Regulation 18 Draft Local Plan Consultation 16 July -18 ... · Regulation 18 Draft Local Plan Consultation 16 July -18 September 2016 Council Responses ... Moore, Mr Gareth Morgan,

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Regulation 18 Draft Local Plan Consultation

16 July -18 September 2016

Council Responses

Planning Policy Team

October 2017

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Contents

Introduction to this document ..................................................................................... 4

List of Consultees ....................................................................................................... 5

Comments Received and Council Responses

PART 1: INTRODUCTION

Chapter 1: Introduction ............................................................................................... 9

PART 2: DEVELOPMENT STRATEGY

Chapter 2: Vision and Objectives ............................................................................. 16

Chapter 3: Development Strategy ............................................................................ 23

PART 3: PLACES

Chapter 4: Sustainable Place-Making ...................................................................... 29

Chapter 5: Brookfield ................................................................................................ 30

Chapter 6: Broxbourne ............................................................................................. 80

Chapter 7: Cheshunt ................................................................................................ 92

Chapter 8: Goffs Oak and St James....................................................................... 147

Chapter 9: Hoddesdon ........................................................................................... 208

Chapter 10: Park Plaza .......................................................................................... 250

Chapter 11: Waltham Cross ................................................................................... 258

Chapter 12: Wormley and Turnford ........................................................................ 272

Chapter 13: Lee Valley Regional Park ................................................................... 277

Chapter 14: Countryside ........................................................................................ 289

Chapter 15: The New River .................................................................................... 299

Chapter 16: Gypsies, Travellers, and Travelling Showpeople ................................ 307

PART 4: INFRASTRUCTURE AND DELIVERY

Chapter 17: Infrastructure ...................................................................................... 315

Chapter 18: Planning Obligations and CIL ............................................................. 315

Chapter 19: Implementation ................................................................................... 339

PART 5: DEVELOPMENT MANAGEMENT POLICIES

Chapter 20: Design and Sustainable Construction ................................................. 341

Chapter 21: Housing .............................................................................................. 354

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Chapter 22: Economic Development ...................................................................... 376

Chapter 23: Retail and Town Centres .................................................................... 382

Chapter 24: Open Space, Recreation, and Community Facilities .......................... 391

Chapter 25: Water .................................................................................................. 407

Chapter 26: Green Belt .......................................................................................... 431

Chapter 27: Natural Environment and Biodiversity ................................................. 455

Chapter 28: Environmental Quality ........................................................................ 470

Chapter 29: Heritage Assets .................................................................................. 483

Chapter 30: Transport and Movement.................................................................... 507

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Introduction to this document

A consultation on the first full draft of the Broxbourne Local Plan was held between

18 July and 16 September 2016. The consultation was carried out in accordance

with Regulation 18 of the Town and Country Planning (Local Planning)(England)

Regulations 2012 (‘the Regulations’). A Consultation Action Plan was agreed by

Cabinet on 12 July and was implemented as planned (see Table 1 below). It is

estimated that in total 600-700 people attended the three public events, each of

which consisted of a presentation followed by a 2-3 hour question and answer

session with the panel. There was extensive media coverage in the local press.

Responses were received through a mixture of different channels, including by letter,

email, and directly through the online consultation portal. A full list of all the

respondents is provided below. All the responses were then been either copied and

pasted (in the case of email) or typed up (in the case of letters) and entered against

the appropriate point in the draft Local Plan (e.g. policy, paragraph number). In total

there were over 2,000 separate comments. All the comments submitted to the

Council were published on the online Consultation Portal.

Council Responses

This document sets out the Council’s responses to the issues raised. In some cases

the same issue was raised by a number of different consultees. In such cases the

issue has been summarised and a single response provided, and the comment IDs

for each individual or organisation are indicated in the response table.

Pre-Submission Local Plan

The issues raised have been taken into account in the preparation of the Regulation

19 Pre-Submission Local Plan, October 2017. A summary of the main changes to

the Pre-Submission Local Plan has been published in the Local Plan Update Report

(Cabinet, 31 October 2017). The Council considers that the amended Local Plan is

sound and, unless critical issues arise as a result of the Pre-Submission

consultation, intends to submit the revised Local Plan to the Planning Inspectorate

by 31 March 2018. Following the Pre-Submission Consultation the Council will

prepare a Consultation Statement which will summarise the main issues arising. The

Planning Inspector will consider any outstanding issues through the examination

process.

For further information please see the Council’s website at

www.broxbourne.gov.uk/localplan

http://www.broxbourne.gov.uk/localplan

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Table 1: Consultation Action Plan agreed by Cabinet, 12 July 2016

Action Timings Team responsible Details/format

Press briefing

Friday 8 or Monday 11 July

Comms to organise Information to be embargoed until close of Cabinet Meeting on 12 July

Staff briefing July Comms to organise Planning to present

To be compulsory for all staff to attend; Three separate sessions for staff to choose from

Press releases

Details of Local Plan Events and consultation process – 12 July

Comms 1. To encourage public attendance at the events

2. To encourage people to take part in the consultation

Canopy/letter footer/franking machine

From 19 July Comms Message: ‘Have your say on the Borough’s Local Plan’

Letter to stakeholders

Immediately after 12 July Cabinet Meeting

Planning 1. To promote awareness of the consultation

2. To fulfil statutory requirements

FAQ document

To be finalised by 12 July

Planning To be sent to all members and published on the Council’s website

Public Events (all at 7pm)

The Spotlight, Hoddesdon, (Thursday 28 July); Wolsey Hall, Waltham Cross (Thursday 25 August); Goffs Oak Village Hall (Wednesday 7 September)

Comms to organise Leader, Portfolio Holder and Planning to represent the Council on the day The Leader to Chair the events

Same format at each event: Introduction by the Leader; About Broxbourne video to be shown prior to start of the session as people arrive; Presentation by Planning on the consultation process and key elements of the plan; Panel Q&A session – Councillors and planning officers

Broxbourne Life (Council Magazine)

To be distributed to residents week commencing 18 July

Comms Planning

Special ‘Local Plan’ edition. To include dates for Local Plan Public Events.

Posters

Have your say - July/August

Comms To be put up across the Borough, in the Borough Offices and in the One Stop Shops

Local Plan update e-newsletter

July edition Planning Distribution to all Broxbourne

Councillors and to planning policy

contacts database.

Mercury advert To be published on 21 July

Comms Statutory notification of the Local Plan consultation period and availability of documents.

Electronic media

Ongoing Comms Twitter campaign E-communications to residents Homepage of the Council’s website

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List of Consultees/Respondents

Individuals:

Mr Andrew Anderson, Mr Mario Angeli, Ms Jill Avery, Graham Aylott, D G Baker, Mr

Andrew Baker, Patricia Ball, Mr Gary Barton, Mrs M Bassett, V Bates, Mr & Mrs

Bavetta, Mrs Beeton, Mr J Beeton, Mr David Bilton, Mr Paul Bird, C Bith, Beryl

Bottoms, Mrs Carol Bowman, Mr Neil Boyle, Mr Nick Bray, Mr V Brockwell, Mr

Anthony Brogan, Mr R D Brooks, Mrs Jane Brooks, Mr Chris Bryne, Mr Simon Butler,

Peter & Nicola Buzzard, Mr Daniel Byne , Ruth & Paul Cable, Mr Ian Cargill, Mr Tom

Carroll , Mr Richard Caselle, Mr Terry Casey, Mr Alan Caslake, Marion Caslake, Mrs

Betty Castle, Mark Chaplin, Mrs Q Cheetham, P.D. Churchill, S Clinton, Ms Christine

Coffield, Ms FrancescaCole, Donna Cooksley, Ann Corgan, Mr Corgan, Ms Bernice

Cornell, Mr Andrew Cosgrove, Steve and Linda Coster, Christopher and Evelyn

Cotter, Mrs C Cottrell, Mr & Mrs Michael Crane, Mr Richard Crouch, Mr Gary

Crowder, Mr Scott Cummines, Mr Nick D’Agati, Ms Alison Dark, Ms Leena Dattani-

Demirci, Mr Gavin Dean, Mr Ian De’ath, Mr Michael Demetriou, Mr James

Detheridge, Joshua Draper, Mr W Eatson, Gerry Fagan, Ms Marion Fieldhouse, Mr

Stewart Fixter, Mr Alan Flook, Mr Jason Folliard, Mr Bob Forrester, Mr S Garp, Ms

Denice Gately , Mr & Mrs Gaunt, Stephen Gerrard, Mr Ronald Gibbs, Mr Stephen

Gollop, Mr I Goodridge, Mrs Katherine Goodridge, Mrs Evelyn Greenwood, Mr & Mrs

B Grew, N.G. Griffth, Ms Julie Hall, Bill Hall, Mrs Jennifer Hammond, Mr Peter

Hanna, Theodora Hannah, Mr Geoff Hayden, Mr William Hayden, Mrs Lorraine

Hayes, Mr Peter Haynes, Mrs Alison Heine, Mr R Henbest, Mrs V J Henbest, Mr

Mark Henderson, Mr Kenneth Hendley, Mr Stephen Hounslow, Ms Lynda Howard,

Mr P Howard, Mrs Betty Howard, Jean Huggett, Mrs Lisa Hughes, Mr A.E. Hughes,

Mr Ryan Hussey, Ms Janet Jackman, Mr Malcolm James, Mrs B A Jarrington-

Howard, Mr Stuart Jarrold, Ms Lorraine Jennings, Mr & Mrs Keilty,Bryan & Josephine

Kennett, Gokmen Kerey, Gill Kimsey, Carol Knapp, Mrs Laud, Ms Marion Le

Gresley, Ms Zoe Leaver, Mrs Ingrid Lewis, Ms Janet Lodge, Ms Jane Lovelock, Mrs

Gillian Ludlam, Mr Constantine Malekkou, Ms Elizabeth McKenna, Mrs Patricia

Mellis, Miss Paula Mellon, Mr Jim Metcalf, Mr A Methven, Mr & Mrs E Milburn ,Mr

Martin Miles, Ms Wilma Mitchell, Mr Mark Montgomery, Mr & Mrs K Moon, Mr John

Moore, Mr Gareth Morgan, Ms Laura Morris, Mr Brian Morris, Ms Wendy Morris, Mr

Anthony Moss, Hugh Moultrie, Ms Penelope Mukherji, Mrs Rosemary Musicka, John

Needle, Mr & Mrs John & Denise Needs, Mr WJ Nevard, D Newman, Mrs J

Newman, Abbie Newman, Mr Keith Noble, Ms Carole Norris , Mr Graham Nuttall,

Gwennie Oakley, June Oakley, Mr Alan P, Mr Sid Paine, Ms Lyndsey Parker, Mr

Rob Pearce, Mr Terry Pearson, Ms Bridget Perez, Mrs Susan Perfect, Mr Adrian

Petty, The Pratley Family, Mrs Sara Priestley, Mr Andrew Proctor, Rosie Rama,

Jetmir Rama, Mrs A Ramsay, Miss Jemma Regis, Mary Rensten, John & Eileen

Richards, Mr Matthew Ridley, Elaine Rockall, Mr David Rogers, Mrs Susan Rogers,

Sharon Rogers, Mr Roper, Chris Schwalm, Mr Mark Scrutton, Christian Secondis, Mr

Michael Sheehan, Mr Eric Smith, Mr J.M. Spagnuolo, Roy Solly, Mr Stephen

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Songaila, Mr J Southey, Mrs L Southey, Mrs Spikesly, Mr Derek Staines, Mrs

Kathleen Stewart, Drs Carole & David Storey, Mrs Sue Storey, Mr Richard Scott

Streater, DG and JB Sturman, Mr Mark Tate, Mr D Thomas, Mr Ian Thompson, Mr

Ken Travers, Denise Travers, Dr Ian Tucker, Mr Nick Turnbull, Ms Hazel Turnbull, J

Turner, Ms Linda Wacey, Mr & Mrs L Wade, Anastasia Walker, Mr Stephen Waller,

Mr A Warren, Mrs P A Warren, Miss Katherine Watson, Ms Susan Wellbeach, Mrs

Angela White, Mr Les Whitmore, Ms Christine Williams, Mrs Sarah Willis, Mr Robert

Willis, Mary Wilson, Mr Richard Wilson, Mrs J Wood

A petition regarding Goffs Oak Village Green and Woodside Primary School was

submitted through the draft Local Plan consultation by the Goffs Oak Community

Association on behalf of local residents.

Organisations:

B3 Living Ltd, British Horse Society, Broxbourne Woods Area Conservation Society,

Campaign to Protect Rural England Hertfordshire (CPRE), Canal and River Trust,

Cheshunt Bowls Club, Cheshunt Club, Conservators of Epping Forest - City of

London, East Hertfordshire District Council, Joint Response from East Hertfordshire,

Epping Forest, Harlow and Uttlesford District Councils, Enfield Council, Environment

Agency, Goffs Oak Community Association, Greater London Authority, Harlow

Council, Hertfordshire County Council - Minerals and Waste Policy Team,

Hertfordshire County Council (Development Services), Hertfordshire Local

Enterprise Partnership, Herts and Middlesex Wildlife Trust, Highways England,

Historic England, Kings Arms & Cheshunt Angling Society, Lea Valley Growers

Association, Lee Valley Regional Park Authority, National Grid, Natural England,

Network Rail, NHS England/NHS East and North Herts CCG, Public Health Service,

Hertfordshire County Council – Spatial Planning, Royal Mail Group, Spitalbrook

‘Village Green’ Conservation Group, Sport England, Transport for London - Property,

Thames Water Utilities Limited, The Hoddesdon Society, The Waltham Cross and

Cheshunt Chamber of Commerce, The Wormley and Turnford Society, Three Rivers

District Council, Transport for London, Veolia, Welwyn Hatfield Borough Council,

Windmill Residents Association, Wormleybury Management Limited, Woodland

Trust.

Developers, Landowners and Planning Organisations:

Aldwyck Housing Group, Bayfordbury Estates Ltd, Derek Bromley, Brookfield

Property Unit Trust, Mr Humphrey Brosnan, Mr Robert Brunton, Capital and Country

Holdings Limited, Catesby Property Group, CEG, CODE Development Planners Ltd,

Constable Homes Ltd, Co-op, Countryside Properties (UK) Ltd, Crest Nicholson, De

Merke Estates, Derrick Wade Waters, Mr Stephen Liddard, Derwent London,

Frontier Estates Limited, Harvey Family, Hertfordshire County Council (Property),

Home Builders Federation Ltd, Hubert C Leach, Mr Adam Hunt and Petts Family,

Inland (Stonegate) Ltd, JEA Manning & Sons Ltd, Landowners of land to the east of

Newgatestreet Road, Lands Improvement Holdings Landmatch s.a.r.l., Messrs,

Lambe and Rafferty, Lindhill, Maxwell Family, Nicholas Graham Ltd, Plainview

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Planning Ltd, Planware Ltd, Receivers of Brynfield Nursery and Landchain, Redrow

Homes Ltd, Mr Joe Ricotta, Jeanette Spencer, Taylor Wimpey Strategic Land,

Templeview Development Ltd, Tesco Stores Limited, The Enfield Gospel Hall Trust,

Trent Developments, Weston Homes PLC, Woodhall Properties

Other:

Eurovia Infrastructure Limited, G & C Produce Limited, JBA Hire Services Ltd, John

Lewis Partnership, Kentucky Fried Chicken (Great Britain) Limited, Sainsbury’s

Supermarket Limited, Tesco Stores Limited and Marks and Spencer PLC, Wickes

Building Supplies Limited

Broxbourne Local Plan Regulation 18 – Council Responses (October 2017)

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Chapter 1: Introduction

Issue No.

Comment ID

Paragraph/Policy No.

Issues Raised Council Response Amendment to the Plan

Introduction to the Local Plan

1.1 PO2198 Introduction to the Local Plan

Concern that the Borough will not be able to cope with additional residents due to the Council’s plan to reduce amenities in the area to save money.

To support the Local Plan, the Council has produced an Infrastructure Delivery Plan (IDP) that details the infrastructure, which includes roads, schools, health facilities etc., that is needed to support the proposals contained within the emerging Local Plan.

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1.1 PO1729 Introduction to the Local Plan

The Plan contains too many general statements about plans/proposals that refer to further consultation going to happen.

The statements reflected that some explanation of the process was felt to be helpful during the Regulation 18 draft Local Plan stage.

These references have been removed from the pre-submission draft Local Plan 2017.

Paragraph 1.1

1.3 PO992 Paragraph 1.1 Welwyn Hatfield Borough Council (WHDC) notes that the Plan envisages an end date of 2031. WHDC comment that even with the extremely ambitious production deadline prior to Regulation 19 consultation, it is considered unlikely based on current examination progress of Local Plans elsewhere that the Plan could be adopted before 2018. This would result in a plan period length of potentially only 13 years. The Government’s Planning Practice Guidance (para 157) advises a minimum plan period length of 15 years from adoption in order for longer term development needs to be sufficiently accommodated. Welwyn Hatfield Borough Council comments that whilst there is scope to justify a shorter plan period, they have not been

Agreed. The National Planning Policy Framework (NPPF) advises in paragraph 157 that Local Plans should “be drawn up over an appropriate time scale, preferably a 15 year time horizon”. The Council has recently updated its Local Development Scheme which anticipates adoption of the Plan to be in June 2018, therefore, to ensure that there is a 15 year plan period from adoption the Council will extend its Plan period to 2033.

Plan end date extended to 2033.


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able to identify anywhere that this has been done.

PO992 Paragraph 1.1 Welwyn Hatfield Borough Council comments that if a shorter plan period cannot be justified and a plan period through to 2032/2033 is required, the Borough’s housing need will be higher. This would likely exceed the available supply of sites within the Borough.

Need accommodated principally by additional homes at Cheshunt Lakeside.

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Paragraph 1.1 Concern that the Plan period is too short. By the time is adopted, the 15 year period will extend to 2032 or 2033.

Agreed. The National Planning Policy Framework (NPPF) advises in paragraph 157 that Local Plans should “be drawn up over an appropriate time scale, preferably a 15 year time horizon”. The Council has recently updated its Local Development Scheme, which details the timeline for the Local Plan. The updated timelines anticipates adoption of the Plan in June 2018, therefore, to ensure that there is a 15 year plan period from adoption the Council will extend its Plan period to 2033.

The Council will amend the Plan period from 2014-2031 to 2018-2033.

Paragraph 1.2

PO1087 Paragraph 1.2 Tesco and M&S are supportive of the preparation of the new Local Plan and they seek to help constructively facilitate the delivery of sound planning policy which is positively prepared, justified, effective and consistent with national policy.

Support noted. -

Paragraph 1.4

PO1056, PO1052

Paragraph 1.4 Highways England note the intention to publish the Regulation 19 plan by the end of 2016, yet to-date the Council has not published the necessary supporting Infrastructure Delivery Plan or Transport Strategy. Different parts of the plan

The Broxbourne Transport Strategy has now been published and is made available for public consultation. Broxbourne Council has worked closely with Highways England in sharing data to progress.

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indicate that the draft Transport Strategy could either be published in late 2016 or early 2017. Highways England comments that the soundness of the plan will only be assessed in the light of all relevant, therefore the Council should look to publish all relevant supporting material at the time of Regulation 19 consultation or before. Highway England states that they stand ready to assist the Council and/or its transport consultants as it is able.

Paragraph 1.10

PO1067, PO1052

Paragraph 1.10 Highways England note that it appears that the policies set out in the draft Local Plan are broadly consistent with the NPPF, although in order to demonstrate soundness a robust evidence base will need to be developed. Therefore, Highways England reserve judgement as to the soundness of the Plan at this stage, particularly in the absence of the transport strategy for the Local Plan and further details of transport capacity measures and requirements

Understood. The Broxbourne Transport Strategy has now been produced with engagement with Highways England.

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PO1052 Paragraph 1.10 Highways England raise concern about whether the transport related evidence base is sufficiently appropriate, up-to-date, transparent and robust, such that it can be deemed sound. For example, the most recent modelling was produced in 2010.

The Council has subsequently prepared a transport strategy report, accompanied by a package of mitigation measures relating to all modes of transport, and informed by extensive transport modelling.

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PO1052 Paragraph 1.10 Highways England states that the transport evidence base was a particular area of concern at the previous 2011 Core Strategy Examination and in the subsequent Inspector’s Report. Therefore, the Council should provide evidence as how the identified shortcomings have been

The Council has subsequently prepared a transport strategy report, accompanied by a package of mitigation measures relating to all modes of transport, and informed by extensive transport modelling.

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addressed; and on what basis is the modelling can still be relied upon in the currently and likely future circumstances. For example, how does it take account of changing development needs and locations within and beyond the Borough, current and forecast traffic levels, and growth on the SRN and local networks etc.

PO1052 Paragraph 1.10 Highways England note that the evidence base should cover an appropriate area; for transport this may be beyond the Borough boundary, for example where traffic from a number of authority areas converges on a junction such as M25J25 or depending upon the level of development proposed, in this and or other plans, further afield such as the A1(M) and M11.

To inform the Council’s transport strategy, the Council’s preferred package of interventions has been tested on the county-wide COMET model. There are many advantages to the use of this model, one of which is that due to it being a strategic model it will enable the cross-boundary cumulative impacts of development to be properly understood.

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PO1052 Paragraph 1.10 Highways England note that the evidence base should also ensure that it assesses the individual and cumulative impacts of development within the study area over the whole plan period and, as necessary, at various intermediate dates to identify any tipping points when action will be required.

To inform the Council’s Transport Strategy, the Council’s preferred mitigation measures has been tested on the county-wide COMET model.

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PO2113 Paragraph 1.10 The Public Health Service recommends that the Council consider utilising the available data, evidence and intelligence available from Public Health England and the Hertfordshire JSNA to inform and support the monitoring of the Local Plan policies. The Public Health Service notes that at the heart of the Local Plan is the need to address many challenges which all contribute to creating a healthy Borough. In order to understand progress there needs to be sufficient evidence and baseline information about the

Agreed. This is addressed through the Infrastructure Delivery Plan.

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health of the current community.

PO2114 Paragraph 1.10 The Public Health Service recommends that the Council consider the use of a Health Impact Assessment (HIA) for strategic sites, if not the Local Plan itself. The Public Health Service notes that a (HIA) can provide recommendations to increase positive health impacts and minimise adverse health outcomes and that it brings potential public health impacts and considerations to the decision-making process for plans, projects and policies that fall outside the traditional public health arenas.

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PO1724 Paragraph 1.10 Natural England notes that some of the evidence base documents are a number of years old. They comment that the Local Plan should be underpinned by up to date environmental evidence, which should include an assessment of existing and potential components of ecological networks working with Local Nature Partnerships, the local record centre and other relevant bodies to ensure that land of least environment value is chosen for development, and to ensure the mitigation hierarchy is followed.

On behalf of the Council BSG ecology carried out Ecological Assessments for the Local Plan Areas of Search (2012) and also for Brookfield (2014). Furthermore, a Habitats Regulations Assessment has been carried out during 2017.

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Paragraph 1.11

PO730 Paragraph 1.11 Concern that the Sustainability Appraisal for the draft Local Plan does not clearly show how there has been an informed choice of options for the urban extension on the western side of Brookfield, instead it looks at the least worst options and uses terms like ‘there is the potential for development at Brookfield to affect the setting of Wormleybury Manor’ and ‘this is

The Sustainability Appraisal flags up any potential impacts. Specific impacts will depend very much on the detailed design and planning, which will be a matter for the planning application. The Council has undertaken high-level options testing which is set out in the Brookfield Development Options study (April 2017), underpinned by

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considered unlikely [authors emphasis] given the woodland that screens Wormleybury Manor from the Brookfield site’.

high-level masterplanning work.

PO975 Paragraph 1.11 Concern regarding the cost of the preparation of the Local Plan, particularly when the Council claims it must save millions over the next four years

The preparing of a Local Plan is a statutory requirement placed on local planning authorities by the National Government. The National Planning Policy Framework requires local plans to be based on up-to-date and relevant evidence on economic, social and economics characteristics and prospects of the area. The production of evidence base documents to support the Local Plan is a costly, but necessary measure.

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Paragraph 1.13

PO412 Paragraph 1.13 Concern regarding the omission of the Lee Valley Navigation, which forms part of the Borough and County boundaries and were an important transport link in the past, from this paragraph.

Agreed. Amend paragraph 1.13 to refer to the River Lee Navigation as forming the eastern boundary of the Borough.

PO607 Paragraph 1.13 Historic England comment that it would be helpful to make reference to this historic environment and the important role it has shaping the Borough.

The Council agrees that historic environment has played an important role in shaping the Borough; however feel that it would be inappropriate to add a reference to this within Paragraph 1.13 as this is providing a geographical overview of the location of the Borough.

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Paragraph 1.17

PO842 Paragraph 1.17 The reference to Crossrail 2 within this paragraph could be strengthened by making a reference to this Borough Council’s support for the project.

The Council’s support for Crossrail 2 is highlighted in Policy INF3 and in the Vision within Section 2 of the Local Plan. The reference to Crossrail 2 within Paragraph 1.17 is highlighting that there are a number

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of benefits that this scheme could bring to the Borough.

Paragraph 1.18

PO413 Paragraph 1.18 Fishing is a relatively cheap leisure activity and needs to be more accessible to all, where possible.

Noted. -

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About this Consultation and How to Respond

PO492, PO1168

About this Consultation and How to Respond

Concern regarding the planning of the consultation. Issues include the consultation taking place during peak holiday season, poor distribution of leaflets, timing on consultation events and venue choices.

Under Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012, the Council has a statutory duty to consult on the Local Plan. The Council acknowledges that the consultation took place during peak holiday season, however the Council’s consultation period was for 8 weeks; 2 weeks longer than that required. A Consultation Action Plan was agreed by Cabinet containing a full programme of publicity, and significantly exceeding the statutory requirements.

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PO1160 About this Consultation and How to Respond

Concern regarding the consultation with the residents of the Wormleybury Management Estate, who are a “community interest group” living on the Wormleybury Manor Park Estate. It is noted that the Broxbourne Council’s Statement of Community Involvement states that “A pubic consultation on the draft document between the 1st March and 15th April 2016, and the responses received were used to shape the final document”. The residents of Wormleybury Manor Park estate were not consulted or invited to take part in the consultation helping to shape the Local Plan.

Shaping of the emerging Local Plan is an ongoing process, which includes the period before, during, and after the Regulation 18 draft Local Plan consultation. Initial concepts were first publicised in the Duty to Co-Operate Framework Document in October 2015. A meeting was held with the Directors of Wormleybury Manor Park Estate to discuss the emerging Local Plan on Wednesday 10 August 2016.

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Chapter 2: Vision and Objectives

Issue No. Comment ID(s)

Paragraph/ Policy No.

Issue Officer Response Proposed amendment to the Plan

2.1 PO608 Vision and Objectives

Historic England broadly welcomes the overall Local Plan Vision for Broxbourne and mention that historic assets will continue to be protected and enhanced. They advise that the term ‘Historic Environment’ is used instead of ‘historic assets’ as it is a broad term which includes both tangible heritage assets such as Listed Buildings, archaeology etc.

Noted. The term ‘historic assets’ will be replaced with ‘historic environments’.

Proposed amendment to the Plan The last paragraph of the Vision will read as follows “The Lee Valley Regional Park, Green Belt and other important green corridors, landscapes, open spaces and historic assets historic

There was additional consultation on the Statement of Community Involvement. As part of this consultation an e-mail was sent to key and statutory stakeholders informing about the Council’s draft SCI and the consultation period and the consultation was publicised through the Council’s Website and the Local Plan update newsletter. The consultation on the Statement of Community Involvement did not shape the content included within the emerging Local Plan, but identified the consultation methods that were to be used for a number of planning documents within both Planning Policy and Development Management.


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but also the less tangible elements such as cultural heritage and setting.

environment will continue to be protected and enhanced.

PO701 Vision and Objectives

Enfield Council support the vision and overall approach of the draft Local Plan to create a pleasant, prosperous, safe, health and green place where people will want to live, work, do business and spend their leisure time.

Support noted. -


Enfield Council notes that Broxbourne is well placed to benefit from the Greater London Authority (GLA) Upper Lee Valley Opportunity Area and London-Stansted-Cambridge Corridor (LSCC). Through on going and proactive cross-boundary working, including the Enfield, Essex and Hertfordshire Border Liaison Group (Six Authorities) meetings, there is an opportunity for Broxbourne to capitalise on proposals for housing and employment growth, and associated infrastructure proposals within the sub region.

Noted. The Council is working with various groups, including the LSCC, and Six Authorities, to address cross-boundary planning issues.

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Lee Valley Regional Park Authority welcome the support give in the draft Local Plan Vision and Policy DS1 ‘The Development Strategy’ to the Lee Valley Regional Park, the Green Belt and other important green corridors, and the inclusion of the Park boundary on the draft Policies Map.

Support noted. -


Hertfordshire County Council comments that the reference to the Green Belt as an ‘asset’ is incorrect. HCC note that the NPPF confirms that “The fundamental

The Green Belt is a policy designation designed to meet specific purposes set out in national and local policy. However, in the context of a vision for the future, the

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aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open, the essential characteristics of Green Belt are their openness and their permanence”.

aspiration to ensure that the Green Belt is treated as an asset is considered appropriate.

PO1567, PO327

Vision and Objectives

CPRE are concerned that the three elements of the Plan’s proposed vision are unjustified and in conflict with both the concept of sustainable development and national planning policy as set out in the National Planning Policy Framework (NPPF). These are that: development will be focussed on strategic sites, including through the strategic release and allocation of Green Belt sites; Brookfield will be re-modelled and expanded as a mixed use Garden Suburb; and, expanding the local economy will have a focus on high value jobs in new office space at Brookfield, a business campus at Park Plaza North and at Park Plaza West. CPRE comments that these aspirations directly conflict with another key element of the Vision; that the Green Belt and key parts of the Borough’s green infrastructure will continue to be protected and enhanced. The Green Belt will not be protected by the removal of several areas of land from it.

NPPF paragraph 84 states that: “When drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development.” The social, economic, and environmental dimensions of sustainable development should be sought jointly and simultaneously (NPPF paragraph 8). This requires consideration of a balance of factors. Further information on the Council’s approach is set out in the Green Belt Topic Paper (2017).

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PO Vision and Objectives

CPRE comments that the three parts of the proposed vision seem to be specific strategic decisions about how the Council’s vision should be delivered, rather than goals in their own right.

A vision without some strategic content would be vague. The objectives set in this section help to create a thread between the vision and the development strategy in the next chapter.

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Therefore, they should be present as part of the Development Strategy that follows.

Paragraph 2.1

PO414 Paragraph 2.1 Concern that Water Sports, such as angling, sailing and rowing, are not considered within the vision.

Whilst it is not considered appropriate to refer to specific sports within the vision, it is proposed to include a new objective on health and wellbeing which will capture this and other sports.

Health and Wellbeing: Promote active lifestyles by protecting and providing new accessible open space, sport and recreational facilities across the Borough, and encouraging active travel and enjoyment of the Borough’s attractive water and land-based environments.

