency weekday route passes close to the Bury Green Farm site; the nearest bus service runs once every 2 hours along Bury Green Road, at least 300m walking distance to the north of the site.

4.13.9 I acknowledge, however, that GoE decided not to call in a planning application for the school on this site. Just before the close of the inquiry, the High Court challenge to the granting of this planning permission for the school was withdrawn. There seems no impediment to the County Council and Diocese of St Albans implementing the proposed new school in any event. However, there are considerable uncertainties about the financial arrangements to fund the new buildings and the residential redevelopment of the existing school site is not needed to meet housing requirements in the lifetime of the Plan; indeed I consider by virtue of its green belt location it is sequentially less preferable to the development of Cheshunt Reservoir South. Given my strong reservations about the planning merits of moving the school to Bury Green Farm, I consider therefore that the green belt designation of the site should remain until the school is built. However, there seems little point in recommending deletion of the policy, given the granting of planning permission for the development.

4.13.10 I have noted other detailed concerns of local residents concerning Bury Green Farm, including flooding prevention and access arrangements in particular. These matters could be addressed through suitable planning measures at the detailed stage, as the conditions attached to the planning permission indicate. I am sympathetic to the need for safe crossing of the A10 but it is not part of my role in reporting on the principles of land use allocations to specify detailed requirements at this stage, providing that technical solutions are available, as they seem to be in this case.

RECOMMENDATIONS


4.14 PARAGRAPHS 4.9.9-4.9.10 LAND AT CHESHUNT SCHOOL (FIRST DEPOSIT)

Objections � First Deposit 99/1 Mr K Rich 616/4 Ms C Haigh 801/1 Cheshunt Sea Cadets 933/5 K Fedorowick


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Issues

(a) Objects due to forced relocation of facility for Cheshunt Sea Cadets

(b) Land being released from the Green Belt may prejudice future expansion


4.14.1 The Council has proposed revisions to these paragraphs to clarify that any release of land would not prejudice the future expansion of the school. I agree that the Plan is not the appropriate mechanism to deal with the need for premises of groups such as the Sea Cadets; detailed requirements such as these are better addressed through the Council�s Community Plan.

RECOMMENDATIONS

EMP.14 Modify the Plan in accordance with PIC054

4.15 EMP12 NURSERIES AND CRECHES

Objections � First Deposit 1002/2 Hertfordshire County Council (Property)

Objections � Second Deposit 1000/119 Government Office for the East of England Issues

(a) Policy omits reference to affordable childcare provision and that provision should be sought for planning obligations on major residential sites

(b) Policy encourages / private car use contrary to PPG13.


4.15.1 The Plan refers to childcare provision in section 10.3, which sets out an appropriate list of items which may be sought at development implementation stage. The need for such facilities is more appropriately addressed in the Community Plan.

4.15.2 I consider the reference to pick up/drop off points is acceptable in the context of the policy. While access on foot and by public transport is to be encouraged through other criteria of the policy, there is also a need to ensure that highway safety is maintained when any children are taken to a facility by private car, which will undoubtedly be the means of transport in some cases.

RECOMMENDATIONS



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5. RETAILING AND TOWN CENTRES

5.1 RTC1 HIERARCHY OF TOWN CENTRES AND LOCAL CENTRES

Objections - First Deposit 0171/1-2 Somerfield Stores Ltd 1010/9 The Countryside Agency 1103/9 Windmill Estate Residents' Association 1289/1 & 4 Marks and Spencer Plc 1296/7-8 Tesco Stores Ltd 1300/2 B & Q Plc 1301/8 Standard Life Investments 1302/6-7 Roger Bullworthy Associates Objections - Second Deposit 0171/1 Somerfield Stores Ltd 0471/13 Mrs I. Beard 1000/120 Government Office for the East of England 1289/1 Marks and Spencer Plc 1296/5, 23-24 Tesco Stores Ltd 1302/20-21, 26 Roger Bullworthy Associates 1366/1-2 Bayfordbury Estates Issues

(a) Paras 5.3.1.and 5.3.2 need clarification and are contrary to PPG6.

(b) Lack of evidence to support quantitative need for 15,000m2 of commitments.

(c) Need for a new retail study.

(d) Greater Brookfield should be included with the hierarchy of centres.

(e) Policy RTC1 needs clarification in respect of Greater Brookfield.

(f) Object to revised status of Cheshunt Old Pond as a district centre.

(g) Policy text does not accord with PPG6 as promotes �out of town shopping�.

(h) Policy is too inflexible and should adopt a criteria-based approach.

(i) A marketing test should be included in the plan which seeks to help prevent the loss of the facility to the community


5.1.1 I consider the Council�s suggested change meets Tesco�s objection by more correctly reflecting PPS6 in terms of edge of centre sites. I do not think it would be appropriate to review the hierarchy of existing centres at this time; any future amendments could be made when the Plan undergoes review, rather than relaxing criteria at this stage. Whilst the sequential test is critical in determining the location of development, the hierarchy of centres


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still plays an important role in informing decision makers as to the suitability of particular centres for accommodating new retail and similar development. This concept has been retained with added emphasis in the very recently published PPS6, which consolidates the government�s established policy to encourage sustainable development that strengthens town and district centres. While not changing the broad thrust of the policy, which is contained in clause II, I consider clause I is unnecessarily repetitious. I suggest a minor revised wording which reflects the most up to date guidance.

5.1.2 GOE�s objection to the Second Deposit has been met by PIC056, which deletes Paragraph III(e) of the Policy and places it in the supporting text, which I consider to be a more appropriate location for this test. I find that the use of the word �function� has a more comprehensive and inclusive meaning than Somerfield�s suggestion of �vitality and viability� in assessing retail impact and should be retained in the revised wording of the policy.

5.1.3 Rialto Homes� objection regarding the retail study period has been overtaken by events, through the publication in March 2004 of the Retail Strategy by DTZ Pieda, which forecast floorspace needs to 2016.

5.1.4 I deal fully with Greater Brookfield in Chapter 6 of the report. Objectors� have two broad areas of concern with regard to Policy RTC1: the degree to which the Policy can accord with PPS6, given the proposed development at Greater Brookfield; and the omission of Greater Brookfield from the hierarchy of centres. As I elaborate below, I consider on balance that the Council�s intention to alleviate the disadvantages, in sustainability terms, of the existing site is appropriate. In current circumstances the policies start to address existing problems but much more needs to be done when the Plan is reviewed in the near future.

5.1.5 Clearly further retail development in this location would not accord with the provisions of the sequential test as set out in PPS6. However, for the reasons I have set out in section 6.1-3 further development here may be acceptable, pending the production of a detailed Masterplan for the area, possibly in the form of an Action Area Plan as part of the LDF, to be included in the promised early review of the Plan. Greater Brookfield is an exceptional case and it would not be practical to apply Policy RTC1 here or to include the area in the hierarchy of centres. This has been made clear by changes to the Policy�s supporting text made at the Second Deposit stage but some clarification in the policy itself would be helpful.

5.1.6 In terms of objectors� other concerns over the wording of the policy, particularly with regards to the test of need, amendments at the 2nd Deposit stage now address considerations of both qualitative and quantitative need and the application of the sequential test, meeting objector�s concerns. However I find that the changes suggested to the Policy by Marks and Spencer Plc would cause the over simplification of the Policy and thereby not fully accord with PPS6. As regards B&Q�s concerns, following changes at the Second Deposit stage, Policy RTC1 is concerned with the broad principles of locating retail development, including the sequential test and the test of need, whereas Policy RTC4 (previously RTC6) is more concerned with assessing the environmental and amenity impact of developments. I consider both Policies to be clearly and accurately worded and the differentiation between the two is logical and without repetition. Therefore it


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would serve no purpose to amalgamate them as suggested by the objector.

5.1.7 In Turning to Mrs Beard�s concerns over issue f), I acknowledge that Cheshunt Old Pond provides a valuable and successful centre for the community, having a good range of shops and services. Given past changes in the provision of shopping and leisure uses, both within and outside the Borough, it is clear that this function is, to a certain extent, more limited than Waltham Cross and Hoddesdon; retail floorspace figures show this. The constraining effect of surrounding residential development makes it unlikely that there is any significant potential for the expansion of the centre. Its characteristics are more in keeping with its designation as a district rather than a town centre. This approach is supported by the adopted Structure Plan. Given the successful nature of the centre, and the protection afforded by Policies RTC2 and RTC6, I find that it would be unlikely that the centre would decline as a result of its designation as a district centre. I find that the small size of the centre, together with the fragmentation of shopping uses with other appropriate district centre uses would make the imposition of a core frontages policy impractical. Again I think that the provisions of Policies RTC2 and RTC 6 (Previously RTC 8) would provide sufficient protection to maintain the vitality of this district centre. As regards objectors� concerns over the quality of the Plan�s inset maps, I consider that this has been addressed by changes made at Second Deposit stage.

5.1.8 In terms of the last issue, given the largely urban and suburban form of the Borough, the Countryside Agency�s concerns do not actually relate to any of the Borough�s settlements. The broad requirements of policies in this Chapter and the Community Leisure and Tourism Chapter provide sufficient protection for all such facilities regardless of their location.

Recommendations

RTC.1 Modify the Plan in accordance with PICS 056 057, and 058.

Modify Policy RTC1 to read as follows;

�THE COUNCIL WILL PERMIT NEW RETAIL DEVELOPMENT WITHIN THE TOWN AND DISTRICT CENTRES THAT IS COMPATIBLE WITH THEIR FUNCTION AND POSITION WITHIN THE RETAIL HIERARCHY SET OUT IN PARAGRAPH 5.13, SUBJECT TO POLICY RTC4. RETAIL DEVELOPMENT WILL NOT BE PERMITTED ELSEWHERE IN THE BOROUGH UNLESS OTHERWISE PROVIDED FOR IN THIS PLAN OR WHERE: ��

In Paragraph 5.3.1 after �in all cases� delete �outside of town centres� and insert �on sites on the edge of town centres and out of town centres�

5.2 RTC2 VITALITY AND VIABILITY OF TOWN AND DISTRICT CENTRES

Objections - First Deposit 1268/2 Snowgold Developments Ltd 1103/10 Windmill Estate Residents' Association


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1302/5 Roger Bullworthy Associates Issues

(a) Cheshunt Old Pond should be included in this policy as a town centre.

(b) A district centre should be identified at Grange Brook, Rags Lane.

(c) Policy as drafted is ineffective.


5.2.1 I have dealt with objectors� concerns over the status of Cheshunt Old Pond at Paragraph 5.1.5 above. For the reasons given there, I find that the centre should remain designated as a district centre.

5.2.2 I have addressed the issue raised in (b) under objections to Policy GBC1 in section 2.12 of the report. I found no good reason to remove this land from the Green Belt or to allocate the land as a district centre.

5.2.3 In terms of issue (c), I have addressed the objector�s concerns over the Plan�s approach to Greater Brookfield in Paragraph 5.1.4 above. In terms of the objector�s concerns over the form of Policy RTC2 I find that the Policy together with its supporting text adequately explains the Council�s approach to supporting the vitality and viability of town centres, where it is within its remit to do so. To extend the Policy beyond these limits would not be acceptable.

RECOMMENDATIONS

RTC.2 No Modification

5.3 FORMER RTC3 TOWN CENTRE FRAMEWORKS (DELETED FROM SECOND DEPOSIT)

Objections - First Deposit 1103/11 Windmill Estate Residents' Association 1302/4 Roger Bullworthy Associates (a) Cheshunt Old Pond should be included in this policy as a town centre.

(b) Policy as drafted is ineffective.


5.3.1 This Policy was deleted at Second Deposit stage and both objectors concerns have been addressed elsewhere in my report.

Recommendation

RTC.3 No modification


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5.4 RTC3 DEVELOPER'S CONTRIBUTIONS (FORMERLY RTC4)

Objections - First Deposit 1001/28 Hertfordshire County Council 1265/9 Malcolm Honour 1302/3 Roger Bullworthy Associates Objections - Second Deposit 1302/23 Roger Bullworthy Associates Issues

(a) Policy omits reference to sustainable transport infrastructure and services.

(b) Planning obligations should only be required where they are necessary for reasons stated in Circular 1/97

(c) Policy is an unreasonable burden on town centre developers.


5.4.1 As regards the first issue, changes at the 2nd Deposit stage have addressed Hertfordshire County Council�s concerns. As regards issue (c) I find that changes made at the Second Deposit stage to the Policy�s supporting text has clarified the importance of the provisions of Circular 1/97. Given this and my suggested amendments to this Policy in the following paragraph, there is no reason to make further reference to Circular 1/97 in the Policy.

5.4.2 The Council rightly state that development at Greater Brookfield will also require contributions, where these can be sought under the provisions of Circular 1/97 and in this respect I do not consider that the objector�s concerns over the fairness of the Policy�s application are justified. However as the Council rightly point out a balance must be struck between the demands placed on developers and the viability of any development scheme. I find the Policy fails to make the need for this balance clear. This can be overcome by introducing a test of appropriateness into the Policy.

Recommendations

RTC.4 Modify the Plan by inserting the phrase �WHERE APPROPRIATE� at the start of the second sentence of the Policy.


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5.5 RTC4 CRITERIA FOR ASSESSING NEW RETAIL PROPOSALS (FORMERLY RTC6)

Objections - First Deposit 1001/27 Hertfordshire County Council 1296/16 Tesco Stores Ltd 1300/4 B & Q Plc 1302/2 Roger Bullworthy Associates Objections - Second Deposit 1296/25 Tesco Stores Ltd Issues

(a) Parking standards for food retail development should reflect those in PPG13

(b) Criteria (d) is too restrictive and will disadvantage those wanting to invest in town centres.

(c) It is not clear whether the policy includes Greater Brookfield or not.

(d) Policy should be combined with policy RTC1.


5.5.1 As regards the first two issues, following a number of changes made to Policy T10, both by the Council and through my recommendations in response to objections, I consider that the approach of the Plan to parking now conforms to the requirements of PPG 13. The Council has amended criterion (d) of Policy RTC 4 at the Second Deposit stage so that it corresponds with the approach of Policy T10. Whilst the Council�s adopted parking standards are slightly below those set out in PPG 13, I find that the Council�s approach is reasonable as it adopts countywide standards that ensure a consistent approach throughout neighbouring boroughs, which is fully in accordance with PPG13. In addition the Council have suggested a further change in its response to objections to this chapter, concerning the status of these parking standards but I consider this change to be inaccurate as these standards are in fact listed in Section 9.7 of the Transport Chapter.

5.5.2 As regards issue (c) I find that following Second Deposit changes throughout the Chapter, it is now clear that the future development of Greater Brookfield is solely addressed in Chapter 6. I have addressed Tesco�s concerns over issue (d) in my consideration of Policy RTC1. For the reasons given there I find there is no justification to combine Policy RTC1 with this Policy.

Recommendations

RTC.5 Modify the Plan as follows;

In Criterion(d) After �the standards set out in � delete �Supplementary Planning Guidance� and add �Section 9.7 of the Plan�s Transport Chapter.�


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5.6 RTC5 NON-RETAIL USES WITHIN CORE FRONTAGES OF HODDESDON AND WALTHAM CROSS TOWN CENTRES (FORMERLY RTC7)

Objections - First Deposit 1103/12 Windmill Estate Residents' Association

Objections - Second Deposit 471/14 Mrs I Beard Issues

(a) Policy omits Cheshunt Old Pond

(b) Not clear what �considerable length of time� means.


5.6.1 I have dealt with objectors� concerns over the status of Cheshunt Old Pond at paragraph 5.1.5 above. For the reasons given there I find that it would be inappropriate to designate core retail frontage in the district centre. The district centre is sufficiently protected under Policies RTC1 and RTC 6 and should not be included under the provisions of this policy.

5.6.2 As regards Mrs Beard�s other concerns, the requirements under part II of the policy amount to a robust test of marketing to ensure that the reuse of premises for A1 purposes has been thoroughly investigated. To include a fixed period of time may in fact hinder the Council�s aims as it could be seen as an encouragement to circumventing the Policy�s requirements. Furthermore what constitutes a �considerable length of time� will vary widely, depending on the economic climate, and to impose a set time period could cause significant periods of vacancy for units that could otherwise make some contribution to the vitality of Cheshunt Old Pond at times of low economic activity.

Recommendations


5.7 RTC7 PROPOSALS FOR CLASS A3 AND SIMILAR USES (FORMERLY RTC9)

Objections - First Deposit 1103/13 Windmill Estate Residents' Association 1265/11 Malcolm Honour


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Issues

(a) Objector seeks change of wording of policy.

(b) Policy adopts an unduly restrictive approach to A3 uses.


5.7.1 The Policy has been amended at 2nd Deposit stage, which I consider meets the objector�s concerns. However, the second half of the Policy contains an excessive amount of detail much of which either replicates the supporting text or indeed is not within the remit of land use planning, such as the intended customers and the expected catchment area from which they would be drawn. Whilst I appreciate that the effects of certain A3 uses can have a detrimental effect on, for example, highway safety or residential amenity, this does not justify the excessive nature of the second half of the Policy, which should be deleted.

Recommendations

RTC.7 Modify the Plan by deleting all of the Policy from criterion (a) of Part II onwards.

5.8 RTC10 ADVERTISEMENTS AND HOARDINGS (FORMERLY RTC12)

Objections - Second Deposit 471/15 Mrs I. Beard 1000/121 Government Office for the East of England Issues

(a) Policy should be strengthened.

(b) S54a does not apply to applications for advertising consent � policy is unnecessary


5.8.1 Whilst I appreciate that advertising and signage may have a significant visual impact on the street scene, many of Mrs Beard�s concerns lie outside the remit of both the planning system and the Advertisement Control Regulations. Similarly as Section 54(a) of the Town and Country Planning Act 1991 does not apply to the Advertisement Control Regulations, I can see no point in having a formal policy in the Plan that addresses this matter, regardless of any suggested Pre Inquiry Change. Section 5.11 provides some useful background but I find that the Policy should be deleted and it would not be beneficial to include any of its wording as supporting text.

Recommendations

RTC.8 Modify the Plan by deleting Policy RTC10 and its supporting text.


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5.9 RTC11 RESIDENTIAL USE IN TOWN CENTRES (FORMERLY RTC14)

Objections - First Deposit 1000/68 Government Office for the East of England Issues

(a) Wording could be more positive.


5.9.1 GOE�s recommendations have been addressed by changes made to the Policy at the Second Deposit stage.

Recommendation


5.10 RTC12 MAXIMISING THE DEVELOPMENT CONTRIBUTION FROM TOWN CENTRE SITES (FORMERLY RTC15)

Objections - First Deposit 1302/1 Roger Bullworthy Associates Objections - Second Deposit 1000/128 Government Office for the East of England Issues

(a) Policy should apply to whole Borough not just town centres.

(b) Policy places an undue burden on town centres


5.10.1 In terms of both objections the Council has, through PIC 062 and other Pre Inquiry Changes, relocated the Policy as Policy H2A in the Plan�s housing chapter. The Policy now applies to all housing developments through the Borough, which I find to be a logical approach.

Recommendations

RTC.10 Modify the Plan in accordance with PIC062


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5.11 APPENDIX - A HIERARCHY OF SHOPPING CENTRES

Objections - First Deposit 1102/51 Goff's Oak Community Association 1296/9 Tesco Stores Ltd 1300/3 B & Q Plc Objections - Second Deposit 1296/1 Tesco Stores Ltd 1366/3 Bayfordbury Estates Issues

(a) Hierarchy excludes Masons Parade, Newgatestreet Road.

(b) Hierarchy excludes Greater Brookfield.

(c) Hierarchy should be better integrated into Plan Chapter


5.11.1 Changes made to the Plan at Second Deposit stage now include Masons Parade within the Goffs Oak neighbourhood centre, which I consider meets the objector�s concerns. As regards issue (b) I have addressed the inclusion of Greater Brookfield in the hierarchy of centres in my considerations of objections to Policy RTC1 above. For the reasons given there I find that Greater Brookfield should remain outside the retail hierarchy, pending any change put forward in regional guidance.

5.11.2 Turning to B&Q�s suggestion of integrating the list of the hierarchy of centres into the Plan in an amalgamated version of Policies RTC1 and RTC6, I have already stated in paragraph 5.14 that I can see no good reason to amalgamate these Policies. Similarly including the detailed list of the hierarchy within any Policy would create a cumbersome, over detailed policy. I consider that the Council�s approach is therefore acceptable.

Recommendations



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6. GREATER BROOKFIELD

6.1 GREATER BROOKFIELD � WHOLE CHAPTER, INTRODUCTION AND OBJECTIVES

Objections - First Deposit 562/7 The Wormley Society 806/1 Chainbow Management Services Ltd 813/11 New River Action Group 1002/5-6 & 19 Hertfordshire County Council (Property) 1102/53 Goff's Oak Community Association 1296/10 Tesco Stores Ltd 1302/12 Roger Bullworthy Associates Objections - Second Deposit 231/2 Mr B. S. Dodimead 420/3 Mr D. G. Dodimead 562/11 The Wormley Society 1000/86 Government Office for the East of England 1001/83 Hertfordshire County Council (Environment) 1002/25 Hertfordshire County Council (Property) 1289/7-8 Marks and Spencer Plc 1296/17 & 20 Tesco Stores Ltd 1301/22 Standard Life Investments 1302/1,14,18, 22 Roger Bullworthy Associates 1366/4-5 & 7 Bayfordbury Estates 1375/1 Mrs S Dodimead Objections - Pre-Inquiry Changes 1366/021 Bayfordbury Estates 1289/11 Marks and Spencer Plc Issues

(a) Approach to Greater Brookfield should be more positive.