Paragraph 2.1 Concern that the provisions to enhance Hoddesdon and Waltham Cross Town Centres as popular destinations for shopping, together with other designated district and local centres, will be undermined by the proposals at Brookfield Riverside

To support the Plan, the Council has prepared town centre strategies for Hoddesdon and Waltham Cross, and is in the early stages of preparing a strategy for Cheshunt Old Pond. Through the implementation of the schemes identified within these strategies the Council believes that these centres will be able to thrive. The Council commissioned the Brookfield Retail and Leisure Impact Assessment (2017) to look at the evidence for the impacts of proposals for Brookfield on existing retail centres. The study concluded that the cumulative impacts of the planned Brookfield development and commitments on the vitality and viability of the existing town centres would be acceptable.

Health and Wellbeing: Promote active lifestyles by protecting and providing new accessible open space, sport and recreational facilities across the Borough, and encouraging active travel and enjoyment of the Borough’s attractive water and land-based environments.

PO1053 Paragraph 2.1 Highways England comments that while Junction 25 of the M25 is addressed in the Insert reference to Junction 25 of


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the M25, including J25 are located just outside the Borough, the plan should recognise and incorporate them as appropriate into policies/text etc. For example, while there are some references (eg para 3.62) to working cross-border, there is no specific mention of the likes of M25 or other parts of the SRN in the summary and key points section or the Local Plan vision. Further iterations of the plan should rectify this omission.

Broxbourne Transport Strategy (2017). the M25 under the ‘transport’ objective.

Paragraph 2.2

PO69 Paragraph 2.2 Sport England concerned about the omission of a health and well-being objective. Sport England comment that an objective would have been expected around how the Plan can encourage healthier lifestyles through a range of measures that the local plan can directly influences such as safeguarding and encouraging access to sport, recreation and leisure facilities and encouraging active lifestyles through the design of new development. This is pertinent in view of the statement in the Plan’s summary that the local plan will support the Council’s health and well-being strategy and the importance attached to promoting healthier communities in the NPPF. Sports England request that an additional objective is added to section 2.2 which sets out how the local plan can support Broxbourne’s health and well-

Agreed. The Council is committed to the promotion of health and well-being for all, as shown through its corporate priorities and the publication of its health and wellbeing strategy.

The following objective will be added to Section 2.2 Health and Wellbeing: Promote active lifestyles by protecting and providing new accessible open space, sport and recreational facilities across the Borough, and encouraging active travel and enjoyment of the Borough’s attractive water and land-based environments.


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being objectives through promoting healthier communities including reference to the role that access to open space, sport and recreation facilities can play and the role of design. Subsequent policies and place based proposals should be checked to ensure that they are consistent with delivering such an objective.

PO415 Paragraph 2.2 Concern that the third bullet point demonstrates an inherent bias against aquatic sports, as they by their nature cannot be centralised. The Plan should take them into account or will be failing in its scope, which should be for all sports and leisure activities.

Agreed that as originally drafted the main focus of this objective was on the town centres. A new Objective on Health and Wellbeing will be added in order to broaden the focus away from the town centres and to include a wide range of recreation, including watersports.

Promote active lifestyles by protecting and providing new accessible open space, sport and recreational facilities across the Borough, and encouraging active travel and enjoyment of the Borough’s attractive water and land-based environments.

PO416 Paragraph 2.2 Reference to ecology in the 5th bullet point should include the aquatic environment and not just the terrestrial environment. This is a particular concern due to objections on Hazlemere Marina development regarding the impacts on the aquatic environmental issues were overrode.

The Council considers that the aquatic environment is included within this objective and that there is no need to make a specific reference to the aquatic environment.

-

PO417 Paragraph 2.2 Concern that the 6th bullet point will be used as a reason for reducing road access to areas, where there are no alternatives to driving especially as with an aging population who might be less able to travel by other means, this would be discriminatory and open to challenge in the courts under DDA regulations.

The NPPF states at paragraph 29 that “The transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel. However, the Government recognises that different policies and measures will be required in different communities and opportunities to maximise sustainable

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transport solutions will vary from urban to rural areas.” The Council’s approach as set out in the Local Plan and the Transport Strategy (2017) reflects this national approach.

PO609 Paragraph 2.2 Historic England welcomes the inclusion of the Historic Environment under the Environment objective of the Framework. Historic England advise that the Historic Environment should preferably sit clearly and separately from natural and landscape assets, all of which topics have their own special and very different requirements and considerations.

It is considered appropriate to link these separate topics in this part of the local plan in order to focus on the contribution to local distinctiveness. Separate chapters on each topic later in the local plan contain the separate requirements and considerations.

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Chapter 3: Development Strategy

Issue No. Comment

ID(s) Paragraph/ Policy no.



Historic England broadly welcomes the overall Local Plan Vision for Broxbourne and mention that historic assets will continue to be protected and enhanced. They advise that the term ‘Historic Environment’ is used instead of ‘historic assets’ as it is a broad term which includes both tangible heritage assets such as Listed Buildings, archaeology etc. but also the less tangible elements such as cultural heritage and setting.

Noted. The term ‘historic assets’ will be replaced with ‘historic environments’.

The last paragraph of the Vision will read as follows “The Lee Valley Regional Park, Green Belt and other important green corridors, landscapes, open spaces and historic assets historic environment will continue to be protected and enhanced.


Enfield Council support the vision and overall approach of the draft Local Plan to create a pleasant, prosperous, safe, health and green place where people will want to live, work, do business and spend their leisure time.

Support noted. -


Enfield Council notes that Broxbourne is well placed to benefit from the Greater London Authority (GLA) Upper Lee Valley Opportunity Area and London-Stansted-Cambridge Corridor (LSCC). Through on going and proactive cross-boundary working, including the Enfield, Essex and Hertfordshire Border Liaison Group (Six Authorities) meetings, there is an opportunity for Broxbourne to capitalise on proposals for housing and employment growth, and associated infrastructure proposals within the sub region.

Noted. The Council is working with various groups, including the LSCC, and Six Authorities, to address cross-boundary planning issues.

-


Lee Valley Regional Park Authority welcome the support give in the draft Local Plan Vision and

Support noted. -


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Policy DS1 ‘The Development Strategy’ to the Lee Valley Regional Park, the Green Belt and other important green corridors, and the inclusion of the Park boundary on the draft Policies Map.


Hertfordshire County Council comments that the reference to the Green Belt as an ‘asset’ is incorrect. HCC note that the NPPF confirms that “The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open, the essential characteristics of Green Belt are their openness and their permanence”.

The Green Belt is a policy designation designed to meet specific purposes set out in national and local policy. However, in the context of a vision for the future, the aspiration to ensure that the Green Belt is treated as an asset is considered appropriate.

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2.6 PO1567, PO327

Vision and Objectives

CPRE are concerned that the three elements of the Plan’s proposed vision are unjustified and in conflict with both the concept of sustainable development and national planning policy as set out in the National Planning Policy Framework (NPPF). These are that: development will be focussed on strategic sites, including through the strategic release and allocation of Green Belt sites; Brookfield will be re-modelled and expanded as a mixed use Garden Suburb; and, expanding the local economy will have a focus on high value jobs in new office space at Brookfield, a business campus at Park Plaza North and at Park Plaza West. CPRE comments that these aspirations directly conflict with another key element of the Vision; that the Green Belt and key parts of the Borough’s green infrastructure will continue to be protected and enhanced. The Green Belt will not be protected by the removal of several areas of land from it.

NPPF paragraph 84 states that: “When drawing up or reviewing Green Belt boundaries local planning authorities should take account of the need to promote sustainable patterns of development.” The social, economic, and environmental dimensions of sustainable development should be sought jointly and simultaneously (NPPF paragraph 8). This requires consideration of a balance of factors. Further information on the Council’s approach is set out in the Green Belt Topic Paper (2017).

-

2.7 PO Vision and CPRE comments that the three parts of the A vision without some strategic -


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Objectives proposed vision seem to be specific strategic decisions about how the Council’s vision should be delivered, rather than goals in their own right. Therefore, they should be present as part of the Development Strategy that follows.

content would be vague. The objectives set in this section help to create a thread between the vision and the development strategy in the next chapter.

Paragraph 2.1

2.8 PO414 Paragraph 2.1 Concern that Water Sports, such as angling, sailing and rowing, are not considered within the vision.

Whilst it is not considered appropriate to refer to specific sports within the vision, it is proposed to include a new objective on health and wellbeing which will capture this and other sports.

Proposed amendment to the Local Plan in response to this issue. Health and Wellbeing: Promote active lifestyles by protecting and providing new accessible open space, sport and recreational facilities across the Borough, and encouraging active travel and enjoyment of the Borough’s attractive water and land-based environments.

2.9 Paragraph 2.1 Concern that the provisions to enhance Hoddesdon and Waltham Cross Town Centres as popular destinations for shopping, together with other designated district and local centres, will be undermined by the proposals at Brookfield Riverside

To support the Plan, the Council has prepared town centre strategies for Hoddesdon and Waltham Cross, and is in the early stages of preparing a strategy for Cheshunt Old Pond. Through the implementation of the schemes identified within these strategies the Council believes that these centres will be able to thrive. The Council commissioned the Brookfield Retail and Leisure Impact Assessment (2017) to look at the evidence for the impacts of proposals

Proposed amendment to the Local Plan in response to this issue. Health and Wellbeing: Promote active lifestyles by protecting and providing new accessible open space, sport and recreational facilities across the Borough, and encouraging active travel and enjoyment of the Borough’s attractive water and land-based environments.


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for Brookfield on existing retail centres. The study concluded that the cumulative impacts of the planned Brookfield development and commitments on the vitality and viability of the existing town centres would be acceptable.

2.10 PO1053 Paragraph 2.1 Highways England comments that while the M25, including J25 are located just outside the Borough, the plan should recognise and incorporate them as appropriate into policies/text etc. For example, while there are some references (eg para 3.62) to working cross-border, there is no specific mention of the likes of M25 or other parts of the SRN in the summary and key points section or the Local Plan vision. Further iterations of the plan should rectify this omission.

Junction 25 of the M25 is addressed in the Broxbourne Transport Strategy (2017).

Insert reference to Junction 25 of the M25 under the ‘transport’ objective.

Paragraph 2.2

2.11 PO69 Paragraph 2.2 Sport England concerned about the omission of a health and well-being objective. Sport England comment that an objective would have been expected around how the Plan can encourage healthier lifestyles through a range of measures that the local plan can directly influences such as safeguarding and encouraging access to sport, recreation and leisure facilities and encouraging active lifestyles through the design of new development. This is pertinent in view of the statement in the Plan’s summary that the local plan will support the Council’s health and well-being strategy and the importance attached to promoting healthier communities in the NPPF. Sports England request that an

Agreed. The Council is committed to the promotion of health and well-being for all, as shown through its corporate priorities and the publication of its health and wellbeing strategy.

Proposed amendment to the Local Plan in response to this issue. The following objective will be added to Section 2.2 Health and Wellbeing: Promote active lifestyles by protecting and providing new accessible open space, sport and recreational facilities across the Borough, and encouraging active travel and enjoyment of the Borough’s attractive water and


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additional objective is added to section 2.2 which sets out how the local plan can support Broxbourne’s health and well-being objectives through promoting healthier communities including reference to the role that access to open space, sport and recreation facilities can play and the role of design. Subsequent policies and place based proposals should be checked to ensure that they are consistent with delivering such an objective.

land-based environments.

2.12 PO415 Paragraph 2.2 Concern that the third bullet point demonstrates an inherent bias against aquatic sports, as they by their nature cannot be centralised. The Plan should take them into account or will be failing in its scope, which should be for all sports and leisure activities.

Agreed that as originally drafted the main focus of this objective was on the town centres. A new Objective on Health and Wellbeing will be added in order to broaden the focus away from the town centres and to include a wide range of recreation, including watersports.

Promote active lifestyles by protecting and providing new accessible open space, sport and recreational facilities across the Borough, and encouraging active travel and enjoyment of the Borough’s attractive water and land-based environments.

2.13 PO416 Paragraph 2.2 Reference to ecology in the 5th bullet point should include the aquatic environment and not just the terrestrial environment. This is a particular concern due to objections on Hazlemere Marina development regarding the impacts on the aquatic environmental issues were overrode.

The Council considers that the aquatic environment is included within this objective and that there is no need to make a specific reference to the aquatic environment.

-

2.14 PO417 Paragraph 2.2 Concern that the 6th bullet point will be used as a reason for reducing road access to areas, where there are no alternatives to driving especially as with an aging population who might be less able to travel by other means, this would be discriminatory and open to challenge in the courts under DDA regulations.

The NPPF states at paragraph 29 that “The transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel. However, the Government recognises that different policies and measures

-


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will be required in different communities and opportunities to maximise sustainable transport solutions will vary from urban to rural areas.” The Council’s approach as set out in the Local Plan and the Transport Strategy (2017) reflects this national approach.

2.15 PO609 Paragraph 2.2 Historic England welcomes the inclusion of the Historic Environment under the Environment objective of the Framework. Historic England advise that the Historic Environment should preferably sit clearly and separately from natural and landscape assets, all of which topics have their own special and very different requirements and considerations.

It is considered appropriate to link these separate topics in this part of the local plan in order to focus on the contribution to local distinctiveness. Separate chapters on each topic later in the local plan contain the separate requirements and considerations.

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Chapter 4: Sustainable Place-Making

Issue No.

Policy/ Para. no.

Comment. ID(s) Issue Officer Response Proposed amendments to the Plan

4.1 4 PO1059 Highways England No evidence provided about transport implications (level/location/timing of any impacts and/or mitigation) of the proposals. Evidence base should not just cover named or previously permitted schemes, particularly those located closest to the strategic road network, but also assess impact of overall levels of proposed development.

Evidence provided in Transport Strategy (2017).

-

4.2 4 PO1008 B3Living Use Built for Life accreditation scheme to encourage good design of housing and public realm in developments.

Noted. General design principles are addressed in policies in Section 20.

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Chapter 5: Brookfield

Issue No.

Policy/ Para. no.

Commt. ID(s)

Issue Council Response Proposed amendments to the Plan

5.1 BR1 PO21 Previous plans for Brookfield have already been rejected by Government

Previous plans for Brookfield were set out in the Broxbourne Core Strategy. This was examined in 2011 and a government inspector considered that the Core Strategy could not be found sound without deletion of the Brookfield policy. The Council therefore chose not to adopt the Core Strategy which is now being superseded by this Local Plan which contains different proposals for Brookfield. The Local Plan will also be subject to examination by a Government inspector who will take into account the comments of the previous inspector in making judgements in respect of Brookfield within this plan.

-

5.2 BR1 PO21 PO852 PO854 PO942 PO95

The proposals for Brookfield will create unacceptable traffic problems

The Council is very mindful of the traffic impacts arising from Brookfield and all the other development proposals within the Local Plan. It has therefore modelled the impact of all the developments and is putting together a series of transport improvements within the borough. These are set out within Chapter 17 of the draft Local Plan and are being developed within an evidence base document entitled the “Broxbourne Transport Strategy”. This will in turn inform the final content of the transport section of the Local Plan when it is published in final draft form prior to submission to the Government for examination.

-

5.3 BR1 PO129 The proposals for Brookfield will require implementation of the previously abandoned A10

Various options are being considered for improvements to the A10. None of these options

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widening scheme include the 1980’s plan for major widening of the A10 corridor

5.4 BR1 PO228 Supports plans for Brookfield as a means to creating a vibrant leisure environment – recommends that Brookfield supports local sports facilities through section 106 agreements.

Support for Brookfield is noted. It is intended that a section 106 agreement(s) will channel funds into a variety of infrastructure improvements to mitigate the impact of the development. These will primarily be drawn from an Infrastructure Delivery Plan which will include leisure facilities. It is too early to specify which facilities will be supported by which developments.

-

5.5 BR1 PO228 Supports access into Brookfield from the Turnford Roundabout on the A10m as a means of reducing congestion

Noted -

5.6 BR1 PO228 Brookfield should incorporate a new swimming pool/leisure centre

These are not proposed. However, it is proposed that a number of commercial leisure facilities will be incorporated within Brookfield Riverside.

-

5.7 BR1 PO312 The previous scheme for Brookfield proposed to re-site Marks and Spencer and Tescos

This was never the case. -

5.8 BR1 PO1910 Thames Water is concerned that it is proposed to re-construct the New River channel and that maintenance access will be impeded. There has been no agreement with Thames Water.

There are no known proposals to re-construct the channel as Brookfield would be developed around the New River with the need for maintenance access recognised and enabled. Detailed proposals will be fully discussed with Thames Water.

-

5.9 BR1 PO860 PO2206 PO532

Concern about the impact of Brookfield on existing town centres

The Council has produced the 2015 Broxbourne Retail and Leisure Study and the 2016 Broxbourne Retail and Leisure Impact study which fully consider impacts on existing centres. The Council considers these impacts to be acceptable.

-

5.10 BR1 PO860 PO214

Concern about the impact of Brookfield on the environment

Proposals for Brookfield have been developed in full cognisance of their potential environmental impact. The Local plan itself has and will continue to be subject to sustainability appraisal and

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further work will be undertaken to justify impacts on the Green Belt. The Local Plan contains various policies that seek to address the environmental impact of development proposals including Brookfield. Planning applications for Brookfield will require to be accompanied by environmental impact assessments which will examine those impacts and put forward appropriate mitigations.

5.11 BR1 PO1993 The Enfield Gospel Hall Trust Meeting Hall at Halfhide Lane is surplus to requirements and a residential allocation is sought.

The Gospel Hall site is not currently allocated for any land use but its close proximity to Brookfield and the potential for the site to contribute to the wider strategic development is recognised. The site is surrounded by heavily trafficked major roads and is not considered to be suited to residential development. However, there will be land uses that would be complementary to the wider Brookfield development and discussions will continue with the Trust to secure the appropriate redevelopment of the site. In order to retain flexibility, it is intended that no Local plan designation will be made for this site.

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5.12 5.3 PO613 An additional principle for Brookfield should read “to conserve and enhance the historic environment”

The consideration and, if appropriate, protection, improvement and interpretation of the historic environment are essential. It is considered that these are enabled by the policies within chapter 29 of the draft Local Plan – Heritage Assets. These policies will for instance ensure appropriate consideration and treatment of the two ancient monuments within the protected Hell Wood. Appropriate emphasis will also be placed on the historic environment in planning applications for Brookfield. However, it is not considered that the historic environment is so significant in relation

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to Brookfield as to afford it weight as a defining principle of the development.

5.13 5.3 PO2112 An additional principle for Brookfield should be added to cover health and well-being

It is not proposed to include a specific health and well-being objective as manifestation of health and well-being issues will be through the design and sustainability measures covered by objective numbers 1 and 6

-

5.14 5.3 PO71 In view of the importance attached to the quality of the design of the Brookfield developments and the importance in the plan and Government policy given to creating healthy communities, there should be specific reference made in policy BR1 or the supporting text to the developments (especially the Garden Village) being designed to promote active lifestyles (through encouraging physical activity and sport) and thereby contributing to the wider healthier communities objectives. In particular, the supporting text should refer to Sport England's and Public Health England’s Active Design guidance

It is not proposed to include specific reference to the promotion of active lifestyles. These will however be promoted as an inherent element of creating a sustainable development (see above)

-

5.15 5.6 PO561 Questions demand for a cinema at Brookfield The attraction of a cinema has always been planned to anchor the leisure facilities at Brookfield. The Broxbourne Retail and Leisure study considers that there is scope to attract a cinema to Brookfield

-

5.16 5.6 PO561 Questions demand for department store(s) at brookfield

Whilst not a requirement of the policy, it is considered that Brookfield would be of sufficient scale to attract a department store operator. Discussions with developers over many years have focussed on the presence of a department store(s) to anchor the development of Brookfield Riverside.

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5.6 PO495 Supports Brookfield as introducing facilities such as cinemas, ten pin bowling, an additional major supermarket and additional bus services which are much needed in Broxbourne.

Noted -

5.17 5.6 PO487 Considers that development of the Spotlight cinema in Hoddeson or a boutique cinema elsewhere in the borough would be more appropriate than Brookfield

The attraction of a cinema has always been planned to anchor the leisure facilities at Brookfield and to provide a central, accessible facility for all the residents of Broxbourne. This would not rule out the development of other cinemas within the borough although it is appreciated that there is a limited market.

-

5.18 5.6 PO487 Ten pin bowling should be developed elsewhere in the borough, perhaps within an industrial area. That would spread the traffic impact of commercial leisure facilities

Whilst not a policy requirement, the Council would welcome a ten pin bowling facility as an appropriate part of the Brookfield leisure mix. This would not rule out other locations in the borough but there has been no market interest elsewhere.

-

5.19 5.6 PO545 The Waltham Cross and Cheshunt Chamber of Commerce strongly supports the provision of the leisure area at Brookfield as this would provide a much need facility within the borough

Noted -

5.20 5.6 PO550 Brookfield development is much needed and in particular the leisure facilities

Noted -

5.21 BR1 PO854 Park and ride should be considered at Brookfield It is not provide to provide a park and ride facility at Brookfield

-

5.22 BR1 PO1593 Augmenting leisure facilities in the existing town centres would enliven and promote these areas

Proposals for Brookfield do rule out leisure improvements in existing town centres. The Broxbourne Retail and Leisure impact study concludes that impacts of leisure facilities on existing town centres would be acceptable and these could happily co-exist with Brookfield.

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5.23 5.8 PO216 PO695

If the Borough Council offices are relocated to Brookfield Riverside, it is imperative that bus services are provided

One of the main reasons for promoting this proposal is that the council’s offices would be considerably more accessible for the majority of

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Broxbourne residents. Good bus services will be critical to that objective.

5.24 5.8 PO310 PO965 PO488 PO2205 PO1445

Moving the civic offices to Brookfield would be a waste of money, is unnecessary and questions the use of the existing offices should this occur

It is unlikely that this move would take place if it were not cost neutral or major advantages outweighed any additional costs. Future use of the existing council offices is not yet known but it is likely that they would remain in office use.

-

5.25 5.8 PO1338 Seeks clarification on the future use of the council’s existing offices

The Local Plan does not designate the site for any purpose, thus retaining flexibility on future use options.

-

5.26 5.8 PO956 Supports the council offices moving to Brookfield Riverside and recommends that Bishops College (current council offices) is retained for community use.

It is premature to speculate on the future use of the existing council offices. The Local Plan does not designate the site for any purpose, thus retaining flexibility on future use options.

-

5.27 5.8 PO216 Notes the difficulty of accessing hospital services for Broxbourne residents

Noted. The Council is discussing with the Clinical Commissioning Group the scope for primary care facilities at Brookfield.

-

5.28 5.8 PO301 The proposed medical centre should include an Urgent Care Centre and pharmacy with 24 hour opening to reduce trips to Chase Farm hospital

The Council would support a range of medical facilities at Brookfield. However, the content and opening hours of any facility will be primarily determined by the Clinical Commissioning Group with which the Council is liaising.

-

5.29 BR1 PO275 Supports the provision of homes for the elderly and notes that elderly people often prefer ground floor accommodation with a garden.

Noted. A range of provision for elderly persons housing needs requires to be considered as part of the master planning for Brookfield.

-

5.30 5.9 PO215 PO694

A number of tall buildings at Brookfield seems inappropriate/is not supported

Whilst not within the policy, paragraph 5.9 does signal the possible appropriateness of a tall landmark building or buildings at Brookfield. This is caveated by stating that this will be determined through master planning. It is intended to retain this paragraph within the document.

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5.31 BR1 PO532 East Herts DC notes that the expansion of Brookfield will put further strain on the A10

This is not necessarily the case as additional trips to Brookfield will be counterbalanced by the re-claim of trips to retail and leisure destinations

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outside the borough. This matter is being examined within the traffic modelling for the borough

5.32 BR1 PO549 The Waltham Cross and Cheshunt Chamber of Commerce supports the proposed business campus to the west of the Turnford Interchange as this will bring valuable inward investment into the area

Noted -

5.33 5.15 PO970 The Plan should make clear that a south bound slip road needs to be constructed at the Turnford Interchange before first occupation of any part of the Brookfield development

This slip road is a very costly intervention with a significant environmental impact. The need for it is therefore being tested within the modelling of various transport options for the Brookfield area. Should it be necessary and desirable to build this slip, the phasing of its construction will be considered through the determination of planning applications for Brookfield.

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5.34 5.16 PO302 An increase in bus services to Brookfield is welcomed but dedicated bus lanes are required

The Broxbourne Transport Strategy will consider the most effective measures for prioritising bus movement within the Borough

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5.35 5.16 PO302 There needs to be a dedicated taxi rank at Brookfield

This is not a requirement of the policy but this will be considered in the detailed master planning for Brookfield Riverside. It is anticipated that a rank would be provided.

-

5.36 5.17 PO817 Supports increasing pedestrian and cycle connectivity between the different areas of Brookfield

Noted -

5.37 5.19 PO68 Greater attention should be given to the importance of retaining trees of amenity value, including the consideration of tree preservation orders

The retention and enhancement of the landscape and ecology of Brookfield is one of the guiding principles at paragraph 5.3 in the draft Local Plan. Many of the trees and much of the woodland at Brookfield are already covered by tree preservation orders.

-

5.38 5.24 PO2009 The sentence of paragraph 5.24 "This includes Hell Wood and the valley of the Turnford Brook

An additional sentence will be added to read: “The village and


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which will be protected and enhanced" is somewhat bland and should be far more detailed. The impact of the additional visitor pressure from 1500 new households needs to be monitored and mitigated in a long-term management plan.

its landscape will be covered by a detailed management plan”.

5.39 Figure 4 The setting of Wormleybury Park and buildings should be protected and enhanced through any masterplanning process. It is also considered that the proposed development should be set further back from the Registered Park to the north. The opportunity to provide public open space in this area should be considered.

Masterplanning is paying cognisance to the setting of Wormleybury Park. However, the proposed Brookfield development abuts the park edge in that a woodland belt along the southern boundary of Wormleybury naturally contains the setting for this development. Wormleybury management are concerned about opening up the edge of the “park” to public access which will influence any provision of public open space along this edge.

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5.40 Figure 4 Whilst there would appear to be a narrow pedestrian corridor linking the open countryside with Hell Wood along Turnford Brook, it is considered that this corridor is too narrow to provide a meaningful wildlife corridor. To that end, Historic England would suggest that this corridor is widened.

Noted. This is being positively considered through master planning and it is likely that the corridor will be widened at this juncture.

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5.41 Figure 4 PO563 Seeks expansion of the Brookfield allocation to the north to encompass land in the respondent’s ownership. Objects to the draft Local Plan if the entirety of the plot is not so included.

It is not proposed to extend the development allocation any further to the north.

-

5.42 Figure 4 PO2008 It is unclear how the irreplaceable ancient woodland is to be adequately protected from direct or indirect harm, such as a clear intention not to allow development on it, nor provision of a buffer strip from the housing development (both during construction and when built).

The woodland will be protected and will be subject to a management plan Agreements and conditions attached to a planning permission would provide protection to the woodland during construction.

An additional sentence will be added to paragraph 5.24 to read: “The village and its landscape will be covered by a detailed management plan”.

5.43 5.25 PO213 Further Green Belt land will be required for relocations, including the household waste

There are no proposals to further expand the Brookfield allocation.

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recycling centre

5.44 5.25 PO960 Takes issue with the proposal to relocate the travellers’ site on Halfhide Lane to a site on Park Lane Paradise. The current residents enjoy access to a wide range of amenities in their current location, and it is not fair to place these homes in a rural location that is a significant distance from many local amenities. This proposal is inadequate, as it fails to take into account what the residents need. The closest road is an unmarked highway that lacks pavement which makes public transport use and journeys on foot impossible, and therefore encourages the use of vehicles which contravenes the infrastructure model favoured by the Council and the experience of children living on the site that are “cut-off” from the bustling centre of Cheshunt that they enjoy in their current location. A site that has vehicular access to the Brookfield Garden Village development would be of much more use and practicality.

It is not proposed that the proposed traveller’s site at Park Lane Paradise will be cut off from the wider Brookfield development. On the contrary, it is proposed that there will be a good quality pedestrian/cycle connection between the two which will provide the travellers with direct access to the primary school and other local facilities. A direct road connection is not, however, planned. The proposed site is considered to be the optimal location for the Halfhide Lane travellers. It is a beautiful setting, has an open outlook, offers a level of privacy above other potential Brookfield locations, it provides for expansion of the local community and a very attractive conjoined paddock area.

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5.45 5.25 PO2193 The travellers should remain in their current location. Has Herts County Council as owner of the Halfhode Lane site been consulted?

It is not practicable or desirable for the Brookfield Riverside development to be developed around the existing travellers site/the allotments. The proposed location is considered to offer benefits to all parties (see above). Herts County Council, as owner of the existing site, is party to discussions about relocation. To date HCC, has been supportive of the proposed location.

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5.46 5.25 PO967 In Para 5.25 it refers to the anticipated relocation of the Broxbourne Depot to the new business park. Policy BR1 makes no mention of the

It was an oversight not to include the depot in the list of relocated uses within Policy BR1 and this will be corrected.

Add Broxbourne depot to policy BR1.


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relocation of the depot but does refer to the Household Waste Recycling Centre. For clarity and certainty in understanding what is being proposed the same terminology should be used.

The Council is not yet in a position to provide clarity on the proposed location of the Household Waste Recycling Centre.

5.47 5.25 PO1332 PO308

Also seeks clarity on the proposed location of the Household Waste Recycling Centre and is concerned that this will be relocated to Hoddesdon

Being in the centre of the borough, the Brookfield area is considered to be the optimal location for the household waste recycling centre. However, the precise location has not yet been determined. The Council has are no plans to move this to Hoddesdon.

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5.48 BR1 PO71 Sports England requests that policy BR1 and its supporting text be amended so that the proposed public open space in the Brookfield Garden Village makes provision for outdoor sports facilities to be included in the proposed public open space.

Master planning for Broookfield is generous in its overall provision of open space and it abuts Cheshunt Park which provides immediate opportunity for outdoor recreation. However, it is accepted that new sports pitches are not proposed as part of the Brookfield development (apart from at the primary school). The borough as a whole is well provided with sports pitches. Pitches are also land hungry and their provision at Brookfield would require significant loss of new homes which are considered to be the greater priority for use of scarce land.

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5.49 BR1 PO5 Wormleybury Management Ltd asks:

1. How close will the properties be built to our border?

2. What does the council intend to do about stopping residents of Brookfield Village from being able to gain access to our grounds / lake (what fencing will be provided / ditches dug etc.).?

3. When do you anticipate work would start

1. The Brookfield development is proposed to abut the border with Wormleybury at its northern edge. The precise nature of this border will be determined through master planning.

2. Master planning and detailed design will consider the relationship between the development and Wormleybury. Security issues will be taken into account.

3. A phasing plan will be produced for Brookfield but it is too early to specify this as it would affect Wormleybury.

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and finish?

5.50 BR1 PO341 Broxbourne lacks facilities and fully supports the proposals for Brookfield

Noted and welcomed -

5.51 BR1 PO369 It is inappropriate to refer to the use of compulsory purchase (which may be available under entirely different legislation) within strategic policies.

Compulsory purchase, or the possibility of it, is likely to be necessary to deliver the council’s objectives within the proposed strategic development areas. It is entirely pertinent for this to be indicated within the respective policies to provide clarity to stakeholders and to set the basis for any compulsory land acquisition that is necessary in the future. The policy states “if necessary (authors emphasis), compulsory purchase will be pursued by the Council.” Any compulsory purchase that was necessary would almost certainly be undertaken through town planning legislation.