(b) Approach is contrary to PPG6, PPG13, and Structure Plan policies 15 and 17. This is an out of town location where further retail and leisure development should be resisted.

(c) Object to policies in this chapter which support development of Greater Brookfield as a town centre.

(d) Development should be resisted until traffic problems are resolved.

(e) Classification of Brookfield as a town centre or suburban district centre.

(f) Inaccuracies in supporting text (para 6.1.5).

(g) Plan should include evidence of updated retail study and sequential approach.


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(h) Plan does not distinguish between expansion of existing uses and new development.

(i) Text overstates congestion levels and should recognise proportional traffic solutions.

(j) Reference to Masterplan lacks detail and clarity.

(k) Inaccuracies in map defining the area.

(l) Allocations require greater clarity.

(m) Text requires specific reference of a link road from Halfhide Lane to A10.

(n) Objective (f) lacks clarity.

(o) Objectives should include educational and medical provision for the area


6.1.1 Greater Brookfield comprises a substantial area of retailing and other mixed uses located on the west side of the A10 in an �out-of centre� position well removed from the established town centres of Hoddesdon, Cheshunt Old Pond and Waltham Cross. As the Council admit, the location of such a significant retail area, with a total retail floorspace of 26,400m2 (only marginally below the equivalent levels of floorspace in Hoddesdon and Waltham Cross centres), is itself contrary to strategic and national guidance. It is clear that the area also suffers from some serious planning problems at present. Retail and traffic studies, together with a considerable amount of anecdotal evidence, show that the local highway network is seriously congested at peak times. There is a real shortage of social and community facilities, and complementary outlets selling food and drink to support the retailing. I agree with the Council that Greater Brookfield lacks a sense of place and design cohesion; the main retail area is dominated by roads and car parking and pedestrian links are poor.

6.1.2 However, there is no doubt that the area will continue to be an important retail focus for many years to come. The Council recognise that existing development will not disappear and accept the need to take positive action to improve the �centre� and deal with the problems identified above. The Plan sets out a number of objectives for the area listed at #6.2.5 although these are not entirely consistent with the wording of explanatory text in #6.2.2-4, which refer to just 4 objectives. Some rewording of the text here to marry up both parts may be helpful.

6.1.3 However, the Council seeks to achieve these improvements to Greater Brookfield while at the same time protecting and enhancing the vitality and viability of the Borough�s existing town centres at Hoddesdon and Waltham Cross, and the district centre at Old Pond, Cheshunt. The policies for Brookfield do not allow for any significant growth of retail floorspace, which is directed to the three centres in accordance with the sequential test that is an established part of national policy, as re-stated in # 2.14 of PPS6. The Council argue that this approach is supported by emerging regional guidance in the draft version of RSS14. Policy E12 of this document states that LDDs should determine the role for existing out-of-centre retail sites. It requires that any development of such sites should be allowed only where it would improve social, environmental and economic stability and deliver improved sustainable transport accessibility, particularly improved public transport


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access.

6.1.4 These objectives are highly relevant to Greater Brookfield. Physical inspection shows that the existing town centres in Broxbourne have little scope for expansion at present and are therefore unlikely to stem the substantial flow of comparison goods retail expenditure from the Borough. I note that the writers of the Borough of Broxbourne Retail Strategy 2004 conclude that the �Brookfield centre offers the best opportunity for the Borough to retain a significantly higher level of expenditure, particularly through a wider range of town centre services, including improved leisure opportunities (CD/BFC/20, # 8.34). From my several visits to Brookfield and the town centres, I agree with their conclusion that the Borough is at a crossroads. The successful balancing of the reinforced roles of town centres with a more sustainable Brookfield �centre� is critical to the success of the Plan; development of evening uses is also crucial.

6.1.5 The adopted Local Plan included an allocation for retail warehousing of land on both sides of Halfhide Lane. That plan did not specify any amount of floorspace at this location, although the Council say that it was expected to accommodate about 9,000m2. The most recent study of retail capacity in the district was carried out by DTZ Pieda and the results were published in March 2004 as the Retail Strategy 2004 (CD/BFC/20). The Council has put forward a PIC which acknowledges this document, although a minor alteration is needed to the wording to bring it fully up to date. The study concluded that between 5,900m2 and 8,100 m2 of new retail warehousing could be accommodated within the Borough up to 2016 without adversely affecting existing retail centres. It also indicates further scope for an increase in comparison goods expenditure to 2016. No alternative contradictory evidence based in retail studies has been put to the inquiry.

6.1.6 An alternative town centre location at Hoddesdon for retail warehouse development identified in the study has already been taken up by a food retailer. The other site of just 0.4ha would accommodate only a small part of the needed capacity and has not come forward. The study also concluded that there would be further capacity for �bulky goods� floorspace if the Borough were to try to claw back some of the expenditure lost to competing centres in adjoining Districts. I see no objection in principle on retail policy grounds therefore to retail warehouse development of this magnitude at Brookfield.

6.1.7 The Council argue that the Retail Strategy figures justify retaining the flexibility within Policies BFC4 and BFC5 to allow a mixture of retail warehouse and leisure uses, subject to safeguards concerning relocation of the existing uses � the Council Depot and Waste Station and the travellers� site. However, the policies and Proposals Map give no detail as to the exact amount of floorspace to be allowed or its location, both of which are to be considered when a Masterplan is prepared. This document does not form part of the plan and at present there is a policy vacuum for detailed future proposals and improvements.

6.1.8 Similarly, the proposed leisure uses are subject to a requirement that they would be allowed only if a sequential test showed that they could not be provided within existing centres. Such a restriction clearly complies with government policy. However, it could prevent the implementation of policies to improve the sustainability of the Brookfield area, in accordance with other


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chapter objectives.

6.1.9 I consider the general thrust of the Council�s policies to maintain the roles of the existing centres and improve the sustainability of Greater Brookfield accords with current national and regional retail policy. However, these two objectives might not be fully compatible with each other. I have some concerns about the realism of other policies to improve the �centre� in the absence of further retail investment to provide financial support for expensive infrastructure such as a new road alignment, improved pedestrian links, improved infrastructure for public transport and other works such as additional landscaping. As currently drafted, the policies give no firm guidance as to the amount of supporting development in the form of leisure uses, ancillary Class A3 uses and social infrastructure that might result. From the evidence of the Council�s witness at the inquiry on 9 June 2004, there seems little prospect of two important sites (the depot/waste station and the travellers� site) being relocated within the Plan period.

6.1.10 Furthermore, Policy BFC3 envisages minimal development up to 2006 on the New River Trading Estate, a reasonably accurate estimate given the limited development that has occurred since it was drafted. A substantial part of this estate appears to be in some form of retail use at present and its redevelopment would not necessarily conflict with the thrust of policy in #2.14 of PPS6. I am far from convinced that allowing on an interim basis the type of quasi-retail uses described in the Plan will contribute towards the environmental and sustainability benefits the Council seeks. To my mind, the problems associated with the incremental growth of retail development in this out-of-centre location now cry out for a more radical solution. What is there will not go away and a comprehensive detailed plan is needed that sets out the type and amount of uses, improved highways and pedestrian links, and a full landscape enhancement plan for the whole area. To be fully effective, I agree with the Council that such a scheme has to depend on the satisfactory relocation of its own depot and the travellers, whatever the difficulties.

6.1.11 Overall therefore, it already seems unlikely that the objectives in #6.2.5 concerning improvements to the �centre� can be fully met in the lifetime of the Plan. I appreciate the constraints on the Council but consider the failure of the Plan to give a clearer vision for the area is unfortunate. The early review of the plan should take matters further; I urge the Council to give serious thought to including a Masterplan giving clear direction as to the location of up to 8,000m2 of retail warehousing and any other retail growth at the key site of New River Trading Estate. The location and quantum of leisure uses, A3 uses, proposals to relieve traffic congestion and improvements to public transport accessibility should be included as vitally important elements.

6.1.12 In summary I am sympathetic to the thrust of those objections that seek greater clarity in the Plan of proposals for Brookfield. However it is not realistic to suggest delaying adoption of the Plan for some time while more detailed work is carried out. It is beyond my remit to put forward in this report detailed suggestions for a Masterplan, which could take the form of an Area Action Plan within an LDF. However, subject to detailed financial appraisal I think it would be reasonable to allow some further enabling development to make the area more sustainable. A comprehensive scheme


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for the improvement of the area would need full justification to accord with emerging regional policy in RSS14 and thus the thrust of policy in PPS6.

RECOMMENDATIONS

BFC.1 Modify the Plan in accordance with PICs 063-68 but reword #6.1.5 to include reference to the results of the DTZ Pieda retail study and reduce the upper limit of retail warehouse space to 8,000m2.

6.2 BFC1 LAND AT CANADA FIELDS Objections - First Deposit 403/2 I. Rix 813/1 New River Action Group 1000/15 Government Office for the East of England 1002/7 Hertfordshire County Council (Property) 1101/47 CPRE - The Hertfordshire Society 1103/14 Windmill Estate Residents' Association 1272/1 Mr A. J. Salter 1301/12 Standard Life Investments 1302/11 Roger Bullworthy Associates Objections - Second Deposit 1000/100 Government Office for the East of England 1002/20 Hertfordshire County Council (Property)

Issues

(a) Objections to development of this site on the basis of the impact on the area.

(b) Site should revert to Green Belt and not be re-allocated for housing.

(c) Policy should include provision for a travellers site at Canada Fields.

(d) Technical constraints limit suitability for housing.

(e) Policy wording delegates policy decisions to SPG


6.2.1 The development of the Canada Fields site is well under way following the granting of planning permissions. Therefore, these objections have largely been overtaken by events or have been met by proposed minor changes to the text concerning the development brief. I deal with issues concerning the travellers� site in section 6.6 below.

RECOMMENDATIONS

BFC.2 Modify the Plan in accordance with PIC 070


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6.3 BFC2 LAND AT BROOKFIELD FARM AND BROOKFIELD RETAIL PARK

Objections - First Deposit 1302/10 Roger Bullworthy Associates Objections - Second Deposit 1000/87 Government Office for the East of England 1296/21 Tesco Stores Ltd 1301/18 Standard Life Investments 1302/17 Roger Bullworthy Associates Issues

(a) Approach is contrary to PPG6, PPG13, and Structure Plan policies 15 and 17.

(b) Policy should encourage new retail development.

(c) Policy should not encourage new retail development, such uses should be directed to existing town centres


6.3.1 I have already dealt with the broad thrust of these objections in section 6.1 above. Objectors are split into two groups: those who object to the proposal to allow a limited amount of Class A3 development; and those who seek more Class A1 retail floorspace and a wider range of associated uses such as restaurants and leisure facilities. I consider the Council is right to seek a wider range of retail facilities at Brookfield to enable the area to function better as a sustainable centre, while at the same time trying to give some protection to existing centres at Hoddesdon, Waltham Cross and Old Pond, Cheshunt. The supporting text to Policy RTC1 states that Greater Brookfield is excluded from the usual sequential test for new retail development (in accordance with PPS6) and I have suggested that the policy itself could be clarified in this respect. Policy BFC2 is silent regarding assessment of new retailing at Brookfield but in the interim allows ancillary supporting quasi retail uses. I consider the Council has taken too restrictive a view of Policy E12 of draft RSS14, which does allow for development subject to justification on sustainability and other grounds.

6.3.2 As I have already said, there is a danger that the objective to improve the sustainability of Greater Brookfield would be compromised if no more retailing were allowed. Additional Class A1 floorspace could have some impact on town centres; a balance between competing retail policy objectives would have to be struck. For the time being further work would be required before more detailed proposals for any necessary enabling development could be promoted in the Plan. However, the policy merely allows existing retail uses to remain, or for these retail areas to broaden their service function through changes of use to ancillary and


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complementary activities. I support the greater flexibility offered by the suggested change which would allow Classes A2 and D2 uses as well as Class A3 outlets.

RECOMMENDATIONS

BFC.3 Modify the Plan in accordance with AIC032

6.4 BFC3 NEW RIVER TRADING ESTATE Objections - First Deposit 1001/29 Hertfordshire County Council (Environment) 1002/8 Hertfordshire County Council (Property) 1007/2 East Hertfordshire District Council 1289/2 Marks and Spencer Plc 1296/11,13 Tesco Stores Ltd 1302/9 Roger Bullworthy Associates Objections - Second Deposit 1000/88 Government Office for the East of England 1002/21 Hertfordshire County Council (Property) 1289/10 Marks and Spencer Plc 1301/20 Standard Life Investments 1302/1 Roger Bullworthy Associates 1366/8 & 11 Bayfordbury Estates Issues

(a) Policy is insufficiently clear or specific � especially mix of uses and timing of development.

(b) Object in principle to extension of retail and leisure development in this location.

(c) Policy is contrary to Council�s objectives for greater Brookfield area


6.4.1 I note that the Trading Estate part of Brookfield was allocated for retail warehousing in the previous Local Plan. Most recent retail strategy (CD/BFC/20) indicates that there is still scope for up to 8,000m2 of such floorspace, which would not have an unduly harmful effect on the Borough�s town centres and would enable some of expenditure flowing out of Borough to be clawed back. However, I note that the previous retail study undertaken by Vincent and Gorbing showed that this quantity of floorspace could be accommodated on the Halfhide Lane site currently occupied by gypsies.

6.4.2 I have already referred to the slim prospect of redevelopment of both the


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travellers� site and the Council depot within the Plan period, due to the difficulty of finding suitable alternative sites for these much needed uses. These problems serve to emphasise the importance of achieving a high quality redevelopment of the New River Trading Estate, which lies at a pivotal position in the Brookfield area. I consider that the policy as formulated will not help achieve the stated objective to improve Brookfield. Indeed, allowing some quasi retail uses in car related industries such as tyre depots or manufacturers of bulky goods with significant retail elements could be harmful to the general appearance of the area and is highly unlikely to encourage more sustainable travel patterns. The Council�s evidence acknowledges that the retention of the estate in its present form would also be a very significant obstacle to improving pedestrian links within the area.

6.4.3 However, the policy is essentially a holding device; while it would do nothing to secure improvements at Brookfield, it contains sufficient safeguards to prevent prejudice to the longer term aims of the Plan for the area. I agree that development should generally be restricted to changes of use, without significant building works, until the Masterplan has been approved. I therefore accept that the policy could have a role as an interim measure; any more detailed redevelopment proposals would have to accord with a Masterplan, which should include a reference to the need for high environmental standards at this key site.

RECOMMENDATIONS

BFC.4 Modify the Plan in accordance with PIC072

6.5 BFC4 REDEVELOPMENT OF HOUSEHOLD WASTE SITE AND HIGHWAY DEPOT

Objections - First Deposit 254/6-7 R. Barnes 635/2 Mr S. Ribbons 1001/48 Hertfordshire County Council 1007/3 East Hertfordshire District Council 1289/5 Marks and Spencer Plc 1296/12 Tesco Stores Ltd 1302/25 Roger Bullworthy Associates Objections - Second Deposit 1000/89 Government Office for the East of England 1302/8 Roger Bullworthy Associates


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Issues

(a) Conflicts with Policy 18 of Herts waste local plan.

(b) Policy contrary to PPG6 and PPG13 � will affect vitality of neighbouring retail centres.

(c) Objections to redevelopment on traffic grounds.

(d) Household waste site in this location should be retained.

(e) Policy encourages fragmentation of uses �contrary to Chapter�s objectives.

(f) Policy lacks clarity into types of uses permitted


6.5.1 The Council�s rationale for seeking the redevelopment of the depot and waste site is clearly explained in the plan. Although the site is well screened from Halfhide Lane it is highly visible from the A10 and new uses complementary to the retail (and proposed supporting uses) at the core some 200m to the south, such as retail warehousing, would help to consolidate improvements. As already indicated, the Council�s retail strategy shows that some additional retail development of this type would not unduly damage the vitality and viability of town centres within and outside the Borough. However, I take seriously the point that the household waste facility in particular is well located for local residents. I fully support the safeguard in the policy, as suggested to be changed, that redevelopment should occur only when a replacement facility in a suitable location has become fully operational. On matters of detail, I accept the Council�s argument that it would not be viable to withhold planning permission until the replacement was running, because some surety would be required to obtain funding for the new site. I note that sufficient collection facilities are already available at the Tesco site for recyclable material brought to the site.

6.5.2 I have already considered the principle and quantum of the proposed retail warehousing. Following a Retail Study completed in 2004, the East Herts District Local Plan indicates that there is limited capacity within that District�s town centres for retail warehouse development, which is directed to nearby centres. The suggested amendments to the explanatory text of the plan help to clarify that the sequential test will still be applied to any retail proposals. However, the availability of another town centre site, although unlikely in current circumstances, could jeopardise this proposal of the Plan. Given the anticipated delay in finding a replacement waste site, I think it would be consistent to require proposals for all sites within the Brookfield area to be subject to the provisions of a detailed Masterplan. At present the proposals put forward by the Council, including the proposed changes, give no clarity of vision as to what type and scale of development expected on various parts of the Brookfield area. A limit of 8,000m2 of retail warehousing is suggested, although this could all be allocated on just one site.

6.5.3 I have strong reservations therefore that the revised policy in AIC035 and supporting text suggested by the Council on page 29 of its statement on Brookfield will be adequate to achieve the improvements sought. On balance, however, I have concluded that the text and policy should stand, pending further detailed studies to inform a Masterplan which should include this site.


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RECOMMENDATIONS

BFC.5 Modify the Plan in accordance with AIC035 and the suggested additional supporting text (#6.3.5A) as set out on page 29 of Doc C209/1000 etc

6.6 BFC5 LAND WEST OF HALFHIDE LANE

Objections - First Deposit 1002/10-11 Hertfordshire County Council (Property) 1007/1 East Hertfordshire District Council 1012/7 East of England Tourist Board 1301/7 Standard Life Investments 1302/13 Roger Bullworthy Associates Objections - Second Deposit 1000/90 Government Office for the East of England 1002/22-23 Hertfordshire County Council (Property) 1302/16 & 19 Roger Bullworthy Associates 1319/3-4 Mrs J.M. Hillman 1366/12 Bayfordbury Estates Objections - Pre-Inquiry Changes 1289/12 Marks and Spencer Plc Issues

(a) Text should refer to acceptability of staged development.

(b) Policy is contrary to PPG6.

(c) Policy omits reference to need for any hotel use to be compatible with adjacent Mariott Hotel.

(d) Object in principle to need for retail warehousing development in this location or in the Borough.

(e) Policy should cover a wider range of uses in this location.

(f) Object to principle of redevelopment as existing uses should be retained.

(g) Plan should identify replacement sites for travellers and allotment holders.


6.6.1 Similar comments apply to this site as to the Council Depot and the New River Trading Estate. I have already discussed the principle of new retail warehousing in this part of Brookfield, and accept that the site could accommodate up to 8,000m2 of retail warehousing in accordance with the retail strategy.


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6.6.2 I have some sympathy with the view of some residents, including the Wormley Society, that the travellers� site is relatively unobtrusive and there is no pressing need for its removal. I heard that the occupants had become well established in the local community after 26 years on site, and that the occupants supported local schools. There has been significant investment in the site in recent years to bring it up to date, with new floodlights and security measures. However, the principle of relocation has already been established by the previous Local Plan. It is questionable that this is realistic within the timescale of this Plan; the Council�s witness confirmed that no alternative site was available at the time of the inquiry, nor was any such site in prospect. Adequate safeguards to protect the occupants of the site would be secured by the provisions of criterion e) of the policy and of Policy BFC6. There is some duplication here and I think a cross reference to policy BFC6 would be preferable, but not essential.

6.6.3 Nonetheless, the site is fairly heavily occupied, with minimal green space and no external landscaping of note. It is not an attractive element in the general environs and its redevelopment would improve appearance of area. Given the peripheral location of the site its early redevelopment is not critical, but remains desirable. I consider the site should be incorporated in the Masterplan perhaps as the final phase of mixed development which could possibly include a hotel or leisure uses, depending on progress elsewhere within the area.

RECOMMENDATIONS


6.7 BFC6 RELOCATION OF TRAVELLERS

Objections - First Deposit 1002/12-13 1002/14

Hertfordshire County Council (Property)

1301/13 Standard Life Investments Objections - Second Deposit 1001/66,85 & 87 Hertfordshire County Council 1002/24 & 27 Hertfordshire County Council (Property) Issues

(a) Policy fails to identify replacement location for traveller�s site.

(b) Policy should apply to needs of travellers throughout the Borough


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6.7.1 The supporting text in #6.3.8 indicates that the Council may be flexible if the needs of the travellers on the Halfhide Lane site change. While the policy could be applied generically throughout the Borough, it would not be appropriate to deal with any other needs for travellers� site(s) in this section of the Plan. The addition of clause (f) through the suggested change meets the remaining objection.

RECOMMENDATIONS


6.8 BFC7 IMPACT OF DEVELOPMENT ON THE HIGHWAY NETWORK WITHIN THE GREATER BROOKFIELD AREA (FORMERLY BFC8)

Objections - First Deposit 562/8 The Wormley Society 815/1 Mr J.V. Smith 1001/3 Hertfordshire County Council 1002/15 Hertfordshire County Council (Property) 1101/49 CPRE - The Hertfordshire Society Objections - Second Deposit 562/12 The Wormley Society 1366/13 Bayfordbury Estates Issues

(a) Policy fails to address issues of congestion in wider area.

(b) Policy is insufficiently clear or specific.

(c) Policy needs to be based around public transport solutions.


6.8.1 The Council acknowledge the concerns about traffic congestion at Brookfield and the shortcomings in public transport provision to the area. As I have already said, the overall planning for the area could go further than it has done in the Plan. I note the comments of objectors that the position has got worse following the Tesco expansion, despite the public transport improvements that were achieved through a Section 106 planning obligation. Evidence from traffic surveys and the retail study, which showed that traffic congestion appeared to be having an adverse effect on sales at peak times, reinforces the need for positive action. I saw for myself that the traffic light junction at The Links can become severely congested, although I did not experience any particularly severe problems when I visited on a Sunday lunchtime. However, I consider the wording of Policy BFC7 should safeguard against a further deterioration in the situation, at least as a result of any new development. The policy is consistent with the requirements of other


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policies regarding development sites that proposals should not prejudice any comprehensive transport solution to these problems, including the need to improve conditions for pedestrians and cyclists.

6.8.2 Public transport improvements will play a crucial role in meeting the Council�s objectives to make Brookfield a more sustainable location. However, I share the Council�s view that committing all available resources to public transport would not be the best way to solve the transport problems of the area. Other measures are needed to resolve traffic conflicts, in particular the need to make the retail focus of the area a more friendly environment for pedestrians. From my visits to the area I consider this could best be achieved by diverting the B156 Halfhide Lane away from the entrance to the retail development on the west side of the road. Any such proposals would have to be considered as part of the proposed Masterplan.

RECOMMENDATIONS


6.9 BFC9 PROTECTION OF THE SETTING OF THE GREEN BELT AND GREAT CAMBRIDGE ROAD

Objections - Second Deposit 1264/36 Higgins Homes Ltd Issues

(a) Policy should promote protection of an A10 �green corridor�


6.9.1 I have dealt with this objection in the green belt chapter of the report. I consider it would be inappropriate to adopt an inflexible policy that sought to protect one part of the Borough at the expense of another and that the suitability of all areas to meet future development needs should be considered when those needs are known in more detail. A more detailed landscape appraisal than that available to the inquiry would be required before such a landscape protection corridor could be designated.

RECOMMENDATIONS

BFC.9 No modification


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6.10 BFC10 PEDESTRIAN LINKS BESIDE THE NEW RIVER Objections - First Deposit 813/12 New River Action Group 1264/19 Higgins Homes Ltd Objections - Second Deposit 1319/6 Mrs J. M. Hillman Issues

(a) Policy is insufficiently detailed and should refer to protection of A10 green corridor


6.10.1 The policy supplements Policy HD19 concerning the protection of green chains and I consider it goes as far as it can in a document such as this, save for the correction of a typing error. More detailed guidance could be provided in the proposed Masterplan for the area.

RECOMMENDATIONS


6.11 BFC11 A3 AND OTHER LEISURE USES

Objections - Second Deposit 1302/15 Roger Bullworthy Associates 1319/5 Mrs J. M. Hillman

Issues

(a) Policy is contrary to national and strategic policy.

(b) Objections that these uses will over-commercialise Greater Brookfield.


6.11.1 I have already dealt with the general principle of locating additional leisure development at Brookfield, and concluded that some diversification of uses would help to make the location more sustainable.

6.11.2 While the principle of leisure uses may be acceptable, the policy itself relates to safeguards to prevent unduly adverse effects from noise on any nearby noise sensitive development. These matters are covered in Policies SUS9-11. Any particular detailed requirements relating to leisure uses at Brookfield could be dealt with through the Masterplan or SPG.

RECOMMENDATIONS

BFC.11 Delete the policy


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7. COMMUNITY, LEISURE AND TOURISM

7.1 WHOLE CHAPTER / INTRODUCTORY TEXT

Objections - First Deposit 265/4 Ms S. J. Storey 471/5-6 Mrs I. Beard 1001/62 Hertfordshire County Council 1009/38 English Nature 1010/8 The Countryside Agency (E. England Region) 1012/5 East of England Tourist Board Issues

(a) Chapter does not highlight need for facilities for young people.

(b) Chapter neglects consideration of role of informal recreation.

(c) Chapter needs a reference to linking green spaces not just a hierarchy of them.

(d) Object to Council�s objectives in relation to appropriate uses of public parks.

(e) FD Para 7.1.6 should refer to East of England Tourist Board.

(f) FD para 7.2.2 � inaccuracies in text.


7.1.1 Paragraph 7.1.4 of the Plan acknowledges the inadequate provision of facilities for young people. However the Plan can only require the provision of these facilities where new development, be that public or private, takes place. The Plan is not an appropriate vehicle for listing precisely what these provisions should be.

7.1.2 The wording of the Chapter has been sufficiently revised at the Second Deposit stage to make additional references to informal leisure pursuits, which I consider meets the objector�s concerns. However I do not consider it necessary for the Plan to make specific reference to commercially based leisure uses, such as Broxbournebury Country Club and Golf Course.

7.1.3 The open spaces protected in this Chapter and other natural spaces such as residential back gardens provide links between green spaces for wildlife. Policies within Chapter 7 and 8 provide a framework for the linking of green spaces, but given the urban nature of the Borough a specific policy requiring the creation of linked green spaces would not be practical.

7.1.4 Over the lifetime of the Plan community leisure and recreation needs may change and it is reasonable that the Plan�s objectives enable the appropriate and flexible use of public open spaces for a range of uses, whilst ensuring the protection of historic open spaces. It would not be reasonable however for the Plan to place an embargo on all development in parks where this would benefit the community. Other Policies in the Plan would ensure that development in parks would only be permitted where there would not be an


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unsatisfactory impact. As regards the objector�s final concern the maintenance of footpaths is an operational matter and not within the Plan�s remit.

7.1.5 Paragraph 7.1.6 in the Second Deposit version of the Plan has been amended to make a specific reference to the East of England Tourist Board. The Council have acknowledged that Paragraph 7.2.1 should refer to Policy 20 (Tourism) as opposed to Policy 40 (Agricultural Land), an error that needs correction.

RECOMMENDATIONS

CLT.1 No modification

7.2 CLT1 COMMUNITY, OPEN SPACE AND RECREATIONAL FACILITIES

Objections - First Deposit 1002/3 Hertfordshire County Council (Property) 1103/15 Windmill Estate Residents' Association Objections - Second Deposit 595/3 & 5 Goffs Oak Community Association 1280/7 George Wimpey UK Ltd (formerly McLean Homes) 1293/30 Colin Buchanan and Partners Objections - Pre-Inquiry Changes 1253/19 The House Builders Federation Issues

(a) Policy lacks reference to built community facilities and requirements for their provision.

(b) Object in principle to any policy which permits loss of open space.

(c) Schedule of open spaces and proposals map should include Jones Road �village green�.

(d) Criteria in policy are over-prescriptive and contrary to Circular 1/97.

(e) It is inappropriate for Supplementary Planning Guidance and the Community Plan to identify developer contributions.

(f) Everest Sports Ground should be deleted from schedule of open space in section 7.12


7.2.1 Policy CLT1 and its supporting text, introduced at Second Deposit, apply to all community facilities, including libraries, youth facilities and community


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halls. The provision of such facilities for new residential development is addressed by Policy CLT2, also introduced in the Second Deposit. I consider that this meets objector�s concerns.

7.2.2 The Second Deposit version of the Policy improves the level of protection offered to facilities, which goes some way to meeting objectors� concerns. However I consider that criterion (c) and paragraph 7.4.3 should be more specific about the location of alternative provision.

7.2.3 The Council have clarified the ownership of the recreational space at Jones Road. Subsequently the Council has recommended its inclusion in Paragraph 7.11 in its response to objections to this Chapter

7.2.4 The explanation of the role played by the Community Plan in #7.5.2 in assessing contributions is not sufficiently clear. The Council�s response has acknowledged that the final sentence of paragraph 7.5.2 could be further clarified by PIC 075. It is reasonable for the Council to utilise the Community Plan as this contains the most up to date information on community need. The Community Plan does not set developer�s contributions but allows the effects of new development on community facilities to be assessed. Similarly it is also reasonable for the Council to utilise SPG as an initial basis for the calculation of contributions, as to include this level of information in the Plan would make it overly detailed. Following these changes I consider that the Policy and its supporting text comply with Circular 1/97.

RECOMMENDATIONS

CLT.2 Modify the Plan in accordance with PIC075. Modify criterion (c) to read:

�(c) SUITABLE ALTERNATIVE PROVISION IS MADE IN A LOCATION WHICH IS EQUALLY OR MORE ACCESSIBLE TO THE FACILITY�S CATCHMENT AREA AND TO A SIMILAR OR IMPROVED STANDARD AS THAT TO BE LOST, OR;�

Replace �local� with �catchment� in # 7.4.3

Include the Village Green site at Jones Road in Paragraph 7.11 under �Local Parks/ Recreation Grounds� as a �part formal/ part informal� facility;

7.3 CLT2 COMMUNITY AND LEISURE, FACILITIES LINKED TO NEW RESIDENTIAL AND EMPLOYMENT DEVELOPMENT

Objections - First Deposit 1253/12 The House Builders Federation Issues

(a) Object to application and approach of this policy.


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7.3.1 I have addressed the objector�s concerns in my recommendations concerning Policies CLT3 and 4 below.

RECOMMENDATIONS

CLT.3 Delete the policy

7.4 CLT3 RECREATIONAL FACILITIES LINKED TO NEW RESIDENTIAL AND EMPLOYMENT DEVELOPMENT

Objections - First Deposit 254/8 R. Barnes 1301/14-15 Standard Life Investments Objections - Second Deposit 1000/122 Government Office for the East of England Objections - Pre-Inquiry Changes 1253/20 The House Builders Federation Issues

(a) Policy is contrary to Circular 1/97 and duplicates IMP2.

(b) Policy fails to promote enhancement of existing public open spaces


7.4.1 I consider that objections to Policies CLT2, CLT3 and CLT4 are of a similar nature and for reasons of brevity I shall address these together. I note that the Council have proposed a number of changes to these Policies at the Pre-Inquiry stage, including the deletion of Policy CTL4. I am not convinced that the changes have sufficiently addressed concerns about the clarity of the Plan�s approach to providing community, leisure and recreation facilities for new residential and employment development. Although I consider that it is reasonable that the Council utilise both the Community Plan and SPG as a framework for assessing possible levels of need, it is clear from Circular 1/97 that the specific circumstances of development need to be taken into account. This is not clear in the Second Deposit Draft Policy. However it is not within my remit to assess the acceptability of the current SPG. The Council�s approach to the negotiation of new community facilities is overly complex and it is not altogether clear from the Policy how the Community Plan and SPG would provide the basis for negotiation. Furthermore these Policies are overly repetitive. I am particularly concerned about the differential between residential development under 200 dwellings and those developments of a larger size, as this is an arbitrary figure for changing the


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nature of contributions and would not allow for site specific circumstances to be taken into account. Therefore I have recommended a revised Policy CLT2 in place of Policy CLT2, CLT3 and CLT4 in order to simplify the Plan�s approach and promote consistency with Circular 1/97.

7.4.2 Policies CLT2, CLT3 and CLT4 aimed to address the provision of community leisure and recreation for new residential and employment developments, whilst Policy IMP2 sets out the Council�s approach to a broader range of provision for development including transport and education, as well as a mechanism for delivery. Subsequently Policy IMP2 should be maintained in the Plan.

7.4.3 The Policy�s remit relates to the provision of facilities for new development. Paragraph 7.5.2 indicates that in doing so, the Council may seek contributions for the improvement of existing facilities in association with demand generated by new development, which could include public open space. I consider that this is a sufficient reference to potential enhancement of existing public open space to meet the objector�s concerns.

RECOMMENDATIONS

CLT.4 Modify the Plan by replacing Policies CLT2, CLT3, CLT4 with a new Policy CLT2 which should read:

CLT2 COMMUNITY, LEISURE AND RECREATIONAL FACILITIES LINKED TO NEW DEVELOPMENT

WHERE APPROPRIATE, THE BOROUGH COUNCIL WILL SEEK THE PROVISION OF COMMUNITY, LEISURE AND RECREATIONAL FACILITIES FOR RESIDENTIAL AND EMPLOYMENT DEVELOPMENT PROPOSALS, EITHER THROUGH ON-SITE PROVISION OR FINANCIAL CONTRIBUTIONS TOWARDS OFF-SITE PROVISION. THE LEVEL OF PROVISION SOUGHT BY THE COUNCIL WILL BE BASED ON:

- THE IMPACT OF THE LIKELY DEMAND GENERATED BY THE PROPOSED DEVELOPMENT ON THE EXISTING LEVEL OF PROVISION OUTLINED IN THE COMMUNITY PLAN;

- THE GUIDELINES FOR CALCULATING APPROPRIATE PROVISION IN SUPPLEMENTARY PLANNING GUIDANCE.

7.5 CLT4 CONTRIBUTIONS TOWARDS THE PROVISION OF COMMUNITY, LEISURE AND RECREATIONAL FACILITIES

Objections - Second Deposit 1000/122 Government Office for the East of England

Issues

(a) Policy is contrary to Circular 1/97 and duplicates IMP2


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7.5.1 The objection which gave rise to this issue was made in relation to Policy CLT3 and CLT4, subsequently my reasoning, conclusions and recommendations for this issue are addressed under Policy CLT3. For the reasons given there I consider that Policy CLT4 should be deleted.

RECOMMENDATION

CLT.5 Delete Policy CLT4

7.6 CLT7 LEE VALLEY REGIONAL PARK

Objections - First Deposit 382/2 R.W.Taplin Objections - Second Deposit 1009/106 English Nature Issues

(a) Text does not reflect the remit of the Park Authority.

(b) Policy is insufficiently supportive of Park Authority

(c) Policy does not give sufficient protection for development outside the Plan boundary


7.6.1 The Policy and its supporting text express sufficient support for the Park Authority�s remit over community leisure and recreation provision within the Park�s boundary and how development proposals are to be assessed within the Park Boundary. Whilst I acknowledge the need to control the potential impact of development adjacent to the Park, I find that other Plan Policies of the Plan satisfactorily address this issue.

7.6.2 The Council have amended paragraph 7.8.1 by PIC 076 to reflect the wording suggested by English Nature and I support this change.

RECOMMENDATIONS

CLT.6 Modify the Plan in accordance with PIC 076


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7.7 CLT8 HOTELS AND OVERNIGHT ACCOMMODATION

Objections - First Deposit 1012/4 East of England Tourist Board Issues

(a) Statistics in para 7.10.2 could be more specific.


7.7.1 I note that both the County wide statistics stated in paragraph 7.10.2 and those suggested by the EETB, that are specific for the Borough date back to 1996. I agree that it would be pointless to replace one set of out of date figures with another set, even if these were specific for the Borough. However even if the purpose of this information is to provide a �snapshot�, then the Plan should contain the most up to date information possible. The Plan should therefore include the most up to date information available, preferably at Borough level, but I make no formal recommendation in this regard.

RECOMMENDATIONS

CLT.7 No modification


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8. HERITAGE AND DESIGN


Objections - First Deposit 1001/32 & 49 Hertfordshire County Council 1101/56 CPRE - The Hertfordshire Society 1011/7,11 & 24 English Heritage 1009/58 English Nature Issues

(a) Text should refer to Structure Plan Policies 38,41 and 44.

(b) Paras 8.4.1 and 8.2.2b should refer to archaeology and historic parks and gardens.

(c) Revisions to Para 8.4.2 to better reflect guidance in PPG16.

(d) Plan omits specific policy to protect Wormleybury Park.

(e) Plan omits a specific policy on trees, hedgerows and woodlands.

(f) First deposit policies BE24-29 should be in Chapter 1 of the Plan


8.1.1 The majority of the changes sought by the objectors have been appropriately addressed in the Second Deposit version of the Plan. With regard to the first issue, the Second Deposit Draft now refers to the correct Structure Plan Policies. Similarly changes have been made at Second Deposit stage that meet the objectors concerns over issue (c) regarding archaeological considerations by better reflecting PPG 16 and providing information on the County Council�s research programme.

8.1.2 As regards issue (b), I consider that these concerns could be met by the unadvertised changes suggested by the Council in their responses to these objections, which includes references to �historic parks and gardens� in Paragraph 8.1.2 and Paragraph 8.4.4.1. In addition a new Policy HD9a (Parks and Gardens of Historic Interest) has been suggested by the Council at Second Deposit stage to further address this concern. I do not consider that a specific reference to historic parks and gardens in Paragraph 8.2.2b or 8.1.1b is necessary, given the broad nature of these paragraphs. As regards issue (d), Policy HD9a provides additional protection for Wormleybury Park from unsympathetic development.

8.1.3 As regards issue (e), I consider that following PIC 090 to Policy HD18, this Policy adequately protects and enables the enhancement of trees, hedgerows and woodlands. As regards the last issue Policies BE24 to BE29 and their supporting text have been moved to Chapter 1 to form Policies SUS9 to SUS14 in the Second Deposit version of the Plan, which I consider meets the objector�s concerns.


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RECOMMENDATIONS

HD.1 Modify the Plan in accordance with PIC 090

Add the following text to Paragraph 8.1.2 after the fourth sentence: �Archaeological remains and registered historic parks and gardens fulfil a similar role.� and the addition of �to archaeological remains and to historic parks and gardens� in the middle of the fifth sentence.

Add the words �historic parks and gardens� to the second sentence of Paragraph 8.4.4.1 after �statutory listed buildings� and before �conservation areas�.

8.2 HD1 EFFECT OF DEVELOPMENT ON NATIONALLY IMPORTANT SITES AND MONUMENTS (FORMERLY BE1)

Objections - First Deposit 1001/33 Hertfordshire County Council 1011/2 & 13 English Heritage 1009/47 English Nature Objections - Second Deposit 1011/13 English Heritage Issues

(a) Adjustments in wording sought to improve application of policy


8.2.1 The majority of the amendments sought to Policy HD1 have been appropriately incorporated into the Policy at the Second Deposit stage. Policies BE1 to BE10 have been revised into Policies HD1 to HD9 in the Second Deposit version of the Plan. I consider that the Heritage and Design Chapter is the most appropriate location for these policies and no further amendment is necessary.

RECOMMENDATIONS

HD.2 No modification

8.3 HD2 REQUIREMENTS FOR EVALUATION OF HERITAGE ASSET (FORMERLY BE2)

Objections - First Deposit 1011/3 English Heritage 1001/34 Hertfordshire County Council


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Objections - Second Deposit 1011/14 English Heritage Issues

(a) Adjustments in wording sought to improve application of policy


8.3.1 The wording of the Policy and its heading have been amended at Second Deposit stage, which meets the objectors� initial concerns. However the additional wording to the Second Deposit Draft, suggested by English Nature, is unnecessary as the Second Deposit Draft already fully meets the requirements of PPG16.

RECOMMENDATIONS


8.4 HD3 PRESERVATION OF HERITAGE ASSET (FORMERLY BE3)

Objections - First Deposit 1001/37 Hertfordshire County Council 1011/4 English Heritage Objections - Second Deposit 1011/15 English Heritage 1000/107 Government Office for the East of England Issues (a) Adjustments in wording sought to improve application of policy.

(b) Policy goes further than advice in PPG16


8.4.1 Objectors� concerns over the First Deposit Plan have largely been incorporated into revised Policy HD3 in the Second Deposit version of the Plan. Furthermore the Council have suggested PIC 081, which partly meets objections to the Second Deposit by GOE and English Heritage. This has been further clarified by an additional change in the Council�s response to objections to this Chapter, which avoids repetitive wording. However the additional text in brackets following Part II of the Policy should be deleted as it is unnecessary. Given these changes the Policy meets objectors� concerns and correctly reflects PPG 16.


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RECOMMENDATIONS

HD.4 Modify the Plan in accordance with AIC 047.

8.5 HD4 DEMOLITION (FORMERLY BE4)

Objections - First Deposit 1001/36 Hertfordshire County Council 1011/5 English Heritage

Issues

(a) Policy omits reference to criteria on PPG 16.

(b) Plan omits specific policy on archaeological assessment and recording


8.5.1 The Second Deposit version of the Plan meets the objector�s concerns over issue (a) and fully accords with the guidance in PPG16. I do not consider that there is any necessity to have a Policy solely concerned with recording archaeological information and information on listed buildings as I consider that this is already appropriately addressed by Policies HD3 and HD4.