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5.52 BR1 PO530 Brookfield will need careful masterplanning in order to ensure that the development provides an appropriate mix of homes in a form that is appropriate to its setting, which maintains a strong outer edge which prevents the need to amend the Green Belt boundary at the end of the Plan Period.

Agreed. Masterplanning is required by the policy and is currently in progress

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5.53 BR1 PO531 It is unclear whether the employment land planned at Brookfield is compatible with the creation of a major new business park at Park Plaza in terms of market demand, the impact on existing employment areas and on the strategic road network.

Broxbourne Council is seeking to diversify its employment base into high value industries such as creative and media and life sciences. Attracting such businesses into the area is reliant on the allocation of a variety of high quality sites – hence the proposals for Brookfield and Park Plaza which are supported by the 2016 Broxbourne Employment Land Study. These are compatible with the council’s existing employment base.

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Impact on the strategic road network is a concern and the Broxbourne Transport Study is examining the mitigations that will be necessary to support the business allocations.

5.54 BR1 PO615 Historic England supports reference to protecting and enhancing scheduled monuments in the policy but considers that this should also include reference to Wormleybury Park and gardens and nearby listed buildings.

Specific reference is made to the ancient monuments because they lie within the allocation. It is not considered necessary or appropriate to refer to nearby heritage assets in the policy. These will receive due cognisance through master planning and documentation in support of future planning applications.

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5.55 BR1 PO896 National Grid requires that no permanent structures are built over or under pipelines or within specified zones.

It is not considered that any proposals would compromise National Grid apparatus. National Grid will be fully consulted on specific proposals through master planning and the planning application process.

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5.56 BR1 PO897 National Grid makes a number of recommendations regarding development in relation to high voltage overhead lines

The Brookfield proposals do not affect high voltage overhead lines whish are to the south of the allocation.

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5.57 BR1 PO1914 Thames Water has concerns regarding water supply capability in relation to Brookfield. That is being examined but for any necessary up-grade, up to three years lead in time will be necessary. The following paragraph is requested: “Developers will be required to demonstrate that there is adequate water supply capacity both on and off the site to serve the development and that it would not lead to problems for existing or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing water infrastructure.”

It is disappointing that concerns are now being raised as Thames Water had previously advised that all new development can be. Urgent clarification on Thames Water’s position on servicing Brookfield is therefore being sought.

It is proposed to introduce a new policy at the end of sections 17.21 to 17.24 of the draft Local Plan as follows: Policy INF X Planning applications for major developments require to be accompanied by a Utilities Statement that explains how such developments are to be serviced in relation to electricity, gas, telecommunications, water and sewerage.


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5.58 BR1 PO1915 Thames Water has concerns regarding wastewater services and the likely needs to up-grade of the waste water network.

It is disappointing that concerns are now being raised as Thames Water had previously advised that all new development can be supplied. Urgent clarification on Thames Water’s position on servicing Brookfield is therefore being sought.

It is proposed to introduce a new policy at the end of sections 17.21 to 17.24 of the draft Local Plan as follows: Policy INF X Planning applications for major developments require to be accompanied by a Utilities Statement that explains how such developments are to be serviced in relation to electricity, gas, telecommunications, water and sewerage.

5.59 BR1 PO426 1. Concern about increased flow rates resulting from hard surfacing such as car parking.

2. Concerned that development at

Brookfield Garden Village is immediately adjacent to the Turnford Brook and thus has no open space buffer for land drainage.

3. Would like to see the existing lake with its good stock of fish retained.

1. Surface water flow rates will be mitigated through the introduction of SUDS networks. Policy W4 of the draft Local Plan addresses this issue.

2. Master planning will ensure that

Brookfield has an appropriate relationship with the Turnford Brook having regards to the requirements of Policy W4 of the draft Local Plan

3. It is proposed to retain this lake and other important water features.

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5.60 BR1 PO720 Brookfield Lane needs a flyover from Flamstead End

A flyover is not planned -

5.61 BR1 PO722 Scepticism about the council’s commitment to the protection and promotion of wildlife interests at

The retention and enhancement of the landscape and ecology of the Brookfield area is one of the

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Brookfield. seven key principles for Brookfield at paragraph 5.3 of the draft Local Plan. Attention is also brought to Policy NEB1 which sets a very high bar for the protection of wildlife interests

5.62 BR1 PO724 PO727

Broxbourne will effectively become a London borough

The Local Plan vision and objectives seek to retain and enhance the identity and sense of place within Broxbourne

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5.63 BR1 PO725 Seeks a high security fence around the respondents landholding

This is not proposed. -

5.64 BR1 PO726 Seeks a multi access track and gate into the respondents landholding Asks that horse riders and carriage drivers are accommodated

This is not a matter for the Local Plan but discussions will take place with the respondent in relation to her landholding interest. The potential for routes through Brookfield to accommodate horses will be considered through master planning

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5.65 BR1 PO753 Concern about the impact of Brookfield on the setting of Wormleybury Park and the Grade 1 listed Wormleybury House, be detrimental to the flora and fauna of the Local Wildlife Site on the estate, put the fishing lake in the park at risk from pollution and reduce the quality of life of the 26 households who live in and safeguard the estate.

It is not considered that the Brookfield development will have a significant detrimental impact in respect of any of these concerns. However, all will be taken into account through master planning.

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5.66 BR1 PO753 Wormleybury Management Ltd considers the Plan to be unsound for the following reasons:

1. It is not in accordance with the NPPF

2. The proposed garden suburb and the safeguarding of a school site on a LWS does not accord with other policies in the plan

1. The respondent has not set out the reasons for this contention. However, the Council believes the Local Plan to be in accordance with the NPPF. 2. The presence of local wildlife sites in respect of Brookfield and the proposed site of the new secondary school within Wormley is recognised. The wildlife value is being assessed and taken into account in the planning of these sites.

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To make the Plan 'sound' in this respect we would expect to see either the deletion of the garden suburb proposal and secondary school site, or:

Wormleybury Management Ltd. Objection to Broxbourne Draft Local Plan (Regulation 18 Consultation)8

1. Clear explanation for the choice of location for the proposed urban extension to the west of Brookfield, and for the rejection of other sites.

2. Clear reasoning and evidence to support the proposed urban extension to the west of Brookfield and the exceptional reasons why a development that is contrary to national policy is acceptable.

3. The allocations for the western extension of the Brookfield Centre to accord with other policies in the Draft Local Plan.

1. The Local Plan and its supporting

evidence base set out the reasons for the Brookfield allocation.

2. These will be expanded upon within an additional topic paper that will set out the exceptional circumstances necessary to demonstrate Green Belt changes to enable developments within the Local Plan.

3. It is assumed that the respondent is

referring to the northern extension of the Brookfield Centre. This is considered to be complementary to and consistent with the other policies in the draft Local Plan.

5.77 BR1 PO754 PO748

Wormleybury Management Ltd. contend that although the plans for the garden suburb are far from being at the planning application stage, Broxbourne Council must follow its own planning policy and make the following amendments to the garden suburb proposal:

1. The built form of the garden suburb must not breach the lip of the natural bowl in which the site of the proposal lies;

2. The Wormleybury Brook and the LWS lying either side of the Brook which contributes to the sylvan setting of the

1. A great deal of thought has been put into the identification of the boundaries of the proposed Brookfield development, particularly in relation to land form, field boundaries and natural features. Whilst the Council has sought to minimise intervisibility, it is also anticipated that any intervisibility is mitigated by tree planting so that a development results that will sit comfortably within the landscape and in relation to landscape and heritage assets in the vicinity.

2. See response to IDXXX

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garden suburb site should be cited in policy CS2 and therefore protected and enhanced;

3. The nature conservation value of the Wormleybury estate must be assessed using the Biodiversity Calculator tool so that its wildlife is properly valued;

4. Avoidance measures such as pollution from light and surface water run-off must be assessed and should be included in the master planning;

5. A landscape buffer of at least 15m, to protect the LWS and Wormleybury Brook, must be planned for in accordance with Natural England’s tried and tested guidelines. This could be achieved by the planting of new community woodland similar to that proposed to the west of the garden suburb;

6. In addition, within the buffer a natural barrier, which is permeable to wildlife but impermeable to residents of the suburb, should be designed to protect the private Wormleybury estate;

7. A thorough assessment of the effect of the proposed garden suburb on the Grade I listed Wormleybury House or the listed park and must carried out before further work on the garden suburb master planning proceeds;

8. The references to Wormleybury House must be corrected;

9. The proposal to relocate the existing Brookfield waste transfer station into the

3. This is a matter for any future planning application(s)

4. These will be matters to be considered by a future environmental impact assessment(s) that will be required to accompany a planning application(s).

5. This is primarily a matter for master planning. However, a buffer of this extent is not currently planned.

6. See response to 5. 7. A broad assessment has been

undertaken at this stage and this will be set out within a topic paper addressing the exceptional circumstances to realign the Green Belt in respect of Brookfield. More detailed assessment will take place within an Environmental Impact Assessment(s) that will be required to accompany a planning application(s).

8. References will be checked. 9. Being at the centre of the borough,

Brookfield is a sustainable location for the household waste recycling centre. It is also the current location but its relocation is necessary to deliver the overall Brookfield proposals.

10. The Council is considering what, if any, mitigation will be provided for. Alternative access arrangements are being considered (from the A10 – Turnford link road) and are likely to be described within the finalised draft Plan.

11. Noted (see above).


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garden suburb should be abandoned; 10. The mitigation measures to justify

safeguarding a LWS for a secondary school should be set out clearly andn the alternative access arrangements for vehicles to the school, other than off Church Lane should be planned for.

11. If the proposal for the garden suburb and secondary school are carried forward to the Submission Draft Local Plan must include all of the above requirements.

5.78 BR1 PO732 Brookfield is contrary to government definition of a garden village in that it is not a freestanding

The council has not relied on government garden village definition in allocating Brookfield. However, it is considered that the garden village element of the wider Brookfield proposals would be consistent with the DCLG guidance.

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5.79 BR1 PO732 PO746

Three core planning principles of the NPPF (paragraph 17) have been disregarded in relation to the garden village proposal:

A significant area of Green Belt would be lost along with the intrinsic character of the countryside in which the village would be located;

The proposal would do the opposite of contributing to conserving and enhancing the natural environment and that the allocation of land for the development is on Grade 3 agricultural land incorporating and adjacent to land of high amenity value and local wildlife significance; and

The considerable heritage assets of the

The Brookfield allocation is considered to be in accordance with paragraph 17 of the NPPF.

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area would not be conserved in a manner appropriate to their significance, with specific reference to the Wormleybury Estate.

5.80 BR1 PO732 The provisions of paragraph 132 of the NPPF have not been applied, particularly in relation to the Wormleybury Estate

The Council disagrees with this contention. The heritage assets within the Wormleybury Estate have been and will continue to be paid due cognisance in the planning of Brookfield.

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5.81 BR1 PO732 PO733

The provisions of paragraph 110 have not been applied in that Brookfield could not be defined as being of low amenity value.

Much of Broxbourne borough is of high amenity value. However, it is accepted that there are areas of the borough with less amenity value that are not being allocated for development. The provisions of the NPPF must be read in their entirety and the overall benefits to be derived from the development are considered to be closely aligned to the entirety of the NPPF. This is to a large extent inherent within the vision, objectives of the Local Plan but will be expanded upon within a topic paper that describes the exceptional circumstances necessary to justify realignment of the Green Belt in relation to Brookfield.

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5.82 BR1 PO733 The provisions of paragraph 117 of the NPPF (biodiversity) are insufficiently applied, particularly in relation to the Turnford Brook and the Wormleybury Brook

One of the guiding principles of the Local Plan in relation to Brookfield is “to retain and enhance the landscape and ecology of the Brookfield area” (draft Local Plan paragraph 5.3). Paragraph 5.24 states that “the valley of the Turnford Brook will be protected and enhanced”. The details of this are for master planning and a planning application. It is accepted that paragraph 5.24 could be

Paragraph 5.24 will therefore be re-written as follows: The village must exhibit exceptional standards of design and landscaping, representative of the garden village approach and the sylvan setting. The Brookfield area as a whole must also be master planned to protect


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strengthened in relation to the Wormleybury brook. It is also accepted that the paragraph could make more explicit reference to biodiversity.

and enhance the biodiversity of the area. This includes Hell Wood and the valleys of the Turnford Brook and the Wormleybury Brook which will be protected and enhanced.

5.83 BR1 PO737 PO728

Wormleybury Management Ltd. concludes that neither the allocation of the garden suburb or the safeguarding of the secondary school site are in accordance with national policy and guidance and should be removed from the plan.

This is not accepted and both sites are still proposed for allocation/safeguarding.

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5.84 BR1, INF9

PO738 The allocations for the Brookfield Garden Village and secondary school are set out in Policies INF9 and BR1 and justified in the preceding paragraphs of the draft local plan. Policies and Paragraphs in the plan should support the allocation but they fail to do so. If Broxbourne Council proceed with this proposal, against National Policy then the master planning of the proposal should reflect the Council’s own local plan policies.

The representation does not amplify how the policies and paragraphs of the Local Plan do not support the allocations or vice versa. It is proposed that master planning should be com-pliant with the policies of the Plan.

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5.85 BR1 PO740 There are no proposals to buffer Wormleybury from the Brookfield allocation. Built development in the garden suburb must not extend to the top of the ridge of the bowl. This will reduce the visual impact, light pollution, potential to pollute the water course and lake, and provide space for the considerable amount of wildlife including protected species, such as bats, on the historic estate of Wormleybury and the wider countryside.

The woodland bordering the southern side of the Wormleybury Brook is proposed to form the main northern backdrop to the development. The community woodland to the west is proposed to continue this woodland belt to create a woodland enclosure for the garden village. It is assumed that the respondent is referring to the break in slope between the valleys of the Wormleybury Brook and the Turnford Brook. The proposed allocation does cross this break in slope The resultant impacts of development on the valley of the Wormleybury brook will be fully addressed through master planning and a

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planning application.

5.86 BR1 PO741 In the section of the plan concerned with the quality of the Water Environment, the Council intends to resist any development that has the potential to contribute to flood risk and which damages wildlife habitats. In particular the Draft Local Plan (Paragraph 25.10) it says that buffer strips, which set development back from the edge of a river or stream, are an essential element in making space for wildlife habitats and to allow natural processes to take place. This policy needs to be applied to the garden suburb proposal by including a buffer to the Wormleybury estate.

Appropriate buffer strips will be protected/created around water courses. These buffer strips do not, however, apply to land ownership boundaries.

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5.87 BR1 PO742 Additional woodland (to that currently proposed) should be planted along the northern boundary of Brookfield

A widening of existing woodland is not within the Wormleybury Estate is not proposed.

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5.80 BR1 PO747 Green Belt Options report fails to define what other Green Belt sites are considered less sustainable and appropriate than Brookfield. Consideration of the environmental designations within and bordering Brookfield that were defined in the Options report have not been paid due cognisance within the draft Local Plan

This is a general statement which would refer to all Green Belt not being considered for allocation at that time. The Local Plan strikes a balance between the need for brevity and the level of cognisance paid to environmental and other designations. Subject to some strengthening of the words (eg see PO740 above), it is considered that the correct balance is being struck.

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5.81 BR1 PO1142 Brookfield should be designated as a town centre Whilst it is proposed that Brookfield Riverside would take its place within the retail hierarchy as a town centre. Paragraph 5.11 of the draft Local Plan sets out the approach that is proposed to be followed.

Alter the bullet points of Policy RTC1 to include Brookfield Town Centre within the list of town centres. This will then be consistent with the content of paragraph 5.11.

5.82 BR1 PO1142 PO1133

Policy BR1 should be less prescriptive. More flexibility should be provided regarding limitations

The Local plan sets out to provide clear ceilings for the scale of development within a general

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on land uses spatial framework.

Policy BR1 does not specify “requirements” for specific levels of floorspace. These are referred to as “up to” (which would be a ceiling) or “circa”. The only exception to this is affordable housing where 40% is sought in total. Convenience retail and business floorspace are set out as approximate figures. They do, however, indicate the general level of those particular development types that should be planned for within the development. It is entirely pertinent that a Local Plan should take this approach.

5.83 BR1 PO1134 The quantum of convenience retailing to be developed as part of the proposed Brookfield Riverside scheme is dependent upon the food retailing operators. Current market signals suggest that food retailers are no longer building large format stores, especially within the close proximity of existing food stores such as those already located at the Brookfield Centre. It may be that a small food store is appropriate for Brookfield Riverside, but this should not be prescribed by the Local Plan process, in advance of masterplanning and market assessment. The Local Plan should be flexible in relation to the convenience content of Brookfield Riverside and should not include a "requirement" for a specified amount of convenience floorspace.

The Local Plan does not “prescribe” any format of convenience retailing within the Policy although it does set out the potential for a major food store at paragraph 5.6.

This is a 15 year Local Plan and the Council’s evidence base indicates significant convenience needs arising over that period. It is considered that an element of that need should be met at Brookfield and that in meeting that need there is a significant opportunity to enhance the retail mix and viability of Brookfield.

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5.84 BR1 PO1135 The intention is to provide for business uses as part of the comprehensive mix of Town Centre uses, although the quantum, type, and timing of

The Local Plan proposes that Brookfield is planned to be a major strategic location for business development. Whilst there may be

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business floorspace to be provided are dependent on the realities of the office market. For example, the large quantum of available employment land at Park Plaza must be taken into account. In addition, we would suggest that the term ‘campus’ does not properly describe the strong sense of place that is proposed to be created at Brookfield Riverside. Place-making will be a key consideration in ensuring that the important locational requirements of office occupiers are met. Business uses should be included in the mix of Town Centre uses at Brookfield Riverside but the Local Plan should be flexible in relation to quantum, type and timing which should be determined as part of the masterplanning and planning application process.

Concentrating employment uses as a ‘business campus’ outside the designation area fits less easily with the concept of a Town Centre and opens the Plan up to criticisms that Brookfield Riverside is just an out-of-town retail centre with a business park attached. This does not accord with BEL’s ambitions or objectives.

flexibility in the way that development is provided for, it is essential to provide a clear policy basis for land uses that may not provide highest or quickest returns for developers. That has been provided in both spatial disposition at the optimum location and in quantitative terms within the policy.

Sustainable place making is a central objective of the plan for Brookfield. The Council is satisfied with the term “business campus” as setting the tone for what is sought in relation to business development. The business campus is separate to the “town centre” but requires to be integrated with it through a seamless transition between land uses. This does not mean that the central area will not contain business uses. On the contrary, it is anticipated that upper floors will provide the opportunity for business and residential uses.

5.85 BR1 PO1135 The Town Centre boundary and BR1 allocation should be moved further north up to the Turnford Interchange and bounded by the proposed link road. BEL considers that the currently designated land to the north of the Turnford Interchange could be appropriate for employment uses. However, BEL note that the relevant policy for proposed ‘New Employment Use’ is ED1, rather

The “town centre” boundary as described in the representation is defined as RTC1. It is not proposed to extend this to the land to the north as to do so could significantly dissipate the main retail and leisure uses set out within the policy.

As Policy BR1 encompasses the entirety of Brookfield, the legend should apply to the business land and this will be corrected. Policies ED1 and ED2 should also apply to this allocation and the Policy ED1 legend will therefore be added.


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than ED2 as currently stated on the proposals map.

5.86 BR1 PO1136 The provision and quantum of affordable housing to be provided at Brookfield Riverside should be determined by applying the affordable housing policies of the Local Plan to a specific detailed scheme in the context of a robust viability assessment of that scheme (for agreement with Borough of Broxbourne). It is not possible or appropriate to carry out that exercise in the absence of a specific scheme and it is not appropriate for the Local Plan to prejudge that exercise. The legislative detail associated with starter homes has yet to be provided. If appropriate the Starter Home provisions can be applied during the application process and it is inappropriate to include a 20% requirement in the Policy. ‘Required’ percentages of affordable housing and Starter Homes should not be specified within Policy BR1.

The 40% affordable housing policy has been the subject of viability appraisal and this will be re-visited. This proportion is, however, a key policy objective. The policy is always open to challenge through viability appraisal attached to a planning application if that level is not proposed to be provided. However, it is not possible at this stage to viability assess every development within the Local Plan as many costs are unknown. Government guidance on starter homes is still awaited. In the absence of such guidance, the interchange between starter and shared ownership products is flexible within the terms of the Policy.

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5.87 BR1 PO1137 Incremental Development

Policy BR1 currently states that Brookfield is to be developed in accordance with a comprehensive masterplan. Policy DSC4 provides that piecemeal development of comprehensive development areas that does not accord with agreed masterplans will be resisted. It is not necessary for that to be repeated in Policy BR1. Furthermore the use of the term "incremental" could be misinterpreted as preventing phasing, "piecemeal" is a better term.

The inclusion of the incremental development clause within the specific policies gives certainty to the reader of that policy. However, the replacement of the word “incremental” with “piecemeal” is accepted and such references will be amended.

Replace word ‘incremental’ with ‘piecemeal’.

5.88 BR1 PO1138 Car Parking The Council does not agree with the approach to car parking that has been proposed by

Replace ‘proposed’ with ‘anticipated’.


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The location of car parking should be the result of a comprehensive masterplanning exercise and not pre-determined through the Local Plan. Paragraph 5.18 of the Draft Plan currently proposes that the car parking will be located along the A10. It is not appropriate or desirable for the Local Plan to prescribe such a detail. The best location for the car parking will be determined through the masterplanning process and robust highways assessment. Current thinking is that locating the car parking along the A10 would not be the right design solution.

Bayfordbury Estates and the reasons for this have been set out in previous correspondence. The wording in paragraph 5.18 is drawn from the council’s own master planning to date and the primary reasons for it are given within the paragraph. However, the word “proposed” will be replaced with “anticipated”.

5.89 BR1 PO1139 Draft Proposals Map

The current Town Centre allocation identified on the draft Proposals Map does not indicate the full extent of the land identified for and needed for the proposed Brookfield Riverside uses. The core retail and leisure uses accommodated within the proposed scheme and identified in the text of BR1 will extend further north towards the Turnford interchange than currently shown and when the associated Town Centre residential and business uses are included the area required will reach north to the interchange. The area designated as Town Centre should be extended to the interchange, but it may be appropriate to identify as part of the masterplanning process, a "Primary Retail Area" within the wider designated Town Centre. As previously noted in paragraph 8 above, the extension of the proposed Town Centre boundary up to the Turnford Interchange will allow for the sustainable distribution of business floorspace throughout the proposed Town Centre,

It is not the role of the Local Plan to reflect the ambitions of the respondent. The Council stands by the proposed allocations. Also see the foregoing responses in relation to these allocations and their extent.

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encouraging good place-making.

5.90 BR1 PO989 Broxbourne’s evidence base clearly indicates that there remains a suppressed demand for comparison retail floorspace within Broxbourne, and we accept that this cannot be accommodated within the existing town centres of Hoddesdon and Waltham Cross where development opportunities already appear to be being maximised. In 2010, Welwyn Hatfield Borough Council was among a number of authorities to object to the proposal to meet the need for new retail floorspace through an out-of-town retail development at Brookfield. This was on the basis of the impact on trade in Welwyn Garden City in particular, which was forecast to drop by 5.2% if Brookfield were implemented.

Whilst a 30,000m2 scheme at Brookfield will presumably have a lesser impact on Welwyn Hatfield than forecast from the 50,000m2 scheme we objected to previously, we have not yet been made aware of any revised evidence on retail impact. We do not object to the principle of amending your retail hierarchy to designate Brookfield as a ‘borough centre’, but we will reserve our position on your plans until such evidence has been provided. The provision of retail floorspace is a duty to cooperate issue, and it is therefore crucial for us to understand whether the proposed increase in floorspace and shift in the sub-regional retail hierarchy will have any significantly adverse impact on this borough.

Broxbourne Council is separately engaging with neighbouring councils through the duty to cooperate on its Retail Impact Assessment. The results of that consultation are appended to this document.

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5.91 BR1 PO546 The Waltham Cross and Cheshunt Chamber of Commerce accepts an element of retail at

The Council has undertaken a retail impact assessment that concludes that the impact of

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Brookfield but has serious concerns over the proposed level of comparison and convenience retailing at and the impact this will have on the current town centres and the Cheshunt Old Pond area.

proposed retail floorspace at Brookfield on other Broxbourne centres would be acceptable. The Chamber of Commerce has been invited to comment on this study.

5.92 BR1 PO976 1. The Brookfield Property Unit Trust support the principle of creating additional retail and leisure floorspace in the Brookfield area, subject to the detailed comments made later in this letter. However, as a major landowner with a large presence in the area, the proposed Brookfield masterplan needs to be, from the outset, carefully considered and coordinated alongside the existing retail offer.

2. When any future development plans come forward, it is considered vital that the Council works positively with the Brookfield Property Unit Trust as a key landowner, to ensure that any additional retail or leisure floorspace complements and integrates with all the existing neighbouring retail floorspace. To date, it is considered that adequate engagement and consultatipn has not taken place.

3. The respondent considers that there has been insufficient consideration of alternative schemes for the development of Brookfield

4. The respondent seeks further dialogue on the proposed new Brookfield Link Road

1. The Council welcomes this support and wishes to ensure the respondent that the master planning of Brookfield has to date and will from hereon continue to carefully consider the appropriate level of complementarity with existing retail developments at the Brookfield Retail Park and the Brookfield Centre.

2. The Council will continue to engage with

the respondent on the development of plans for Brookfield as they affect the respondent’s interests.

3. Alternative propositions to Brookfield for residential and retail/leisure development have been considered within the borough wide options and scenarios report 2016 and the Retail and Leisure Study 2015. Broad alternative schemes within Brookfield have been considered through the Brookfield Area Development Options Report 2015. Master planning/procurement have and will consider the more detailed disposition of land uses. It is therefore considered that appropriate consideration has been and will continue to be given to reasonable alternatives.

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5. The respondent raises concerns in

relation to the robustness of the Council’s Broxbourne Retail and Leisure Study 2016: a. Insufficient respondents within

sample zones b. Market share must be treated with

caution c. No empirical data for the inflow of

expenditure d. The trading performance of existing

centres may be over-stated e. Reservations regarding sales densities f. No justification provided for pursuing

an uplift in market share g. Previous retail impact study out of

date h. Overall, the Study does not provide

adequate up-to-date and relevant evidence and is not consistent with paragraph 158 of the NPPF.

i. Insufficient duty to cooperate with adjacent boroughs and major stakeholders and the Local Plan is therefore not in compliance with Paragraph 181 of the NPPF

j. Local plan is unsound in relation to paragraph 182 of the NPPF.

4. Dialogue is and will continue to take

place with the respondent on the location and nature of the link road as it affects their interests.

5. a. The sample size is considered to be statistically significant b. Check c. Origin/destination interviews were undertaken

d. Trading performance statistics are considered to be substantially accurate – check

e. Noted. However, various sales densities

have been tested within the subsequent Broxbourne Retail Impact assessment. The respondents views on this have been canvassed.

f. The Broxbourne Retail and Leisure Study provides that rationale which is based on clawback of unsustainable leakge of comparison retail expenditure to centres outside Broxbourne borough.

g. The 2010 impact study has now been superseded by a 2016 study on which has been sent to the respondent.


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h. The Council and WYG disagree with this contention. Further evidence up-dates will be provided as the Local Plan nears examination.

i. The Council believes that it has and continues to fulfil the requirements under the Duty to cooperate.

j. The Council intends to submit a sound plan in accordance with Regulation 19 of the T&CP (Local Planning) (England) Regulations 2012.

5.93 BR1 PO703 Enfield recognises the importance of ‘Brookfield Riverside’ as part of the overall retail offering proposed in Broxbourne to accommodate forecast population growth. However, with the majority of new retail and leisure floorspace proposed in a single location there is concern about the proposed concentration of development and the impact this may have on existing town centres at Waltham Cross and Hoddesdon as well as within adjoining boroughs such as Enfield Town.

Planning for and managing retail provision continues to remain a key issue for Enfield and the impact of Brookfield on existing town centres should be assessed. To this end, Enfield would wish to explore the option of commissioning a study that will assess the scale of the proposed retail development at Brookfield, the evidence base that supports the retail development and the

The Council has undertaken a Retail and Leisure Impact Study that includes predicted impacts on Enfield and other town centres. Enfield Council has been consulted on that assessment but has not formally responded.

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potential impacts on existing centres and planned allocations.

5.94 BR1 PO885 The local road system is grid locked during rush hours, and could not cope with the additional traffic. The local infrastructure is insufficient to support this development

The Council has produced a Transport Strategy and Transport Models that demonstrate that the local road network could cope with the Brookfield development with appropriate mitigations.

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5.95 BR1 PO889 What account has been taken of The New River Clearway for pedestrians right of way

The pedestrian path along the New River will be retained

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5.96 BR1 PO876 To the south of Hell Wood, and within the proposed Housing Estate area, is a former gravel pit subsequently used as a land fill site, with a high water - table - see map B attached, supplied by the Environment Agency. This site may be contaminated, and has an engineered capping layer. Infiltration into the ground would provide a pathway to leach contamination from the landfill material into the adjacent gravel aquifer and surface water. Piling and any other foundation designs using penetrative methodss would obviously be potentially hazardous to all groundwater in the area. Any disturbance to this water table could cause problems elsewhere, as water will find its own level. After heavy rain, the slip road from the A10 to the Turnford interchange, already has water draining across it from this site.

The Council is aware of all areas of landfill and potential flooding. Those have been further investigated and development will pay due cognisance to those constraints.

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5.97 BR1 PO877 This Green Belt area is totally unsuitable for a housing estate. To surround Hell Wood with housing will destroy it, and the wildlife contained within it.

Comment noted. Hell Wood will be protected and it is proposed that there will be a net gain in biodiversity across the Brookfield development.

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5.98 BR1 PO966 Supports the imaginative and aspirational objectives of these proposals and consider the level of housing need, employment and retail need justify the exceptional circumstances for releasing the land from the Green Belt.

Noted -

5.99 BR1 PO968 Section 22 - Economic Development refers that the Brookfield campus in particular is to be knowledge based high value users. The relocation of the Broxbourne Depot or Waste Recycling Centre simply does not achieve either the preamble or policy wording in ED1. Indeed, if such

Whilst the Council sympathises with the comment, these are uses which require to be re-located. Other sites are being considered but at the present time, the Master Plan indicates the re-location of these uses within Brookfield.

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uses were regarded as acceptable within the business park this could lead to other occupiers with low value users. Low value users such as the Broxbourne Deport or Waste Recycling Centre are not the type of neighbouring uses that knowledge based value users would accept. These low value users will therefore deter the type of occupier the Council seeks locating on the Business Park/Campus and are inconsistent with policy ED1.

5.100 BR1 PO969 Policy BR1 - Brookfield Riverside, floor areas provided in Items 1 and 2 should be expressed as net sales areas. Stating the quantity of the expected floor space in the business campus is premature as it is wholly reliant upon deliverability which would be dependent on market forces. Office demand is more likely to come from town centre office occupiers complementing the integrated sustainable and mixed use envisaged in Section 5 - Brookfield.

The quantum has been reduced but the delivery of a significant business campus to help enable a step change in the Broxbourne economy is a primary objective of the development. It is considered that the expression of floor areas in respect of the individual land uses is correct.