RECOMMENDATIONS


8.6 HD5 ALTERATIONS AND EXTENSIONS (FORMERLY BE6)

Objections - Second Deposit 1011/16 English Heritage 1000/94 Government Office for the East of England Issues

(a) Policy should be strengthened.

(b) Policy should be reworded to give greater certainty


8.6.1 The Policy has been revised both at Second Deposit and by PIC 082 to meet the concerns of both GOE and English Heritage. The Council have suggested a further change in their response to objections to this Chapter, which follows a positive rather than negative format. I consider that these changes


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provide a concise, criteria-based policy that provides the necessary degree of protection for listed buildings.

RECOMMENDATIONS

HD.6 Modify the Plan in accordance with AIC048

8.7 HD6 DEVELOPMENT WITHIN THE CURTILAGE AND / OR SETTING OF LISTED BUILDINGS (FORMERLY BE7)


(a) Revise policy to be more positive and criteria-based


8.7.1 The Council have proposed in PIC 083 that Policies HD6 and HD7 should be amalgamated, which meets the concerns of GOE. The proposed Policy has been further amended in the Council�s response to objections to this Chapter to address the concerns of English Nature regarding the strength of the Policy. I find that it avoids repetition to amalgamate these policies and given the further suggested changes the Policy provides adequate protection for listed buildings.

RECOMMENDATIONS


8.8 HD7 CHANGES OF USE (FORMERLY BE8)

Objections - Second Deposit 1000/101 Government Office for the East of England 1011/17 English Heritage

Issues

(a) Revise policy to be more positive.

(b) Amended policy is less effective than the original


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8.8.1 For the reasons I have set out in my consideration of objections to Policy HD6 above, Policy HD7 should be deleted.

RECOMMENDATIONS

HD.8 Modify the Plan by deleting Policy HD7.

8.9 HD8 ENABLING DEVELOPMENT (FORMERLY BE9)


(a) Policy lacks clarity


8.9.1 The Council have agreed to the incorporation of English Heritage�s suggested modifications to the Policy in its response to objections to this Chapter. I consider that these changes clarify the Policy so that it is no longer contradictory.

RECOMMENDATIONS


8.10 HD9 CONDITION OF BUILDINGS (FORMERLY BE10)


1001/51 Hertfordshire County Council Issues

(a) Policy lacks clarity


8.10.1 The objection which raised this issue has been addressed under Policy HD8 and I refer to my recommendations concerning this Policy. The original objection was to Policy BE9, which has subsequently been rewritten as Policy HD8 in the Second Deposit version of the Plan. I consider that the amended version of Policy HD8 meets the objector�s concerns.


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RECOMMENDATIONS


8.11 HD10 NEW BUILDINGS AND CHANGES OF USE OF EXISTING BUILDINGS IN CONSERVATION AREAS (FORMERLY BE11)

Objections - First Deposit 1011/6 English Heritage Objections - Second Deposit

1011/20 English Heritage 1000/123 Government Office for the East of England Issues

(a) Improvements to application of the policy


8.11.1 Second Deposit changes to the Plan meet English Heritage�s objections to the First Deposit Policy. AIC052, incorporating PIC084, further amends the Policy, which addresses GOE�s concerns over the Policy according with national policy guidance on conservation areas.

8.11.2 Whilst the content of conservation area appraisals is not in the remit of my report, as the Council have produced some form of appraisal for its conservation areas it would be helpful if these were referred to in the Plan�s supporting text. However it would be outside the Plan�s remit to require the preparation of these appraisals or prescribe their content.

RECOMMENDATIONS


8.12 HD11 DEMOLITION WITHIN CONSERVATION AREAS (FORMERLY BE12)

Objections - Second Deposit 1000/83 Government Office for the East of England 1011/19 English Heritage Issues

(a) Amendments sought to improve clarity of the policy


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8.12.1 I consider that the Policy in the Second Deposit version of the Plan is sufficiently clear and does not require further amendment. With regard to objectors� concerns over the preparation of the conservation area appraisals, I refer to my reasoning and conclusions on this matter under Policy HD10.

RECOMMENDATIONS


8.13 HD12 DEVELOPMENT ADJOINING, OR VISUALLY RELATED TO, CONSERVATION AREAS (FORMERLY BE15)


(a) Amendments sought to improve clarity of the policy


8.13.1 With regard to the preparation of conservation area appraisals, I refer to my reasoning and conclusion on this matter under Policy HD10.

RECOMMENDATIONS


8.14 HD13 DESIGN PRINCIPLES

Objections - Second Deposit 1000/84 & 124 Government Office for the East of England Issues

(a) Policy does not strictly fall within the scope of matters detailed in PPG12 and appears to delegate requirements to SPG


8.14.1 The Council have suggested PIC 086 to address GOE�s concerns over the role of SPG. I consider that this PIC correctly reflects the differing roles of Plan Policies and SPG. Furthermore paragraph 8.4.16c explains the role of SPG in the implementation of the design policies. I endorse PIC 087, which


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deletes supporting text that has been superseded.

RECOMMENDATIONS

HD.14 Modify the Plan in accordance with PICs 086 & 087

8.15 HD15 COMPREHENSIVE APPROACH TO URBAN REGENERATION (FORMERLY BE16)

Objections - Second Deposit 1000/125 Government Office for the East of England 1011/9 English Heritage Issues

(a) Amendments to improve coverage of policy.

(b) Policy appears over-onerous


8.15.1 In terms of GOE�s objection, that the Policy as written is unduly onerous for all types of urban development, I consider that PIC 088 has appropriately moderated the Policy. PIC 089 addresses English Heritage�s concerns by broadening the coverage of the Policy by including a reference to support conservation-led regeneration in paragraph 8.5.1.

RECOMMENDATIONS

HD.15 Modify the Plan in accordance with PICs 088 and 089.

8.16 HD17 RETENTION AND ENHANCEMENT OF LANDSCAPE FEATURES (FORMERLY BE19)

Objections - First Deposit 1001/58 Hertfordshire County Council Issues

(a) Amendments sought to improve clarity of policy and its approach


8.16.1 I consider that Hertfordshire County Council�s objection to this Policy has been met by amendments at the Second Deposit stage. Furthermore I consider that this Policy is located in the correct chapter.

RECOMMENDATIONS



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8.17 HD18 TREES, HEDGEROWS AND WOODLANDS (FORMERLY BE20)

Objections - First Deposit 1001/58 Hertfordshire County Council Objections - Second Deposit 1000/103 Government Office for the East of England Issues

(a) Amendments sought to improve clarity of policy and approach.

(b) Appears as a statement of intent and should be deleted


8.17.1 PIC 090 incorporates the changes sought by objectors to the Policy and its supporting text in terms of its clarity and approach. The changes improve the clarity and potential implementation of the Policy and I support them. The amended Policy is not a statement of intent. Furthermore, given its content, I consider that this Policy is located in the correct chapter.

RECOMMENDATIONS


8.18 HD19 WATERSIDE GREEN CHAINS (FORMERLY BE21)

Objections - First Deposit 1009/51 English Nature 1001/53 Hertfordshire County Council Objections - Second Deposit 1104/01,10 15,21 The Spitalbrook Village Green Conservation Group 1000/104 Government Office for the East of England Issues

(a) Policy requires clarification in relation to landscape character.

(b) Should be borough-wide policy.

(c) Policy is too weak in practice.

(d) Significant amendments sought to improve clarity and accuracy of policy.


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8.18.1 Changes at the Second Deposit stage and Pre-Inquiry revisions to the Policy have satisfactorily addressed the concerns of GOE about the Policy�s wording amounting to a statement of intent. English Nature�s concerns are mostly addressed by the Second Deposit version of the Policy, but given its content, I consider that the Policy is located in the correct chapter.

8.18.2 With regard to Spitalbrook Village Green Conservation Group�s objection, I endorse the Council�s decision to include land at the rear of Meadway next to the New River within the green chain. This pleasant informal grassland area forms an important link in the chain of open space alongside the river. It does not link to the green belt and is not part of any area of conservation value in the normal sense but the form of protection proposed is entirely appropriate. I consider it would enable the Council to resist built development and meet the residents� objection in full.

RECOMMENDATIONS

HD.18 Modify the Plan in accordance with PIC 091 & AIC 055

8.19 HD20 WATER COURSES IN URBAN AREAS (FORMERLY BE22)

Objections - First Deposit 1008/20 Environment Agency 1009/53 English Nature 1000/5 & 63 Government Office for the East of England 1104/6 The Spitalbrook Village Green Conservation Group Objections - Second Deposit 1104/17 The Spitalbrook Village Green Conservation Group 1000/91 Government Office for the East of England Issues

(a) Policy should refer to hedgerows and woodlands.

(b) Policy needs to be more positive and criteria-based.

(c) Elements of policy are a statement of intent and contrary to PPG12.

(d) No need for this policy except in emergency situations


18.19.1 AIC 056 to the Policy meets the objections of GOE by providing a positive criteria based approach to assessing development proposals with a potential impact on such features of the urban environment. The objection from English Nature, concerning trees and hedgerows, has been


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addressed under Policy HD18.

18.19.2 As regards the Environment Agency�s objection, whilst I have some sympathy for their concerns, I consider that its suggested replacement Policy would amount to a statement of intent, which would not be acceptable. The amended Policy strongly resists culverting and is in that respect in accordance with national planning policy. However I can see no good reason why this Policy should apply solely to urban areas and so I consider that the Policy�s title should be amended to address this concern.

RECOMMENDATIONS


8.20 HD21 PROTECTION OF OPEN SPACES NOT INCLUDED WITHIN THE HIERARCHY OF OPEN SPACE (FORMERLY BE23)

Objections - First Deposit 1000/64 Government Office for the East of England 1104/5 & 7 The Spitalbrook Village Green Conservation Group 1009/54 & 56 English Nature 1001/54 Hertfordshire County Council Objections - Second Deposit 1104/16 1104/18

The Spitalbrook Village Green Conservation Group

1000/108 Government Office for the East of England Issues

(a) Elements of policy are a statement of intent and contrary to PPG12.

(b) Reword policy, text and proposals map to include other watercourses.

(c) Policy lacks clarity in its application and is too subjective.

(d) Policy gives insufficient protection to New River.

(e) Policy needs reference to areas of wildlife importance.

(f) Policy is contrary to wider environmental objectives in the Plan


8.20.1 GOE concerns over the Policy�s wording relate to HD19/BE21. Similarly English Nature�s objection ref 1009/054/0 relates to Policy HD19/BE21. I have addressed both objectors� concerns in my reasoning on objections to Policy HD19. English Nature�s other objection does refer to this Policy and I consider that its concerns are addressed by the Second Deposit version of the Policy. Given the very specific nature of the Policy I do not consider that


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it is necessary to make additional reference to landscape character appraisal as suggested by Hertfordshire County Council.

RECOMMENDATIONS


8.21 HD22 COMMUNITY SAFETY (FORMERLY BE30)


(a) Reword policy to be more positive or criteria-based


8.21.1 I consider AIC 094 has met the objector�s concerns that the policy should be worded in a positive manner, rather than as statements of intent.

RECOMMENDATIONS


8.22 HD23 ACCESS FOR THE DISABLED (FORMERLY BE31)

Objections - First Deposit 711/2 Mr F. Scott Issues

(a) Policy should be extended to cover pavement kerbing


8.22.1 I consider that, in so far as the kerbing of pavements, as part of new development, is a matter of planning control, this is addressed by the broad remit of the Policy. However where the kerbing of pavements relates to the maintenance and improvement of existing public roads and pavements, the Plan has no remit to address this matter. I do not consider therefore that the Policy requires further amendment.

RECOMMENDATIONS



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8.23 HD24 TELECOMMUNICATIONS (FORMERLY BE32)

Objections - First Deposit 1101/51 CPRE - The Hertfordshire Society 1000/75 Government Office for the East of England 1102/70 Goff's Oak Community Association 1254/1, 3-4 Crown Castle International Objections - Second Deposit 1000/126 Government Office for the East of England 1360/1 T-Mobile (UK) Ltd Issues

(a) Text in para 8.12a should refer to requirements on other broadcasters.

(b) Policy is too restrictive and not enforceable and fails to provide adequate planning framework.

(c) Policy is too weak in practice.

(d) Policy requires simplification


8.23.1 In terms of GOE�s objections I consider that PIC 095 meets the objection made to the Second Deposit Plan but does not address those made at the first deposit stage. I consider that GOE�s concerns over the use of the word �technological� are valid and this word should be deleted from criterion (c) of paragraph I, which will also be addressed by my later recommendations. As regards the inclusion of paragraph V, I consider that this matter can be adequately dealt with by the use of conditions and there would be no necessity to use planning obligations to ensure the removal of surplus or obsolete equipment from a site.

8.23.2 Turning to the concerns of Crown Castle International, whilst I consider that the Policy could helpfully be abbreviated in a number of instances, and I have recommended the amalgamation of several criteria, I find that it provides a sound, criteria-based approach to the identification of sites for telecommunications development. Information on mast location is admittedly useful, but there is no requirement in PPG8 for the Plan to identify current telecommunications sites, or to identify sites for future development. I acknowledge the importance of mast sharing but consider this matter is adequately addressed by the Policy and the objectors� suggested amendments are unnecessary. Furthermore the amendments suggested by the objector to the supporting text are not in this instance helpful as I consider that it strikes the correct balance between the protection of the environment, public health and amenity with the needs of telecommunications operators. As regards Crown Castle�s remaining concern, whilst the conditions of a telecommunications operator�s licence do require that surplus or obsolete equipment should be removed, I do not


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consider that this provides the necessary safeguards that a condition of planning permission could provide, particularly as regards the Council�s ability to take enforcement action. Therefore I find that this criterion is reasonable.

8.23.3 In terms of CPRE�s concerns I do not consider that the Policy is too weak. I have already stated that PPG8 requires a balanced approach the sitting of telecommunications facilities and structures in Plans. I consider that following my suggested amendments the Policy achieves this requirement.

8.23.4 I share some of T Mobile�s concerns about the overly repetitive nature of some parts of the Policy. In terms of Part I, I consider that criteria b-d could be successfully combined, as they all effectively cover the same broad issue. However, I consider criterion (e) should remain as it addresses a slightly different issue. Similarly criterion (f) is adequately worded and requires no amendment. In terms of Paragraph II of the Policy, I disagree that all the criteria could be amalgamated into one paragraph as this would significantly weaken this part of the Policy as each criteria addresses a distinct point. There has been no objection to the content of Paragraphs (IV) and (V) by T Mobile. Paragraphs III and VI have been deleted as result of PIC 095.

RECOMMENDATIONS


Delete criteria b,c and d of Paragraph I and replace with the following text:

�WHETHER THE APPLICANT HAS DEMONSTRATED THAT THE FEASIBILITY OF SHARING TELECOMMUNICATIONS APPARATUS OR UTILISING OTHER BUILDINGS OR STRUCTURES HAS BEEN FULLY INVESTIGATED.�


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9. TRANSPORT


Objections - First Deposit 1001/12-17 Hertfordshire County Council 1016/9 Network Rail 1296/14 Tesco Stores Ltd 778/3 & 6 Mr G. N. Nixon 480/1 Mr A. Hoines 562/6 The Wormley Society Objections - Second Deposit 1000/140, 133 Government Office for the East of England 495/1 & 6 Mr G. Knight 471/19 Mrs I. Beard Issues

(a) Car Parking standards in line with PPG13 should be included in the Plan.

(b) Plan lacks specific policy for powered two-wheelers.

(c) Plan lacks policy encouraging use of railway network for freight.

(d) Text should refer to updated version of PPG13.

(e) Objectives should contain more pragmatic approach to car parking provision, limitations of Lea Valley Green Route and Cycle Lanes.

(f) Plan should include the objective of promoting a new rail station at Turnford.

(g) Amendments sought to ensure consistency with Local Transport Plan.

(h) Objectives should include better facilities for cyclists.

(i) Plan should identify locations for rail/road to water interchanges


9.1.1 The paragraphs in the background section of the Chapter and the supporting text of the �local transport plans and �integrated packages�� sections have been amended at the second deposit stage to meet Hertfordshire County Council�s concerns over the wording of the Plan. PIC096 replaces �detr� with �central government� thus meeting GOE�s objection. As regards the County Council�s remaining concern, whilst I appreciate the argument that powered two wheel vehicles can be more sustainable than other powered road vehicles, I am not persuaded that provision for such vehicles substantially differs from other road vehicles to warrant a specific policy in the Plan. I concur with the Council�s view that this is a matter that can be best addressed by SPG.

9.1.2 As regards Hertfordshire County Council�s concerns over freight interchange facilities, # 9.2.4 (h) acknowledges the Lea Valley Area Plan�s recognition of


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the potential for freight to be transported by rail and water and it states that Plan�s commitment to seek such opportunities. However I have not seen any evidence to suggest that any such facilities are being proposed at present. Given the commitment in Policy TI to implementing the Lea Valley Area Plan, and the strong national policy support encouraging both the transportation of freight by rail, and rail transport in general, I do not consider it is necessary for the Plan to give greater prominence to freight interchange and the role of rail transport. I consider that this also addresses Railtrack�s concerns over the role of rail transport in the Borough.

9.1.3 I have addressed objections concerning the Council�s approach to Parking Standards, under Policy T10, which is a matter of concern for several objectors. As regards Mrs Beard�s objection, whilst there may be instances where the detailed design of cycle ways has been counterproductive, the promotion of cycling as a non polluting form of transport forms a key part of government transport policy. The Plan�s approach in supporting the provision of facilities for cyclists is absolutely correct. Whilst the provision of a train station in Turnford may provide many of the benefits highlighted by Mr Hoines, I have seen no additional evidence to suggest that this proposal is supported by relevant transport operators or authorities. The Local Plan can only safeguard land for transport infrastructure facilities from inappropriate development. Therefore it would not be reasonable for the Plan to safeguard land for this project.

9.1.4 As regards The Wormley Society�s objection, I am unable to address her concerns over the detailed provision of Bus Lanes as this matter falls outside the remit of this Land Use Plan. I consider that it is reasonable for the Plan to refer to the Lea Valley Green Route and other matters contained in the Lea Valley Area Plan as this provides useful background information for the Chapter.

9.1.5 The Lea Valley Area Plan is a separate document to the Local Plan. Whilst I appreciate the reasoning in Mr Knight�s first objection, changes to the Lea Valley Area Plan are outside the remit of my report. Furthermore the provision of facilities for cyclists is adequately addressed by Policy T9A. Similarly I do not consider that paragraph 9.2.4 (d) would make a suitable place for Mr Knight�s suggested insertion as this Paragraph largely sets out the Lea Valley Area Plan�s Policies for cyclists. Again I consider that Mr Knight�s concerns are largely addressed by Policy T9A.

RECOMMENDATIONS

T.1 Modify the Plan in accordance with PIC 096.

9.2 T1 LOCAL TRANSPORT PLAN

Objections - First Deposit 1001/18 Hertfordshire County Council


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(a) Amendments sought to ensure consistency with Local Transport Plan.

(b) Para 9.3.1.could be elevated to policy rather than text.

(c) Requirement for obligations is arbitrary and inconclusive


9.2.1 I consider that the Second Deposit Draft Plan has met Hertfordshire County Council�s concerns. Similarly I find that PIC097 meets the concerns of GOE regarding the Policies wording and should be made.

RECOMMENDATIONS

T.2 Modify the Plan in accordance with PIC 097

9.3 T2 PASSENGER TRANSPORT AND INTERCHANGE FACILITIES

Objections - First Deposit 1280/8 George Wimpey UK Ltd (formerly McLean Homes) 1301/16 Standard Life Investments 1001/19, 24 Hertfordshire County Council 1293/25 Colin Buchanan and Partners 149/1 Mr I. Hunter Objections - Second Deposit 1000/135 Government Office for the East of England 1004/1 Essex County Council Issues

(a) Policy should allocate a rail halt at Turnford.

(b) Policy should include reference to programmed rail improvements.

(c) Policy needs clarification as to when it will apply and be strengthened


9.3.1 The provision of a train station in Turnford may provide many of the benefits highlighted by Mr Hunter. However the Local Plan does not have the remit to promote the construction of rail stations or similar facilities, although it can safeguard land for their development. I have seen no additional evidence to suggest that this proposal is supported by relevant transport


167

operators or authorities. Therefore it would not be reasonable for the Plan to safeguard land for this project.

9.3.2 Whilst improvements to the WAGN line have been highlighted in a recent multi modal study, and Essex County Council are keen to progress these improvements as soon as possible, I do not consider it is necessary to make specific reference to these improvements in Policy T2 as there is nothing in the Policy that would restrict the implementation of these proposals, particularly as the London/South Midlands Multi-Modal Study does not recommend their implementation until 2017.

9.3.3 As regards objectors concerns over the Policy�s requirement for contributions to passenger transport infrastructure, I consider that it is necessary to amend the wording of the Policy�s second paragraph so that it complies more fully with the provisions of Circular 1/97. However I find the phrase �significant number of visitors� used in the Policy self explanatory. As regards GOE�s objection I consider that paragraph 9.3.1 provides a useful background to passenger transport in the Borough and it would serve no purpose to convert this sentence to a Policy.

RECOMMENDATIONS

T.3 Modify the Plan by inserting the phrase �SEEK TO� in the second line of the policy between �AND� and �USE�.

9.4 T3 TRANSPORT AND NEW DEVELOPMENT

Objections - First Deposit 1001/2,9 & 11 Hertfordshire County Council Objections - Second Deposit 471/17 Mrs I. Beard Issues

(a) Policy omits reference to powered two-wheelers and service vehicles.

(b) Policy conflicts with development allocations at Bury Green Farm and Greater Brookfield


9.4.1 Changes made at the Second Deposit address all of Hertfordshire County Council�s concerns over the Policy�s wording.

9.4.2 As regards Mrs Beard�s concerns, part II of the Policy refers to a �significant detrimental impact on road congestion and movement�. Given this I find that the Policy recognises that some degree of impact from development on traffic safety and flow may be inevitable. An assessment of this impact will be made when any planning application is being considered. While I have


168

some sympathy for the objector�s concerns about the transportation aspects of the proposal for a school at Bury Green Farm, Policy T3 itself sets out appropriate criteria for assessing new schemes.

RECOMMENDATIONS

T.4 No modification

9.5 T4 GREEN TRAVEL PLANS

Objections - First Deposit 1280/9 George Wimpey UK Ltd (formerly McLean Homes) 1301/17 Standard Life Investments 1001/1 1001/30

Hertfordshire County Council

1102/73 Goff's Oak Community Association Objections - Second Deposit 471/18 Mrs I. Beard Issues

(a) Policy appears in conflict with PPG13 and Structure Plan policy 25.

(b) Policy should exclude major residential development.

(c) Object in principle is unrealistic and unworkable


9.5.1 I find that all of Hertfordshire County Council�s concerns have been addressed by changes made at the Second Deposit stage for the Plan. In particular these changes resolve the discrepancies between the Plan, PPG13 and the County Structure Plan. PPG 13 supports the use of green travel plans for all types of development.

9.5.2 It is quite clear that the location and design of residential development can have a significant impact on travel patterns. Whilst requiring a difference in approach to travel plans for other forms of development, such plans have been produced and the Council point to the redevelopment of the Merck, Sharpe and Dhome complex as an example. Therefore I can see no good reason why the Plan should not require green travel plans for residential development. As regards the concerns of George Wimpey UK Ltd, following my later recommendations concerning Policy T10, the Plan should be changed to avoid minimum parking standards, and so the utility of green travel plans would not be undermined

RECOMMENDATIONS

T.5 No modification


169

9.6 T5 DEVELOPMENT STANDARDS


(a) Policy is too inflexible


9.6.1 Both the Council and GOE are in agreement that the Policy as worded in the Second Deposit Draft is not sufficiently flexible. The replacement Policy set out in PIC099, and the amendment to its supporting text in PIC098, allows for considerably more flexibility and more fully reflects current guidance.

RECOMMENDATION

T.6 Modify the Plan in accordance with PIC098 and PIC099.

9.7 T6 RURAL ROADS

Objections - Second Deposit 1009/88, 113 English Nature 1000/129 Government Office for the East of England Issues

(a) Policy should include reference to rural greenways.

(b) Policy as worded could be a barrier to farm diversification projects


9.7.1 English Nature is concerned that a reference to the development of a network of Greenways should be included in the Policy. The Council in its response to objections to this Chapter has suggested an additional sentence at the end of paragraph 9.4.6, which meets the objector�s concerns.

9.7.2 As regards GOE�s concerns, it is clear that the encouragement of farm diversification is clearly supported by PPS7. However this must be balanced with the need to maintain road safety and the protection of amenity. I find that the wording of Paragraph (b) of the Policy may be interpreted in a way that could restrict opportunities for farm diversification and would not therefore reflect this balance. Limited changes to the Paragraph�s wording would address this.


170

RECOMMENDATIONS

T.7 Modify the Plan in accordance with AIC058.

Delete �EITHER TO THE RURAL CHARACTER OF THE ROAD OR THE AMENITIES OF NEARBY RESIDENTIAL PROPERTIES� from Paragraph b of the Policy.

9.8 T7 HOME ZONES

Objections - Second Deposit 1009/89 1009/114

English Nature

Issues

(a) Policy could be extended to include concept of rural greenways


9.8.1 Home Zones serve a very different purpose to that of greenways. Therefore I do not consider that Policy T7 would be an appropriate location for a reference to Greenways. Following my recommendations the supporting text to Policy T6 now refers to the Greenways network, which I find to be a more appropriate location.

RECOMMENDATIONS

T.8 No modification

9.9 LOCAL HIGHWAY NETWORK - INTRODUCTORY TEXT

Objections - First Deposit 1001/5-7 Hertfordshire County Council 1000/77 Government Office for the East of England 495/2 Mr G. Knight Objections - Second Deposit 471/21 Mrs I. Beard 495/9 Mr G. Knight 471/1 Mrs I. Beard 1000/136 Government Office for the East of England


171

Issues

(a) Plan does not recognise added congestion on A10 generated by Park Plaza and Bury Green school allocation.

(b) Revisions to wording to be consistent with Local Transport Plan.

(c) Plan omits provision for the needs of cyclists on the A10.

(d) Plan should contain reference to restrictions on delivery times to employment areas


9.9.1 The increased volume of traffic on the A10/M25 caused by the development of Park Plaza has been considered in the previous Local Plan and when planning permission for the proposal was granted. I have considered the proposed new school at Bury Green Farm, for which permission has also been granted, in section 4.13.

9.9.2 Changes to the text at Second Deposit stage adequately address Hertfordshire County Council�s concerns over the Plan�s consistency with the Local Transport Plan. Similarly these changes address GOE�s concerns over the wording of the First Deposit Draft. However I can see no reason why there is any necessity to amend Paragraph 9.5.7 of the Second Deposit as it is obvious what type of traffic the sentence refers to.

9.9.3 In terms of Mr Knight�s objection, given the contents of Policy T9A, which addresses the needs of cyclist in all new development, I do not consider that there is any need for an explicit reference to the needs of cyclist in this paragraph.

9.9.4 Whilst I consider that there may be some merit in staggering freight traffic movements to and from employment areas, I consider that this is a matter more appropriately addressed in relation to individual planning applications.

RECOMMENDATIONS

T.9 No modification

9.10 T8 GREATER BROOKFIELD AREA

Objections - First Deposit 1002/16 Hertfordshire County Council (Property) 495/3 Mr G. Knight 1301/6 Standard Life Investments Objections - Second Deposit 1366/18 Bayfordbury Estates


172

Issues

(a) Policy is too prescriptive and should allow for more flexible, proportional solutions.

(b) Policy requires reference to road link from Halfhide Lane to Turnford Interchange


9.10.1 Given my comments in Chapter 6, I am aware of the significant transport implications for any future development of Greater Brookfield. Many of these problems, particularly with respect to public transport, relate to the physical planning of the area, so I think it would be appropriate for the Council to try and solve these by means of a comprehensive traffic solution developed through a masterplan. In terms of both Hertfordshire County Council�s and Standard Life Investment�s specific concerns I find that there is nothing in Policy T8 and Paragraph 9.5.8 in this Chapter and Policy BFC7 in Chapter 6 that prohibits development in Greater Brookfield, provided that it does not inhibit a comprehensive solution to these problems. Furthermore for the Policy to include the phrase �all required changes will be proportionate to the actual problems experienced� would be a misinterpretation of national policy on the reasonable use of conditions and obligations. These matters are both clearly addressed in Circulars 11/95 and 1/97 respectively and so it would be inappropriate for the Policy to repeat this advice. The wording of the Second Deposit Draft Policy does not therefore need to be changed in respect of these objections.

9.10.2 In terms of Mr Knight�s concerns I have discussed the principle of allowing a relatively large development in this location in my response to objections under Chapter 6. Whilst there are certainly implications for sustainable transport for this development, I conclude that the benefits of the development outweigh these impacts. Given this I find that it is appropriate for the Plan to address the traffic management and road safety implications for the development of Greater Brookfield.

9.10.3 As the Second Deposit version of Paragraph 9.5.8 includes a reference to assessment of a link road between the Turnford Interchange to Halfhide Lane as part of any masterplan, I consider that this meets objectors� concerns on this issue.

RECOMMENDATIONS

T.10 No modification

9.11 T9 PEDESTRIAN NEEDS


711/7 Mr F. Scott


173


(a) Lack of reference to wheelchair users.

(b) Policy needs greater reference to land use matters


9.11.1 Mr Scott�s concern about the needs of wheelchair users has been met by the amendment to the Policy�s supporting text suggested in the Council�s response to objections to this Chapter.

9.11.2 As regards GOE�s concern over the Policy�s lack of focus on land use planning matters, I find that this has been adequately addressed by PIC 100.

RECOMMENDATIONS

T.11 Modify the Plan in accordance with PIC100 & AIC059

9.12 T9 (A) CYCLING PROVISION

Objections - First Deposit 1001/8 Hertfordshire County Council 480/2 Mr A. Hoines 1012/1 East of England Tourist Board 0495/1-4, 6, 9-12 Mr G. Knight Objections - Second Deposit 471/22 Mrs I. Beard 1016/15 Network Rail Issues

(a) Plan should address more detailed aspects of cycle provision in the Borough

(b) Policy does not promote an effective cycle strategy as emphasises 'safe routes' and is not sufficiently comprehensive in approach.

(c) Plan should not promote additional cycling.


9.12.1 In terms of detail I consider that Hertfordshire County Council�s and the East of England Tourist Board�s concerns have been met by changes made at the Plan�s Second Deposit Stage. Network Rail�s objection should not be met as it is unreasonable for the Plan to impose a blanket embargo on cycle crossings of railway lines, where this can be done safely. In terms of Mr


174

Knight�s and Mr Hoine�s objections I consider that many of these concerns, whilst broadly reasonable, cannot be dealt with by a land use plan. The Council has proposed PICs 101 and 102 to the Chapter�s introductory paragraphs to help meet some of these concerns where they relate to the land use implications of the Lea Valley Area Plan but PIC 104 adds nothing significant to the Second Deposit Policy and is repetitive of advice contained in the supporting text. However in terms of their concerns over the operation, design and efficiency of cycle routes, including safe routes to schools, and the integration of cycling with rail services I find that the County Council�s Local Transport Plan would be a more appropriate vehicle to address these issues.

9.12.2 In terms of Mrs Beard�s concerns I refer to my comments at Paragraph 9.1.3 of my report. For the reasons given there I consider that the Council is quite justified in supporting cycling as a sustainable means of transport.

RECOMMENDATIONS

T.12 Modify the Plan in accordance with PICs 103 and 104.

9.13 T10 CAR PARKING

Objections - First Deposit 337/1 Mr & Mrs D. Mort 1001/25 Hertfordshire County Council 1252/01 Taywood Homes 778/4-6 G. N. Nixon 254/9 R. Barnes 1001/10 Hertfordshire County Council 1296/15 Tesco Stores Ltd 1102/92 Goff's Oak Community Association 872/3 Mr A. LeBaigue 1102/78 Goff's Oak Community Association 1104/8 The Spitalbrook Village Green Conservation Group 1000/130 Government Office for the East of England Objections - Second Deposit 471/24 Mrs I. Beard 1016/16 Network Rail Issues

(a) Object to principle of reducing car parking requirements.

(b) Object to definition of accessibility corridor.

(c) Policy should recognise the issues around car parking at rail stations.

(d) Policy, parking standards and para 9.6.8 are not in conformity with PPG13


175

9.13.1 A number of objectors, both to this Policy and the wider chapter, have raised concerns over the use of maximum parking standards and in particular consider that these are unrealistic given the lack of public transport provision and the necessity of the private car in modern life. Reducing the need to travel is one of the key objectives for planning and transport policy set out in PPG13. The PPG goes on to state that the availability of car parking has a major influence on the transport people choose for their journeys. Maximum standards should therefore be used as part of a package of measures to support sustainable transport and reduce reliance on the private car. The parking policies of the Plan must follow this guidance.

9.13.2 Similarly a number of objectors, both to this policy and the wider chapter, have raised concerns that the proposed parking standards are more rigorous than those set out in PPG13. Again PPG13, at Paragraph 53 clearly states that it is open for Council�s to apply more rigorous standards than PPG13 where appropriate. The Council have adopted the Countywide parking standards. Whilst more detailed than the standards set out in PPG 13, they do not differ radically in the maximum levels of provision required. The County wide approach to these standards also complies with the need for a consistent approach to parking standards required by the PPG and in this respect I find the Plan�s approach acceptable.

9.13.3 In terms of the broad concept I consider that the use of an accessibility corridor is supported by PPG13, as levels of parking provision significantly below maximum standards may well be acceptable in town centres or other locations well served by public transport. It is helpful for developers that this is identified, but it needs to be kept up to date. I have accepted therefore that the corridor should be shown in SPG.

9.13.4 In terms of the provision of new car parks the Plan does not allocate any additional land for parking, nor have the Council received any proposals from landowners for new car parks. Whilst this is a slightly different issue from maximum parking standard for new development, I have seen no convincing evidence of an identified need and find that there is no necessity for a specific policy to address this issue. Furthermore I find that the concerns of Network Rail are unfounded as Section 9.7 clearly states that parking requirements for Rail and Bus stations will be decided on the individual merits of each case.

9.13.5 However I consider that the Policy and its supporting text are not clear, as on several instances they present a muddled approach to parking standards that could be used to impose minimum parking standards on development. Both PPG13 and PPG3 are clear that in many instances parking provision significantly below maximum levels will be acceptable in a variety of sustainable locations and that the rigid application of these standards should not be used to inhibit otherwise acceptable development. Whilst I welcome the introduction of these maximum standards into the Plan under PIC 108, Paragraphs 9.6.6 and 9.6.8 of the Policy�s supporting text still imply that whilst standards will be applied as maximums, unless particular circumstances prevail they will also be considered as minimum standards. This is clearly contrary to national policy guidance. Similarly the wording of Part II of the policy remains very negative and implies that parking standards will only be relaxed in exceptional circumstances; again, this


176

implies the imposition of minimum standards. This approach is also carried over to Section 9.7 in relation to residential development.

RECOMMENDATIONS

T.13 Modify the Plan in accordance with PICs 106, 107 & 108, in so far as they are not affected by my other recommendations

Delete paragraph 9.6.6 and reword follows:

�Car parking standards are set out in Section 9.7 and in Supplementary Planning Guidance to the Borough Local Plan Second Review (SPG). These are maximum standards. Provision of car parking space at new developments should not exceed these maximum levels. Provision below this level will be acceptable in locations where it can be shown that there is a reduced need for private car journeys. These may include locations well served by public transport or within easy walking distance of services or facilities, such as Town Centres, interchanges, along the Green Route or the defined accessibility corridor. The Council may require the developer to take additional measures to ensure that this reduction does not place unreasonable pressure on street parking.�

Delete Paragraph 9.6.8

Delete the phrase �AND WILL BE EXPECTED TO BE MET ON SITE� from part I of Policy T10

Delete Part II and replace with the following text;

�A REDUCED LEVEL OF PARKING PROVISION IS LIKELY TO BE ACCEPTABLE WHERE;

THE DEVELOPMENT IS LOCATED WITHIN THE DEFINED TOWN CENTRES, ON THE GREEN ROUTE OR ACCESSIBILITY CORRIDOR OR;

THE DEVELOPMENT IS LOCATED CLOSE TO FACILITIES, SERVICES AND PASSENGER TRANSPORT LINKS

WHERE APPROPRIATE THESE REDUCED PARKING LEVELS WILL BE SUPPORTED BY A GREEN TRAVEL PLAN.�

Delete �The Council will consider up to 60% of the maximum 1.5 dwelling parking guidance in town centres and 75% within the accessibility corridor� from Section 9.7 under use class C3.�


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10. IMPLEMENTATION

10.1 IMP2 DEVELOPER REQUIREMENTS

Objections - First Deposit 1001/4, 20-21 Hertfordshire County Council 1293/26-27 Colin Buchanan and Partners Objections - Second Deposit 1000/131 Government Office for the East of England Issues

(a) Para 10.3.4 is not in conformity with PPG13 in respect of car parking.

(b) List of issues with regard to environmental enhancement is too onerous.

(c) Policy is ambiguous and lacks clarity


10.1.1 The objection from GOE has been met by the proposed deletion of the policy. The Council has put forward other changes to general text which meet the thrust of the remaining objections.

RECOMMENDATIONS

I.1 Modify the Plan in accordance with PICs 109 & 110 and AIC061

10.2 IMP3 SUPPLEMENTARY PLANNING GUIDANCE


(a) Not considered a land use issue - should be deleted from Plan.


(a) This objection has been met by the proposed deletion of the policy.

RECOMMENDATIONS

I.2 Modify the Plan in accordance with PIC 112


178

10.3 PROPOSALS MAP - OBJECTIONS TO PLAN IMPLEMENTATION

Objections - First Deposit 1001/57 Hertfordshire County Council 1254/2 Crown Castle International 1258/6 Hubert C. Leach 1264/8 Higgins Homes Ltd 1277/10 Landmatch Ltd (formerly Lafarge Aggregates) 1296/13 Tesco Stores Ltd 1007/4 East Hertfordshire District Council 1101/45 CPRE - The Hertfordshire Society 1264/1,2,9,18,28 Higgins Homes Ltd 1277/9 & 12 Landmatch Ltd (formerly Lafarge Aggregates 1006/1 Epping Forest District Council Objections - Second Deposit 1104/1, 19-21 The Spitalbrook Village Green Conservation Group 1264/45 Higgins Homes Ltd 1009/79 English Nature 1000/138 Government Office for the East of England Issues

(a) Corrections and minor alterations required.

(b) Omission of large telecommunication installations.

(c) Omission of floodplain as recommended by PPG25.

(d) Omission of candidate SAC and SPA wildlife boundaries.

(e) Need to reconcile differences in Landscape character area boundaries.

(f) Need to reconcile differences in Essex Road Key Site area boundaries with Map.

(g) Notation in relation to New River Trading estate requires clarification.

(h) Notation in relation to Land rear of the Meadway requires clarification.

(i) Alterations in relation to specific Green Belt sites


(b) The Council has agreed to make a number of corrections to the Proposals Map and notations when it is finalised, as set out in its document C258. These include the indicative floodplain, identified from the most up to date information from the EA, and SAC and SPA wildlife boundaries.

(c) There are no large telecommunications structures in Broxbourne and I consider it impractical to identify other masts on the Proposals Map.

(d) The County Council has identified 8 landscape character areas that will be identified on the Map.

(e) The Council has proposed a new boundary for the employment area


179

following its decision to grant outline planning permission for a scheme, subject to a Section 106 agreement (Doc C258, Appendix 1).

RECOMMENDATIONS

PM.1 Modify the Plan in accordance with PICs 120-126 and AIC063, and other changes as set out in Document C258, including Appendix 1.

10.4 PROPOSALS MAP AND INSET PLANS - WILDLIFE SITES

Objections - First Deposit 1100/12 Herts & Middlesex Wildlife Trust 1102/81 Goff's Oak Community Association Issues

(a) Criteria for definition of sites queried


10.4.1 The description of sites and criteria for definition are set by the Hertfordshire Biological records Centre, English Nature and the Herts and Middlesex Wildlife Trust. Although some survey information is out of date, in general the areas have been chosen on a sound basis and have identified ecological value.

RECOMMENDATIONS

PM.2 No modification

10.5 SCHEDULE OF LISTED BUILDINGS AND AREAS OF ARCHAEOLOGICAL SIGNIFICANCE

Objections - First Deposit 1011/8 English Heritage 1102/82-83 Goff's Oak Community Association Issues

(f) Minor amendments/omissions.


(g) The Council has agreed to insert some extra text to meet the objection from English Heritage. Objections concerning Poyndon farm are satisfied by PICs


180

119 and 122. Cheshunt Common is not a scheduled area of Archaeological Interest.

RECOMMENDATIONS

PM.3 Modify the Plan in accordance with PICs119 & 122 and AIC064

10.6 GLOSSARY


1009/84-85 English Nature 1001/22-23, 52 Hertfordshire County Council Issues

(a) Amendments to improve definitions in the glossary


(b) The Council has agreed to a number of changes to meet these objections, which I endorse.