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5.101 BR1 PO971 The policy envisages integrated master plans for Brookfield Riverside and Brookfield Garden Village and this must be the correct approach given the entirely different development nature of the two schemes and where the master plans would be followed through in the planning applications. There clearly needs to be integration in approach both in terms of highway links, boundaries, connectivity and permeability. Unfortunately, the policy conflicts with itself referring to a comprehensive Master Plan but then integrated Master Plans. An overall comprehensive Master Plan is not required if there are integrated Master Plans.

The integrated master plans will combine to create a single overall master plan. The Council stands by its policy wording in this respect.

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5.102 BR1 PO972 We are unclear of the policy intention by reference to 'incremental development should be resisted'. Clearly while the Brookfield scheme is intended to ultimately be delivered as a whole it will be developedin different elements and phases of

Incremental development infers implementation in accordance with the phased master plans referred to above.

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development.

5.103 BR1 PO973 In Policy BR1 Brookfield Riverside the level of Affordable Housing and tenure mix will be the subject of a Viability Assessment. In the circumstances the policy wording should make some reference that the level of Affordable Housing and tenure mix will be the subject of a Viability Assessment. This is perhaps of less importance in respect of Brookfield Garden Village, given the nature of the scheme but nevertheless additional wording relating to viability should also be included

Policy BR1 does not state that the level and mix of affordable housing will be subject to viability assessment. The policy on al strategic sites is to deliver on-site affordable housing. If viability appraisals are submitted with planning applications and demonstrate that the policy intent cannot be delivered, that will be considered at that time.

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5.104 BR1 PO1048 The strategy proposes to provide 30,000 sqm (net) of new comparison floorspace, 3,500 sqm of convenience floorspace and 10,000 sqm of leisure floorspace at the Brookfield Riverside, which is to developed as, effectively, a regional centre.

This allocation is broadly the same at the allocation promoted by the Council in the previous Core Strategy. In assessing this proposed allocation in 2011, the Core Strategy Inspector confirmed at paragraph 70 that:

"The amount of retail and leisure floorspace proposed has not been adequately justified. The creation of a new sub-regional centre would not accord with Policy E5 of the EEP. The new centre would have significant adverse retail impacts on Hoddesdon, Waltham Cross and neighbouring town centres at Harlow, Enfield and Welwyn Garden City".

Although the East of England Plan has been revoked, the imperative to protect from existing centres remains a key aim of a national planning policy. The retail evidence abse simply does not demonstrate the need for a new regional centre. The impact has not been adequately assessed,

Retail floorspace has been significantly reduced since the 2011 plan. The Council has undertaken a retail and leisure impact assessment of the current proposal and the predicated impacts are significantly less. Brookfield is being considered as a town centre within the hierarchy.

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and there is no reason to expect that the impact will now be acceptable. For these reasons, the Brookfield Riverside allocation must be deleted.

5.105 BR1 PO1088 The preparation of the Brookfield policy is supported, including development proposals for Brookfield Riverside and Brookfield Garden Suburb, especially the creation of a new town centre and High Street for the area.

However it is vital a range of important considerations are taken account of by the Council in relation to progressing draft Policy BR1 as part of the new Local Plan. These relate to working in partnership, convenience shopping, highway network, car parking and charging, and urban design and connectivity.

Noted and agreed. -

5.106 BR1 PO1089 1. Working in Partnership - it is important that Tesco and M&S, as two of the main existing landowners/occupiers within the proposed development area set out in the Local Plan Concept - Inset Plan 3, must be kept updated with detailed proposals for Brookfield Riverside. Although it is acknolwedged that the Tesco and M&S sites will not be redeveloped, the proposals would be expected to impact upon the operation of the stores and associated activities e.g. car parking, access etc.

Noted -

5.107 BR1 PO1090 2. Convenience Shopping - Draft Policy BR1 proposes 3,500 convenience floorspace. Given the level of convenience floorspace at Brookfield in existing shops it is proposed that this proposed figure is a maximum and should not be exceeded.

The Broxbourne Retail Study indicates the potential for considerably more convenience floorspace within the borough. That is not proposed within Brookfield but the c. 3,500 sqm is a guideline figure. Any significant floorspace above this is unlikely to be acceptable.

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5.108 BR1 PO1091 3. Highway Network - the Council must discuss and notify Tesco and M&S of proposals relating to any changes to the highway network. Any proposals should be discussed with landowners/occupiers in advance of public consultation or notification. It is our current understanding the final highways solution is yet to

At the time of writing, the Council has only just settled on its proposed highway network in respect of Brookfield. It is accepted that this will have an impact on Tesco Stores and the Council will undertake further liaison with the company in this respect.

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be determined by the Council and appointed transport consultants.

5.109 BR1 PO1092 4. Car Parking and Charging - the Council must discuss and notify Tesco and M&S of proposals relating relating to car parking including and charging mechanisms to be applied. Tesco currently operate a free car park and any adjacent charging would need to be considered.

The Council is well aware of the dichotomy of charged parking adjacent to free parking. It is about to undertake a procurement for the Brookfield Riverside development and once a developer is selected further discussions will take place in relation to parking.

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5.110 BR1 PO1093 5. Urban Design and Connectivity - the new High Street is proposed to the north of the Tesco site. This new centre must be well connected to existing large stores at Brookfield, so that the area the operates in a well-planned and complimentary manner.

Agreed. This is an objective of the Policy. -

5.111 BR1 PO1094 In terns of next steps, the preparation of a new Local Plan is supported, and we seek to help constructively to facilitate the delivery of sound planning policy. Any matters set out in this letter can be further explained upon request, and we would welcome the opportunity to further discuss matters with the Council.

Noted and agreed

5.112 BR1 PO1109 More shops and homes will bring more out-of-the-area shoppers and increase traffic congestion. Why expand the Brookfield Centre when Hoddesdon and Waltham Cross are rundown with empty shops? These centres could be given new lease of life with more retail outlets.

The primary intention of Brookfield is to retain local expenditure within Broxbourne. Hoddesdon and Waltham Cross are not both resilient centres but the Council is working to improve their offers through town centre strategies. The Council is confident that Brookfield can successfully co-exist with its existing centres.

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5.113 BR1 PO1161 The Local Plan 2016-2031 details the construction of 1500 homes on the Brookfield Village site, a period of twelve years from the first housing block development. This will bring serious disruption along with noise and air pollution to the quality of Wormleybury Manor Park residents lives for 12 years.

The local planning process exists to provide all respondents with the rights of representation

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As a community interest group, the residents have a legal right under the Localism Act 2011 to have been consulted by Broxbourne Council prior to the release of the proposed Local Plan. As the most impacted community interest group with respect to the development of Brookfield Village, Broxbourne Councillors and the planning staff have a legal and moral duty to offer the residents of Wormleybury Manor Park the opportunity to communicate their views regarding the proposed Local Plan before its publication.

5.114 BR1 PO1163 The major road serving the proposed development at Brookfield Village and Brookfield Retail development sites is the A10. The local plan’s suggested road developments for the A10 are not sufficient to accommodate the huge extra volumes of traffic the Brookfield Village and Retail Park site will generate. ‘Improved traffic flow and on and off slip roads from the M25’ and ‘traffic management’ fall well short of a major road-widening investment required for the A10 to accommodate the huge volumes of traffic.

Broxbourne Council need to revisit this area of the Local Plan or indeed, the Government Planning officer should pay particular attention to this huge short-coming in the Broxbourne Local Plan.

Paragraphs 31 & 32 of the National Planning Policy Framework states ;

Local authorities should work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development, including large scale facilities such as rail freight interchanges, roadside facilities for motorists or

The Broxbourne Transport Strategy and the revised Regulation 19 Local Plan seek to address the respondent’s concerns. Modelling is indicating that with appropriate mitigations, the local road network can accommodate all of the proposed development within the Local Plan.

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transport investment necessary to support strategies for thr growth of ports, airports or other major generators of travel demand in their areas. The primary function of roadside facilities for motorists should be to support the safety and welfare of the road user.

All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. Plans and decisions should take account of whether:

the opportunities for sustainable transport modes have been taken up depending on the nature and location of the site, to reduce the need for major transport infrastructure;

safe and suitable access to the site can be achieved for all people; and

improvements can be undertaken within the transport network that cost effectively limit the significant impacts of the development. Development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.

5.115 BR1 PO2007 Whilst welcoming the suggestion within this proposal to create new community woodland, the Trust is unable to support the proposal as stated due to the encirclement of an ancient woodland, and the uncertainty over the protection and management of that ancient woodland, named as Hell Wood.

In fact the woodland is listed on the Ancient Woodland Inventory, held by Natural England, as Spring Wood, of which Hell Wood seems to be a small part – see the appended map extract from

Hell Wood and other important habitats will be protected, enhanced and appropriately managed. A woodland/open space corridor will continue to connect the woodland to the wider countryside.

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the "Magic" database. The name Spring Wood is not mentioned in the Plan, but it is clear that a development of 1500 homes will surround this ancient woodland on all sides, along with new roads etc.

The Trust’s experience is that the inclusion of woodland in a site allocation plan for housing leaves that woodland open to damage from detailed proposals in subsequent planning applications. Furthermore, the woodland would be completely cut off from the surrounding countryside, causing fragmentation of connectivity in the landscape that government policy is trying to reverse.

5.116 BR1 PO2010 Therefore the Trust objects to this proposal as it is currently written and mapped, because an ancient woodland, refered to in the text as Hell Wood, is included within the site boundary. The Trust recommends that the area of ancient woodland, and a buffer of at least 50m, is excluded from the Site Allocation boundary of Brookfield Garden Village, and that a green corridor to the surrounding countryside is maintained.

The Trust also recommends that within any planning application for this proposal: no ancient woodland will be directly lost or harmed; a buffer of at least 50m around the woodland is retained to reduce indirect effects; a baseline survey of the ancient woodland is carried out; and a 25-year monitoring and management plan of the retained woodland will be expected, including how the additional visitor pressure will be mitigated.

Whilst there will be a buffer, this is not proposed at 50 metres. A green corridor to the wider countryside will be provided along the Turnford Brook. It is agreed that a full survey of the woodland and proposals for its long term management should form part of any planning application/permission(s).

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5.117 BR1 PO2057 Hell Wood is a listed Ancient Woodland, and associated with it are five numbers Monumnets - see attached Map A.

2227 - Double Moated site. The earthworkds are

Environmental and archaeological assessments will be required to attach to any planning application(s). These will require the investigation, appropriate protection/management/interpretation of historic features. Invasive field investigation has

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virtually 'castle' quality

Medieval - 1066 to 1500

2283 & 2445 - Pillboxes from 2nd World War

10232 - World War 2, anti-tank ditch, outer London stop line, eastern section from Newgate Street to Wormley. Part of the outer London defence ring.

10463 - Possible prehistoric features, south of Hell Wood.

The site of an old spring fed Watercress Bed is located to the east of the Moated area, and further to the east of this is the Priests Osiers area

been recommended prior to a planning submission.

5.118 BR1 PO2058 To the south of Hell Wood, and within the proposed Housing Estate area, is a former gravel pit, subsequently used as a land fill site, with a high water table - see map B attached, supplied by The Environment Agency. This site may be contaminated, and has an engineered capping layer. Infiltration into the ground would provide a pathway to leach contamination from the landfill material into the adjacent gravel aquifer and surface water. Piling and any other foundation designs using penetrative methods would obviously be potentially hazardous to all groundwater in the area. Any distrubance to this water table could cause problems elsewhere,as water will find its own level.

After heavy rain, the slip road from the A10 to the Turnford interchange already has weater draining across it from the site.

The Council is aware of all areas of landfill and potential flooding. Those have been further investigated and development will pay due cognisance to those constraints.

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5.119 BR1 PO2059 This Green Belt area is totally unsuitable for a housing estate. To surround Hell Wood with housing will destroy it, and the wildlife contained

Comment noted. Hell Wood will be protected and it is proposed that there will be a net gain in biodiversity across the Brookfield development

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within it.

5.120 BR1 PO2060 The local road system is grid locked during rush hours, and could not cope with the additional traffic. The local infrastructure is insufficient to support this development

The Council has produced a Transport Strategy and Transport Models that demonstrate that the local road network could cope with the Brookfield development with appropriate mitigations.

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5.121 BR1 PO2061 What account has been taken of The New River Clearway for pedestrians right of way

The pedestrian path along the New River will be retained

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5.122 BR1 PO1511 The LEP supports the policy for Brookfield Riverside, including the provision of the proposed link road to the Turnford Interchange, allied with high quality pedestrian connectivity to the existing Brookfield Centre, Brookfield Retail Park and the proposed Garden Village.

Noted

5.123 BR1 PO1052 Brookfield Garden Village

The LEP supports this policy.

Noted

5.124 BR1 PO1753 Development Impact

The proposals represent very significant trip generation close to areas where the public highway is already close to or at capacity. The masterplan development should therefore be designed to be as self-sustaining as possible and to minimise trip movements to other parts of the Borough (cf. paragraph 34 of the NPPF: “Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised”). This includes consideration to be given to minimising private car trip movements to existing secondary schools outside the site.

The A10 throughout the Borough of Broxbourne is close to capacity during peak times, with the section to the south of this development site particularly severe. Central to any development

The Broxbourne Transport Strategy and revised Local Plan address the issues raised by the consultant. The fourth arm at the Turnford Interchange is not currently proposed.

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proposals will be the need to undertake junction capacity model checks at key junctions, and/or making use of more detailed transport models of the Borough. Key attractor points across the Borough are existing town centres (Cheshunt, Broxbourne and Hoddesdon), rail stations (in particular Cheshunt, Broxbourne and Cuffley stations), secondary schools, and the Lea Valley Park. Many parts of the highway network close to these areas are already close to capacity and have local issues with heavy roadside parking.

It is likely that mitigation measures will be required to address the impact of increased traffic arising from the proposals on the parts of the network currently under stress. In addition, the impact on the other parts of the strategic highway network needs to be understood – as well as the A10 this should also include the A414, A10/M25 junctions, and Essex Road.

The broad principle of adding a fourth arm to the Turnford Interchange / A10 grade separated roundabout is acceptable, but more detailed designs will be required at a later stage along with safety audits. The second main vehicle access point onto the proposed Turnford Link Road is also acceptable, subject to suitable design details. Any additional vehicle accesses onto the wider public highway network will need to be considered very carefully. To the west of the development site the highway network is rural in nature and it would not be appropriate for significant amounts of development traffic to route onto such parts of the network unless upgrade works form part of the proposals. In addition, access points into the development for pedestrians and cyclists should be clearly defined and sensibly located.

5.125 BR1 1754 Existing public transport accessibility and The Council agrees with the respondent and -


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recommendations

The existing site of the Brookfield Garden Village proposal is predominantly rural, and, as such, no services currently operate in the north part of the Brookfield site. Two routes serve the existing Brookfield Centre in the southern part of the site: up to twice hourly Metroline 242 Potters Bar to Waltham Cross (7 days a week), and up to twice hourly Trustybus 410/410A/411 Harlow to Waltham Cross (7 days a week). The nearest rail station is Cheshunt, approximately 2 miles from the site.

Given the scale of the proposed development, developer contributions would be sought for new and enhanced existing bus services to link the site with key destinations such as Cheshunt station and other parts of the borough. Appropriate supporting infrastructure, including accessible bus stops and a suitable interchange facility at Brookfield, would be required to ensure all areas of the site are within an acceptable 400 metre walking distance. As part of the construction of a new link road, the feasibility to convert the existing access to use by sustainable modes only should be investigated.

Overall, the masterplan layout should actively encourage sustainable travel within and across the whole site placing pedestrians and cyclists first, followed by bus services and finally private car users (cf. paragraph 35 of the NPPF: “developments should give priority to pedestrian and cycle movements, and have access to high quality public transport facilities” as well as “create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians, avoiding street clutter and where appropriate

sustainable travel provision is a key element of the master planning of the development. Appropriate contributions will be sought to bus infrastructure though an “interchange” is not currently proposed.


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establishing home zones”). Whilst access to sustainable travel opportunities is vital, the development should also look to minimise the need to move large distances within it by sensibly locating different land use class elements (cf. paragraph 38 of the NPPF: “Where practical, particularly within large-scale developments, key facilities such as primary schools and local shops should be located within walking distance of most properties”).

5.126 BR1 PO1778 There will be a significant intrusion into the Green Belt west of the A10 into open countryside to create Brookfield Garden Village. This loss cannot be compensated, although areas of community woodland are proposed. Whilst this area is largely former mineral workings, the ancient woodland complex will be seriously degraded compared to its currently undisturbed condition, and it is unlikely that this can be compensated for elsewhere.

The Council does not understand the comment in relation to degradation of the ancient woodland complex. T is proposed that this will be protected and enhanced. The comment in relation to the Green Belt is noted.

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5.127 BR1 PO1781 Policy BR1, Brookfield Garden Village - the Plan recognises that the village woodland setting demands good design and that the woodland and valley of the Turnford Brook should be protected and enhanced. The County Council recommends that Policy BR1 should also include an aim to provide additional woodland habitat to that proposed in order to compensate for the impact on the ancient woodland complex.

The Policy seeks new community woodland -

5.128 BR1 PO1818 The new town centre area known as Brookfield Riverside will include the incorporation of Brookfield Centre and Brookfield Retail Park. The proposed Brookfield Centre mixed use development site currently includes the Household Waste Recycling Centre and the District Council Depot, both of which are existing operational waste sites that are safeguarded under Waste Policy 5 within the Waste Core Strategy and Development Management Policies document, adopted 2012. The proposed relocation of both facilities is (para 5.25 and Policy BR1) is essential

Noted -


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to ensure waste arisings are managed and the County Council will of course be fully involved in those processes.

5.129 BR1 PO1707 Whilst Welwyn Hatfield Borough Council is now content with the principle of the scaled-back proposals for Brookfield, without revised evidence on retail impact we cannot definitively conclude that the scheme will be acceptable.

Noted. Welwyn Hatfield Borough Council has now been consulted on the Council’s Retail and Leisure Impact Assessment and dialogue continues on these matters.

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5.130 BR1 PO1428 With regard to the development of Brookfield, I like the plans to put in significant pedestrian and cycle ways but would like to ask if these can be well defined and possibly separated to make them safer and, therefoer, more likely to be used.

The detailed planning and specification of the footpath network will take place through master planning and through planning applications. An appropriate hierarchy of paths will be established with user safety paramount within that arrangement.

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5.131 BR1 PO2179 A significant area of green belt land is proposed to be released for Brookfield expansion. The 2008 Green Belt Review judges the performance of green belt land in the Brookfield area as performing a strong role in checking sprawl and safeguarding country land. Broxbourne may face scrutiny in regards to the sustainability of the development, with the Council needing to give very careful consideration to the ecological and environmental impacts of the development.

Noted. The Council has produced an exceptional circumstances paper to justify the release of this Green Belt site

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5.132 BR1 PO974 The reference to the Council using Compulsory Powers should be deleted

It is not proposed to delete this reference. If as a last resort compulsory purchase is required, the intent to pursue this within development plan policy is clear to all those with an interest.

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5.133 BR1 PO2118 Recommendation

That sustainable and active connectivity between Brookfield and the wider Borough is given priority within Policy BR1 and reinforced by Policies TM1 (Sustainable Travel) TM2 (Transport and New Developments), INF6 (Bus Transport) and INF7 (Walking and Cycling)

Such connectivity is integral to the principles and policy for Brookfield.

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5.134 BR1 PO2130 Recommendations

That the impact of poor air quality on the

Comment noted. Air quality considerations/mitigations will be an important element of Environmental Statements attaching to

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Brookfield Riverside community is considered and that mitigation measures are designed-in from the outset, particularly where accommodation for elderly people is being provided

planning applications.

5.135 BR1 PO2204 At present, there are many allotments on this site. Where has the Council identified suitable fertile land for them to be transferred to?

A site is shown on the Policies Map for the relocation of the allotments

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5.136 BR1 PO1306 The proposed relocation of the business units currently located in the Brookfield business area may lead to their loss to the Borough.

As part of any planning application for Brookfield Riverside, it is anticipated that an employment paper will set out proposals for the individual businesses. Whilst no guarantees can be provided, it is hoped that many of these will be retained in the Borough.

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5.137 BR1 PO1333 The proposed relocation of the business units currently located in the Brookfield business area may lead to their loss to the Borough.

Noted -

5.138 BR1 PO1331 Policy BR1 refers to up to 4 forms of entry (FE) of primary schooling to be provided within the wider Brookfield development; however the number of dwellings proposed is 1500. Appendix A outlines the County Council requirements for 1FE of school places for every 500 dwellings. The Brookfield development is therefore anticipated to yield a demand for 3FE of primary school places. The County Council preference would be for this to be provided in one 3FE primary school.

This school will need to be delivered early on in the development as there is no contingency in nearby schools to accommodate demand for the new families moving into this housing.

Comment agreed. A single 3fe primary school is now being provided for.

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5.139 BR1 PO1334 The requirement in Policy BR1 for the Brookfield developments to be master planned is welcomed and supported.

Noted -

5.140 BR1 PO1409 The County Council owns land at Cheshunt Park Farm and the adjoining Brookfield Centre which lies within the proposed Brookfield Garden Village and Brookfield Riverside developments. As landowner the inclusion of this land is supported in

Noted -


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principle provided the infrastructure costs can be borne economically. The phasing of this development in relation to other allocated sites will be very important. HCC are currently working jointly with the Borough Council on a masterplan for this area.

5.141 BR1 PO1443 The Brookfield area is cited as being a Council 'aspiration' for development and takes this as a given rather than challenging this view. This is not a robust basis upon which to release land.

Noted -

5.142 BR1 PO1454 Draft Policy BR1 refers to three distinct areas at Brookfield which are to provide a focus for future development within the Plan period. Land at Brookfield is proposed to be removed from the Green Belt to create Brookfield Garden Village. The development of this area is purported to be a long held Council aspiration although it has no basis in evidence or justification for the allocation of this land.

The previous proposal to include this land as an allocation was rejected by the Inspector examining the Core Strategy on the basis that it was unsound.

It is not clear why this land is being proposed to be removed from the Green Belt, nor is it entirely clear where the existing uses will be relocated within the Borough boundary. It is considered that this proposal be removed from the Local Plan as the lack of evidence renders its inclusion unsound.

Noted. The Council has produced an Exceptional Circumstances paper to explain the removal of the Brookfield area from the Green Belt.

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5.143 BR1 PO1446 I strongly object to this proposed development. Instead Cheshunt Park should be extended to include this whole new area. This enlarged county park form a wonderful conservation and recreation area which would be enjoyed by all the residents.

Comment noted. This is not proposed. -

5.144 BR1 PO1547 I feel the proposed developments on the Brookfield Site should not go ahead to the scale planned as it

The Broxbourne Transport Strategy and traffic modelling indicate that the strategic and local road

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will cause unmanageble traffic congestion in this area.

network can accommodate the proposed development with appropriate mitigations.

5.145 BR1 PO1549 The proposed Allotment site in Park Lane Paradise will increase traffic considerably because of the existing site many local residents walk to, where if it is placed in Park Lane Paradise the only access is by road. This proposed site regularly floods.

A new site is proposed for the allotments. This is shown on the Policies Map. It is not considered that this site will lead to significant traffic generation.

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5.146 BR1 PO1558 Finally on meeting an officer it seems that the council want to call the area a “Garden City” which it is not. Broxbourne Borough is not a new town it is a part of Historic Hertfordshire and should be kept as such.

Comment noted. -

5.147 BR1 PO1552 The proposed Travellers site in Park Lane Paradise does not seem to be a very suitable site for the following reasons.

No services available

No bus routes

No local shops

More vehicles on this country lane

The site will possibly be cutting through the Roman road

Many considerations have gone into concluding that this site is on balance the most appropriate travellers’ site. It is essential that this site is properly integrated through master planning and delivery.

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5.148 BR1 PO1553 The existing site in Halfhide Lane has been there for 30 plus years and the Travellers form part of the local community.

They are able to walk to shops, local schools, doctors etc,.

It seems the council policy on this matter seems to be “out of sight out of mind”

The existing site is not consistent with the proposals for Brookfield Riverside which will necessitate its re-location.

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5.149 BR1 PO1546 Having attended two local plan consultations in July and August we are writing to object to the proposed new housing estate that is planned in one area of prime green belt land. This can never be replaced when its “gone its gone”. There are other smaller green belt areas within the borough with less impact visually than 1250 houses in one

Comment noted. It has been decided to retain the land referred to at Cock Lane within the Green Belt

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place. Why with the new housing estate at High Leigh’s being passed for housing has the council not considered allowing houses to be built on east of the A10 between Cock Lane and Lord Street. This land is not green belt (formally reinstated pit land) Thus reduce losing so much prime green belt land at Brookfield to be built on.

5.150 BR1 PO1683 The proposal to "strengthen the identity of the Borough by expanding and improving the Brookfield centre" and in particular "at Brookfield Riverside of "up to 30,000 square metres net retail comparison floorspace."

The justification for this significant increase, notwithstanding the Inspectors comments in relation to the Core Strategy Examination, and how the impact on other well established sub regional shopping destinations has been considered. This is of particular concern to Harlow Council having regard to the towns long term regeneration needs and the fact that it is to be the focus for some significant housing growth that has been identified in the joint SHMA prepared for the East Hertfordshire/West Essex area.

Noted. Harlow Council has been consulted on the Council’s Retail and Leisure Impact Assessment.

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5.150 BR1 PO1730 There is no proposed rail station at the Brookfield Centre. It must be accessible but all means of transports - trains means less cars.

There is no railway at the Brookfield centre and the emphasis is therefore on bus connectivity. A new railway station is proposed at Turnford, c. 1km to the east.

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5.151 BR1 PO1733 Brookfield’ is Ancient and Semi-Natural Woodland. Since the development encircles the woodland this allocation has the potential to fragment and disconnect this ecological feature, something which would conflict with other policies in the plan. Consideration should be given to how best to maintain connectivity with the wider landscape and other ecological features including Biodiversity Action Plan (BAP) Habitat and the new community woodland.

Connectivity is proposed through a Green Corridor to the west.

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5.152 BR1 PO1823 Brookfield Garden Village

The site has been extended to the west and a slither to the north of the polygon in March 2015. The western extension covers an area that the Institute of Geological Science (now BGS) data sheets show as ‘Exposed mineral, assessed’. There is no record of mineral and waste applications covering the additional parts of the revised polygon. Therefore there may be the opportunity to extract resources for use on site during development.

With regard to additional comments to add to those provided previously regarding the remainder of the site, it appears from BGS GIS layers that there are superficial deposits of sand and gravel which cover the eastern side of the site.

Any opportunities for further extraction will be considered through the planning application for Brookfield Garden Village.

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5.153 BR1 PO1828 Brookfield Riverside

The site has been extended to the north and south since commenting on the March 2015 polygon. This site is within the sand and gravel belt and the Institute of Geological Science (now BGS) data sheets show the area as ‘Continuous or almost Continuous spread of mineral beneath overburden’. It appears from BGS GIS layers that there are superficial deposits of sand and gravel in this area. Therefore there may be the opportunity to extract resources for use on site during development should the site be allocated and be brought forward for development.

The previous comments are still applicable and it should be noted that the extension to the south includes the entire application area that was refused permission in 1966 for the extraction of gravel.

Any opportunities for further extraction will be considered through the planning application for Brookfield Riverside. Relocation of the Turnford HWRC is proposed within the Policy.

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Comments are as follows:

The site contains the Turnford Household Waste Recycled Centre and the Council depot which would need to be relocated if the site were to be brought forward for housing. These sites are safeguarded waste facilities by HCC.

The south west corner of the site was refused permission in 1966 for the extraction of gravel.

5.154 BR1 PO1848 Brookfield (Existing and Merged Employment Allocations)

This site is within the sand and gravel belt. The allocation has been increased in size since March 2015. The Institute of Geological Science (now BGS) data sheets show the area as ‘Continuous or almost Continuous spread of mineral beneath overburden’. It appears from BGS GIS layers that there are superficial deposits of sand and gravel in this area. There may therefore be the opportunity to extract resources for use on site during development should the site be allocated and be brought forward for development, particularly if developed in combination with Brookfield Garden Village and Brookfield Riverside sites.

The site is covered by multiple County Matter applications at Cheshunt Park refused (E/0580-58 & E/0750-58) and withdrawn for extraction (7/0960-03) and withdrawn for waste (7/0910-00). The south-western corner of the site overlaps a small area of planning application 7/0432-98 at Cheshunt Park Farm for waste permitted in 2000. The site is a historic landfill designated by the Environment Agency.

Any opportunities for further extraction will be considered through planning application(s) for this area.

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5.155 BR1 PO1940 If the following sites/improvement areas do move forward to the next stage of the plan we would like to make you aware of the following:

Comments noted and agreed in principle. -


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Brookfield Riverside: Any development must enhance the river and its riparian zone for biodiversity, as well as for public access. The river must not be culverted as part of the development.

Brookfield Garden Village: Development should be planned sequentially to ensure no building in the floodplain. There must be no net loss of habitat or biodiversity as a result of the development. A buffer strip of at least 8 metres (m) must be left alongside the river channel. The Local Wildlife Site and Ancient Woodland must be protected and left undeveloped.

5.156 BR1 PO1998 The Plan includes the delivery of at least 3,733 units within the Green Belt, through major redevelopment of existing countryside locations. One of these locations is Brookfield, where it is envisaged to deliver Brookfield Riverside and Brookfield Garden Village which will deliver 1,500 new homes, 50,000 sq m business floorspace, 50,000 sq m retail floorspace, a new school and various further community uses, public open space and woodland (Policy BR1 of the Local Plan).

Releasing Brookfield from the Green Belt to facilitate the proposed regeneration would significantly encroach into the countryside, arguably sprawling out of the built-up area of Turnford, which would be contrary to paragraph 80 of the NPPF.

Focusing development to Brookfield, before fully encouraging development of all redundant brownfield sites, such as the Meeting Hall site, would go against the final requirement of paragraph 80 by not assisting with urban regeneration.

The Council has produced a Green Belt Topic Paper on Exceptional Circumstances paper that seeks to justify the removal of Brookfield from the Green Belt. Residential development is not considered to be appropriate on the respondent’s site.

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It is therefore the case that the approach currently taken by the Local Plan is not consistent with national policy.

5.157 BR1 PO2041 Brookfield Centre should be a priority for development. The Council must deal with the car traffic that cross between the shops as soon as possible. There is no space for children at the centre, no walking or resting areas. At the centre, either you are in the car or in the shop. No breathing space is available. It is not possible to move from one shop to another one by walking.

Comments noted and generally agreed. Master planning for Brookfield is seeking to create a new and inclusive place for all

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5.157 BR1 PO2223 The site at Brookfield will only attract retail/restaurant employment which will be taken from the sites already in place in Waltham Cross, Cheshunt, Broxbourne & Hoddesdon

The Council has produced a Retail and Leisure Impact Assessment. This concludes that the impacts of the retail and restaurant proposals would be acceptable.

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5.158 BR1 PO2225 Excessive, unnecessary. Noted


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Chapter 6: Broxbourne

Issue No. Comment ID(s)


Issue Officer Response Proposed amendments to the Plan

Chapter 6: Broxbourne

6.1 PO486 Chapter 6: Broxbourne

The Broxbourne chapter was quite vague and was not sufficient to count as a meaningful consultation.