RECOMMENDATIONS

G.1 Modify the plan in accordance with PICs 114-117 and AIC065


1

APPENDICES

Page

1 List of Core Documents 2

2 Housing RTS Note 10

3 Appearances 18

4 Objectors not listed in main report 24


2

1 LIST OF CORE DOCUMENTS

DISTRICT PLAN AND SUPPORTING DOCUMENTS Document Number

Title of Document Author Date

CD/DP/10 Borough of Broxbourne Local Plan Review 1994 (including one proposals map)

Borough of Broxbourne

December 1994

CD/DP/20 Borough of Broxbourne Local Plan Second Review 2001-2011 Key Issue Report


March 2000

CD/DP/30 Borough of Broxbourne Local Plan Second Review First Deposit 2001-2001 (including one proposals map and 37 inset maps)


April 2001

CD/DP/40 Borough of Broxbourne Local Plan Second Review Second Deposit 2001-2011 (including 64 inset maps and 4 appendices)


March 2003

CD/DP/50 Borough of Broxbourne Local Plan Second Review Second Deposit 2001-2011-Background Paper Environmental Appraisal


April 2001

CD/DP/60 Borough of Broxbourne Local Plan Second Review Second Deposit 2001-2011-Background Paper Summary of Alterations/ Representations


March 2003

CD/DP/70 Borough of Broxbourne Local Plan Second Review Second Deposit 2001-2011 Pre-Inquiry Changes


December 2003

CD/DP/80 Borough of Broxbourne Local Plan Second Review Second Deposit 2001-2011-Background Paper Urban Area Appraisal


January 2003

CD/DP/90 Borough of Broxbourne Local Plan Second Review Second Deposit 2001-2011-Background Paper Habitat Survey for Broxbourne Borough


April 2001

CD/DP/100 Borough of Broxbourne Local Plan Second Review Second Deposit 2001-2011-Background Paper Assessment of Retail Requirements 1999-2006


January 1999


3

CD/DP/110 Borough of Broxbourne

Borough Wide Supplementary Planning Guidance Consultation Draft


February 2004

CD/DP/120 Broxbourne Borough Council Adopted District Plan (Adopted August 1983) Written Statement (including 2 proposals maps)

Broxbourne Borough Council

January 1984

CD/DP/130 Broxbourne Borough Council Broxbourne Local Plan Review Report of the Public Inquiry into Objections and Other Representations January � February 1993


1993

CD/DP/140 Broxbourne Local Plan Review Opening Remarks on behalf of Broxbourne Borough Council commencing Tuesday 9th March 2004


March 2004

CD/DP/150 A3 map in colour showing land promoted for development in the Borough of Broxbourne during the Local Plan Second Review 2001-2011


January 2004

CD/DP/160

Borough of Broxbourne Land at Canada Fields, Turnford Development Brief Adopted July 2001


July 2001

CD/DP/170 Amendments to Paragraphs 3.51 - 3.5 4 (West Cheshunt)


22nd April 2004

CD/DP/180 Conservation Areas Broxbourne


CD/DP/190 Conservation Areas Churchgate


CD/DP/200 Conservation Areas Hoddesdon


CD/DP/210 Conservation Areas The New River


CD/DP/220 Conservation Areas Wormley


CD/DP/230 Churchyards of Broxbourne St Augustine�s Church Broxbourne


CD/DP/240 Churchyards of Broxbourne St Catherine and St Paul�s Church Hoddesdon


CD/DP/250 Churchyards of Broxbourne St Laurence�s Church Wormley


CD/DP/260 Churchyards of Broxbourne St Mary�s Church Cheshunt



4

CD/DP/270 Grade I Listed Buildings in Broxbourne


CD/DP/280 Grade II* Listed Buildings in Broxbourne


CD/DP/290 Scheduled Monuments of Broxbourne General Information


CD/DP/300 Scheduled Monuments of Broxbourne Half Hell Wood


CD/DP/310 Scheduled Monuments of Broxbourne Hoddesdon Park Wood


CD/DP/320 Scheduled Monuments of Broxbourne Moat Manor House


CD/DP/330 Scheduled Monuments of Broxbourne Motte Castle


CD/DP/340 Scheduled Monuments of Broxbourne Perrior�s Manor


CD/DP/350 Scheduled Monuments of Broxbourne Queen Eleanor Cross


CD/DP/360

Committee Report - Essex Road Key Site


CD/DP/370 Committee Report � M & S Extension


June 2004

CD/DP/380 Committee Report � St Marys School - Revisions to Policy H6


May 2004

CD/DP/390 St Mary's High School Churchgate, Cheshunt Development Brief - adopted 2nd September 2003.


September 2003

CD/DP/400 Committee Report - Cheshunt Reservoir South


October 2004

CD/DP/410 Borough-Wide Supplementary Planning Guidance


Adopted August 2004

CD/DP/420 Borough-Wide Supplementary Planning Guidance Statement Of Consultation


CD/DP/430 Schedule Of Changes Proposed By The Council In Response To Representations.


October 2004

CD/DP/440 Planning and Licensing Committee � 5 October 2004, Minutes


October 2004


5

TOPIC PAPERS CD/TP/10 Borough of Broxbourne Local Plan

Second Review 2001-2011 Green Belt Topic Paper


December 2003

CD/TP/20 Borough of Broxbourne Local Plan Second Review 2001-2011 West of Cheshunt Topic Paper


December 2003

CD/TP/30 Borough of Broxbourne Local Plan Second Review 2001-2011 Housing Topic Paper


January 2004

CD/TP/40 Borough of Broxbourne Local Plan Second Review 2001-2011 Affordable Housing Topic Paper


January 2004

CD/TP/50 Borough of Broxbourne - Proof of Evidence to the Housing Round Table


March 2004

CD/TP/60 Borough of Broxbourne Local Plan Second Review 2001-2011 Housing Topic Paper - Update


August 2004

STRUCTURE PLAN CD/SP/10 Hertfordshire Structure Plan Review

1991-2011 Hertfordshire County Council

April 1998

CD/SP/20 Hertfordshire Structure Plan Alterations 2001-2016 Deposit Draft Version February 2003


February 2003

NATIONAL POLICY DOCUMENTS CD/NP/10 Planning Policy Guidance Note

No 1 � General Policy and PrinciplesDETR February 1997

CD/NP/20 Planning Policy Guidance Note No 2 Green Belts

DETR January 1995

CD/NP/30 Planning Policy Guidance Note No 3 � Housing

DETR March 2000

CD/NP/31 Proposed Change to PPG3 � Housing (Consultation Paper) Influencing the size, type and affordability of housing

ODPM July 2003


6

CD/NP/32 Proposed Change to PPG3 � Housing (Consultation Paper) Supporting the Delivery of New Housing

ODPM July 2003

CD/NP/40 Planning Policy Guidance Note No 6 � Town Centres and Retail Developments

DETR June 1996

CD/NP/50 Planning Policy Guidance Note No 8 � Telecommunications

DETR August 2001

CD/NP/60 Planning Policy Guidance Note No 9 � Nature Conservation

DETR October 1994

CD/NP/70 Planning Policy Guidance Note No 12 � Development Plans

DETR December 1999

CD/NP/80 Planning Policy Guidance Note No 13 � Transport

DETR March 2001

CD/NP/90 Planning Policy Guidance Note No 15 � Planning and the Historic Environment

DETR September 1994

CD/NP/100 Planning Policy Guidance Note No 17 � Planning for Open Space, Sport and Recreation

DETR July 2002

CD/NP/110 Planning Policy Guidance Note No 22 � Renewable Energy

DETR February 1993

CD/NP/120 Planning Policy Guidance Note No 23 � Planning and Pollution Control

DETR July 1994

CD/NP/130 Planning Policy Guidance Note No 24 � Planning and Noise

DETR September 1994

CD/NP/140 Planning Policy Guidance Note No 25 � Development and Flood Risk

DETR July 2001

GOVERNMENT CIRCULARS CD/GC/10 Department of the Environment

Circular 1/94 � Gypsy Sites and Planning

DETR January 1994

CD/GC/20 Circular 1/97 � Planning Obligations

DETR January 1997

CD/GC/30 Department of the Environment Circular 6/98 � Planning and Affordable Housing

DETR April 1998

CD/GC/40 Advice to Local Authorities on Environmental Impact Assessment

ODPM Undated


7

REGIONAL PLANNING POLICY CD/RP/10 Regional Planning Guidance for the

South East (RPG9) GOSE GOE GOL

March 2001

CD/RP/20 East of England

Draft Regional Planning Guidance (RPG14) for the East of England

East of England Regional Assembly

February 2004

CD/RP/30 Report to the Regional Planning Panel Draft RPG14 � final draft

East of England Regional Assembly

January 2004

SUSTAINABILITY CD/SUS/10 Local Agenda 21

Improving the Quality of Life in Broxbourne Strategy and Action Plan


November 2003

GREEN BELT AND COUNTRYSIDE CD/GBC/10 A Landscape Strategy for

Hertfordshire, Volume 1: Background Information


October 2001

CD/GBC/20 Hertfordshire Landscape Strategy, Volume 2: Landscape Character Assessment, Evaluation and Guidelines for Southern Hertfordshire


October 2001

CD/GBC/30 West Cheshunt Study Area Discussion Paper


February 1989

HOUSING CD/H/10 Borough of Broxbourne

Housing Strategy 2004/09 Borough of Broxbourne

October 2003

CD/H/20 Housing Needs Assessment 2001 Final Report


July 2002


8

CD/H/30 Essex and Hertfordshire Housing Market Study 2002

University of Cambridge

2002

CD/H/40 Housing Land Availability Department of the Environment

CD/H/50 Affordable Housing Strategy Borough of Broxbourne

April 2001

CD/H/60 Notes of the Housing Round Table Session - Borough of Broxbourne Local Plan Second Review Inquiry 10th March 2004


May 2004

CD/H/70 St Mary's High School, Churchgate Environmental Statement - Further Information

Vincent & Gorbing

February 2004

EMPLOYMENT AND EDUCATION CD/EMP/10 Borough of Broxbourne

Economic Development Strategy 2003-06


2003

GREATER BROOKFIELD, RETAIL AND TOWN CENTRES CD/BFC/10 Transport Study

Halfhide Lane and Environs, Cheshunt Volume 1

Boreham Consulting Engineers

August 2000

CD/BFC/20 Borough of Broxbourne Retail Strategy 2004 Volume 1


March 2004

CD/BFC/30 Borough of Broxbourne Retail Strategy 2004 Volume 2: Appendices


March 2004

CD/BFC/40 Greater Brookfield Centre Transport Review

Colin Buchanan & Partners

March 2004

COMMUNITY, LEISURE AND TOURISM CD/CLT/10 Lee Valley Regional Park Plan

Part 2: Proposals Lee Valley Regional Park Plan Authority

April 2000


9

HERITAGE AND DESIGN CD/HD/10 Hertfordshire Sustainable

Development Guide

CAG Consultants

March 2003

TRANSPORT CD/T/10 Hertfordshire�s

Local Transport Plan 2001/02-2005/06


July 2000

CD/T/20 Weekly Bus Services within the Borough of Broxbourne


June 2004

IMPLEMENTATION CD/IMP/10 Community Plan 2003-06 Borough of

Broxbourne April 2003

CD/IMP/20 Comprehensive Performance Assessment - Broxbourne Borough Council

Audit Commission

May 2004.


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APPENDIX 2 Borough of Broxbourne Local Plan Second Review Inquiry Housing Round Table Session Beaufort Suite, Bishop�s College, Churchgate, 10th March 2004, 10:00am

Paul Cronk (PC) House Builders Federation Chris Wilmshurst (CW) George Wimpey UK (Boyer Planning) Greg Lee (GL) Crest Nicholson (Colin Buchanan & Partners) Mike Walker (MW) Crest Nicholson Jed Griffiths (GEP) Mr H Pritchard (Griffiths Env. Planning) Michael Osman (MO) Thames Water (Planning & Regeneration) Flo Churchill (FC) Thames Water (Planning & Regeneration) Jane Gardner (JG) Landmatch Ltd & Leach Homes (Smith Stuart Reynolds) Neil Osborn (NO) Persimmon Homes (Anglia) Ltd (DLP Consultants) Valerie Scott (VS) Woodhall Properties Ltd (Anthony Bowhill & Associates) Emma Walker (EW) Higgins Homes Ltd (Andrew Martin Associates) Kevin Coleman (KC) Higgins Homes Ltd (Andrew Martin Associates) Andre Sestini (AS) Borough of Broxbourne Jane R Orsborn (JO) Borough of Broxbourne (Prospect Planning) Martin Ledger (ML) Borough of Broxbourne (Prospect Planning) John Giesen (GIE) Borough of Broxbourne Sue Scanlan (SS) Borough of Broxbourne Robert Jameson Borough of Broxbourne (Advocate, as observer)

1 Introduction 1.1 GS opened by explaining the aims and scope of the session. It was pointed out that site-specific issues would not be discussed in detail. Notes would be taken and circulated to all participants. 1.2 The Inspector was asked if Reserved Sites and ASR would be included for discussion in this session, or left for a later Inquiry session (KC). GS advised that they would be part of Round Table session. 2 Housing supply - general 2.1 All participants accepted that the Plan would provide enough housing to meet Structure Plan requirements up to 2011. The 2002 consultation draft Structure Plan Review gave no guidance on levels of housing the Borough would be required to provide beyond 2011. 2.2 In July 2003 Keith Hill, the Minister of State had provided clarification of policy in PPG3 concerning the need to plan for at least 10 years supply of housing from the adoption date of the Local Plan (PC). If the cut off were to be 2011, then this would not meet the required 10 year requirements. (JG) It is extremely


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important that the allocation figure in respect of Borough of Broxbourne is capable of being increased should any further strategic growth be imminently identified for this part of Hertfordshire. It is inevitable that Broxbourne will very soon be expected to accommodate significantly higher amounts of housing growth. (PC) As it is reasonable to assume that the statutory process for adoption of the Second Review of the Local Plan is unlikely to be completed until at least mid 2005, it is imperative that the housing land identified covers the period up to 2015 at least. 2.3 The position regarding the supply to 2011 in Broxbourne shows a significant surplus and also a sufficient short and medium term supply (AS). Although a 10 year supply is not available at present, there is no need to look for further housing land until PPG14 figures have been produced. (JO) 2.4 PPG12 states in that there is a need to look up to a 10 year period. Supply may dry up; then the Council would not be in a position to catch up (PC). Because of the housing shortage in the South East, all districts are being urged to provide a step change in housing provision. Therefore, it is unacceptable that the Council has not produced a plan to meet a 10 year supply (JG). 2.5 In the strategy plan target to 2011 the requirements for Affordable Housing and Special Needs Homes have not been met. (GL) 2.6 The RPG is likely to require more development in Broxbourne than presently planned for, even though it is over a longer time scale to 2021. Looking at the current rate of delivery, Table 1 of the Housing Topic Paper shows that only 340 units per year are available, which is only 7 years' supply. If 340 turns out to be an over estimate, medium term supply would become critical. Sites coming forward could dry up by 2011 (KC). 2.7 On the subject of 10 year supply, the Ministerial Statement talks about the potential to provide for a 10 year term. However, within 1 year there will be a change to housing requirements. The Council pursued a review to 2011 on the understanding that the situation will change. A similar situation was accepted by the Uttlesford Local Plan Inquiry report. We can only look at housing supply in relation to the current adopted Structure Plan, and the Council is well ahead of Structure Plan allocation. To a degree the Plan is front loaded, and an urgent review will be required. This review will take place once the Regional Planning Guidance is published. (ML) 2.8 Most people have seen the draft of the emerging RPG14, which shows an increase in the housing requirement for Hertfordshire of approximately 10% on the current RPG figure. The initial figure for Borough of Broxbourne is slightly lower than the figure contained in the adopted Structure Plan i.e. 255 dwellings per annum, compared to 270. However, there is a clear indication that the Structure Plan will continue to be projected. (JG) 2.9 The Council is fully aware that the figure may be increased. However, we do not want to commit to something, which proves to be wrong in the future, and are therefore sticking with original proposals. We will do a full review once we have concrete figures from RPG14. (ML)


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2.10 The Uttlesford Local Plan Inquiry (Report for which was released to the public last Friday) was held in the autumn of last year (2003) when the draft RPG12 was not available. Uttlesford is also different due to the Stanstead situation. It is a much more volatile area due to its location and the proposed airport expansion. It is therefore, harder to predict future housing requirements. Also the figure of 270, although higher than 255 it is less than the 281 quoted in the Hertfordshire County Council Structure Plan. Does the Council have a timetable to carry out a review? (KC) 2.11 The Council does not have a timetable for review of housing figures, as we are waiting for RPG14. (ML) However, the onus is on the Council to review by the end of the year. The starting points will be the Urban and Greenfield reports and also RPG14. It will be about finding sustainable levels of growth overall. (AS) 2.12 This Borough is likely to run out of housing supply sites and needs alternative ad hoc sites allocated. There is a need for a clearer idea of where this District is going now rather than later. The process of preparing and completing a new LDF will be lengthy (NO). Caution is required regarding the Council�s early review as Council planning would inevitably be delayed and this would lead to housing supply shortage (CW). Hertfordshire has an inadequate infrastructure, so need to plan ahead, any delays regarding planning will cause things to be put back further (PC). 2.13 The Council should revise its approach to the release of brownfield sites and address development potential in current urban areas. This would help to assess whether the Council should look before 2011. (MO) 2.14 Looking at Policy H2 � �Windfall Residential Development � Urban Capacity� - does that reflect current Government guidance? (GS) 2.15 This issue was raised at Three Rivers Council where an Inspector supported a similar policy (JO). A moratorium has been supported, as current policy is not to contribute to oversupply. (RJ) 2.16 This occurred in West Hertfordshire and not in an identified growth corridor. However, 800 more homes than the target of 5400 have already been built or given go-ahead in Broxbourne. In terms of housing land supply the Borough is in a remarkable position. At March 2003, already 3866 dwellings have been provided. On top of that 1045 dwellings are under construction or have planning permission, with capacity for a further 1048 from allocated housing sites. There is no case to be made for additional housing to be allocated. That cannot be justified in a situation of existing considerable over supply. Broxbourne is located within M11 Growth Corridor, but it is far too early to say at this stage what the growth requirements to 2016 or 2021 will be. (JO) (RJ) 2.17 There should be reasonable development of Brownfield Sites instead of release of Green Belt. In paragraph 3.18 of the Plan there is a cavalier discussion regarding the release of land from the Green Belt. With regards to amenity land in the Local Plan, the Council does not show careful husbandry. (MO) 2.18 The Council is very concerned about infrastructure and wants to wait (JO). However, the Council agreed to reconsider Policy H2 in terms of deciding at


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what point there would be oversupply. A 10 year supply could be predicted by projecting the average annual rate (ML). 3 Completions 3.1 There were no queries relating to completions - 3866. 1534 was the correct figure for the outstanding requirement (AS)

4 Sites with permission 4.1 There was a doubt that a site at Hammondstreet Road would come forward; it has ownership constraints, and has been delayed for bring forward from the 1994 Local Plan. It is therefore, not genuinely available (JG). 4.2 This has outline approval, but no reserved matters application received. The area was released from the Green Belt in the last review (AS). The current owner is not likely to bring this site forward but it may change hands and remains in the Plan. (JO) It is shown as �white� land on current plan (AS). A 5% non-completion allowance had been applied in Table 2. However, the Council have assumed that Table 3 will come forward in entirety. 4.3 There was discussion as to whether an allowance of 5% in Table 2 was reasonable, or whether 10%, as used in a Roger Timms Report, was reasonable. 4.4 Some of the sites in Table 2 have been included since 1997-1998 and 1999 and 2000 � these must be old sites, so it is likely that quite a lot of sites with planning permission will not come forward (KC). A 10% allowance for non-completion would be appropriate because planning consent can take a long time to come forward (PC). This would give greater flexibility (MO). Other participants thought 10% to be fair. 5 Allocated sites 5.1 There is a fair amount of certainty of housing sites coming forward and with at least the number of dwellings specified, for example Fawkon Walk site (VS). 5.2 It is academic whether the figure is 5% or 10%, as Council is 16% over current Structure Plan (ML). Paragraphs 3.14 and 3.15 of the Council�s Housing Round Table Proof list a more up to date figure. This shows 77% of units, which were previously outstanding, have now come forward (JO). 5.3 The Council agreed to consider the logic of applying 5% to sites allocated with planning permission, in Table 3 (ML). Any revised figures for completions and sites under construction that become available would be reported to the Committee in June 2004 and then circulated to all relevant objectors before the Inquiry closes.


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6 Windfall 6.1 House Builders Federation suggested an annual total of 35 dwellings on windfall sites, based on 1998-2003 averaged out. There have been no greenfield sites included in calculations (PC). 6.2 A specific allowance should be made for windfall developments if the background information supports this. However, only limited justification has been provided by the Council for its windfall allowance in paragraph 3.4 of the Housing Topic Paper. The Council�s statement refers to not 40 but 35 dwellings from windfall sites per annum, based on last 5 years, which is a reduction of 11% (PC). The figure of 35 would be a reasonable assumption if completions were to be taken from Windfall sites, and then also deduct sites with Planning Permission, otherwise double counting applies. (JG) 6.3 Regarding the figure of 35 � when figures are set out they do come to 35-36, but other small sites are now coming forward, so the Council expects 40 dpa from this source. (JO) 6.4 If there is a higher completion rate than permission rate then this should be taken into account. Small sites are not comparable to large sites. All other sites should be deducted. (JG) 6.5 The Council did not have an average figure for annual planning permissions, but agreed to circulate this separately to all parties (AS). 6.6 The density assumptions were accepted by all parties. 7 Phasing 7.1 The Plan has limitations as a result of its approach to phasing and the front-loading of housing development. The impetus provided by PPG3 should not be lost in Broxbourne. The emphasis on greenfield sites could delay provision on brownfield (MO). 7.2 Canada Fields is the only Greenfield site going ahead and that site previously had planning permission for employment and leisure use. The MAAF site was PDL, albeit green belt (JO). 7.3 The opportunity for phasing is not now appropriate as the sites already have Planning Permission (VS) 7.4 The HBF considered that there was a role for phasing but it should not be arbitrary. (PC)


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8 Other matters 8.1 Although there are no strategic allocations of ASRs, the negative approach to �Land in West Cheshunt� in the Local Plan should be reviewed. Any review of the Plan should treat potential sites on an equal footing (VS). There has been a revision to the wording in the Local Plan relating to the �West Cheshunt� section, and this will be provided to the Inspector. The Council will not preclude any areas of the Borough from review once RPG14 is produced. Further development of �West Cheshunt� is not appropriate at present (ML). The amendments to the wording of the Local Plan regarding �West Cheshunt� are viewed to not go far enough (VS). The Council agreed to send a copy of the revised wording to all parties so that it could be taken into account when preparing Proofs. 8.2 The number of flats being built in England has overtaken the number of detached houses being built for the first time. Although half of the homes built in Borough of Broxbourne between 1995 & 2000 were 4 & 5 bedroom properties, likely in future there will be a higher proportion of 1 & 2 bed homes in Broxbourne than there has been in the past. The proportion of flats almost doubled from 17% to 32% from 1999 to 2002. Figures for the first quarter of 2003 show an acceleration of this trend, with flats making up 37% of completions, with detached houses declining to 27%. The HBF considers that these figures reveal an unprecedented change in the way we will live in the future. Balancing the supply of flats and houses is essential. (PC) The Council is not aware of any problems as far as house builders are concerned. (ML) 9 Closing Statements 9.1 The parties made brief closing statements summarising objections set out more fully above.


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AFFORDABLE HOUSING RTS 10 Housing needs survey 10.1 The housing surveys need to address full range of needs across the spectrum. (PC) 11 30% quota 11.1 There is a need for flexibility; as well as affordability, assessments should address the housing required by current and anticipated households, including groups such as key workers, disabled or elderly, and look at particular types and sizes of accommodation. The 30% target is too high, as many proposed projects are on Brownfield sites, which can be more expensive to develop. The level of affordable housing should be open to negotiation and must take into account the viability of a scheme, in line with latest Government advice (PC). 11.2 The Council does negotiate on a site-by-site policy and has not sought to define what exceptional costs are. The policy is sufficiently flexible. (AS) 11.3 Exceptional costs can be open to wide interpretation. (PC) 11.4 Housing needs in Broxbourne are comparable with the London situation, in relation to the homeless. (GIE) 12 Implementation � Policy H18 12.1 Paragraph 3.8.4 of the Plan implies that low cost market housing will be unlikely to meet any of the housing needs quoted in the Council�s �Housing Needs Survey�. Instead, social rented accommodation will be sought. Government guidance is to avoid specifics, but to address all needs. It asks for flexibility in the discussion regarding types of provision. (PC) Definition of low cost housing provision 12.2 The Council accepts that there is a need to consider Shared Ownership, and Key Worker housing. Broxbourne has among the lowest number of Council and Housing Association homes in Hertfordshire. Research has shown that two-thirds of households can afford to buy or rent on the open market, while 1741 households cannot afford to do either, and less than 1% of socially rented homes are empty. Despite an initiative to make the most efficient use of its Council homes, such as families trading down to release bigger houses, this does not alter the need for affordable housing to be provided in the planning process. It is reasonable to seek greater allocation as rented accommodation (GIE). 12.3 Clause 3 of the policy is too specific, in conflict with Government strategy (PC).


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12.4 The Government has changed its strategy regarding the priority for Key workers (GIE) 12.5 The level of housing need and the ability of the Council to meet that need as detailed in the Local Plan Second Deposit paragraph 3.8.5 shows that if all housing were to be developed as affordable housing, there would still be a shortfall. (GL) 12.6 It has been demonstrated that the Council�s policy is working, as developers have been willing to provide 30% affordable housing. The question of being able to deliver through the policy is proven, as the developments at Canada Fields and the MAFF site indicate. (GIE) 12.7 The Government states that �off site provision� can be allocated for affordable housing, ie on the edge of towns etc (PC). The Council would not dismiss �off site provision�, but there is no land available for this type of development at present. There are funds available for sites but Housing Associations tend to negotiate with landowners and acquire the whole site. (GIE) 12.8 The wording of the policy should be amended to reflect that if a planning application was received for 100% affordable housing, then this would be accepted by the Council (GL). The Council has not received applications for that level of affordable housing. The phrase �at least 30% affordable housing� could be included in the Plan to give more flexibility (AS). There could be confusion if the wording was changed to �at least 30%�. 12.9 It would be better to have a separate policy (PC). The Council would welcome developers making a contribution of affordable housing to a higher level. (GEI) 13 Close 13.1 The parties made closing summaries of the above points and the session concluded.


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APPENDIX 3 APPEARANCES Tuesday 9th March 2004 Appearing Representing Terry J Betts BA (Oxon) M Phil (Lond) MRTPI Mrs J Liddard (TJB Planning Consultancy) Martin Ledger MRICS Borough of Broxbourne (Prospect Planning) Robert Jameson LLB (Solicitor) Borough of Broxbourne (Jameson and Hill) Andre Sestini MA BTp Borough of Broxbourne (Local Plans Manager) Wednesday 10th March 2004 Housing Round Table Session Paul Cronk BA (Hons) Dip TP MRTPI House Builders Federation Chris Wilmshurst BA (Hons) MRTPI George Wimpey UK (Boyer Planning) Greg Lee BA (Hons) BPI MRTPI Crest Nicholson (Colin Buchanan & Partners) Mike Walker Crest Nicholson Jed Griffiths MA DipTP FRTPI Mr H Pritchard (Griffiths Environmental Planning) Michael Osman MRTPI Thames Water Property Sevices (Planning and Regeneration) Flo Churchill MRTPI Thames Water Property Sevices (Planning and Regeneration) Jane Gardner BA (Hons) MRTPI Landmatch Ltd and Leach Homes (Smith Stuart Reynolds) Neil Osborn BA (Hons) MRTPI, FPCS Persimmon Homes (Essex) Ltd (DLP Consultants) Valerie Scott BSc McD MRTPI Woodhall Properties Ltd (Anthony Bowhill & Associates) Emma Walker BA (Hons) MA MRTPI Higgins Homes Ltd (Andrew Martin Associates) Kevin Coleman BSc (Hons) DipTP (Dist) MRTPI Higgins Homes Ltd (Andrew Martin Associates) Andre Sestini MA BTp Borough of Broxbourne Local Plans Manager Jane R Orsborn BA (Hons) DipTP MRTPI D.M.S. MCIM


(Prospect Planning) Martin Ledger MRICS Borough of Broxbourne (Prospect Planning) John Giesen Borough of Broxbourne (Director of Housing and Community Care) Sue Scanlan Borough of Broxbourne


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(Policy and Project Officer) Robert Jameson LLB (Advocate, as observer) Borough of Broxbourne (Jameson and Hill) Wednesday 7th April 2004 Appearing Representing Patrick Clarkson QC Thames Water Property Services Robert Jameson LLB (Solicitor) Borough of Broxbourne (Jameson and Hill) Borough of Broxbourne Witnesses Michael Osman MRTPI (Planning) Thames Water Property Services (Planning and Regeneration) Geoff Heard B Eng, C Eng MICE (Highways) Thames Water Property Services (WSP Development) Brita von Schoenaich MLI (Landscape) Thames Water Property Services (Schoanaich Rees Associates) Keith Seaman BSc C Biol (Ecology) Thames Water Property Services (ELMAW Consulting) Jane Orsborn BA (Hons) DipTP MRTPI D.M.S. MCIM Borough of Broxbourne (Prospect Planning) Andrew B Roberts B Eng (Hons) MIHT Borough of Broxbourne (Colin Buchanan and Partners) Tuesday 20th April 2004 Appearing Representing Neil Osborn BA (Hons) MRTPI FPCS Persimmon Homes (Essex) Ltd (Development Land and Planning Consultants Ltd) Jane Orsborn BA (Hons) DipTP MRTPI D.M.S. MCIM(Prospect Planning)


Thursday 22nd April 2004 Appearing Representing Jonathan Milner (Counsel) Woodhall Properties Ltd

Valerie Scott BSc McD MRTPI Woodhall Properties Ltd (Anthony Bowhill and Associates) Robert Jameson LLB (Solicitor) Borough of Broxbourne (Jameson and Hill) Andre Sestini MA BTp Borough of Broxbourne (Local Plan Manager) Witnesses Jonathan Billingsley MA (Oxon) Bphil MLI (The Landscape Partnership)

Woodhall Properties Ltd


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Friday 23rd April 2004 Appearing

Representing

First Session Mrs J E Petts Martin Ledger MRICS (Prospect Planning) Andre Sestini MA BTp

Herself Borough of Broxbourne Borough of Broxbourne

(Local Plan Manager) Second Session Terry J Betts BA (Oxon) M Phil (Lond) MRTPI Mr C I Maxen (TJB Planning Consultancy) Robert Jameson LLB (Solicitor) Borough of Broxbourne (Jameson & Hill) Martin Ledger MRICS Borough of Broxbourne (Prospect Planning) Andre Sestini MA BTp Borough of Broxbourne (Local Plan Manager) Third Session Valerie Scott BSc McD MRTPI Woodhall Properties (Anthony Bowhill and Associates) Andre Sestini MA BTp Borough of Broxbourne (Local Plan Manager) Witnesses Jaquelin Clay Fisher BSc MSc MLIFAE (Ecology) Woodhall Properties (Jaquelin Clay Fisher Associates) Martin Hicks BSc (Ecology) Borough of Broxbourne (Hertfordshire Biological Records Centre) Tuesday 27th April 2004 Appearing Representing Kevin Coleman BSc (Hons) DipTP (Dist) MRTPI Higgins Homes Ltd (Andrew Martin Associates) Jane Orsborn BA (Hons) DipTP MRTPI D.M.S. MCIM Borough of Broxbourne (Prospect Planning)


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Thursday 29th April 2004 Appearing Representing Greg Lee BA (Hons) BPI MRTPI Crest Nicholson Residential

(Eastern) Ltd Tim Johnson (Advocate) Crest Nicholson Residential

(Eastern) Ltd (Davies Arnold Cooper) Andre Sestini MA BTp Borough of Broxbourne (Local Plan Manager) Robert Jameson LLB (Solicitor) Borough of Broxbourne Jameson and Hill Friday 30th April Appearing Representing First Session Drummond Robson BSc DipTP MRTPI Nicholas O�Dwyer (Robson Planning Consultancy) Andre Sestini MA BTp Borough of Broxbourne (Local Plan Manager) Robert Jameson LLB (Solicitor) Borough of Broxbourne (Jameson and Hill) Second Session Jed Griffiths MA DipTP FRTPI Harold Pritchard (Griffiths Environmental Planning) Andre Sestini MA BTp Borough of Broxbourne (Local Plan Manager) Tuesday 11th May 2004 Appearing Representing First Session Jeremy Elsom BA DipLD MRTPI London Merchant securities Plc Jane Orsborn BA (Hons) DipTP MRTPI D.M.S. MCIM Borough of Broxbourne (Prospect Planning) Second Session Colin Tebb BA (Hons) BTp MRTPI Mr B Barrett (Hertford Planning Service) Andre Sestini MA BTp Borough of Broxbourne (Local Plan Manager)


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Wednesday 12th May 2004 Appearing Representing Barbara Tyrrell The Spitalbrook Village Green

Conservation Group Dr John Clarke The Spitalbrook Village

Green Conservation Group Andre Sestini MA BTp Borough of Broxbourne (Local Plan Manager) Thursday 13th May 2004 Appearing Representing Craig Howell Williams (Counsel) Hertford Regional College Mrs D C Parsonage The Wormley Society Robert Jameson LLB (Solicitor) Borough of Broxbourne Jameson and Hill Jane Orsborn BA (Hons) DipTP MRTPI D.M.S. MCIM Borough of Broxbourne (Prospect Planning) Witnesses Louise Morton MSc MRICS (Planning) Hertford Regional College (GVA Grimley) Paul Harvey MSc BSc Cert Ed Hertford Regional College (Principal and Chief Executive) Thursday 20th May 2004 Appearing Representing Martin Kingston QC Landmatch Ltd and Hubert C Leach Lt Robert Jameson LLB (Solicitor) Borough of Broxbourne Jameson and Hill Witnesses Garth Hanlon BSc (Hons) MRTPI (Planning) Landmatch Ltd and Hubert C Leach Lt(FPD Savills) Moira Hankinson BSc (Hons) DipLD FLI (Landscape)

Landmatch Ltd and Hubert C Leach Lt

(Hankinson Duckett Associates) Martin Paddle BSc Ceng MICE FIHT MCIWEM (Highway)

Landmatch Ltd and Hubert C Leach Lt

(Mouchel Parkman UK Ltd) Jane Orsborn BA (Hons) DipTP MRTPI D.M.S. MCIM Borough of Broxbourne (Prospect Planning)


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Tuesday 25th May 2004 Appearing Representing Patrick Clarkson QC Thames Water Property Services David Taylor BSc (Hons) Councillor Martin Greensmyth Robert Jameson LLB (Solicitor) Borough of Broxbourne (Jameson and Hill) Witnesses Michael Osman MRTPI Thames Water Property Services (Planning and Regeneration Ltd) Howard Fielding MA M.Ed Thames Water Property Services (Fielding Consultants) Jane Orsborn BA (Hons) DipTP MRTPI D.M.S. MCIM Borough of Broxbourne Richard Parsons BA (Hons) DipTP MRTPI Borough of Broxbourne (Vincent and Gorbing) Wednesday 9th June 2004 Appearing Representing Mrs D C Parsonage The Wormley Society Jane Orsborn BA (Hons) DipTP MRTPI D.M.S. MCIM Borough of Broxbourne (Prospect Planning)


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APPENDIX 4 OBJECTORS NOT LISTED IN MAIN REPORT H3 - STRATEGIC HOUSING SITES - WARE ROAD, HODDESDON (PART OF POLICY H3 (H3-III) IN FIRST DEPOSIT) Objections - First Deposit 700/02 Mr R.F Breezie 2/01 Councillor L Groucott 3/01 Mr P Hillyard 4/01 Mrs M Moss 58/01 Mr & Mrs R.A. Frost 65/01 Mrs D Bhutti 79/01 Mrs P. Scales 102/02 Mr & Mrs C West 173/02 Mr & Mrs Albury 215/015 RSG Properties Ltd 216/01.03 Mr J. Piner 218/01.02 Mrs C. Piner 233/01 Mr & Mrs D Voller 234/01.02 Mrs M. Field 264/01 Mr F. Gulisano 270/01 Ms P. Sultana 271/01 Mr J. Sultana 272/01.02.03.04 Mr & Mrs Scutchings 273/01 J. Jones 274/01 M.A. Waller 277/01.02 Mrs A. Clinch 278/01 Mr I. Buckle 279/01 R. Marlow 283/01 Mr & Mrs Pomfrett 284/01 Mr S. Elkins 288/01 Mr & Mrs Street 301/01 Mr K. Cronwell 303/01.02 Mrs S. Provenzano 304/01 Neighbourhood Watch 305/01.02.03 Mr & Mrs S J Bull 306/01 Mrs J. Gant 307/01.02 Mr & Mrs E. Berriff 308/02.03 Mr & Mrs S. Gibbs 309/01 Mr & Mrs I. Wilkinson 310/02 Mr & Mrs Gannon 317/01 Mr J. Ward 336/01.03 Ms D. Moxham 337/02.04 Mr & Mrs D. Mort 347/01 Ms P. Rowley 371/04 Mr D.Shields 409/01 Mrs H.M Blackford 421/02 Mr & Mrs D. Locker


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426/03 D. Carter 427/01 Mrs M. Pilgrim 449/03 Mr M. Richardson 451/01.03 Mr & Mrs Eley 452/04 Mrs T Richardson 454/03 Mrs T Trick 456/01.03 L. Roger 457/01 Mr & Mrs J. Brookman 458/01 Mr & Mrs Saint 460/01 J & A M Glover 461/01.02 Mr & Mrs Lane 462/01 Mr P. Cuffaro 465/01 K.A Buck 467/01 Mr & Mrs D. Murray 471/07 Mrs I. Beard 473/02.04.05 Mr M. Reynolds 477/01.03 T J A Jordan 481/01.02.04.05 Ms M. Hastings 488/01 Mr & Mrs D. Butler 492/01 Mr R.M Halfhide 500/01.04 Mr & Mrs A Mitchell 503/01 Mr S.F Raniere 504/01 Mr & Mrs Jackson 527/01.02.04 Mr & Mrs M.Taylor 528/01 E.Thomson 541/01 R.E Arnold 562/02 The Wormley Society 627/02 Miss B. Peters 629/01 Mr I. Bartlett 631/01 Mr & Mrs N J Francis 633/01 Mr B.D. Lacey 634/01 Mr & Mrs Darton 641/01 Mr C. Hughton 642/01 Mr & Mrs Adamo 644/03.04 Mrs A. Marsh 660/01 Mrs F. Matthews 662/01.02 Miss J. Cooper 663/01 Mrs W.V. Warden 664/01 Mr A.E. Warden 666/01.02 Mr & Mrs W. Marsh 690/02 Mrs Y Read 693/01 Mr W.C Pelling 698/02.04 Mr S. Maniscalco 700/01.03.04.05 Mr R.F Breezie 702/01 Mr K Trick 715/01 Mrs C. Bass 780/01 Mr & Mrs A.V.P. Moss 782/01 Mr D. Hinwood 785/01 A. Fallert 787/01 B Davies 792/01 Mr A. King 793/01 J. Russell


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797/01 Mrs P. Knight 802/01 Mr B. Riley 810/01 Mrs E. Chalkley 824/01 Mr & Mrs Bradbury 825/01 Mrs Tillbrook 826/01 Mr & Mrs Murphy 827/01 R. Bradbury 840/01 B.P Bowman 869/01 Mrs A. Zerafa 872/01.02 Mr A. LeBaigue 873/01 Mrs P Manning 874/01 Mr D. Manning 876/02 Mr P Smith & Miss Laverack 877/01 K. Barltrop 888/02 Dr & Mrs Garside 904/01.04 Mr & Mrs Sawyers 907/02 Mrs Scott 938/01 Mr P.J. Whiting 940/01 Mrs N. Whiting 985/01 Mr & Mrs Parrinello 1101/040 CPRE - The Hertfordshire Society 1105/02 Abbey Road Surgery 1106/01 Mrs F.M Clements 1107/02 Mr V. Tye 1113/01 Mr G. Genuardi 1115/01 Mrs B. Pledger 1118/01 Mr & Mrs D.J Hale 1121/01 Roselands Scouts and Guides 1133/01 Mrs M. Bullimore 1136/01 Roselands Scout and Guide

Group 1137/01 Mr & Mrs Ratcliffe 1262/07 George Wimpey UK Ltd 1293/010 Colin Buchanan and Partners 1294/017 Bellway Estates 1316/02 Mr & Mrs B. Smith 1330/01 Ms Cooper Objections - Second Deposit 1304/013 D H Turner Consultancy 1365/04 St James Road Ltd 1264/043 Higgins Homes Ltd


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H3 - STRATEGIC HOUSING SITES - - CANADA FIELDS (PART OF POLICY H3 (H3-VI IN FIRST DEPOSIT) Objections - First Deposit 17/01 Mr A. I Watt 30/01.02 Mr & Mrs R Clarke 109/01 The Croft Management Co. Ltd 142/01 Mr J.D Rowe 174/01 R. Gardner 192/06 Mr M Kousoulou 197/01 D. Collyer 371/05 Mr D. Shields 423/01 Ms C. Hubbard 453/01 Mr J Wells 480/03 Mr A. Hoines 487/01 Mr L. Stripp 562/09 The Wormley Society 583/01 Mr A. Barter 625/01 Mr P. Saunders 627/03 Miss B. Peters 628/01 Mr D.J. Llewellwn 636/01 Mrs J.E Petts 684/01 Mr R.B. Morris 695/04 Ms J. Crew 769/01 Mr & Mrs R.J Webb 786/01 Mr C W Chamberlain 795/01 Mr & Mrs J. Haynes 804/01 A. Petts 813/05 New River Action Group 817/01 Mr A.H.C. Walker 818/01 Mrs J. Day 823/04 Mrs D.M. Weston 828/01 Mrs L Waldock 839/01 Mr & Mrs R.D Castle 865/01 Mr & Mrs Hilton 918/01 Mr & Mrs S. Cannon 946/01 P. Proctor 947/01 Mrs C.M. Proctor 988/01 M & B Sanderson 1002/017 Hertfordshire County Council

(Property) 1272/06 Mr A J Salter 1275/02 London Merchant Securities plc 1280/01 George Wimpey UK Ltd 1280/02 George Wimpey UK Ltd 1301/01 Standard Life Investments


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1316/03 Mr & Mrs B. Smith 1318/01 Ms J Lawrence 1319/02 Mrs J.M. Hillman