The content of the Local Plan has to reflect to a significant degree the development proposals in specific areas. With the exception of Broxbourne School, there are no current significant development proposals or sites of sufficient scale to merit an allocation within the Local Plan. Nevertheless, it is considered helpful to include a section on Broxbourne to address the future development of the station area and the village improvement plan.

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Hertfordshire County Council comments that there is no “Schools and Health Centre” section as there is with other settlements. They note that the children from Broxbourne attending secondary schools located within the Hoddesdon Education Planning Area

Information regarding the Borough’s educational and health facilities, and the proposed improvements are contained within Chapter 17 of the Plan.

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Object to the re-negotiation of the Green Belt around Broxbourne. Access to open spaces provides a number of benefits to residents in the immediate area, and to those who travel to Broxbourne to enjoy it. The physical barrier between the urban areas and the countryside helps preserve the character of small towns and prevents them merging together. Green Belt land offer better air quality to the urban area

The Council has only identified one area of land to be removed from the Green Belt within Broxbourne; the Broxbourne School site. The development of 153 dwellings on this site will be enabling development that will facilitate the provision of new schools buildings and a leisure hub. The redevelopment of the school will also involve an expansion of 1FE, aiding in the provision of secondary school places within

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and is vital to nature conservation. the Borough during the Plan period. The exceptional circumstances necessary for release of Green Belt are set out in the Green Belt Topic Paper (2017).

Paragraph 6.1

PO616 Paragraph 6.1 Historic England welcomes the acknowledgment of the historic nature of the village of Broxbourne.

Support noted. -

PO958 Paragraph 6.1 Concern about the population of Broxbourne remaining stable whilst Cheshunt as to face a large increase. More homes should be built in Broxbourne, especially as it is going to be the starting point of Crossrail 2.

As part of the Local Plan process, the Council undertook a number of studies to identify appropriate and sustainable land for development. Broxbourne does not cover a large area of land when compared to Cheshunt. There are also limited opportunities for development within this area of the Borough as a result of its constrained nature (Lee Valley Regional, strong defensible Green Belt boundaries, Conservation areas, lack of regeneration opportunities). A number of opportunities have arisen within Cheshunt to enable the Council to provide a significant amount of housing in relatively sustainable locations.

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Policy BX1

PO617 Policy BX1 Historic England notes that there is no mention of the conservation area and the need to protect and enhance this as part of any village improvement plan in Paragraph 6.2 and Policy BX1. Ideally this should be included in Policy BX1 as well as the supporting text

Conservation areas are addressed in the section on Historic Environment (previously heritage assets).

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6.7 PO1765 Policy BX1 Hertfordshire County Council support environmental and streetscape enhancements. However, in order to facilitate travel by walking and cycling, bus movements through the area should not be impeded. HCC note that the area is served by the following: the high frequency Arriva 310 Hertford to Waltham Cross (up to 6 per hour, 7 days a week), hourly Trustybus 392 Harlow to Rye Park (6 days a week), hourly Uno 341/641 Broxbourne to Hatfield/Hertford (6 days a week), and Trustybus 410/411. Any proposals should be subject to discussions with TARS and consider bus operations, in particular avoiding vertical traffic calming measures where possible.

Noted

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6.8 PO2117 Policy BX1 The Public Health Service recommends that policies BX1 and BX2 include a specific focus on new and improved active/sustainable travel infrastructure (accessibility, signage, safety and attractiveness), to encourage physical activity and better health.

Noted

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6.9 PO1941 Policy BX1 The Environment Agency comments that development should be planned sequentially to ensure no building in the floodplain.

Noted

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6.10 PO1941 Policy BX1 The Environment Agency comments that the development must also enhance the river and its riparian zone for biodiversity, as well as for public access.

Development will be assessed with reference to emerging Policy W1: Water Quality, which seeks to preserve and enhance the Borough’s water environment.

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6.11 PO1941 Policy BX1 The Environment Agency comments that a buffer of at least 8m must be left alongside the river channel and that the river must not be culverted as part of the development.

Buffer strips are addressed in the section on Water later in the plan.

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Policy BX2

6.12 PO618 Policy BX2 Historic England comment that Broxbourne Station is a grade II listed building and that this should be highlighted in both the policy and supporting text. Any proposals for the station will need to protect and enhance the listed building and its setting.

Such details will be addressed within the proposed development plan. The historic environment section of the plan affords protection.

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6.13 PO1216 Policy BX2 Broxbourne station is larger and has more platforms and scope for expansion than Cheshunt Station. The station also currently has more express services to London.

Noted. -

6.14 PO1217 Policy BX2 Car parking facilities at Broxbourne are larger and will be easier to expand than those at Cheshunt Station

Noted. -


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6.15 PO1891 Policy BX2 Transport for London comment that Broxbourne is likely to be the northern terminus of Crossrail 2. The wording of Policy BX2 should be strengthened to better reflect the opportunities that Crossrail 2 would bring to this area, and the need to have an appropriate policy framework in place to support and justify the investment in Crossrail 2. This goes beyond infrastructure requirements and needs to consider the potential for development in areas around the station that could be unlocked by rail investment.

Agreed. The Council acknowledges that if Broxbourne is the northern terminus of Crossrail 2 there would be numerous benefits for the Borough. This is already stated in the supporting text.

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6.16 PO1513 Policy BX2 Hertfordshire LEP support the proposed development plan for Broxbourne Station. This should aim to achieve dense and high quality development, together with a transport interchange as well as good pedestrian and cycle network to the surrounding areas.

Support noted. -

6.17 PO2078 Policy BX2 Lee Valley Regional Park Authority supports policy BX2 which identified the need for a long term development plan for the Station. This is linked to the current proposals for the Station as the northern terminus of Crossrail 2. Supporting text identifies the need to work with the Authority to consider the development potential of parkland to the east site of the station, at Spitalbrook, and possibly the former Leisure Pool site. There is the potential for synergy with draft policies for Spitalbrook. The redevelopment of station sites afford the opportunity to design each

The policies have been grouped together in the Lee Valley Park section to indicate the synergies.

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site as a major public transport accessibility hub in a way which responds to the presence of the Regional Park. Supporting text in the draft plan should be revised to account for this.

6.18 PO1766 Policy BX2 Hertfordshire County Council comments that a long term development plan for Broxbourne station should prioritise access by non-car modes, including continued support for a high quality bus interchange facility. A recent scheme has remodelled the bus stopping facilities, and opportunities for further increasing sustainable access to the station should be secured should developments come forward.

Agreed. The Council is committed to promoting sustainable modes of transport.

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6.19 PO1766 Policy BX2 Hertfordshire County Council notes that the station is served by Trustybus 392 and Uno 341/641 Broxbourne to Hatfield/Hertford. Any additional demand for access to Broxbourne station associated with Crossrail 2 proposals should be supported by enhanced public transport.

Noted. Due to the expected completion date for Crossrail 2 falling in the latter period of the Plan, the Council considers it to be too early to create proposals for enhanced public transport. The Council will continue to work proactively with Transport for London and Hertfordshire County Council to ensure that, when needed, there is appropriate and enhanced public transport to support Crossrail 2.

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PO1942 Policy BX2 The Environment Agency comment that the Council must ensure that there is no negative impact on the New River or Spital Brook. Options to enhance the rivers should be explored as part of the redevelopment to give a net gain for biodiversity. There should be

The Lea Valley Park contains much sensitive habitat and the Council will work with relevant stakeholders to ensure that there is an appropriate environmental strategy in place.

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implementation of 8m buffer zone where possible.

Paragraph 6.4

6.20 PO619 Paragraph 6.4 Historic England comments that part of the Broxbourne School site, where there are proposals for new school buildings, homes, a leisure hub and community facilities is within the New River Conservation Area and the Wentworth Cottages Conservation Area is in close proximity. There are also a number of listed buildings nearby, including The Red House (Grade II listed) and 175-177 High Road (Grade II listed). Concern about the impact the proposed development upon the listed buildings, Conservation Areas and their settings. Recommend that reference is made should be made both in the supporting text and policy to the requirement to protect and enhance the Conservation Areas and listed buildings and their settings. Proposals should be of high quality of design, and respond to the sites relationship with the Conservation Area and being sympathetic to the setting of the nearby listed buildings

A hybrid planning application for this site has been granted planning permission. As this site falls partly within and adjoins another conservation area and there is a grade II listed building close to the High Road site entrance, the impact on the historic environment was considered. As part of the application, design codes were submitted. The design code for the part of the site within the conservation area will set out clear guidance for submission of reserved matters for the housing element of the scheme and subsequent condition discharge of material and finishes.

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6.21 PO619 Paragraph 6.4 Historic England suggests that the eastern portion of the Broxbourne School site that lies within the Conservation Area could be left open and fairly un-developed and could lend itself to be used as public open. Reference in the text to the need for high quality design, responding to the relationship with the Conservation Areas and listed building and the suggestion to leave the eastern portion of the site open for public open space be included in the supporting text.

Hybrid planning permission for this site has been granted. Full planning permission has been granted for the construction of school buildings, with outline permission being granted for the residential element of the scheme.

Policy BX3

6.22 PO11, PO9, PO10

Policy BX3 Object to the planning request on the Broxbourne School site

Objection noted. At the meeting of the Planning and Regulatory Committee on 26

October 2016, it was resolved that planning permission be granted for this site subject to, submission to and clearance by the Secretary of State, the application completing a planning obligation under s.106 of the Town and County Planning Act (1990) as amended.

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6.23 PO11 Policy BX3 The development at Broxbourne school will have a negative impact on the nature reserve and ancient woodland adjacent to the site.

The Herts and Middlesex Wildlife Trust were consulted on this planning application. They raised no objection to the proposed development subject to conditions requiring measures to mitigate impact and promote bio-diversity. Such conditions include a limit placed on the height of the house next to the nature reserve and the tree planting on the western boundary of the site to come forward as an early part of the scheme. Such actions will aid in negating against the

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impact will have on the adjoining Local Nature Reserve and woodland.

6.24 PO895 Policy BX3 National Grid comment that the underground pipelines at this site are protected by permanent agreements with landowners or have been laid in the public highway under our licence. These legal agreements grant National Grid legal rights to enable use to achieve efficient and reliable operation, maintenance, repair and refurbishment of our gas distribution network. National Grid require no permanent structures are built over or under pipelines or within the zones specified in the agreements, materials or soils not stacked or stored on top of the pipeline route and that unrestricted and safe access to any of National Grids are maintained at all times. National Grid notes that gas distribution pipeline diversions may take several years and might not be possible at all.

National Grid was consulted on this planning application. Their response confirmed that there is a high pressure gas main which crosses the site.

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6.25 PO1916 BX3: Broxbourne School

Thames Water Limited comment that on information available to date they do not envisage infrastructure concerns regarding Water Supply capability in relation to this site.

Noted. -


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Thames Water Limited comment that on the information available to date they do not envisage infrastructure concerns regarding wastewater infrastructure capability in relation to this site.

Noted. -


Thames Water Limited comment that initial flow and pressure tests have indicated that this site can be served by the existing mains, however, should proposals change, further tests may need to be carried out.

Noted -


Hertfordshire County Council comments that the proposals include junction amendments at the junction of High Road and Bella Lane, and other mitigation measures, which have been agreed.

Noted. -


Hertfordshire County Council comments that a developer contribution to the improvement of bus stops “opposite and near New River Garage” would be expected in order to support easy access to services including the high frequency Arriva 310 Waltham Cross to Hertford (up to 6 per hour). The improvement is likely to require Kassel kerbing at both stops and possible realignment of the layby at the southbound stop.

A hybrid application for this site has recently been granted planning permission. The committee report presented to the Planning and Regulatory Committee on 26/10/2016 indicated that the viability of the scheme may not provide scope for additional obligations outside of the provision of a secondary school and leisure hub. The report notes that ‘Any additional scope for planning obligations will result from on-going viability and review of costs and returns’.

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Hertfordshire County Council comments that the redevelopment of Broxbourne School should be mindful of the Wildlife Site immediately adjacent to the site to the west.

A hybrid application comprising part full, part outline for the redevelopment of the existing school to provide an 8 form of entry and the redevelopment of the existing school buildings and part-playing field area to the west for residential development comprising of up to 153 dwellings has been granted planning permission. Herts and Middlesex Wildlife Trust were consulted on this application, and raised no objections subject to conditions requiring measures to mitigate impact and promote bio-diversity.

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Hertfordshire County Council comments that the notation on the Proposals Map should cover both the residential and education proposals for this site. It is currently only displayed on the education area.

Noted. The Council will amend the Policies Map so both the residential and education proposals for the Broxbourne School site are displayed.

Proposed amendment to the Plan in response to this issue. The notation on the Policies map will be amended to ensure that the residential and education proposals for this site are properly presented.


The Hoddesdon society supports the re-development of The Broxbourne School. The Hoddesdon Society comments that one of the most important aspects of ensuring the development of a successful community is the provision of high quality education and that, hopefully, the other schools in Hoddesdon will be supported by contribution from developers

Support noted. To accompany the emerging Local Plan, the Council has prepared an Infrastructure Delivery Plan (IDP) that details the infrastructure required to support the proposed development. The IDP will be the evidence needed to support Section 106.

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6.33 PO1829 BX3: Broxbourne Hertfordshire County Council comments that it appears from BGS GIS layers that there are superficial deposits of sand and gravel in this area. Therefore, there may be the opportunity to extract resources for use on site during development. HCC GIS Layers have been checked and nothing is registered for this site.

Noted -

6.34 PO1829 Policy BX3: Broxbourne School

Hertfordshire County Council comments that the extended part of the allocation lies directly adjacent to application E/1506-07 which was refused permission for the extraction of sand and gravel in 1970 and E/0041-70 which was withdraw for extraction in 1970. Hertfordshire County Council as Minerals and Waste Planning Authority have provided comments on planning application 07/16/0512/F, which is being determined by the Council, in respect of the site location within the sand and gravel belt and the opportunistic use of some limited or poorer quality minerals at the site that could be utilised in the development itself.

Noted. -


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Chapter 7: Cheshunt

Issue No.

Policy/ Para. no.

Commt. ID(s)

Issue Officer response Proposed amendments to the Plan

7.1 7 PO111 PO1723

The roads will not be able to cope with the extra traffic generated by so many new houses. Journeys will be impeded by traffic jams.

Extensive transport modelling has been undertaken which demonstrates that whilst traffic will get heavier, the measures proposed in the Transport Strategy will enable the road network to continue to function.

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7.2 7 PO2171 PO1314

Cheshunt and Goffs Oak will take over two thirds of development in the Borough and lose Green Belt; instead there should be less development here and more in the northern part of the Borough.

Careful consideration has been given to a large number of sites across the borough, as set out in the Sustainability Appraisal and the Development Options reports. Based on this assessment the Council has put forward the proposed sites as offering the best available.

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7.3 7 PO1721 Do not allow a repeat of the loss of amenity and parking caused by intensive development by Aldwyck Housing Association on Russells Ride estate.

Noted. -

Cheshunt Lakeside

7.4 Cheshunt Lakeside CH1 Rosedale Park CH2 Maxwells Farm West and Rush Meadow CH8

PO370 PO371 PO1299 PO2242 PO374

As landowners in the area, object to the policy referring to the Council using compulsory purchase powers. This is not a matter for planning policy as the powers are under different legislation, and it is unnecessary anyway.

It is not proposed to amend this reference. Compulsory purchase may be required to deliver parts of these developments. If that is the case, it will almost certainly be pursued under town planning legislation.

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7.5 Cheshunt Lakeside

PO2256 Windmill Lane is becoming a no go area in the evenings due to no real shops or places that people over 25 would want to visit; building many flats in this area will make it worse

Master planning of this development is seeking to ensure that it will be a place that people will want to visit at all times.

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PO2256 PO2195

This development will cause the area to be overrun by an influx of commuters who see the station’s proximity as a way of overcoming high London property prices.

This development is aimed primarily at local people, many of whom will be commuters. It is also likely to attract commuters out from London but that is the nature of a development close to a railway station.

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PO191 PO1311 PO239 PO562 PO497 PO1103 PO602 PO963 PO1102 PO1560 PO1561 PO1562 PO1563

Object to compulsory purchase of houses in Delamare Rd and Windmill Lane because:

Owners will be forced out of their homes of many years

Owners will not be offered the full value for their property

People who bought earlier this year were not informed of the possibility, despite the proposal being put forward on 16 February

Residents were not given enough time to respond as the consultation started during the summer holidays, and they need time to appoint professional advisers.

It is unnecessary – the development could be smaller and leave these houses alone. The houses could form the boundary of the development. The neighbourhood centre could be placed south of Delamare Rd where there are currently low density commercial buildings.

It will destroy an urban village with friendly residents.

These older houses add to the residential mix.

Development will front onto the pavement on both sides, making the road very enclosed, rather than the gardens of the houses currently

The Local Plan does not specifically propose compulsory purchase but is part of the enabling of it if that is necessary. Within the master planning of this development, it is not currently proposed to redevelop the houses on Delamare Road. However, it is proposed to redevelop the Windmill Lane properties. The Council’s preference is for negotiated acquisition but should that not be successful, compulsory purchase is a probability. Should that be the case, the Council will be fully respectful of compulsory purchase and related legislation.

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providing a more open, village-like aspect to the gateway to Cheshunt.

Crossrail2 may require the same land on Windmill Lane; it will be cheaper to wait and see rather than building flats now that have to be demolished later.

Homeowners are being threatened and intimidated by developers, e.g. trying to obstruct rights of way, compromising the security of residents of Windmill Lane through their actions re. the former Tesco car park. Developers who do this should be barred from developing the site.


PO406 PO1314 PO1308 PO1310

Keep Delamare Rd for business purposes, and build houses elsewhere.

The area needs jobs, not houses; it is over-populated already, and there is a shortage of school places and doctors locally.

Delamare Rd is near the station, which enables workers to come in by public transport rather than car.

There are existing business premises in Delamare Rd; it is more cost-effective to retain and build around them than to build housing.

The Cheshunt Lakeside development proposes jobs as well as houses. It also proposes a primary school and is making provision for health care if the health care providers are seeking facilities within the development. Where practicable, the development is seeking to re-accommodate existing businesses within it.

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PO498 PO501 PO949 PO1167 PO1209

This is over-development; a) Why so many flats on this one development,

rather than putting more of the flats at other sites elsewhere in the Borough? Having so many flats in this development will require high rise blocks of 10 storeys, and the estates of the 60s and 70s prove that these do not provide a good environment to live in and cause problems.

b) There is not enough room for 1000 dwellings

Master planning is/will demonstrate the capacity of this area to accommodate the number of apartments being proposed. This has in fact now increased to a figure of c. 1,750 within the Local Plan policy and the developers are targeting a figure above this. With much of the area having been vacated by Tesco and with it being adjacent to Cheshunt Station, a high density mixed use development is considered to be the most sustainable approach to this site in meeting wider housing and business needs.

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plus open space, a school, neighbourhood centre etc. Reduce it back to 400 dwellings.

c) Bad impact on current residents of the area. d) Too many flats, rather than family homes,

which is what local people need. Flats so near the station will attract London commuters who do not already live here, and buy-to-let landlords.


PO865 Change the name; there is already a Lakeside Rd in Cheshunt.

It is not proposed to change the name. -


PO200 Trains from Cheshunt are already packed; is there a guarantee that more trains will run to accommodate the thousands of new inhabitants?

Crossrail 2 and 4-tracking will provide a significant amount of additional capacity.

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PO562 PO91 PO171 PO252 PO256 PO864 PO959 PO949 PO1210 PO1218 PO2210 PO2211 PO1166 PO1312 PO1315 PO1565

Windmill Lane and Cadmore Lane cannot cope with the extra traffic 1000 new homes will generate; because:

a) Windmill Lane is already very busy from railway commuter traffic, and in evenings, especially when Spurs is playing at home in the evening, it can be gridlocked.

b) People will park outside the proposed shops in Windmill Lane

c) Crossrail 2 will increase traffic around the station

d) The road surface in Windmill Lane is below par and additional heavy traffic will cause further degradation

e) At the junction with Cheshunt railway station the turning circle is poor and the junction is dangerous; this will need to be improved

f) The proposed primary school will increase traffic, and the busy road will be unsafe for children and parents.

Traffic modelling is on the basis of 2,000 homes. To date, the Broxbourne Transport Model is demonstrating that the local highways network can cope but that is a matter of on-going assessment. Additional local parking controls are being discussed with the prospective developer. Major increases in parking provision are not being proposed through Crossrail 2 which is beyond the Local Plan period. The road surface of Windmill Lane is not a Local Plan matter. Master planning of the Cheshunt Lakeside development is proposing a new road that will enable turning manoeuvres. It is expected that most trips to the primary school will not be car borne. The safety of children and parents will be paramount in the detailed planning.

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g) Air pollution and noise pollution will be excessive

Consider making Windmill Lane and Cadmore Lane urban clearways or have parking regulations to prevent parking, to prevent the development causing major inconvenience to current residents. Consider building a new access road to alleviate traffic.


PO201 PO92 PO253 PO365 PO427 PO905 PO1219 PO1313 PO1720

Parking provision inadequate for 1000 dwellings planned, and to accommodate extra commuting due to Crossrail 2:

a) Parking between Russells Ride and Roundmoor is already very difficult due to commuters parking there, and on-street parking narrows the roads, creating a bottleneck. There is difficulty for emergency vehicles access.

b) The development removes two car parks in the Delamare Rd area that are always full with commuter traffic

Because of the relatively high level of public transport accessibility to the site, parking provision will be relatively less than in less sustainable locations. However, the level of parking to be proposed and its management continues to be the subject of detailed planning with the prospective developer. A key element of the development will be to provide a new and regular bus service connecting to many parts of the borough. That is intended to reduce the need to park within the vicinity of the station.

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PO303 Must enhance bus services along Windmill Lane via the new urban village, linking to both Cadmore Lane and Cheshunt Station, with a new bus terminus near the station, to help reduce increase in traffic arising from Crossrail 2 and the development.

A new and regular bus service to the station is proposed.

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PO499 Due to Crossrail 2 the railway level crossing will be replaced with an underpass or traffic bridge, which will require the land earmarked for the neighbourhood centre on Windmill Lane. Four-tracking will also reduce the land available for this development.

That is not the case. An alternative bridge location(s) is being pursued. Four tracking will not require land take on the west side of the railway.

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7.16 Cheshunt PO254 Live nearby and concerned about disturbance during Any planning permission would require a -


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Lakeside PO258 PO303 PO1317

construction: a) Where will workmen park their vehicles

during construction? b) What will be done to minimise dust and

noise? c) Full vehicle and pedestrian access to Lea

Valley Park at Windmill Lane must be maintained throughout construction

d) How will residents be compensated for depreciation to their properties during 15 years of construction?

Construction Environmental Manage Plan which would address these concerns. There would not be compensation for living close to a construction site.


PO906 PO962 PO1220 PO1309

Object to businesses having to move because a) They are useful for residents in their current

location; easy to access on foot from Cheshunt, specifically Fast Fit, Car Spares shop, drama/dance school – an asset for local children.

b) This will mean a loss of low cost, spacious premises suitable for engineering and car maintenance, as Park Plaza is focussed more on facilities for high tech businesses. Loss of such premises may lead these employers to relocate out of the Borough or go out of business, meaning local job losses.

The Council is concerned about the future of the businesses within Delamare Road and is seeking their re-accommodation within the development where possible. The Council will assist and may directly provide for others that are displaced.

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PO1863 PO1864 PO1865 PO1866 PO1867

(On behalf of owner/occupier Eurovia Infrastructure Ltd) Station House (site ref. CG-U-45) was bought in 2014 and refurbished without any knowledge of the proposal in the draft Local Plan to demolish it to build a neighbourhood centre. This would require a compulsory purchase order (CPO). If the policy is not changed, Eurovia may challenge adoption of the Plan. The Council’s evidence about the use of this

Whilst the Eurovia building remains within the development area, current plans are for it to remain in situ. It would not therefore be subject to compulsory purchase.

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property is out-of-date and inaccurate. It is described in the SLAA as vacant, and having been subject to pre-application discussions for conversion to residential use. This was before it was purchased by the current owner/occupier. It now houses offices for a local and successful business for highway infrastructure and maintenance employing more than 50 staff, and the building is integral to the functioning of that business. The evidence backing the proposal is based on premise that Crossrail 2 will be built, but the plans are at an early stage, and it may not go ahead. The earliest it could be delivered is 2033; despite this the Council wants to build houses from 2021-2026. It is not critical to the development for this building to be allocated and the current use of the building is compatible with future residential development around it.


PO801 PO782 PO959 PO1425 PO1892

As a business, object to having to relocate.

What assistance will the Council provide for this, including financial support to avoid detriment to the business?

Uncertain about which development companies have been approved by the Council to purchase premises.

Uncertainty is affecting our business tenants’ ability to plan and tenants are moving out, affecting our income stream.

Unclear where businesses can move to locally, as they are not the sort of businesses that fit into the Plan’s proposed developments.

Where appropriate, the Council is seeking to re-accommodate local businesses within the development. Where that is not feasible, the Council is investigating options for re-provision elsewhere. Assistance will be provided by the Council. The type and level of assistance to be provided will be dependent on the circumstances of individual businesses.

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Our customer base is local, so we do not want to move further than a mile from Delamare Rd

Suitable alternative premises are not available for purchase in the area.


PO134 PO949 PO954 PO1165

Concern that houses on the development will not be affordable for Cheshunt residents.

Want affordable homes for rent

Want to prevent homes being all taken by people from London wanting to commute there for work; prefer them to go to people already living in the area.

The Policy requires that 40% of the dwellings within the development will require to be affordable. These will be for local people.

-


PO2176 PO1166 PO684 PO2177

Ensure there is sufficient infrastructure to support the new development, specifically health services, schools, sewerage

All of the necessary infrastructure is/will be planned for.

-


PO173 What is the point of building a neighbourhood centre here when Wolsey Hall could be retained instead?

Wolsey Hall has now been demolished. -


PO1032 PO1033 PO2040

(On behalf of largest site owner/developer) Delivery of the site should be subject to agreement of a comprehensive master plan framework, and the policy should set out that this framework will form a material consideration in determination of any planning application on the site, so the Council can guard against unhelpful piecemeal development. See masterplan, transport position statement, flood risk and SuDs report at \\Broxstore1\r_drive\Planning Policy\New Local Plan\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO1032 and PO1033 and PO2026

That master plan is currently being developed with the developer in accordance with the Policy

-

7.24 Cheshunt PO2039 (On behalf of largest site owner/developer) The policy remains largely unchanged but -


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Lakeside Propose change in wording for Policy CH1. Suggested amendments are in bold and explanatory comments in square brackets:

Cheshunt Lakeside will be developed as a new mixed use urban village, maximising the use of the site for residential and complementary employment and local centre uses. The development will accommodate:

[For the reasons explained above, the site must be optimised for residential-led development and ensure that employment and other uses are complementary to the residential use (i.e. that disruptive industries will not be appropriate to the allocation)]

C. 1000 c. 1,200 new homes, configured as an apartment village including a mixture of one, two and family sized dwellings (3 or more bedrooms) to reflect the site’s sustainable location and suitability for an increased proportion of smaller units;

[The enclosed masterplan strategy demonstrates how the site could accommodate up to 1,200 dwellings as part of an apartment village configuration to optimise the use of land for housing whilst maintaining an effective local centre and employment element. The policy should clarify that an exception is made to the requirements of draft policy H3 in that it is suitable for an increased proportion of smaller units given the ‘apartment village’ approach, ability to deliver increased

the site is now proposed for c. 1,750 new homes and the detail of the affordable housing provision now seeks more rented homes for local people. The additional wording proposed is considered to be superfluous.


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densities and its sustainable location in proximity to Cheshunt Station]

Subject to viability, the scheme will incorporate an appropriate level of affordable housing according to the following targets (given as a proportion of overall unit numbers):

a) 20% starter/shared ownership homes;

b) 20% affordable rented homes;

[The incorporation of a suitable amount of affordable homes, including starter homes, is supported in accordance with draft Policy H1, however the policy should clarify (as does H1) that the appropriate level of affordable housing must be determined giving regard to viability]

3. As appropriate, specialist and supported housing types (for example, elderly persons or similar accommodation);

[The inclusion and quantum of elderly and specialist housing types should be determined on a needs basis and the need to optimise the site for housing]

4. Businesses and business floorspace for new business start-ups appropriate to the new residential quarter;

[Again, the policy should clarify that only compatible uses will be sought, for the employment uses this


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will effectively be limited to B1 uses]

5. A local centre, situated along Windmill Lane, connecting Cheshunt Lakeside to Cheshunt Railway Station;

6. A two form of entry primary school;

7. Landscaped open space;

8. Relocation of Network Rail depot.

[Whilst we welcome this in principle, from our discussions with Network Rail and TfL we understand that this land is unlikely to be available due to railway operation needs]

Cheshunt Lakeside is to be developed in accordance with a comprehensive Master Plan Framework which will ensure that the site will be developed in a co-ordinated manner. The Masterplan Framework will set out how the objectives of this policy will be delivered and will detail the locations and quantum of development and its parameters along with the strategic infrastructure necessary for the development of the site.

The Council will use the Master Plan Framework as a material consideration in the context of the requirements of the Local Plan which forms the main policy basis for determining any subsequent planning application(s) for development on the site. The Council will not support proposals for development prior to the production of the Master


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Plan Framework and prior to its contents being agreed by the Council. Incremental development of the area and development which does not accord with the Master Plan Framework will be resisted.

The Master Plan Framework will include an agreed schedule of necessary strategic on and off-site infrastructure which will detail the phasing of the agreed measures. A section 106 agreement will accompany a future planning permission, reflecting the agreed infrastructure schedule and proportionate contributions to be allocated to priorities within the Infrastructure Delivery Plan. In the circumstances where two or more applications come forward for the development of the site, obligations will be secured through S106 which contain appropriate trigger and implementation requirements according to the agreed infrastructure schedule and phasing.

If necessary, compulsory purchase will be pursued by the Council.


PO2036 PO2037

(On behalf of largest owner/developer). Developer has commissioned specialist studies which show:

a) Flood risk: the site lies in Flood Zone 2 (medium risk) with a small portion in Flood Zone 3 (high risk) so a review of the modelled fluvial flood levels will be done to assist with the next stage of master planning. Detailed flood resilience measures will be advanced, using SuDs, attenuation and design mitigation measures as necessary.

b) An extended Phase 1 habitat survey has

Noted -


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confirmed that the land is of low ecological value. A Phase 2 bat survey on two buildings considered to have low potential for bat roosts found no bats emerging from the building or within site.

c) A noise and vibrations consultant has determined that a modest landscaped barrier will be needed along the eastern flank of the development as well as elevation treatments and positioning private amenity spaces to mitigate for railway noise.


PO1070 (On behalf of developer) 1000 homes is too low; more could be achieved, in particular if taller buildings with increased density are built on the eastern side of Delamare Rd

c. 1,750 homes is now proposed -


PO1072 PO2119

(On behalf of developer) Consider providing the elderly persons accommodation earmarked for this development by the local community centre close to the station, so the older people can benefit from transport links and community support. Herts County Council Public Health agree access to transport links important for older people.

That will be a matter for detailed master planning

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PO1075 (On behalf of developer) Understand the need for a primary school, but it should not be located in the development because Windmill Lane is a very busy road – it will be unsafe for the children, and will generate extra traffic in an already busy area.

The developer’s master plan incorporates the primary school within the development

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PO1889 TfL Support for Crossrail and the associated growth agenda in the Plan could be strengthened and clarified by making following alterations:

a) Where relevant link this development closely to 4-tracking and Crossrail 2 to help support the emerging proposals for

This development is not an enabling development for Crossrail 2 or vice versa. Specific provision for an alternative road crossing of the railway has been the subject of detailed consideration but is not being made within the Policy.

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Cheshunt Station, e.g. in paras. 7.2-7.5, make a stronger link to Crossrail 2 being an important enabler of development in this location. TfL’s Crossrail 2 development team will want to ensure full development capacity linked to future transport capacity and connectivity is realised on the site.

b) Mention that the current level crossing at Cheshunt station will need to be closed and alternative crossing facilities provided and this should be factored into any future master planning process.

c) The Network Rail depot, included in the boundaries of the development, will have to be retained to support 4-tracking/Crossrail 2, but further investigation will be done as part of the design work, to identify if it can be relocated.

The redevelopment of the Network Rail depot is key to the overall Cheshunt Lakeside development. Its relocation is being discussed with Network Rail.

7.30 CH1 PO1918 Thames Water Water network capacity unlikely to support the scale of demand expected from this development; the Council should require the developer to provide a detailed water supply strategy, and when planning permission is sought, Thames Water is likely to request appropriately worded planning condition to ensure this strategy is implemented before occupation of the development. Local network upgrades can take 18 months to 3 years to deliver. Wastewater infrastructure capability appears sufficient. There are sewers crossing this site which will need protection.

The developer is negotiating with Thames Water to provide for and protect the necessary infrastructure.

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PO1755 PO1756

Herts County Council Transport a) Do a pedestrian audit of the area to identify

works, e.g. dropped kerbs and tactile paving at junctions, required to improve pedestrian access to employment in this area and to reach the A1170 and Cheshunt town centre.

b) There are no bus services currently on Cadmore Lane, Delamare Rd or Windmill Lane, and it is not desirable to divert the nearest services from the High St. Instead, seek developer contributions for a bus service east-west across the Borough connecting Cheshunt station and the new development at Brookfield, with good quality bus infrastructure, e.g. bus shelters.

A planning application will be accompanied by a full Transport Assessment that will consider the needs of pedestrians. This bus service is proposed.

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PO1337 Herts County Council Schools The new primary school will require an s106 agreement. Agree with master planning for the development, essential to ensure the infrastructure, including the school, is provided at the right time.

Agreed. -


PO1830 PO1850

Herts County Council Minerals and waste There are superficial deposits of sand and gravel that could possibly be extracted for use during the development; no previous mineral/waste applications were made for this site.

This will be brought to the attention of the developer.

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PO1943 Environment Agency Development should include enhancements to the Windmill Lane Ditch and Small River Lee surrounding the site, to improve biodiversity.

Agreed. These improvements are proposed. -

Rosedale Park

7.35 Rosedale Park

PO342 PO343 PO349 PO351

(Agent on behalf of developer). Land at the northern end of Faints Close should be allocated for development because:

a) It provides a pedestrian connection between

The Green Belt boundary is proposed for relocation to Burton Lane/Rags Lane in order to accommodate the proposed Rosedale Park development. The site

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PO352 PO353 PO354 PO355

the Rosedale Park scheme and existing development on the Caldecot Estate.

b) Would provide a site for at least five dwellings

c) Is surrounded to south and east by housing on Caldecot Estate. The western edge is well defined with mature trees and the northern side adjoins land used as a temporary playing field by the Rosedale Sports Club.

d) Access to the site from Faints Close is already available and all utility services are in place; the dwellings could be delivered within 18 months of permission being granted.

e) The site is no longer a designated local wildlife site (please amend the Policies Map accordingly).

f) Developer could be willing to provide contributions to enhance recreation and sports facilities in the area.

See map of site at: \\Broxstore1\r_drive\Planning Policy\New Local Plan\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO342

referred to will therefore also be removed from the Green Belt and will become ‘white land’. It would be appropriate for a planning application for development on this site to be considered on its own merits. However, it is considered too small to allocate through the Local Plan. Should permission be granted it would be considered a windfall permission.

7.36 Rosedale Park CH2 Figure 7

PO878 PO883 PO884 PO886 PO881 PO882

(Developer) Burton Grange and the land to the west on the south side of Rags Lane should be allocated for development because:

a) Most of the site is brownfield land, and it contains a building that is suitable for conversion to residential use and new buildings in the wider site to replace outbuildings and external storage.

b) There is development under construction to

The Green Belt boundary is proposed for relocation to Burton Lane/Rags Lane in order to accommodate the proposed Rosedale Park development. The site referred to will therefore also be removed from the green Belt and will become ‘white land’. It would be appropriate for a planning application for development on this site to be considered on its own merits. However,

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the south and there is already residential development to the north of Rags Lane.

c) The site is available and can provide 15 dwellings in the next five years.

d) If the master plan for Rosedale Park does not specify development on some areas of land, it should not preclude development in those areas when they are suitable and available.

This area of land should be added to Figure 7 as a residential development site for about 15 dwellings, and to Chapter 3 – Housing in the Key Diagram at para. 3.12.

it is considered too small to allocate through the Local Plan. Should permission be granted it would be considered a windfall permission.

7.37 Rosedale Park CH2

PO926 PO923 PO924

(Agent for developer) The Tudor Nursery site has been allocated for development as part of a larger area of land that includes the Rags Valley, but it could have been assessed as a stand-alone development, as it is not similar to the rest of the land to the north, and it is suitable for development within the next 5 years. Policy CH2 should be made more flexible to permit development here.

a) Accept that the site could accommodate about 340 dwellings but the mix of housing and the retirement village may change during detailed planning of the site, so there must be a degree of flexibility in the number of dwellings.

b) There are various types of older people’s housing, which have different infrastructure requirements and density profiles. Policy and text should permit flexibility over the number of older people’s dwellings.

c) Suggest alternative wording about

The comprehensive approach set out is considered intrinsic to the principle of development of the two sites together, including a network of connections and shared facilities. The other points listed here are matters for discussion as part of the planning application process.

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affordable housing: The mix of affordable housing will be assessed at the time of an application for planning permission having regard to identified requirements, market conditions and viability.

d) Affordable housing. Add a reference in policy CH2 to the viability test in draft policy H1 (Any provision falling short of the 40% affordable housing threshold “shall only be acceptable where they are accompanied by a full economic appraisal of the development costs and anticipated values”)

e) The current draft masterplan prepared by the promoters indicates a lower density of development on the scrubland lying between the densely developed nursery buildings and the existing residential development to the east. The Plan is illustrative and shows only one possible form of development. Policy CH2 should not contain specific masterplan layout commentary such as this.

f) Apartments: the specific limit of 5% on this site is not justified by evidence and may inappropriately limit delivery, for example, the older people’s housing may include apartments, so the limit of 5% would be too restrictive within the 340 dwellings allocation. Instead, it would be better to rely on a housing mix policy illustrated by Policy H3.

g) Local shop. This is dependent on market interest and viability. Modify the policy to read, A local shop subject to market viability


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assessment. h) Infrastructure. The policy should require the

development to provide measures to deliver and maintain on-site infrastructure and to provide proportionate contributions to off-site priorities necessary for delivery of the Tudor Nurseries site.

i) Compulsory purchase powers. It is unclear what land needs to be compulsorily purchased to achieve the aim of the development, so there is no need for this part of the policy.

j) The draft masterplan provided at Fig 7 differs a little from the promoters’ more detailed masterplan attached; these differences should be reconciled. The version in the Draft Local Plan seems to show development extending beyond the Tudor Nursery northern boundary. The promoter feels this is unnecessary and would extend development beyond the clear boundary at the treeline. There also seems no need for a road to be opened at this point through the gap separating an already developed Tudor Nursery site from St James.

k) The master planning of the site shows it could deliver an improved junction onto Goff’s Lane, bypassing the existing restricted visibility junction of Burton Lane with Goff’s Lane.

l) The planned trajectory for housing at the site should be for guidance only and not be used rigidly to reject or phase development,


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as it may be sensible to bring forward delivery on certain sites. The Council should consider drafting a new policy to explain how any shortages identified in housing trajectory will be addressed, similar to the modification to the Maldon Local Plan, …that any shortfall will be met by a number of possible measures including intensifying development on existing housing sites (committed and/or allocated) which are sustainable and would not prejudice the long term delivery of the Plan as a whole.

Documents submitted: \\Broxstore1\r_drive\Planning Policy\New Local Plan\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO923


PO1291 PO1296 PO1298 PO1300 PO1307 PO2253

(Agent on behalf of developer) Land to the south of Andrews Lane has been allocated for development; the issues we raise are:

a) 5 dwellings are proposed for the land south of Andrews Lane. This is too low, far short of the area’s actual development capacity, and it also means that sale of this piece of land would not be commercially viable, thus threatening delivery of the master plan objectives for the area.

b) Inset Map 2 for the Goffs Oak area shows a new road linking Rosedale Park North and South, and this should be reflected in part 9 of policy CH2. Suitable vehicular and pedestrian links between the two sites are important, particularly for the route to and

Following exchange of various conceptual options for this site, the Council believes that there is a realistic prospect of incorporating this land into the comprehensive, masterplanned approach to Rosedale Park. The concept of the Green Link between Burton Lane and Andrews Lane is considered to be a sound one in order to provide a structure to the pattern of development in the area.

The strip of land adjoining St James’ has been incorporated into the development. 50 dwellings have been added to the housing trajectory, shared between land south of Andrews Lane (including Ballymour and the Langdons) and Lea Mount Meadow. The concept diagram has been updated to make clear the links between the various development parcels and direct vehicular access points off Burton Lane and Andrews Lane.


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from the new primary school. The links need to be delivered early in the build programme; both links run through the client’s land; happy to discuss delivery.

c) Policy CH2 states Council’s resistance to incremental development. While comprehensive master planning needs to take place it does not mean that all development needs to come forward together or in the same planning application, or be promoted by the same developers. Individual landowners should not be prevented from making their own applications if these are consistent with the master plan.

d) The Council’s proposals are shown graphically on the Policies Map and on Inset Map 2. These two maps show part of the client’s site south of Andrews Lane identified as a residential and mixed use allocation and the rest as local green space, where policy ORC3 applies. As a matter of principle, the whole of the client’s land should be include as part of the allocation if part of the land is identified for other, non-residential uses that nevertheless contribute to achieving the master plan and objectives set out in policy CH2.

e) St James is a small hamlet that does not need a green buffer to separate it from the rest of the Rosedale Park development. However, if it proceeds it could be a smaller buffer emphasised through layout, design and materials used, e.g. a green corridor


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through the client’s side incorporating a pedestrian and cycle link with landscaping either side. Introducing a small access road would also provide the place definition, with St James on one side and Rosedale Park on the other. See our proposal in attached document, figure 2. This would also enable 17 more dwellings to be built on the client’s land, providing natural surveillance over the green area and so preventing anti-social behaviour. If, even so, the green buffer is seen as essential to the development, it should be stated as a specific objective in policy CH2, along with any envisaged landscape and environmental enhancements.


PO875 (Developer) The land put forward for development for the SLAA, formed by The Langdons and Ballymour, two existing housing plots on Andrews Lane, is key to sustainable development of this area. Development should be permitted at the same time as the rest of Rosedale Park to ensure consistency between their development and the rest of the area.

Agreed that these two small plots should be incorporated as part of a comprehensive approach.

Incorporate Ballymour and the Langdons into the Rosedale Park allocation on the policies map and on the concept diagram.


PO1645 PO1651 PO2238 PO2239 PO2240 PO2241 PO2242

(Agent on behalf of developer) Objects to the following parts of the policy:

a) In para. 3.36 questions use of term ‘local strategic gap’ as this concept is not applied consistently to all allocations. Recommends alternative wording: A Green Infrastructure network will be created including informal and formal open spaces which will respect the character of Goffs Oak, St James and residential areas of west Cheshunt.

b) Affordable housing requirement: Too


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prescriptive, not providing flexibility required by the NPPF. Recommends alternative wording: The mix of affordable housing will be assessed at the time of an application for planning permission having regard to identified requirements, market conditions and viability.

c) 5% apartment requirement: Inappropriate, as there is a need to provide a mix of dwellings, including smaller units suitable for first time buyers and the elderly, and the 20% provision of starter homes included as part of the policy requirement cannot be achieved unless one and two bedroom apartments are included in the overall mix.

d) All-weather pitch at Rosedale Sports Club: Too prescriptive, now allowing flexibility to address the specific needs of the Club identified through a specialist needs assessment of suitability given the local context. Recommends revision to read: Enhanced facilities at Rosedale Sports Club including an all weather pitch or equivalent enhancement, and expanded sports area.

e) Two-form entry school: Unreasonable as 375 houses in Rosedale Park North will not generate the need for a 2-form school, according to Herts CC schools projection data. Revise this to require a readily expandable 1-form entry school for Rosedale Park North which can be expanded to a 2-form entry school on implementation of the 340 new homes at Rosedale Park South.


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f) Extensive tree planting throughout the development: Excessive, given the extensive trees and hedgerows across the site. Revise the policy to require retention of existing trees where possible, as well as providing appropriate enhanced green infrastructure throughout the development.

g) Compulsory purchase order provision: Unnecessary, and should be deleted.

7.41 Rosedale Park

PO826 PO838 PO150 PO514 PO827 PO839 PO1085 PO2170 PO2216 PO1417 PO1502 PO2055 PO2051

Developing Rosedale Park will cause coalescence between Goffs Oak/St James and Cheshunt, destroying the village nature of the settlements. The proposed green buffer will not keep the settlements distinct. (One person) This is at odds with not developing green belt in other areas such as between Cuffley and Goffs Oak, and down Newgatestreet Road.

Creation of a structured Green Infrastructure network will create a clearer identity to the area and create a permanent. The Green Belt between Goffs Oak and Cuffley is characterised by very clear and distinct edges to both settlements, with an open valley landscape in between. By contrast the edge of West Cheshunt is lacking in clear edges and sense of cohesion. Rosedale Park provides a way to address this.

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7.42 Rosedale Park

PO866 PO132 PO151 PO2216 PO2053 PO60

The facilities in the area, e.g. doctors, drains and sewers, cannot cope with extra residents.

There is no evidence to suggest that the facilities will not be able to cope. Further work will be undertaken through the Infrastructure Delivery Planning process, and contributions will be sought in relation to planning applications.

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PO2156 The trains are already very crowded from both Cheshunt and Cuffley. There will need to be more trains.

The Train Operating Company will take account of the potential for increased passenger numbers as part of its long-term investment plans.

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PO2154 PO2155

Facilities such as shops, restaurants, activities for children and young adults, and secondary schools

Agreed. Additional school capacity is set out in the Local Plan and Infrastructure Delivery

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are needed if the development goes ahead, and the developer should help pay for them.

Plan. This will be addressed as part of the Section 106 agreement.


PO72 Sport England Supporting text to CH2 should describe a) What is meant by extended sports pitches (see point 9 of the Rosedale Park South section of the policy) as the area shown for extended sports pitches on the proposals map is already a playing field and is used for sports pitches by users of the Rosedale Sports Club site. It is unclear what additionality would be provided if this proposal was implemented – enhanced security of tenure, better pitch quality? b) What is meant by expanded sports area at Rosedale Park (see point 5 of the Rags Brook Park section of the policy) – is this the same area described in the Rosedale Park South? If so, what is the additionality proposed? c) Intention to the development being designed to promote active lifestyles by encouraging physical activity and sport, and thereby contributing to the wider healthier communities objectives. In particular, supporting text should refer to Sport England’s and Public Health England’s Active Design guidance, which is Government-endorsed.

The proposed expansion of the Rosedale Sports Ground is to the south of the existing ground Reference to Sport England and Public Health England Active Design Guidance has been added to Chapter 3: Development Strategy. References to external guidance are not appropriate in the Local Plan because they will date over time. The Council will maintain a separate list of guidance which can be updated periodically for the benefit of service users.

New section on Health and Wellbeing in Chapter 3: Development Strategy


PO827 The Rosedale Sports Club should be able to continue using its facilities without any restrictions, e.g. noise restrictions, or reduced access, resulting from this new development.

The proposals for Rosedale Park will make the club more accessible to more local residents. Noise restrictions will be considered on a case-by-case basis.

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PO14 PO918

Object to development on Andrews Lane at end of Granby Park Road (Rags Brook), particularly on grounds of traffic/roads. Questions about vehicular access for proposed Rosedale Park North:

a) Will Andrews Lane be blocked off to through

Andrews Lane will be a local access route only, plus access for walking, cycling and potentially a new bus service. The Walking and Cycling Strategy identifies

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traffic, with the new road for through traffic following the bold dotted line on the map, with exit back on Andrews Lane eastbound, behind and to side of 69 Granby Park Rd?

b) Will the access route/pedestrian area be completely blocked at both ends or will two-wheeled traffic be able to get access to the pedestrian area and use it as a race track?

c) Will Granby Park Rd still be a cul de sac or will there be a new through route to the new development?

Andrews Lane as an important cycle route. It is proposed to tackle anti-social behaviour by adjustable barriers, filling in of the Andrews Lane subway, and use of the Council’s new powers through the Public Space Protection Order. Further information is set out in the Walking and Cycling Strategy. There are no proposals for a through-route utilising Granby Park Road.


PO125 PO1036

Accept that the northern boundary of the Tudor Nursery site on Burton Lane can be redeveloped as the glasshouses are derelict, but object to housing development on the rest of the holding. This is 16 acres of modern glasshouses and auxiliary buildings providing jobs. If any of these were replaced, the height, a maximum of 6m, would still be less intrusive than houses, which have a ridge height of 9m.

The Green Belt Topic Paper sets out exceptional circumstances to justify release of the site from the Green Belt.

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PO130 As there is access to the M25 and north London from Rosedale Park and Burton Lane via Lieutenant Ellis Way, thus avoiding the A10, there should be greater development density off Andrews Lane, to accommodate 200 – 300 more homes.

Not agreed. Higher density development would not be appropriate given the location and setting of the development as a parkland area.

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PO132 PO150 PO247 PO2228 PO489 PO551 PO1083 PO1248

This is an unnecessary loss of trees and green space, to the detriment of local wildlife and amenity for local residents, and the loss of land being farmed. Build on brownfield and derelict sites instead. Dangerous precedent in area creating impetus for more development later. Cannot see point of losing Green Belt at Great

The proposals will benefit local residents through the creation of a new public park in an area of hitherto inaccessible private land. Mature trees will be protected and there will be extensive tree planting throughout the development. A local green infrastructure network will include land adjacent to Great Groves.

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PO2216 PO2231 PO2047

Groves just to build 10 properties. Keep the fields by Andrews Lane as they are integral part of Green Belt life.


PO489 PO1083 PO2216 PO1502 PO145

Far too many houses in one area of the Borough.

Site selection has been based on careful consideration of a broad range of planning issues. The evidence behind the site selection process is set out in the sustainability appraisal and the development options reports on the Council’s website.

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PO2226 Reduce to 500 dwellings with improved access and parking.

The proposed amount of development has been derived through careful masterplanning and is considered appropriate. The transport assessment accompanying the planning application will address issues of access and parking.

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PO132 PO152 PO153 PO276 PO489 PO551 PO893 PO1086 PO1251 PO1252 PO1872 PO2245 PO2235 PO1523 PO1502 PO2052 PO2054 PO2048

Concerned about rural roads not coping with the extra traffic:

a) B156 already congested b) These are narrow country lanes with no

pavements; extra traffic will make it dangerous for children walking to school, and discourage walking and cycling, which the Council wants to promote

c) Will be to detriment of green belt – keep traffic on the main roads

d) People speed along these lanes; extra traffic from side roads will be dangerous, e.g. planned road from Tudor Nursery to Andrews Lane.

e) Junction at Rags Lane/Burton Lane, Andrews Lane/St. James is hazardous already as it is not possible to see past parked cars; there will be accidents if there is more traffic there

a) Transport modelling shows that the B156 should be able to cope with the levels of growth proposed;

b) Andrews Lane will be local access, walkers and cyclists – see also h);

c) Local access/feeder roads will be required but main spine road will link onto Rosedale Way, avoiding Burton Lane/Rags Lane and Andrews Lane;

d) The main access will be via the spine road onto Rosedale Way

e) Local access configuration will be addressed through planning; application/Transport Assessment

f) No reason to believe that air quality and noise pollution will be excessive or reason to prevent development

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PO2049 PO2050

f) Air and noise pollution g) Extra parking and congestion arising from

the primary school – particularly a 2-form entry school which will bring in pupils from a wider area

h) Andrews Lane and Rags Lane are so narrow, cars cannot pass; if there is to be extensive housing development here the road will need to be improved.

i) Goffs Lane is very busy; adding a road connecting with Rosedale Park near the top end of Burton Lane would be a very dangerous junction.

j) Danger of vehicle cut-throughs – consider making Burton lane and St James Road access only, or imposing a width restriction to prevent lorries using Burton Lane.

k) Expense of the new housing will require inhabitants to work in London, thus creating more commuting by car, particularly to Cuffley station, along the already very busy B156. It is not easy to cycle instead because Cuffley Hill is so steep.

g) The layout has been configured to encourage walking to school;

h) See b above; i) Traffic modelling shows that Goffs

Lane can cope. Local access issues are being addressed as part of the planning application;

j) See e above; k) The policy requires 40% affordable

housing. Local Cycling and Walking Infrastructure Plan proposes a cycle corridor along Andrews Lane – gradient will deter many but electric bikes may be an option for some residents.


PO891 PO1086 PO2231

Object as disruption (noise, water supplies cut off without warning, noisy trucks turning) caused during the development will badly affect residents, as known from other developments currently underway nearby. Residents should be compensated, e.g. council tax reduction.

Planning conditions will be applied to the grant of planning permission which will limit the disruption during construction.

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PO153 Proposed shops will not be viable since there is a Tesco in walking distance.

This will be tested when a proposal goes to the market. It is hoped that the scale of development, when combined with existing residential development in the area, is

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sufficient to support a local shop or shops.


PO224 PO225 PO683 PO744 PO751 PO752 PO1014 PO223

Invest s106 funds in community facilities, an expansion to the local doctor’s surgery or a new surgery, and improved sports facilities so more residents can participate in sport near their homes.

Co-location with the school and possible shared facilities are a good opportunity for developing sport.

Want more sports facilities and more sports-related land to be added to this development, e.g. south of Lea Mount.

Want Rosedale Club to benefit from an artificial playing surface, additional pitches, improved clubhouse facilities, and availability of more sports.

Make facilities at Rosedale Club available for community sport use.

The composition of the Section 106 agreement will be considered through the planning application process as part of the development management function.

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PO1516 LEP seeks extensive pedestrian connections to integrate the new homes to the surrounding communities.

Noted. This is provided for within policy CH2.

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7.58 7.6 Rosedale Park CH2

PO621 Historic England Para. 7.6 and policy CH2 should mention the nearby grade II listed Burton Lane Farm, 480 Goffs Lane, Colesgrove Farm and The Old Barn, and that any development will need to be of high quality design to protect and enhance the setting of these historic assets.

Agreed. Addition to policy CH2: (Rosedale park south) 11. Protection and enhancement of the setting of the listed buildings at Burton Lane Farm, 480 Goffs Lane, Colesgrove Farm and the Old Barn.


PO621 Historic England Consider relocating the public open space south of Lea Mount to the south east of the access road, near the existing built development, to help protect the setting of historic assets nearby.

The proposed area of open space is an extension to the proposed Rosedale Park and Rosedale Sports Ground and is not proposed to be relocated. It is considered that the detailed masterplanning of Rosedale Park is paying due cognisance to historic assets in the area.

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PO1944 Environment Agency Site is next to Rags Brook. Ensure a buffer strip of at least 8m alongside the river channel.

The masterplan includes a wide parkland setting, with development set back from the river channel.

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PO428 PO429 PO430 PO431 PO432 PO433 PO434

Kings Arms and Cheshunt Angling Society Concerns about water bodies and drainage on site: Rosedale Park South: To protect the lake in Claremont Open Space, for which we have fishing rights, from drying out there must be no diminution of the flow in the ditch downstream from the development. Due to an earlier development in the area diverting a water source from this lake, it is the sole water source for the lake apart from land drains. The Environment Agency recommended that if further development takes place, a weir and abstraction point would be needed to create a better water supply to the lake. Ideally the flow in the drains should be increased slightly to benefit the lake. The drainage systems should also be designed to prevent large volumes of deoxygenated water going into the drain as this is toxic to aquatic life. Also, the drain in Rosedale Park south is susceptible to flooding. Any development has to avoid adding to this flooding or the site of the former Everest sports club will often be flooded. Rosedale Park North: We have fishing rights for Cheshunt North Reservoir, for which Rags Brook is a water source. It is important to protect Rags Brook from contamination by chemicals or by large volumes of de-oxygenated water. There should be no increase in flood water volumes or frequency as this raises the water level in the reservoir which causes fishing platforms to be inundated and results

A drainage strategy will be prepared for the site as part of the planning application.

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in increased deposits of silt into the reservoir requiring an increased frequency of dredging to de-silt it. There should also be no decrease in flow along Rags Brook as this would harm the aquatic environment, e.g. more predation by birds. Rags Brook Park: Want to retain vehicular access to the adjoining lake on the eastern border of the Rosedale sports ground. Would also request an additional path on the western side of the lake abutting Rosedale sports ground funded by s106 monies. Placement of new trees should avoid creating a wind shadow on the lake as in the past this has caused fish kills due to low dissolved oxygen levels.


PO151 PO2047

Rainwater runoff from paving the land to build houses will cause flooding through the valley. Even though a new mains sewer was built when Foresters Close, the Laurels area and St James was built, there are still problems in this area. At the best of times and even in times of low rainfall, Rags Brook is prone to flood in this area, despite the holding tank/pond created by the Environment Agency at the junction of Crouch Lane and Argent Way. The developer must address this by investing in drains.

A planning application will be accompanied by a comprehensive sustainable drainage strategy.

No change proposed.


PO1931 PO1929 PO1927 PO1928 PO1930 PO1933

Thames Water Water supply: No concerns about supply capability for Rags Brook Valley south of Peakes Way or for Rags Brook Valley Rags Lane. However, there are concerns for Rags Brook Valley north of Lea Mount, Rags Brook Valley north of Andrews Way and east and west of school site, and Tudor Nurseries. Capacity is unlikely to support the

Details of the sewerage capacity form part of the ongoing discussions in relation to the planning application. A drainage strategy should be provided.

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scale of demand expected from development in these areas. For Rags Brook Valley north of Lea Mount, and north of Andrews Way and east and west of the school site, Thames Water will have to investigate the impact of the development. If an upgrade is required, up to 3 years lead time will be necessary, and the council will be asked to add this paragraph to the Plan: “Developers will be required to demonstrate that there is adequate water supply capacity both on and off the site to serve the development and that it would not lead to problems for existing or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing water infrastructures.” For the Tudor Nurseries site, the Council should require the developer to provide a detailed water supply strategy, and when planning permission is sought, Thames Water is likely to request appropriately worded planning condition to ensure this strategy is implemented before occupation of the development. Local network upgrades can take 18 months to 3 years to deliver. Waste water infrastructure: Do not expect concerns arising from proposed development on any part of Rosedale Park area except for Tudor Nurseries. At Tudor Nurseries, the wastewater network capacity is unlikely to be sufficient to support


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anticipated demand, and it is likely upgrades will be needed. The Council should require the developer to provide a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered. When planning permission is sought, Thames Water is likely to request appropriately worded planning condition to ensure this strategy is implemented before occupation of the development. Local network upgrades can take 18 months to 3 years to deliver. The point of connection should be discussed with Thames Water Developer Services as soon as possible. Sewers cross Rags Brook Valley north of Andrews Way and east of the school site, and will require protection.


PO1831 PO1835 PO1836 PO1837 PO1838 PO1842

Herts County Council Wastes and Minerals All areas of the site fall within the sand and gravel belt, and no mineral or waste applications have been previously received. The land off Peakes Way, Rags Brook north of Andrews Lane and west of the school site, and the land north of Andrews Lane: For these three areas of the site, sand and gravel are either not potentially workable or are absent. Lea Mount: partly within an area of exposed mineral – assessed. It appears there are superficial deposits of sand and gravel that could possibly be extracted for use during development of the site. Rags Brook Valley – north of Andrews Lane and east

Noted. The Minerals Local Plan forms part of the Develoment Plan for the area and the requirement not to sterilise mineral resources in compliance with the Plan forms part of the requirement on the applicants.

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of the school site: superficial deposits of sand and gravel in the north eastern part of the area that could possibly be extracted for use during development of the site. Tudor Nurseries: The area is predominantly within the categories of deposits of continuous or almost continuous spreads of minerals beneath overburden and also partly in an area of exposed mineral, assessed. There are superficial deposits of sand and gravel that could possibly be extracted for use during development of the site.


PO1757 PO1758 PO1783 PO2207

Herts County Council Spatial Planning a) The development will require significant

investment in sustainable travel opportunities and upgrading the highway network, much of which is narrow lanes. Particular concern about impact of more housing on the already congested B156; there are limited gaps in traffic throughout the day, and particularly at peak times. Will need also to consider impact of the development on the A10 and key approach roads to it.

b) Buses currently run along Goffs Lane and Rosedale Way next to the site, and there is a frequent site along Hammondstreet Road north of Rags Brook. Greater frequency of the Metroline 242 route along Goffs Lane and Rosedale Way could be suitable to serve the new dwellings. Early discussion with Metroline has shown support for greater frequency, with some journeys directed along Andrews Lane and Burton Lane or St

The Broxbourne Transport Strategy provides a framework transport strategy and includes diversion of some of the 242 service buses from Rosedale Way into the development.

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James Road. Peak services could connect with Cuffley railway station and Waltham Cross bus station, and off-peak services with Brookfield. However, Andrews Lane, Burton Lane and St James Road would all need to be improved as per Passenger Transport in New Developments guidance if they are to accommodate bus traffic.

c) There are no indications what the net gains in biodiversity in Rags Brook Park will be

d) The extended sports pitches at Rosedale Park South, which is a Wildlife Site, should be subject to an ecological survey and any remaining interest compensated for through biodiversity offsetting.


PO2249 Develop an Area Action Plan to provide a comprehensive approach for the long term future of the area.

An Area Action Plan is only necessary where there are particularly complex issues of land assembly and co-ordination. In this case it is considered that development can be managed through the planning application process.

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PO2235 Change the name from Rosedale Park – it gives the impression it is an extension of the Rosedale estate, and hence a single, large settlement bigger than Goffs Oak.

The name is considered appropriate given its location in the Rosedale area.

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PO2235 Insufficient consultation with local residents;

The development of a masterplan suggests this development is a done deal;

Many residents don’t know about the proposals.

The meeting in Goffs Oak was only one week before the deadline for submissions

On the website this development is mentioned under Cheshunt and not under Goffs Oak.

The Council exceeded the minimum statutory requirements for consultation. The details were set out in a Consultation Action Plan agreed by Cabinet, which included publicity through a wide range of channels.