H4 SHORT TERM HOUSING ALLOCATIONS 2001-2005: LAND AT FAWKON WALK (POLICY H3-1 IN FIRST DEPOSIT) Objections - First Deposit 1/01 Councillor J Rose 6/01 Mr & Mrs J. E Enoch 8/01 G.H Attenborough & Co 11/01 Mr L. W Groome 14/01 Mr M Smith 15/02 Mrs J Ellis 16/01 Attfield & Jones 18/01 M.G Petter 19/01 Ms A. Tayler 21/01 Miami Flooring Supplies 22/01 Miami Flooring Supplies 27/01 Mr M Pledger 28/02 Mr P Lardi 32/01 L.V Bowden 34/01 Lloyds Pharmacy 35/01 Mr & Mrs D. A Thurley 37/01 Mr & Mrs J Westcombe 38/01 S.A Bennett 39/01 Mr C. Monk 41/01 Mr A Hambling 42/01 Mr G. Brown 43/01 R. E Jowsey 44/01 The Bakers Pantry 45/01 V. Simmonds 46/01 Mrs G. Lardi 47/01 Mrs E. Tackley 48/01 Miss T Godfrey 49/01 Mr & Mrs Mooney 50/01 Mrs M Cooper 51/01 Mrs J. Horsley 52/01 Mrs A. R Bernardy 56/01 K. J. Gibb 59/01 Mrs D. L Chilton 60/01 Mr & Mrs E. Chalkley 61/01 Mr H Richardson 62/01 Terri's Coffee House 63/01 Mrs A.E May 66/01 Mr R. Apps 67/01 Mr J Baldwin 69/01 Mrs J. Flitney 70/01 Mrs E. Gunn 71/01 Scrivens


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73/01 Mr T. Clinch 74/01 Mr J. Nicholls 75/01 Mr M. J. Weaver 76/01 Mr & Mrs J. F Forshaw 77/01 Mrs H. Turnell 79/02 Mrs P. Scales 80/01 Mrs A. Keighley 81/01 Mrs J.P Weir 82/01 Mr A.G Weir 84/01 S.J Rose 87/01 Lady Bingley 93/01 Mr & Mrs Blewett 95/01 Ms L. Wilson 96/01 Mr & Mrs Stocker 97/01 Mr & Mrs I Blackaby 100/01 Mr F. Cassar 101/01 Mrs D Cassar 102/015 Mr & Mrs C West 105/01 Mr N. Back 109/02 The Croft Management Co. Ltd 112/01 Mr & Mrs E. Weeks 113/01 Mr G. Jennings 114/01 Mr S. Leeson 115/01 Mr G. Holt 117/01 C.B Parsons 118/01 Mrs Pateman 119/01 J. Doyce 120/01 M. Tarrant 122/01 Mr A. Hale 123/01 Mrs J. Cridland 124/01 Mr C. Rogers 125/01 Mr J.G Jones 126/01 Mrs J. Malloch 127/01 Mr C.P Tilley 128/01 Mr & Mrs F.A Clements 131/01 Mr A. Morgans 133/01 Mr B.Watson 134/01 Mr R.W Waller 135/01 Just Cards 136/01 Mr J. Dellar 138/01 Mrs B. J Dale 139/01 Mrs A. Fry 140/01 Mr G. Auger 141/01 Nazeing Glass Works 145/01 Mrs L. Fuller 146/01 Mrs W.B Forne 147/01 Mr & Mrs F.A Hyland 148/01 Mr & Mrs P. Shannon 151/01 Mrs O. Harrison 152/01 Mr & Mrs Tomlinson 153/01 Mrs E.R Bottomley 157/01 Mr A.J Summers


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173/01 Mr & Mrs Albury 175/01 Mrs B.A. Greenfield 176/01 Mr J.E Gaywood 177/01 Mr & Mrs D.K Adams 187/01 Mrs C. Hart 189/01 Mr M Stephens 191/01 Mr & Mrs A. Schlenker 193/01 Mrs C. Byham 194/01 Mr R.Thomas 195/01 Mrs J. Beck 198/01 Mr & Mrs H. Golding 201/01 Mrs B.Marks 202/01 I.G. Saban 203/01 J. Marrington 204/01 Mrs G.M Mattingly 205/01 P. Mattingly 206/01 M.H. Lee 207/01 Mr F.J. Judd 208/01 Mr R.E. Conway 209/01 Mrs A.J Chandler 211/01 Dr A. Barclay 213/01 Mr & Mrs A.F. Painter 214/01 Mrs Thabit 216/02 Mr J. Piner 218/03 Mrs C. Piner 219/01 Lloyds Pharmacy 220/01 Mrs O'Kelly 222/01 Mrs A. Shields 224/01 Ms J. Hyde 226/01 I.C Wheeler 228/01 Hertford & District University of

the Third Age 229/01 M. Stephens 230/01 Mr & Mrs Rhodes 231/01 Mr B.S. Dodimead 232/01 A.R Neale 0235/01 Mrs S. Golledge 236/01 Mr & Mrs H. Stockwell 237/01 Mrs A. Loveday 255/01 Mrs E. Mills 257/01 P. Bloomfield 260/01 Mr D. Mills 263/01 Mr P.C. Grant 275/01 Mrs D. Bloss 276/01 Mr A.J. Bloss 281/01 Mr G.A.Way 283/02 Mr & Mrs Pomfrett 287/01 J.H. Vallery 315/01 Dr R. Condon 319/01 Mrs M. Lewis 320/01 Mrs C. Pepper 323/01 Mr & Mrs M Lawton


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324/01 Ms A. Cane 325/01 Falco Packaging 336/02 Ms D. Moxham 337/03 Mr & Mrs D. Mort 353/01 Mr J Prew 375/01 Mr K.A.E Green 376/01 Ms A. Lewis 377/01 Mrs C. Smith 378/01 Dr & Mrs B. E Lowe 379/01 Mr & Mrs D. Perkins 380/01 Mrs E.M Fish 381/01 Mrs W.A Robinson 382/01 R.W Taplin 383/01 Mrs E. Hines 384/01 Mr & Mrs D.J. Butterfield 385/01 Mr & Mrs Edwards 386/01 Mr C. J. Smith 387/01 Mr & Mrs J. Reeves 388/01 Mr P.R Dobson 389/01 Mr R. Butterfield 390/01 Mrs D. Russell 391/01 M.H.J Cornish 392/01 Mrs A. Parlour 393/01 Mr D. Parlour 394/01 Mrs A. Draper 395/01 Mrs S.R. Fegan 396/01 Mr & Mrs A. Gude 397/03 Mrs S. Stapley 398/01 Mr J. Morphen 399/01 Mrs M.E. Slee 400/01 Mr P. Wilkinson 402/01 Mr & Mrs R. Herbert 403/01.03 I. Rix 404/01 P.K. Hough 405/01 G. Cooper 406/01 Mr & Mrs J. Bailey 407/01 Mr & Mrs M. Velasco 410/01 Dr & Mrs J. Earle 411/01 Mrs S.J. Clark 412/01 Mrs P.J Edwards 413/01 M.M Boulter 414/01 Mr & Mrs R. Chaplin 415/01 Mrs S. Caldecote 416/01 I.M Pearson 417/01 D.W Pearson 418/01 Mrs I.D. Nicholls 419/01 The Book Centre 420/02 Hoddesdon Retail Association 421/01 Mr & Mrs D. Locker 422/01 Mr & Mrs R. Lorimer 424/01 Mrs G.L. Thompson 426/02 D. Carter


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428/01 H. Mills 429/01 Mr G. Green 431/01 Mr & Mrs J. Kemp 432/01 Mrs J E Moncur 433/01 APP Management 434/01 Mrs M. Davies 435/01 R.S Thompson 436/01 Mr D. Ainge 437/01 Mr Fry 438/01 Mrs A E Murison 439/01 Mrs Y Rider 440/01 Belmont 441/01 Mrs R.A. Monk 442/01 Mrs M J James 443/01 Miss S.R Billington 446/01 Mrs M Dodd 447/01 P.H Groom 448/01 Mrs B. Barrick 450/01 Mr Ollis 451/04 Mr & Mrs Eley 452/01 Mrs T Richardson 459/01 Mrs F.J. Foster 464/01 Mr P. Carter 466/01 H Carter 468/01 Mr B. Newton 469/01 Mrs S. Dodwell 470/01 Mr & Mrs F. Kitchen 471/09 Mrs I. Beard 472/01 Ms S. Trenett 476/01 R.V Pickett 479/01 J. Leighfield 490/01 Mr & Mrs Dunham 492/02 Mr R.M Halfhide 496/01 Mrs I Fish 500/02 Mr & Mrs A Mitchell 510/01 Mr & Mrs Powell 513/01 Mrs V. Walpole 517/01 Mr W.A. Green 519/01 Mr & Mrs J. Murrell 521/01 Mr P. Nellis 529/01 M.J Clarkson 530/01 R Clarkson 531/01 On the Spot Developing &

Printing 532/01 P. Collett 534/01 Mr & Mrs W.H Pearce 537/01 Mrs C.A Tungatt 538/01 Mrs C. Bailey 539/01 K. Sadler 540/01 Mr & Mrs E.F Garrett 552/01 The Shop Box 553/01 Mrs C. Phipps


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561/01 The Shoe Box 582/01 Ms Y. Flowers 585/01 Mrs H.Warner 616/011 Ms C. Haigh 630/01 P. Hillier 632/01 Ms J. Scott 644/01 Mrs A. Marsh 688/01 Cannon Travel Hoddesdon 689/01 E. Sinden 693/03 Mr W.C Pelling 694/01 Ms L. Bennett 695/05 Ms J. Crew 696/01 Mrs M. Hewitt 698/01 Mr S. Maniscalco 699/01 J.M. Todd 701/01 Mr J.A. Lewis 703/01 Mrs E. Edwards 704/01 Mr C. Waterhouse 705/01 Ms D. Rothwell 706/01 The Occupier 707/01 Mr C.J. Hurst 708/01 Ms A. Bowles 710/01 Mrs M. Ingrey 711/04 Mr F. Scott 712/01 Mr M.J. Papworth 713/01 Mr K. Gates 714/01 Ms T. Eyre 716/01 Mrs M. Jack 719/01 Mrs Ellis 720/01 K. Carless 721/01 Mrs S.C. Carless 722/01 Mr N. Jackson 723/01 Ms B. Jackson 725/01 Mr R. Treend 728/01 P. Matthews 731/01 Mrs G. Chadwick 733/01 Mr I.E. Benson 746/01 J.H. Gervis 750/01 Mr A. Hallgarth 752/01 A. O'Brien 753/01 Dr F.G. Clayton 756/01 D.L. Phipps 759/01 Mr E.W. Crew 778/01 Mr G N Nixon 788/01 Mrs E McKinnon 790/01 Ms I. Dinnes 791/01 Ms A Tweed 807/01 Miss L.G. Crawley 811/01 L.A. Young 812/01 D. Young 816/01 Mr M A Giles 820/01 Mr & Mrs A. Blackwell


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821/01 B. Woolmer 822/01 Miss R.A. Chartres 823/02 Mrs D.M. Weston 830/01 Mrs L. Robinson 831/01 Ms A. How 833/01 Mr J W Harvey 834/01 Mr & Mrs G. Benson 844/01 Mrs R. Rodrigues 846/01 Equinox Jewellery Design Studio 876/03 Mr P Smith & Miss Laverack 878/01 Equinox Jewellery Design Studio 881/01 The Vanity Box 884/01 R. Horlock 885/01 Mr & Mrs A.A. Sando 887/01 Mrs G. Stripp 888/01 Dr & Mrs Garside 889/01 Mr & Mrs G.R. Morris 892/01 Ms M. Easton 899/01 Mr J.G. Anderson 900/01 Ms A. Curlenu 901/01 Ms K. Stickley 902/01 Ms N. Taplin 903/01 Ms B. Nye 904/02 Mr & Mrs Sawyers 905/01 Mrs S. O'Keeffe 906/01 Mrs E. Marinos 912/01 Ms Y. Fisher 914/01 Ms S. Fisher 919/01 E. Fisher-Brown 921/01 Mrs S. McClement 924/01 Mr & Mrs J.M. Gordon 925/01 Mrs E. Potten 927/01 Ms S. Faulkner 928/01 Mr C.J. Piner 929/01 Mr N. Bowan 930/01 B & P Hooper 931/01 Mrs K. Delasalle 934/01 Mr R. H Lenton 987/01 Mr D. Amor 996/01 Mr T.J Stacey 997/01 HSBC PLC 999/01 BE & SP Hart 1079/01 Ms A. Upson 1086/01 N.D & V.B Wakefield 1089/01 Mr & Mrs D. Saward 1090/01 Mrs A.M Girdlestone 1091/01 D. Edney 1107/01 Mr V. Tye 1114/01 Miss K. Chapman 1117/01 Wok-u-Like 1120/01 Mrs V. Simpson 1123/01 Mrs J.B Lenton


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1124/01 S.G Doree 1125/01 H. Boran 1126/01 Mr A. Piccluto 1127/01 Mrs L. Morphew 1133/02 Mrs M. Bullimore 1135/01 Mrs J. Nicholls 1273/01 Woodhall Properties 1307/01 Mr M.W Nicholls 1308/01 Mr P. Clark 1309/01 J.A Mackenzie 1312/01 Mr P H L Worth 1313/01 Dr & Mrs S West 1317/01 A C Bearne 1321/01 M Hunt 1322/01 Mr J Donovan 1323/01 Stadium Sports Ltd 1344/01 Mr & Mrs A F Skelton 28/01 Mr P Lardi 102/07 Mr & Mrs C West 419/02 The Book Centre 420/01 Hoddesdon Retail Association


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H5 LONG TERM HOUSING ALLOCATIONS: CHESHUNT SOUTH RESERVOIR (H3-4) Objections - First Deposit 17/02 Mr A. I Watt 30/05.06 Mr & Mrs R Clarke 40/01 S.F Emmett 154/01 Mr & Mrs D. Parker 166/04 Mrs J. Turner 174/03 R. Gardner 186/01 The Occupier 215/011 RSG Properties Ltd 223/01 Mr & Mr & Mrs Vassiliou 249/03 Mr R. Ponder 250/04 Mrs M. Ponder 259/01 Mrs A.L. Webb 262/01 Mr A.G. Smiley 285/01 Mr & Mrs Dean 313/01 Mr J Emmett 358/01 J.P Amos 359/01 M. Gregory 360/01 Ms N. Mezen 362/01 Mr & Mrs P. Linwood 363/01 Mr & Mrs Grenwood 364/01 Mr & Mrs & Miss French 365/01 Ms S. Peck 366/01 Mrs M. Austin 367/01 Mrs I. Roskhams 368/01 Mr & Mrs Harrison 369/01 Ms K. Bulch 370/01 M. Whitmore 372/01 Mr J. Shore 373/01 Mr & Mrs E. Melton 374/01 N. Mathews 408/03 Mr & Mrs L. Boland 471/010 Mrs I. Beard 478/01 Mr & Mrs A. Grix 493/01 Ms J. Bridgewater 511/01 Mr & Mrs A. Green 562/01 The Wormley Society 581/01 Mr & Mrs Taylor 583/02 Mr A. Barter 584/01 Mrs S. Green 616/010 Ms C. Haigh 617/01 Mr R. Brinton 619/02 Ms T. Purcell 620/01 Mr S. Shepherd 635/04 Mr S. Ribbons 636/02 Mrs J.E Petts


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637/02 Ms L. Ribbons 638/01 Mr J. Holdsworth 639/01 Mrs P. Holdsworth 646/01 C. Wilkinson 647/01 Mr J. Gibbs 648/01 V. Whines 649/01 K. Gibbs 650/01 Ms I. Whines 651/01 Miss J. Frisby 653/01 Mr N. Wilkinson 654/01 Ms K. Wilkinson 655/01 Mr C. Wilkinson 656/01 Mr B. Newman 657/01 Ms A. Seymour 658/01 Mr S. Wilson 659/01 Ms K. Whines 665/01 Ms D. Venables 667/01 Mr R. Bouttwood 668/01 Mrs J. Kelly 669/01 Mrs Heracleous 670/01 Ms I. Morgan 671/01 D. Morgan 672/01 Mr J. Wilson 673/01 Ms S. Georgeson 674/01 Ms G. Coomes 675/01 Mrs S. Cecil 676/01 Mr M. Cecil 677/01 Mr S. Minors 678/01 Ms P. Jordan 679/01 Ms R. Heracleous 680/01 Mr R. Amey 681/01 C.L. Bedford 682/01 Miss L. Gallagher 683/01 Mr & Mrs G.R Livermore 685/01 Mrs W. Morris 686/01 Mr A. Wilson 687/01 Mr A. Blackman 692/01 Ms A. Wilson 739/01 Mrs S. Brown 757/01 J Sturgeon 772/01 Mr & Mrs Wren 775/01 Mrs C. Melton 781/01 Mrs J. Smith 842/01 Mr G. Adams 857/01 Mrs M. Adams 861/01 W. Prior 864/01 Mr R. Adams 868/01 Mr D. Heiden 886/01 Mr & Mrs Dukes 933/07 K. Fedorowick 1009/034 English Nature 1015/02 Thames Water Property


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1100/019 Herts & Middlesex Wildlife Trust 1314/02 E Munro 1319/01 Mrs J.M. Hillman Objections - Second Deposit 1015/01 Thames Water Property


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EMP11 �4.9.4 � 4.9.8 ST MARYS SCHOOL, RESERVE SITES AT PARK LANE, CHESHUNT AND JONES ROAD, GOFFS OAK Objections - First Deposit 613/01 Mr M. Fry 574/01 Woodside School 616/03 Ms C. Haigh 471/01 Mrs I. Beard 282/07, 350/02

Friends of Cheshunt Park Mr & Mrs V Redmond

156/01 Mr E. Dickens 837/01 Mrs S. Pugsley 616/09 Ms C. Haigh 838/01 Mr J. Pugsey 576/01 Mr A. Hood 474/01 Mrs S. Butcher 622/02 Miss M. Bloomfield 616/01 Ms C. Haigh 593/02 R.M.Solly 107/02 Mrs F Young 618/02 S Brooks 590/01 Ms J Tillbrook 586/01 Mr & Mrs T Slabber 587/01 Mr & Mrs Mayo 589/01 Mr & Mrs R Ashley 578/01 Mr & Mrs J Wilkins 592/01 Mr & Mrs T Shutler 593/01 R.M.Solly 594/01 Mr & Mrs M Wigglesworth 596/01 Mr & Mrs A Parker 599/01 Mr & Mrs C R Dixon 588/01 The Occupier 352/01 Mr & Mrs Kimsey 591/01 Mrs A Ramsey 351/01 S.D.Paine 600/01 Mrs E.R. Waller 573/01 LD & DA Kitcher 282/05 Friends of Cheshunt Park 579/02 Mr & Mrs Forde 348/01 Mr & Mrs T.A. Clark 580/01 Mr M .Atkinson 354/01 Mr & Mrs M.G.Barnard 425/01 Mrs S. Biffen 497/01 R & S Philo 239/01 Woodside Primary School PTA 614/01 Mr O. Chard 579/01 Mr & Mrs Forde 266/01 Mr G.Chilcott 326/01 J.F.Tootill


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915/01 Mr W.D.Jackson 600/02 Mrs E.R.Waller 933/01 K.Fedorowick 569/01 Mr & Mrs D.Dickinson 933/09 K.Fedorowick 939/01 J.Clune 108/02 Mrs K.Hughes 192/07 Mr M.Kousoulou 908/01 Mr & Mrs .A. Roper 916/01 Mr & Mrs W.D.Jackson 935/01 J.Taggart 910/01 Mr & Mrs D.Hummerston 314/01 Mrs D.Holden 920/01 R & J Rooke 327/01 P.H.Hitchcock 329/01 Mr L.J.Arches 330/01 F.A.Spring 339/01 Mr B. Armitage 340/01 Ms K.Armitage 341/01 Mr & Mrs J.E & M. Johnston 342/01 J.Allen 343/01 Mr & Mrs J.Colley 344/01 Mr & Mrs M.Bird 345/01 E.E.Easton 350/01 Friends of Cheshunt Park 265/03 Ms S.J.Storey 612/01 Mrs D.Atkinson 601/01 Mr & Mrs G.Whittaker 603/01 Ms J.Grossman 604/01 Mr M.Lessons 605/01 Mr D.G.Tillbrook 606/01 Mr & Mrs P.F.Shepherd 607/01 Mr & Mrs S.J.Shipp 608/01 Mr & Mrs J.Bottoms 609/01 Mr & Mrs G.Barlow 611/01 Mr & Mrs B.Linsell 577/01 Dr A.Mukherjee 616/02 Ms C.Haigh 894/01 Mr W.Heblich 1315/01 Mr & Mrs Roach 575/01 Mr J.C Ablitt 571/01 Mrs P.I.Dafforn 610/01 Mr V.H.Stratford 567/01 Mrs T.M.Butler 951/01 E.A.Walker 950/01 Mr & Mrs Reeves 624/01 Ms G.Rist 623/01 Mr M. Al-Jabban 502/01 A.Hughes 895/01 Mr & Mrs Milton 568/01 Mr & Mrs M.Cotsworth


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Borough of Broxbourne · 1.7.2 The Council has proposed an acceptable change to deal with the...

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Transcript of Borough of Broxbourne · 1.7.2 The Council has proposed an acceptable change to deal with the...