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7.69 Rosedale PO2214 Herts County Council Public Health The proposed mix of uses may help to -


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Park CH2 For the older people’s accommodation, ensure there is access to sustainable transport, and consider how the development can avoid social isolation. Cross-refer to Policies TM1 and INF6.

reduce social isolation. The proposed elderly person’s accommodation is located next to the bus stop and local centre.


PO1339 Herts County Council Schools An s106 agreement will be required to provide the infrastructure requirements of the development, including the school. Master planning is essential to ensure the infrastructure is delivered.

Agreed. -


PO1522 Set the Tudor Nursery development back from Burton Lane with an open area with trees and seating in front to reduce the impact on existing residents.

It is anticipated that there will be a landscaped frontage to Burton Lane. The details of that relationship would be included in a planning application.

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PO1509 Council needs to make it clear that further incremental developments will not be allowed.

The retention of the majority of Green Belt will enable this objective.

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PO1509 To reduce the negative impact of the proposed development on the area:

Retain a gap between the Rags Brook and Tudor Nursery developments.

Do not build any of the planned 95 dwellings near Lea Mount

Focus on 2-3 bed houses affordable for younger people, which will also have a smaller footprint than luxury housing.

Masterplanning has established linkages between the north and south development areas in order to create a coherent development area and allow walking routes to the school and sports centre. An appropriate mix of housing is sought as set out in the affordable housing policy.

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PO2055 PO2048

Instead of this development work with other Boroughs to create a new settlement elsewhere, or else spread development more evenly in areas that are close to transport and amenities.

Proposed sites in Broxbourne have been selected in part with reference to their proximity to transport links, services and facilities.

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7.75 Fig 7 PO356 (Agent on behalf of developer owning Faints Close land)

Figure 7 does not show all the pedestrian routes proposed as part of this development. These include a route running

It should be noted that the concept diagrams in the Local Plan are indicative. The appropriate use of this area of land will be resolved through masterplanning.

Appropriate amendments will be made to the concept diagram to show the paths and the local centre.


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along the southern side of the “Sports pitches extended” area.

The access into Faints Close is wrongly positioned and should be shown running in a north-south direction along the eastern side of this site, connecting to the east-west path mentioned above.

The area of green space on Rosedale Park South should also be used for sports pitches.

The local centre next to the proposed primary school should also be shown.

7.76 Fig 7 PO1652 (Agent on behalf of developer) Amend Fig 7 to: a) Take account of the latest masterplans

prepared by developers, particularly in terms of the extent of new public open space and proposed, vehicular, cycle and pedestrian links.

b) The north west corner of the Tudor Nursery site should be shown as sport pitches.

c) Add a key with the proposed vehicular, cycle and pedestrian routes shown as indicative

d) The figure shows a vehicular route between Rosedale park south and Rosedale Park north. This is considered unnecessary because of the existing road network and proposed pedestrian and cycle connections.

a) Agreed b) This is not proposed c) All the concept diagrams are

indicative. d) Agreed

Delete road link between Rosedale Park North and South on the concept diagram.

Cheshunt Old Pond

7.77 Cheshunt Old Pond CH3

PO2257 PO904 PO1727

More variety in shops, and fewer eateries, banks, estate agents, charity shops and pharmacies, is required.

The Council is preparing a strategy for the Old Pond which will seek to enhance the attractiveness of the centre and the vitality of the area. The Council cannot prescribe exactly what type of shops will occupy the premises.

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7.78 Cheshunt PO304 Take steps to protect local shopping facilities from The aim of the proposed Old Pond Strategy -


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Old Pond CH3

PO502 the impact of the Brookfield development, particularly:

a) Seek to keep Tesco for at least 20 more years, as it is accessible for older and less mobile people.

b) Make parking free

is to improve the long-term viability and vitality of the Old Pond shops and facilities. The Council is also preparing a Car Parking strategy which will look at the options.


PO311 PO315 PO366 PO367 PO907 PO955 PO1598

Retain Wolsey Hall. a) A community hall is needed in Cheshunt Old

Pond, particularly with the anticipated increase in residents aged over 70 and under 19, and the hall, unlike LTLC, is accessible by bus. The Spotlight is not suitable – it takes two buses to get there.

b) The hall will provide leisure activities, such as low impact sports, that are attractive to older people, who do not consider shopping a leisure activity.

c) Building flats on this site will make Cheshunt lose open aspect.

d) 16-25 flats will make little difference to the overall housing requirement.

e) (One comment) Refurbish the hall and incorporate it into a new development on the existing site or at Brookfield Riverside that is a more energetic and refreshing space.

Consider renaming it Laura Trott Hall.

Any planning application submitted prior to the adoption of the Local Plan will require assessment against Policy CLT1 of the adopted Local Plan. Policy ORC2 of the emerging Local Plan also addresses loss of leisure facilities. This will also be a material factor in consideration of any planning application.

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PO622 Historic England Modify supporting text and policy CH3 to note that any proposals for development will need to take account of the grade II listed buildings at 38, 40, 45 and 47 College Rd.

This will be addressed as part of the detail of the Cheshunt Old Pond Strategy.

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7.81 Cheshunt PO547 Waltham Cross and Cheshunt Chamber of The Council is seeking to do this as soon as -


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Old Pond CH3

Commerce Produce the Cheshunt Old Pond Strategy as soon as possible and definitely to be delivered before any retail enhancement at Brookfield.

possible, consistent with achieving a solution that works for all modes of transport and consistent with suitable public consultation.


PO1764 Herts County Council Spatial Planning Any street scene and pedestrian enhancements planned at the Old Pond should not be at the expense of local bus services.

The Council is addressing this through the Broxbourne transport strategy. The strategy for this corridor will inform the Old Pond strategy.

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PO1945 Environment Agency Any options to deculvert the College Brook river channel should be explored.

This will be investigated as part of Old Pond strategy. However, the competing demands for movement and public realm as well as access to businesses will need to be considered.

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PO1727

Inadequate traffic control at the Old Pond roundabout causes congestion. The Plan should show how this can be improved.

This is being addressed as part of ongoing work on the Old Pond and the transport strategy, and by the transport consultants for Inland Homes

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7.85 Cheshunt Old Pond CH3 and CH4 Old Cambridge Rd corridor

PO1517 LEP Improvements are needed to shift the balance from car to pedestrian movement. In particular, the junction at Old Pond needs radical examination to make it the heart of Cheshunt whilst improving the connection to the station via Windmill Rd.

Agreed. This is a major focus of the Old Pond Strategy. However, the context is providing by a multi-modal strategy as part of a strategy for the corridor.

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7.86 CH4 Old Cambridge Rd corridor

PO623 Historic England Any strategy will need to take account of the various historic assets along the A1170 corridor from Turners Hill to Waltham Cross and seek to protect and enhance both the assets and their settings.

These assets are beyond the Old Pond study area and are protected by the Historic Assets policies.

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Old Cambridge Road Corridor, Cheshunt Park, Cedars Park

7.87 CH4 Old Cambridge Rd corridor

PO1340 Herts County Council Property If any housing is proposed as part of the improvement plan for this area it may have implications on school place planning.

Noted. The Council has been working closely with the County Council to take account of the implications for school place planning.

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7.88 7.12 PO345 Keep Cheshunt Park as it is, to prevent negative An appropriate balance should be struck New policy on Cheshunt Park


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impact on fishing between the needs of different park users.

7.89 7.12 PO1017 Develop better jogging routes and provide outdoor fitness equipment in the Park, to help prevent obesity.

This is a detailed point beyond the scope of the Local Plan.

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Cheshunt Football Club/Albury Farm

7.90 Cheshunt FC CH5

PO305 Maintain the current footpath from Albury Ride providing direct pedestrian access to Cedars Park, both during and after completion of the development.

Construction should not impinge upon access to this path. Should temporary disruption be unavoidable, this would be controlled by means of a planning condition.

No change proposed


PO867 Will a new access road be built from the development onto the A10? Otherwise, cars will have to use the narrow Theobalds Lane which is used by children going to and from St Mary’s School.

No new road connection with the A10 is proposed. It is anticipated that Theobalds Lane will need to be upgraded.

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PO625 Historic England We are concerned about impact of development in this area on the setting of the Theobalds Palace scheduled monument and listed buildings and structures, all Grade II to the south. There is also the Grade II listed part of the Theobalds Palace Deer Park wall to the north at Albury Farm. This implies that the whole of this proposed development area was formerly deer park associated with Theobalds Palace, so there is potential archaeology in this area. Policy CH5 and supporting text should refer to the listed buildings/structures and scheduled monument and the importance of preserving and enhancing their settings, should also highlight the potential for archaeology in this area. It is also important that the proposed primary school does not encroach upon the listed wall to the north of Albury Farm.

The area referred to above is proposed for designation as a Landscape Protection Zone (Policy CH6), which will preserve the setting of the wall on the northern side of the farm buildings. This area is contiguous with the designated Area of Archaeological Interest. The proposed development area falls outside the AAI.

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PO1917 Thames Water Water supply capacity is unlikely to support the scale of demand expected from the development. Thames Water will have to investigate the impact of the development. If an upgrade is required, up to 3 years lead time will be necessary, and the council will be asked to add this paragraph to the Plan: “Developers will be required to demonstrate that there is adequate water supply capacity both on and off the site to serve the development and that it would not lead to problems for existing or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing water infrastructures.” Wastewater network capacity is unlikely to be sufficient to support anticipated demand, and it is likely upgrades will be needed. The Council should require the developer to provide a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered. When planning permission is sought, Thames Water is likely to request appropriately worded planning condition to ensure this strategy is implemented before occupation of the development. Local network upgrades can take 18 months to 3 years to deliver.

It is noted that this is Thames Water’s standard response to most development sites. The points are fair but not appropriate text for the Local Plan. A drainage strategy will be required as part of the planning application.

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PO1759 Herts County Council Spatial Planning a) Concerned about already heavily loaded

road network, particularly constraints on Theobalds Lane

b) Opportunity to improve accessibility to sustainable transport through an s106

These matters will be addressed through the planning application.

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obligation, e.g. further kerbing enhancement and shelter for the southbound bus stop (£16k), or ‘real time’ info’ displays on bus arrivals (2 screens for £40k).


PO2131 Herts County Council Public Health Consider the impact of the adjacent A10 on air quality for the residents of the new development, and contribution to worsening air quality that would be made by traffic to and from the development. The design of the development should incorporate mitigation measures from the outset.

Noted. The Local Plan provides a Landscape Protection Zone which means that development will be set back from the A10. A land swap with the Cheshunt Club offers the opportunity to set the school site further away from the A10.

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PO1410 PO1411

Herts County Council Property As freehold landowner of this site, the County Council does not object to removal of this site from Green Belt or allocation of land for 120 homes. However, it does object to the wording of Policy CH5. The policy is promoting enabling development to allow a private football club to improve its facilities on publicly owned land, and via a policy restriction to enabling development, effectively to require public subsidy from publicly owned land to the stadium development. A policy for enabling development is not required, nor is it appropriate. No info’ has been provided to HCC to demonstrate that the Football Club has sought alternative funding, even though there are many other potential sources. The club has a long lease till 2040 through which it might seek, through negotiations with the head-leasee (Broxbourne BC) and the freeholder (HCC) to obtain a premium for surrender and re-grant of a lease to enable a re-development scheme and part of the capital funding

A key principle of this development proposal is to enable the Cheshunt FC stadium redevelopment. Through the processing of the planning application the Council will seek to ensure that any betterment to the football club is to the benefit of the community.

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required. Including a policy that requires enabling development could have the effect of precluding successful capital funding bidding to other sources owing to the mere presence of the policy, and it could also delay development during the life of the Plan because of the lack of benefit to the freeholder, the County Council. It is not appropriate that two public authority landowners should have their commercial position constrained in favour of the privately owned sub-lease interest by an enabling development policy. The effect of the policy is to achieve a new stadium that would be controlled by a private club, may provide some contribution to the Borough Council’s leisure services responsibility, but limited or no contribution to the services for which HCC is responsible. Recommends: replace the words ‘to enable’ with ‘and’ in policy CH5, so that it reads: A development of c.120 new homes, community and commercial floorspace is proposed at Cheshunt FC and the development of the Cheshunt FC Stadium.”


PO1843 Herts County Council Minerals and Waste Site is in the sand and gravel belt; there are superficial deposits of sand and gravel and it may be possible to extract resources for use on site during development. No mineral and waste applications have been registered for this site.

Noted. -


PO1947 Environment Agency Ensure an 8m buffer strip and habitat enhancements. There should be no disturbance/impact to the

Cheshunt Football Club is not near the Rye Meads SSSI and there are no significant watercourses through the site.

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adjacent Rye Meads SSSI as a result of development.

7.99 CH6 Albury Farm

PO373 (Agents for owners of Albury Farm). The policy wording should make clear reference to this land being removed from the Green Belt. It would not fulfil any of the purposes of the Green Belt if it is surrounded by proposed development on all sides.

This is clear from the Policies Map. -

7.100 Cheshunt FC CH5 And CH6: Albury Farm Figure 8

PO1341 Herts County Council Property There is no mention in either policy of the proposed primary school site at Albury Farm required to serve proposed developments in the locality. The site area shown for the new school needs to be revised following recent information about land ownership. A revised site plan will be provided by the County Council.

The proposed primary school is included in policy INF10: New and Expanded Primary Schools. It is also mentioned in paragraph 6.25 within the Cheshunt section of the draft Local Plan.

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7.101 Figure 8 PO1006 It is unwise to site the new primary school next to the A10, due to air pollution and noise.

Agreed. Policies map amended to show the school site further back from the A10, closer to Albury Ride.

7.102 Figure 8 PO797 The Cheshunt Sports Ground Co Ltd owns the freehold of the Cheshunt Club and thinks that this would make a better site for a primary school, next to residents, while the field owned by the County Council next to the A10 would be better suited to a sporting complex. A land swap is proposed.

Noted. The policies map and concept diagrams have been amended to show this. It is understood that the Cheshunt Club are working together on a masterplan.

Amendments to policies map and concept diagram.

Bury Green and Churchgate

7.103 7.18 PO436 Kings Arms and Cheshunt Angling Society: As the Society leases fishing rights for the moat, it wants the developer to provide:

a) Precautions in place to ensure no impact to quality or quantity of water going into groundwater or draining into the moat

b) Vehicular access to double-gates in side of fence facing Dark Lane.

c) A small car parking area next to it so that

A development brief is proposed for the site, as set out in the policy. This will consider these representations. If a planning application is received in advance of the brief having been prepared, the representations will be similarly considered.

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they can perform maintenance work with heavy tools, and to enable less able members to access the fishery more easily

d) Any plans should have the moat with open aspects, to provide natural aeration of the moat so there is less need for the Society to do this artificially, except in emergencies, as it is noisy.

7.104 7.18 CH7 Bury Green and Churchgate

PO628 Historic England Para. 7.18 should mention the need to protect and enhance the setting of the scheduled monument. Recommend that the northern part of the allocation should be left open as public open space in order to protect and enhance the setting of the scheduled monument. These requirements and the need for high quality design of any development should be included in policy CH7b

Policy HA1 states that “development proposals that harm the significance of a heritage asset will not generally be permitted.” Policy HA10: states that proposals which would adversely affect the site or setting of nationally important archaeological remains will not be permitted.” A development brief is proposed for the site, as set out in the policy. This will consider these representations. If a planning application is received in advance of the brief having been prepared, the representations will be similarly considered. These representations have been sent to Hertfordshire County Council as landowner to inform any future planning application.

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7.105 Figure 10 PO627 PO437

Historic England and one other Part of the scheduled monument site, Half Moat Manor House, appears to lie within the land allocated for residential development, and there is

A development brief is proposed for the site, as set out in the policy. This will consider these representations.

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concern about the impact of the proposed development upon the scheduled monument and its setting.

If a planning application is received in advance of the brief having been prepared, the representations will be similarly considered. These representations have been sent to Hertfordshire County Council as landowner to inform any future planning application.

7.106 CH7 Bury Green and Churchgate 7.19

PO921 PO910

(Agent on behalf of landowner) The policy proposes to remove the client’s land to the east of the B198 from the Green Belt, and it is proposed for residential development and retention of sports club/pitches in the Proposals Map. This allocation would include adjoining land which is the V&E Sports Club. Development would entail joint working between the three landowners. The client is willing to discuss this and does not object, but there are constraints to the site which would need to be addressed prior to its development for a residential-led scheme, including land ownership, access, and the mix of dwellings and sports pitches, and there may be viability constraints too. These constraints may not be resolved during the life of the plan. \\Broxstore1\r_drive\Planning Policy\New Local Plan\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO921 and PO910.

Noted. A development brief is proposed for this allocation, which will address the matters raised in these representations.

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7.107 7.19 PO1343 Herts County Council Property It would be helpful to know the proposed number of dwellings to plan for school places.

The SLAA indicates that the total area could accommodate c. 45 dwellings.

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7.108 7.20 PO1346 Herts County Council Property St Mary’s school has confirmed that it has -


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The County Council would want to ensure any provision of a primary school by St Mary’s Academy would meet an identified local need and served the local community through admission arrangements which prioritised them. HCC has sought a new 2FE primary school site in the Rosedale park development, and this could meet the additional demand for primary school places arising from the Bury Green and Churchgate developments. Para. 7.20 should be amended to refer to policy INF10.

an aspiration to develop a primary school. This will need to be factored into future demand forecasts.

7.109 CH7 Bury Green and Churchgate

PO232 This will stretch existing roads and NHS services. Transport modelling demonstrate that with the measures proposed in the Broxbourne transport strategy, the roads in the area should be able to cope.

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PO232 Local developers should make s.106 payments to local sports clubs for long term improvements to meet the needs of families moving to the area.

Reasonable S106 payments will be negotiated in order to mitigate the impacts of development on local services and facilities.

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PO629 Historic England Dark Lane lies on the route of the Roman road, Ermine Street, so there is likely to be archaeology in the area, and the policy and supporting text should highlight the need for archaeological evaluation before any development in the area.

Noted. These comments have been passed on to the landowner, Hertfordshire County Council. It is considered that the Historic Environment Policies provide suitable protection.

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PO438 Kings Arms &Cheshunt Angling Society expects to be involved at an early stage with this development brief because of possible impact on their adjoining fishery, and may take legal action if this is not done.

Noted. The Kings Arms & Cheshunt Angling Society will be consulted on a draft development brief, provided that this occurs in advance of a planning application. If a planning application is received in advance of the brief having been prepared, the representations will be similarly considered.

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These representations have been sent to Hertfordshire County Council as landowner to inform any future planning application.


PO1919 PO1934

Thames Water No identified concerns about water supply capability or wastewater infrastructure capability have been identified in the area east of Dark Lane in Bury Green. However, for Theobalds Brook Field, Bury Green, water supply capacity is unlikely to support the scale of demand expected from the development. Thames Water will have to investigate the impact of the development. If an upgrade is required, up to 3 years lead time will be necessary, and the council will be asked to add this paragraph to the Plan: “Developers will be required to demonstrate that there is adequate water supply capacity both on and off the site to serve the development and that it would not lead to problems for existing or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing water infrastructures.” Wastewater network capacity is unlikely to be sufficient to support anticipated demand, and it is likely upgrades will be needed. The Council should require the developer to provide a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered. When planning permission is sought, Thames Water is likely to request appropriately worded planning

Noted. A drainage strategy will be required. -


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condition to ensure this strategy is implemented before occupation of the development. Local network upgrades can take 18 months to 3 years to deliver. There are also concerns about the sewer network’s ability to handle the proposed pumped flow. A developer-funded impact study may be required.


PO1824 PO1839 PO1840

Herts County Council Minerals and Waste

a) Land east of Dark Lane: Greenfield site within the sand and gravel belt but BGS data sheets show it as ‘urban area or area already worked’. Superficial deposits of sand and gravel that it may be possible to extract for use on site during development.

b) Land on eastern side of Lieutenant Ellis Way: Apart from the club house is greenfield land. Sand and gravel either not potentially workable or absent. No previous mineral or waste applications registered for this area.

c) Theobalds Brook Field: Greenfield site; continuous or almost continuous spreads of mineral beneath overburden; superficial deposits of sand and gravel that it may be possible to extract for use on site during development. No previous mineral or waste applications registered for this area.

Noted. These designations will be shown on the accompanying maps.

Show the minerals consultation areas on the Local Plan interactive map.


PO1763 Herts County Council Spatial Planning Bus services to these sites are limited. Opportunities to increase frequency of services through Dark Lane by developer contribution should be explored. It is difficult to enhance access to Theobalds Brook Field, but pedestrian links to the

The Broxbourne Transport Strategy 2017 proposes the upgrading of the bus stops and provision of additional services along Goffs Lane.

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Bury Green Road stops should be maximised, also pedestrian links across the B156/B198 roundabout to ensure access to bus stops on Goffs Lane. The closest stops to each site should be upgraded.


PO1784 Herts County Council Spatial Planning Goffs Lane, Bury Green is next to Bonny Grove Wood Wildlife Site. It is important that this woodland does not become isolated from surrounding open ecological corridors.

Bonney Grove Wood is already isolated since the construction of previous development in Bury Green and the construction of Lieutenant Ellis Way.

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PO1569 There is an abundance of wildlife on the former Bury Green Farm site, including sparrow-hawks, barn owls, bats and stag beetles, which are protected by the 1981 Countryside Act, also many types of butterflies, wildflowers and birds. Destroying their habitat will add to the decline of these species.

None of the proposed development areas in Bury Green are designated Wildlife Sites. Use of the Biodiversity Impact Calculator (Policy ) will ensure that compensatory habitat will provide a net improvement.

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PO1559 Using the last part of Bury Green Farm for housing will preclude further extension of Bury Green Cemetery, causing a shortage of burial spaces in the future.

The cemetery has recently been significantly expanded and the Local Plan provides for further expansion in future.

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PO1559 When St Mary’s High School was built at Bury Green Farm the Council promised residents this would not lead to further developments on the site.

The Council is unaware of any such promises and has no record of such.

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7.119b Policies Map PO1414 The Proposals Map includes the site of the Former East Playing Fields of St Mary's High School, South of Goffs Lane in Cheshunt for open space, leisure, sport and recreation. The site has an area of 2.0 hectares. This site is in the ownership of the County Council and is no longer required for service needs. The former school playing fields were replaced and enlarged at the new site of St Mary's HIgh School at Bury Green Road, Cheshunt. The former playing fields were taken out of use in April 2009 when the school relocated and they have been unused since that date. Consent to the disposal of these former

Agreed. Allocate site for 75-bed residential care home and a new community hall.


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playing fields has been granted under the provisions of S77 of the School Standards and Framework Act 1998. The County Council therefore objects to the inclusion of this site under Policy ORC2 and seeks to promote the site for residential development. A plan of the site is contained in Appendix A.

Maxwells Farm West and Rush Meadow

7.120 7.22 PO1911 Thames Water This field (Maxwells Farm) is next to the New River, which is on a slight embankment. The bank here is wharfed with wood, but development of the site would require something more substantial such as trench sheets or concrete.

Noted. Construction details should be considered as part of more detailed work on development in this area, perhaps as part of further work on the proposed New River Cycle path.

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7.121 CH8 Maxwells Farm West and Rush Meadow

PO374 (Agent for owner of Maxwells Farm West land) This land should be released now from the Green Belt and safeguarded for development, either housing or employment, because:

a) For Park Plaza to have regional status it needs critical mass, which could be provided by this site.

b) The Planning Inspector for the previous Local Plan said (para. 14) that in the absence of any other comparable sites the strategy clearly indicates that releases of Green Belt are needed to widen the Borough’s employment base, and in para. 36-37 the inspector confirms there are exceptional circumstances for its release to create a critical mass with Park Plaza North and West. Had the Council accepted the inspector’s recommendations and moved forward with the Plan, Maxwells Farm would

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now be excluded from the Green Belt and available for development.

c) This land could help meet unmet development needs arising during the plan period, e.g. proposed allocated sites not being deliverable for some reason

Suggested re-wording for Policy CH8: Maxwells Farm West and Rush Meadows will be removed from the Green Belt and safeguarded for development to meet an established and identified development need which cannot be delivered on the allocated sites in the Local Plan.

7.122 CH8 Maxwells Farm West and Rush Meadow 7.22

PO631 Historic England Cedars Park and Theobalds Palace (a scheduled monument) are located to the east of the site, so there are concerns about the impact of any development in Rush Meadow on the setting of the scheduled monument and listed buildings/structure and Cedars Park. Suggest Rush Meadow is left open to protect and enhance the settings of these heritage assets. The importance of protecting and enhancing the settings of the nearby listed buildings and scheduled monument, and the requirement to leave Rush Meadow open and undeveloped should be mentioned in para. 7.22 and Policy CH8.

The impact upon Cedars Park will be considered as part of the planning application. The importance of the setting of the historic assets is acknowledged.

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PO2217 Herts County Council Public Health Design of any development on Maxwells Farm should from the outset consider measures to mitigate the impact of the adjacent A10 on air quality for future residents, and the impact of the development in creating more air pollution due to increase in traffic movements.

A new hamburger junction at Park Plaza combined with additional junction capacity at College Road will reduce pollution from idling traffic. A set-back from the A10 will mitigate the impact on any future residents.

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7.124 CH8 Maxwells

PO1543 (Agent on behalf of land owner) Request that Rush Meadow be taken out of the Green Belt and zoned

Rush Meadow should only be developed as part of a comprehensive approach to

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Farm West and Rush Meadow

for development. Rush Meadow can be a standalone site with access from Lieutenant Ellis Way, and when Maxwells Farm West is developed, the access to Rush Meadow can then be adjusted to connect up with the intended access to Maxwells shown.

Maxwells Farm West.


PO1350 Herts County Council Property It would be useful to have an indication of the scale of housing proposed after 2031 to be able to assess the impact on HCC services, particularly school places.

At this stage the amount and type of development is highly speculative and so it is not considered appropriate to include a figure within the plan itself.

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Hammondstreet

7.126 7.23 PO277 Suggest closing Crouch Lane as it is very narrow and dangerous for cars.

Crouch Lane provides a local access road to a number of properties. It is not considered that the proposed development will lead to a significant increase in traffic on Crouch Lane since it forms no part of a desire line from the new developments.

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7.127 7.23 CH9: South of Hamm-ondstreet Rd

PO632

Historic England There is a Grade II listed building, the Woodman Stores to the north west of the site. The text and policy should highlight the need to consider the impact of any development on the setting of this listed building.

Friern Close lies between the proposed site and the Woodman Stores, which is already surrounded by twentieth century development. Development of the site is therefore not considered to have any material impact on the setting of the stores.

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7.128 CH9: South of Hamm-ondstreet Rd

PO957 The proposal to build on the strip of land next to Tesco Hammond St Express must incorporate the green space effectively into the area. It would be unsustainable to destroy the biodiversity of this strip of land. Consider laying paving and allowing residents to use it to improve connectivity with in the Rags Brook estate from Little Grove Ave to Higgins Close/Argent Way and offshoots up to Hammond Street, and provide information on signs

The policy includes ‘amenity open space’. This space could incorporate provision for a nature garden, pond or other small-scale wildlife habitat. The details should properly be addressed through a planning application.

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about the nature of the flora and fauna.


PO1922 Thames Water There are no infrastructure concerns about water supply or wastewater infrastructure capacity in relation to this site envisaged. There are sewers crossing the site which will need protection.

Noted -


PO1825 Herts County Council Minerals and Waste Sand and gravel are either not potentially workable or absent, and no minerals are recoded on site.

Noted -


PO1767 Herts County Council Spatial Planning All areas of the site are within walking distance of bus services on Hammond Street Rd. The bus stops near and opposite Oaklands Rd should be upgraded.

Noted -


PO1785 Herts County Council Spatial Planning There will be an impact on remnant fields resulting in a local loss of ecological resource and potentially protected species, so the site should be subject to appropriate mitigation and biodiversity offsetting to compensate for this.

Noted -


PO2232 Object, as this development is on Green Belt land that is currently farmed.

The proposed site allocation at Hammondstreet is not designated as Green Belt.

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PO2232 Local residents are already suffering at least six major developments that are suffocating the communities and infrastructure. This development is too much.

The Council considers that the proposed sites are the most sustainable options. The evidence of transport modelling and infrastructure planning suggests that the developments can be accommodated without a severe adverse impact on the existing community.

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7.135 7.24 PO868 PO1351

It is contradictory to say no secondary schools are planned during the Plan period and schools still have

This matter relates to whether the proposed Church Lane school site is

Paragraph 7.24


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capacity, yet later on in the text to state that children from northern Cheshunt may attend the proposed new school at Church Lane. Which is correct? Herts County Council Property. Text of this para. is incorrect. Cheshunt is located within the Cheshunt EPA. A new secondary school site is proposed within the EPA to the south of Church Lane in Wormley which it is proposed will meet anticipated need for additional secondary school places towards the end of the Plan period.

required within or beyond the plan period. This section of the plan relates to secondary school provision in Cheshunt rather than the whole borough. It relates to Cheshunt rather than the EPA.

Cheshunt and St. Mary’s Schools have significant new capacity and no new schools are planned in Cheshunt during the Plan period.

7.136 7.25 PO1352 Herts County Council Property. Amend the text, as only four sites are being considered for primary schools (Albury Farm, Brookfield Garden Village, Cheshunt Lakeside and Rosedale Park) within the Cheshunt EPA.

Five primary school sites are planned – including at St Mary’s, which is proposed by the secondary school.

Amend from 6 to 5 primary schools.

7.137 7.26 PO264 NHS England/NHS East and North Herts CCG Keen to discuss land adjacent to Cheshunt Community Hospital which is currently vacant aside from a couple of temporary buildings. Herts Community NHS Trust would like to know the future of the site and if they can purchase this for a community hospital extension.

The Council is waiting for the NHS/CCG to explain their strategy for Primary Care provision within Broxbourne, particularly in relation to plans for centralised healthcare provision within Brookfield. Once that strategy is clarified, discussions can take place in relation to the Community Hospital.

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7.138 7.26 PO869 There should be provision for a doctor’s surgery in the Hammondstreet Road area to ease the surgeries at Stockwell Lodge and Goffs Oak when the development in and around Rags Valley is built.

New provision, if any, is expected to be located within the Rosedale Park development. This is being specifically planned for within the masterplan for the development.

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7.139 ? [Comment was raised re. policy WD1]

PO645 Historic England Put in place an improvement plan for the Conservation Area at Risk at Churchgate, Cheshunt.

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Chapter 8: Goffs Oak and St James Issue

Number Comment ID(S) Paragraph/

Policy Number


General

8.1 PO8, PO26, PO36, PO38. PO39, PO48, PO50, PO54, PO56, PO65, PO156, PO164, PO166, PO181, PO185, PO190, PO237, PO246, PO295, PO299, PO319, PO329, PO376, PO378, PO379, PO382, PO385, PO400, PO404, PO511, PO513, PO604, PO821, PO479, PO481, PO484, PO595, PO596, PO577, PO578, PO579, PO580, PO581, PO582, PO583, PO584, PO585, PO586, PO587, PO588, PO589, PO590, PO591, PO592, PO593, PO594, PO496, PO503, PO508, PO510, PO558, PO598, PO848, PO712, PO713, PO715, PO763, PO756, PO785, PO787, PO790, PO789, PO792, PO798, PO961, PO922, P01105, PO1107, PO1143, PO1144, PO1149, PO1151, PO1152, PO1153, PO1155, PO1170,

Section 8 – Goffs Oak

Goffs Oak road infrastructure is unable to cope with current traffic, particularly during rush hour and school drop/pick up times. The lanes around Goffs Oak area are unsustainable and will be used as ‘rat-runs’ by commuters trying to avoid congestion on the main roads. To add to this, road problems on the M25 result in the road infrastructure within the village to become chaotic. Therefore, this infrastructure will not be sufficient to support the proposed development, with no solution in the plan being identified. Three roads within the Goffs Oak area that are a particular area of concern are:

B156 (Goffs Lane) - Several problems were identified for this road, which include: problems on the M25 result in the road becoming chaotic, the road is used as a through road, the increase in residential development will result in the rush hour traffic worsening, the Cattlegate junction

The Council has carried out detailed transport modelling, working with neighbouring authorities, where appropriate, and Hertfordshire County Council as highways authority, to understand the impact that the proposed development will have on both the local roads and the strategic highway network. To inform the production of this strategy, the Council has modelled the planned development sites using both the Council’s own model (the Broxbourne Transport Model) and the county-wide COMET model. This information has been used in the preparation of the Council’s Transport Strategy, which is a blended approach of cost effective highway improvements and sustainable transport modes. Full details, including the transport modelling technical report, are on the Council’s website at www.broxbourne.gov.uk/transportstrategy Transport modelling suggests that signalisation of the Newgatestreet Road roundabout junction can avoid ‘severe’ impacts on the local road network.

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http://www.broxbourne.gov.uk/transportstrategy


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PO1176, PO1181, PO1199, PO1202, PO1222, PO1224, PO1226, PO1230, PO1232, PO1236, PO1238, PO1240, PO1242, PO1244, PO1246, PO1249, PO1256, PO1258, PO1426, PO1112, PO1228, PO1234, PO1253, PO1260, PO1261, PO1265,PO1267,PO1269, PO1271, PO1274, PO1277, PO1279, PO1281, PO1284, PO1287, PO1289, PO1292, PO1294, PO1368, PO1420, PO1441, PO1538, PO1539, PO1587, PO1599, PO1600, PO1601, PO1604, PO1858, PO1869, PO1876, PO1897, PO1009, PO894, PO840

Newgatestreet Road - Concerns raised regarding the speed in which cars travel down this road, which has resulted in fatalities. There are no enforcement measures in place.

Cuffley Hill – An increasingly busy thoroughfare that is currently congested.

The Plan does not indicate that any improvements will happen to the Goffs Oak road infrastructure during the 15 year period.

It should be noted that the Transport Strategy does not allow for ‘worst case’ events such as disruption caused by traffic accidents – it is not practicable to over-design transport networks to cope with abnormal conditions.

8.2 PO8, PO1149, PO1170, PO1174, PO1260, PO1538


Construction will be disruptive to the Goffs Oak residents. Goffs Oak road infrastructure will not be able to cope with the construction traffic.

As with any development, there is a temporary period of disruption during the construction phase. To help mitigate this disruption, planning conditions such as the requirement to produce a construction plan, can be implemented to minimise the impact of development. Utility companies endeavour to minimise the disruption of services to existing properties when infrastructure is being installed/upgraded.

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8.3 PO22, PO66, PO31, PO180, PO511, PO520, PO821. PO828, PO496, PO833, PO763, PO1479


The preservation of Goffs Oak’s identity and character must by the prime consideration for development.

The Council acknowledges the importance of Goffs Oak character and considers that the level of development proposed in the Plan will not have a significant detrimental impact on the character and identity of the village. Any

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proposals for the allocated sites will be determined with reference to emerging Policy DSC1 which states that all proposals must enhance local character and distinctiveness taking into account existing patterns of development, significant views, urban form, building typology and details, height, roof form, fenestration details, materials, building lines and other setbacks, trees, landscaping and features of local and historic significance.

8.4 PO22, PO149, PO155, PO520, PO1303


The proposed development will brings Goffs Oak village closer to neighbouring areas, which could result in their coalescence. This would turn the village into an area of urban sprawl.

The proposals for Rosedale Park are based on Green Infrastructure principles in order to create structure and coherent urban form in an area where this is currently lacking. As identified in emerging Policy ORC3: Local Green Space, development is not permitted on areas designated as open green space and should include a mix of formal and informal recreational space, parks and gardens, planting schemes or landscaping. The proposals for a ‘Green Link’ at St James’ form part of this concept. The Council has rejected proposals from the landowners at Pendine and the eastern part of Whitehouse Farm which would result in coalescence of the fragile gap.

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8.5 PO30, PO45, PO56, PO52, PO159, PO168, PO246, PO295, PO299, PO319, PO376, PO387, PO511, PO761, PO821, PO829, PO507, PO552, PO598,


The proposed development will place additional pressure on Goffs Oak healthcare facilities, particularly Valley View Surgery, for which current registrants already experience long wait times.

The Council is working with healthcare providers to ensure that there is sufficient provision of healthcare facilities across the Borough. The Council’s Infrastructure Delivery Plan details where and when healthcare facilities will be provided in the Borough.

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PO841, PO756, PO798, PO1105, PO1107, PO1262, PO1477, PO1544, PO1856, PO1860, PO1871, PO2215

8.6 PO36, PO58, PO66, PO155, PO379, PO400, PO511, PO520, PO479, PO481, PO484,PO595, PO596, PO577, PO578, PO579, PO580, PO581, PO582, PO583, PO584, PO585, PO586, PO587, PO588, PO589, PO590, PO591, PO592, PO593, PO594, PO598, PO799, PO922, PO1204, PO1224, PO1226, PO1230, PO1232, PO1236, PO1238, PO1240, PO1242, PO1244, PO1246, PO1249, PO1256, PO1258, PO1228, PO1234, PO1253, PO1261, PO1265, PO1267, PO1269, PO1271, PO1274, PO1277, PO1279, PO1281, PO1284, PO1287, PO1289, PO1292, PO1294, PO1601, PO1604. PO203, PO1221


The proposed development will result in the loss of Green Belt in the Goffs Oak area.

The Council has tried to utilise all brownfield land as far as possible, however these sites cannot accommodate the entirety of the Borough’s identified development need. Development of Green Belt land is therefore necessary to meet the Borough’s identified development need. The adoption of a strategy where no Green Belt land was built on would result in a severe undersupply of housing and long-term stagnation of the Borough. A number of development options for the Goffs Oak area were assessed, as presented in the Council’s Goffs Oak Development Options Report. The Council considers that the sites included within the Plan will form sustainable development and create a stronger Green Belt boundary that will last beyond the Plan period. An explanation of what the Council considers to be the necessary ‘exceptional circumstances’ needed to justify Green Belt release is set out in the Green Belt Topic Paper (June 2017).

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8.7 PO36, PO114, PO185, PO496, PO791, PO1110, PO1441, PO1897


The impacts of the proposed development (i.e. pollution, noise, congestion) will have a negative impact on the environment, which in turn affects the quality of life of the

The emerging Environmental Quality policies requires major developments to undertake an air quality assessment that considers the potential impact the development will have on air quality at the site and immediate

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Goffs Oak residents. neighbouring areas and a noise impact assessment that provides details on the level of noise and the mitigation measures proposed.

8.8 PO38, PO379, PO400, PO520, PO479, PO481, PO484, PO922, PO1104, PO1111, PO1224, PO1226, PO1230, PO1232, PO1236, PO1238, PO1240, PO1242, PO1244, PO1246, PO1249, PO1256, PO1258, PO1228, PO1234, PO1253, PO1261, PO1265, PO1267, PO1269, PO1271, PO1274, PO1277, PO1279, PO1281, PO1284, PO1287, PO1289, PO1292, PO1294, PO1601, PO1604, PO1862, PO383, PO1221


The development proposals for the Goffs Oak area need to be scaled back.

The NPPF states that local planning authorities should seek to meet their objectively assessed housing needs. The comparatively modest sites contained in the draft Local Plan are not considered to be out of scale with the village, taking into account the level of services and facilities in the area. The Council has considered a number of different development options, as presented through the ‘Development Option’ reports published in April 2016. Goffs Oak is considered to be a sustainable location for further development – it already has a good range of shops and services and is accessible by bus.

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8.9 PO38, PO894 Section 8 – Goffs Oak

Trees and areas subject to a Tree Preservation Order should be saved

Tree surveys will need to be undertaken prior to the determination of a planning application for the proposed development to identify the quality of trees along with their location. This information, along with TPOs designated by the Council, will inform tree protection plans for development sites. Planning applications for the proposed development will be determined against emerging Policy NEB4 which indicates that areas of TPOs will only be removed in exceptional circumstances and replacement provision made.

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8.10 PO39, PO56, PO58, PO52, PO237, PO246, PO295, PO376, PO821, PO828, PO496, PO833, PO798, PO1105, PO1151, PO1112


Goffs Oak infrastructure (i.e. water, gas and sewage) will not be able to cope with the proposed development. The Plan offers no guarantee that the infrastructure will be improved.

All developments proposed will be required to meet the infrastructure needs that arise from the site. This can be achieved through on-site provision and through contributions to existing facilities located off-site, where appropriate. The Council’s Infrastructure Delivery Plan (IDP) will identify the infrastructure required to support the proposed development, how it will be delivered, who will provide it and who will pay for it.

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8.11 PO45 Section 8 – Goffs Oak

Concern that Goffs Oak residents will not benefit from the proposed improvements to the A10 and the introduction of a high speed rail at Cheshunt

The Borough will benefit as a whole from any improvements made to the A10 and improved access to more frequent railway services.

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Concern the Council has not made accurate estimates for the increase in population and increase in vehicles as a result of the proposed development along a 3 mile stretch of the B156 (Northaw Road East to Dark Lane)

The population estimates come from the national dataset published by the Office for National Statistics and which form the starting point for all Local Authority estimates across the country. Transport modelling has taken account of the proposed development in Welwyn Hatfield Borough as well as Broxbourne Borough and demonstrates that there is no case of ‘severe’ impacts during the plan period.

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8.13 P050, PO156, PO376, PO386, PO821, PO789, PO798, PO1176, PO516


Concern the proposed development will worsen the car parking problem within Goffs Oak particularly around areas of interest i.e. local shops.

Any development proposal will be required to adhere to the parking standards included within the Plan and referred to in emerging Policy TM4: Parking Standards. The Council will seek a sensible balance of car and cycle parking spaces based on the nature of the proposal, site context and wider surrounding area, and with the overall aim of reducing

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private car use.


Concern that the proposed development along the B156 will have a negative impact on Goffs Oak Village and Cuffley

Transport modelling has taken account of the proposed development in Welwyn Hatfield Borough as well as Broxbourne Borough and demonstrates that there is no case of ‘severe’ impacts during the plan period.

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8.15 PO50, PO763, PO1107, PO1368, PO1420, PO1869, PO56, PO166, PO513, PO595, PO576, PO569, PO577, PO578, PO579, PO580, PO581, PO582, PO583, PO584, PO585, PO586, PO587, PO588, PO589, PO590, PO5914, PO592, PO593, PO594, PO366


The proposed development at Cuffley will add to the congestion to the B156. Concern that this road will be unable to cope.

Evidence gained from transport modelling and testing of mitigations measures on both the Council’s own transport model and the county-wide COMET model, suggests that whilst development will not constitute a ‘severe’ impact during the Plan period.

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Concern that conflict has been created between the need for new houses and the expansion of community facilities, with reference being made to the V&E club.

The proposed housing development at the V&E club is enabling work to improve/upgrade the facilities at the club and improve the frontage onto Goffs Lane.

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Development Option 2 places all development within Goffs Oak village. The identified housing sites, with the exception of two, are all located on green spaces which would result in an increase in the size of the village. Development Option 4 will spread out the development, therefore the impact on the village is not as great.

This comment refers to development options contained within the ‘Goffs Oak Development Options Report’, an evidence base study used to inform the preparation of the draft Local Plan. Not all sites included within this document were taken forward into the draft Local Plan.

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Developing on derelict greenhouse sites in and around Goffs Oak would enhance the area.

The Goffs Oak Development Options Report (April, 2016) concluded that allocation of glass house sites for development at conventional densities would result in unsustainable urban sprawl and that the assessment of the majority of derelict sites have found them “…not to be preferable for development at conventional densities”. Emerging policy GB2: Residential Development on Derelict Glass House Sites highlights the Council’s ambition to prevent urban sprawl and unsustainable developments as well as tidy up the appearance of the derelict glass houses, by permitting self-build housing at low densities, subject to a number of criteria being met.

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8.19 PO56, PO149, PO180, PO379, PO400, PO381, PO520, PO479, PO481, PO484, PO922, PO1224, PO1226, PO1230, PO1232, PO1236, PO1238, PO1240, PO1242, PO1244, PO1246, PO1249, PO1256, PO1258, PO1228, PO1234, PO1253, PO1261, PO1265, PO1267, PO1269, PO1271, PO1274, PO1277, PO1279, PO1281, PO1284, PO1287, PO1289, PO1292, PO1294, PO1601, PO1604, PO1221


The size of Goffs Oak village has increased over the past 20-30 years due to a considerable amount of residential development. The planned proposal will result in the village’s further expansion.

Broxbourne has and will continue to grow to support the increase in the population. The NPPF states that local planning authorities should seek to meet their objectively assessed housing needs. The Council has considered a number of different development options, as presented through the ‘Development Option’ reports published in April 2016. Goffs Oak is considered to be a sustainable location for further development – it already has a good range of shops and services, and is located on a bus route.

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The proposed development will result in the loss of agricultural land.

The Council has taken account of Agricultural Land Classifications through its site selection process and has sought to use areas of poorer

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quality land in preference to that of a higher quality.

8.21 PO58, PO154, PO520, PO1878


The sense of community with Goffs Oak will be significantly altered by the proposed development. The Plan does not provide a framework for the community to be developed.

The policy for the area North of Goffs Lane seeks to extend the village centre, contributing to the vitality of the village. The proposed development sites represent a modest uplift in the provision of housing in the village.

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Goffs Oak residents paid a premium to live within a rural spot outside of London. The proposed development will result in the area becoming similar to surrounding areas, such as Enfield

The price paid to live within an area is not a matter that can be considered through the Local Plan process.

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8.23 PO66, PO52, PO156, PO273, PO760, PO763, PO1105, PO1460


Public transport within Goffs Oak is inadequate. Bus services are limited and there is no train station within the village. The closest train station, Cuffley, does not enable residents to travel anywhere local. During rush hour, these trains are at capacity.

It is considered adequate to sustainably accommodate the modest amount of development proposed in the draft Local Plan. The 242 service operates at a reasonable frequency between Cuffley and Waltham Cross. The Train Operating Company has set out its own plans to increase capacity.

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Development Option 1 is the only option that will preserve the character of Goffs Oak

This comment refers to development options contained within the ‘Goffs Oak Development Options Report’, an evidence base study used to inform the preparation of the draft Local Plan. Option 1 refers to ‘committed and urban infill development only’. Other options which focus on brownfield sites and improving the Local Green Space have been carried forward, whilst some proposals on the edge of the village have not been.

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8.25 PO149 Section 8 – Concern that residents were not As part of the planning application process, -


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Goffs Oak informed about development on east of Grange Brook, which has already commenced.

neighbours and relevant stakeholders are notified when a planning application has been received. More information about the consultation process can be found in the Council’s Statement of Community Involvement (SCI).


The Plan refers to areas of ‘dereliction’ and ‘areas of illegal businesses’. The Council or relevant authority should step in and take appropriate action.

This comment refers to a statement contained with the ‘Goffs Oak Development Options Report’, an evidence base study used to inform the preparation of the draft Local Plan. Clean-up of large derelict sites is expensive. The proposed approach set out in policy GB2 is considered a practical way to achieve the objective of improving the openness of the Green Belt.

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The Plan places emphasis on the need for local employment, however it contains no proposals for new employment opportunities within Goffs Oak.

The Council’s Employment Land Study projects strong demand for employment space across all key employment sectors over the next 15 years. The Council does not consider Goffs Oak to be a suitable location to accommodate the large-scale employment sites needed to meet this demand. However, at the site allocation North of Goffs Lane (policy GO2), there is a proposal to create a commercial development site along the frontage of Goffs Lane.

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8.28 PO154, PO990, PO763, PO162


The proposals will turn Goffs Oak into a large housing estate

Policy DSC1 requires development proposals to enhance local character and distinctiveness. The Council has undertaken feasibility masterplanning work to determine appropriate densities for the proposed development which are most suited to the Goffs Oak character. The areas proposed for development are fairly small and well-

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http://www.broxbourne.gov.uk/sites/default/files/Documents/Planning/pp_Adopted_SCI_12th_May.pdf

http://www.broxbourne.gov.uk/sites/default/files/Documents/Planning/pp_Adopted_SCI_12th_May.pdf


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contained when compared with the extensive residential areas of the existing settlement.

8.29 PO156, PO760, PO604, PO1105, PO1110, PO1460


Due to the topography and age-demographic of Goffs Oak, the ability to access and utilise modes of sustainable transport will be difficult for some residents.

It is acknowledged that the topography of Goffs Oak presents a mobility challenge for older people and the less able. Promotion of sustainable transport is part of the Borough’s overall transport strategy, which seeks improvements wherever possible.

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8.30 PO157, PO319, PO376, PO511, PO821, PO552, PO598, PO756, PO798, PO1105, PO1262, PO894


Concerns about the capacity of education facilities such as schools, nurseries and childminders.

Land has been allocated for the expansion of Woodside Primary school. The Council will continue to work with Hertfordshire County Council, as education authority, to ensure that education is appropriately planned for in the Borough. The supply of childminders within the Borough is not an issue that can be considered through the Local Plan process.

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8.31 PO166, PO513, PO595, PO596, PO577, PO578, PO579, PO580, PO581, PO582, PO583, PO584, PO585, PO586, PO587, PO588, PO589, PO590, PO591, PO592, PO593, PO594, PO763


Concern that the Council has not taken into consideration the impact that the proposals to build new homes in Cuffley will have on Goffs Oak.

The ‘Duty to Co-operate’ was introduced in the Localism Act 2011, and places the requirement on local planning authorities to engage with relevant local planning authorities and prescribed bodies “constructively, actively and on an on-going basis’ on strategic issues (i.e. housing, retail, infrastructure). The Council has been in discussions with Welwyn Hatfield Council, and will continue to discuss the impacts that the proposed development of Cuffley will have on Goffs Oak. The County-wide COMET model contains proposed sites in Cuffley and has informed the Council’s transport strategy.

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8.32 PO179, PO180, PO184 Section 8 – Goffs Oak

The proposals will result in Goffs Oak losing ‘quality of life’ facilities i.e. coffee shop and garden centre. Concern that the Council have not

The Council acknowledges that the proposals will result in the loss of some existing facilities at the garden centre. As part of the development North of Goffs Lane the Council

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acted to save such facilities. proposes to create a commercial development site along the frontage within Goffs Lane.


The planning gains for Goffs Oak as a result of this Plan are not clearly identified.

The benefits of the proposals are set out in the draft Local Plan and include: the tidying up of the former showman’s yard south of Goffs Lane; the provision of additional capacity at Woodside Primary School, enabling village children to be educated locally; the provision of additional open space off Newgatestreet Road; the provision of a small extension to the village centre North of Goffs Lane; and the provision of local housing.

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8.34 PO193, PO507, PO552, PO787, PO794, PO1175, PO1199, PO1871, PO1855, PO1874


Concern regarding the delivery of infrastructure due to previous experience. Improvements to local infrastructure should be completed alongside housing expansion.

The proposed development will be required to meet the infrastructure needs that arise for the site through on-site provision or by making contributions to improve facilities located off-site. In addition, the Council is preparing an Infrastructure Delivery Plan (IDP) which will detail what infrastructure is required, where it is needed and when it will be delivered. This will be a ‘live’ document that will be updated on a regular basis.

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8.35 PO217, PO388, Section 8 – Goffs Oak

Concern regarding water pressure and water quality when additional housing has been added to an area where current demand cannot be handled. Water cuts are regular in this area.

Utility providers, such as water services, have a statutory duty to ensure adequate infrastructure is in place. The Council is working with Thames Water to understand the impacts that the proposed development will have on the existing infrastructure and assist in the planning of necessary upgrade programmes.

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Developments should jointly pay for the increase and improvement in local amenities and community

As outlined in emerging Policy PO1: Planning Obligations will be used by the Council to deliver sustainable development. Planning

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facilities within Goffs Oak. Areas where money could be allocated included the improvement of local sport facilities, play areas, the Village hall and improving local facilities (i.e. GP surgery)

obligations may take the form of financial contributions or actions (i.e. improvements to the highway, construction of a road/cycle path). The Council’s Infrastructure Delivery Plan (IDP) will provide the evidence required to support planning obligations through the Plan period.

8.37 PO238, PO1107, PO49, PO167, PO186, PO1874, PO1473


Welwyn Hatfield Borough Council has made no provision for educational facilities in Cuffley. There is concern that the expansion of Woodside Primary School and Goffs Oak Secondary school is to provide school places for children from the proposed Cuffley housing developments.

Welwyn Hatfield Borough has a duty to provide primary school provision to support the need generated from the proposed development in Cuffley within their Borough. The expansion of Woodside Primary School means that in future fewer Goffs Oak children will be schooled at Cuffley Primary School. This should result in a reduced need to travel between the two villages.

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The proposed development sites in Goffs Oak should be used to build a retirement village with a section for those suffering with dementia.

The Council’s “Review of Objectively Assessed Need” (May, 2016) identified the Council‘s projected future need for specialist housing, which equates to 38 dwellings per annum. The Council has identified a number of sites where this provision can be built; a retirement village in Rosedale Park south (CH2), elderly persons accommodation in Rosedale Park North (CH2), elderly persons accommodation in Cheshunt Lakeside (CH2), elderly persons accommodation at Brookfield Garden Village (BR1) and a residential care home at High Leigh Garden Village (HOD5).

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Concern that the replacement of a large section of permeable soil with impermeable hard surface will result in a significant increase in the amount of surface run off discharging

Development proposals will need to be accompanied by a surface water drainage strategy, which may incorporate sustainable urban drainage systems (SuDs). See Policy W4: SuDS.

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into the existing highway drainage network.


Concern that an increase in surface run-off on the highway network would have an impact on Theobalds Brook, and the sump pumps which deal with the excessive flows through the culverted section of the brook under Isabelle Close and Doverfield.

Development proposals will need to be accompanied by a surface water drainage strategy, which may incorporate sustainable urban drainage systems (SuDs). See Policy W4: SuDS.

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The Rosedale Park development is not mentioned within this section. Acknowledgement should be made that the development will have an impact on Goffs Oak.

This is addressed in the paragraph on St James’.

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8.42 PO298, PO763, PO1200, PO1264


There is a need for affordable housing within Goffs Oak due to young local people not being able to afford to stay in the area

As identified in the policy for the allocated sites, the Council has made provision for affordable housing within Goffs Oak. The types of affordable housing to be provided are starter/shared ownership homes and affordable rented homes. Affordable rented housing is provided to people on a waiting lists maintained by Broxbourne Borough Council and in accordance with agreed and accepted criteria.

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Construction of a bypass from the M25 to Crews Hill is needed to ease congestion

The construction of a bypass may divert some traffic, however it could draw in a greater volume of traffic from the surrounding strategic network. The cost of a bypass would also be considerable. However, as this bypass would not sit within the Borough, and there is no indication from the Council’s neighbouring authorities that this is to being considered, inclusion of this scheme within the Plan would be inappropriate.

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A roundabout at the Cattlegate junction on the B156 would keep traffic flowing

This lies in Welwyn Hatfield Borough. The Council has raised this with officers at Welwyn Hatfield for consideration as part of their transport work.

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A roundabout at the Station Road junction

This lies in Welwyn Hatfield Borough. -


The proposed development is disproportionate when compared to the present population figure of Goffs Oak.

The current population of the village is estimated at around 2,700. The plan proposes around 230 new dwellings in the village, yielding around 550 additional population (assuming 2.4 people per house). This equates to a 20% rise in population by 2033, which is considered proportionate compared with the Borough-wide increase of 19% (96,500 plus 18,400 to 114,900 by 2033).

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St James’ is part of Goffs Oak and should not be headlined separately

Not agreed. St James’ is physically separate from Goffs Oak. It is located within the Goffs Oak section, reflecting the relationship between the two.

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Welwyn Hatfield Borough Council support that the Plan proposes development around the Goffs Oak area. Due to Goffs Oak close links with Cuffley, the area falls into Welwyn Hatfield Borough Council’s Strategic Housing Market Area, therefore a failure to provide new homes within Goffs Oak could create additional housing need within Welwyn Hatfield.

Support noted. -


Welwyn Hatfield Borough Council notes that the allocation of just over 200 homes within the village creates a critical mass, and allows necessary

Noted. -


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site assembly to bring forward Hertfordshire County Council’s planned extension of Woodside Primary School from 1 to 2 forms of entry. Currently a number of children travel from the Goffs Oak area to attend a school in Cuffley, and the extension of Woodside facilitates a ‘rebalancing’ of this flow. In addition to the benefit of reduced trips along Cuffley Hill between the two villages, this will also create capacity within Cuffley Primary School needed to support Welwyn Hatfield Borough’s proposed growth.


No new secondary school is being provided in Goffs Oak

The Council has been working closely with Hertfordshire County Council to ensure there is sufficient secondary school provision with the Borough to support the proposed developments. There is currently secondary capacity within the existing schools, but this is anticipated to fill up during the Plan period as a result of the ageing of existing school children and new children within the new development. A new secondary school is likely to be required during the latter part of the Plan period, with the preferred location being at Church Lane, Wormley.

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8.51 PO821, PO828, PO833, PO1180, PO1539


Concern that there is the expectation for residents to work from home and walk and cycle everywhere.

Transport modelling carried out does not assume a significant increase in cycling for the Goffs Oak area. Travel behaviour will be influenced by a number of factors, but the

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Broxbourne Transport Strategy is designed to improve choice wherever possible, rather than restrict car usage.


Concern that youth facilities are not included within this section of the Plan.

The Council’s ‘Youth Strategy’ states that there is not necessarily the demand from young people in Goffs Oak for clubs, however as part of the strategy the demand for indoor youth provision in areas without current provision will be researched.

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Concern that local businesses are being encouraged to close in order to sell their land for housing.

The Council is committed to enabling a full range of economic development opportunities within the Borough. Emerging policy ED2 states that development which would cause the loss of an existing employment use will only be permitted if certain criteria have been met.

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8.54 PO713, PO714, PO1153, PO1154


Due to traffic problems/issues on Goffs Oak current road, a new road should be constructed. This would be able to divert cars from village traffic.

Transport modelling demonstrates that such a road is unnecessary. The construction of such a new road is considered to be unviable due to the huge cost and complexity of land assembly, as well as damaging to a sensitive area of Green Belt countryside, much of which lies within Welwyn Hatfield Borough. Whilst the Broxbourne Transport Strategy does contain some significant highways measures, strategic interventions are restriction to strategic corridors (i.e. the A10).

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The construction of affordable housing should not be at the expense of the village.

The Council’s ‘Review of the Objectively Assessed Housing Need’ shows that the Borough has an assessed affordable need of

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232-438 per annum (dependent on the affordability threshold dependent). The NPPF states that Local Planning Authorities “where they have identified that affordable housing is needed, set policies for meeting this on site, unless off-site provision or a financial contribution of broadly equivalent value can be robustly justified and the agreed approach contributes to the objective of creating mixed and balanced communities.”


Concern regarding the housing mix of new development. This is the presumption that the new developments within Goffs Oak will be 4-5 bedroom homes.

The housing mix of developments within Goffs Oak will determined against emerging policy H3: Housing Mix.

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Due to the age demographic of Goffs Oak, road safety for pedestrians and cyclists needs to be carefully thought through.

Please see the section the Council’s Local Cycling and Walking Infrastructure Plan (2017), which is open for public consultation during November/December 2017.

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A pedestrian crossing should be installed on Newgatestreet Road.

Agreed. This would provide a safe crossing to the new open space and help to calm traffic as it approaches the village centre.

Include reference to the pedestrian crossing in policy GO4.


Attention needs to be given to the roundabout at the end of Lieutenant Ellis Way, where there is currently no sensible pedestrian route.

There is an existing signalised crossing opposite Goffs School, and there is a central pedestrian crossing island at Rosedale Way. A further crossing by the V&E club will be investigated as part of the proposed Development Brief associated with the site.

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The wildlife located within Goffs Oak will be impacted by the proposed development.

The proposed allocation South of Goffs Oak lies east of Poyndon Farm Local Wildlife Site, and North of Goffs Oak lies west of the Tudor Villas Local Wildlife Site. Policy NEB1: General Strategy for Biodiversity and NEB2: Wildlife Sites set out a criteria-based approach to

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protection of local wildlife. Ecological assessments will be required as part of planning applications for both sites. Recommendations from the assessment will be required to be considered as part of the development to ensure the impact the proposed development has on wildlife is minimised.


The junction of Jones Road with Cuffley Hill should be either widened into a roundabout or have traffic lights installed

This will be considered as part of the proposals to expand Woodside School from 1FE to 2 FE.

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Concern that the Council is unable to provide safe cycle lanes in Goffs Oak due to the pavements being too narrow to convert and accommodate both pedestrians and cyclists.

The Council’s Local Cycling and Walking Infrastructure Plan identifies a quiet route from Goffs Oak along Andrew’s Lane.

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A car free zone should be created to enable intimate public transport to provide access to and from destinations. All household cars should be stored at a “park and ride” that is maintained 24/7 and has restricted access.

The implementation of this scheme would not be practical. There is not adequate space within Goffs Oak or the surrounding area that will be able to accommodate a car park big enough to accommodate the level of parking provision that will be needed for the proposed developments within Goffs Oak. This will also require continued maintenance, security provision that will make the scheme financially unviable in the long –term.

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The ideology of community living and its associated infrastructure (local police station, local community hospital etc.) needs to be reinvented in a new town/village.

Planning a new town and its associated infrastructure, will take a number of years, a vast amount of land that landowners are willing to develop and a significant amount of initial investment. As identified in the National Planning Policy Framework (NPPF) “Local

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planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirement with an additional buffer of 5%” as well as address the undersupply accumulated from previous years. Although the creation of a new town would reduce the impact of development on the Borough’s current settlements, it would not be a realistic way for the Council to meet the Governments requirements.


Concern that land behind Thompson Close, off Caldecot, which is currently designated as a local wildlife site, will be built on.

This refers to the meadow south of Rosedale Sports Ground, which has been in use as an overspill sports pitch for a number of years. The Local Plan does not propose development of this site.

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8.66 PO1148, PO1169, PO1180, PO1539, PO1542


Goffs Oak residents will not benefit from the proposed developments.

Residents will derive some benefit from the tidying up of some brownfield sites, and the provision of additional public open space.

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Concern there is a lack of construction knowledge, experience and qualification behind the proposed development at Goffs Oak

There is a significant amount of planning knowledge and experience behind the Local Plan. Construction knowledge is supplied by developers, and where appropriate this knowledge is incorporated through consultation feedback.

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Concerns regarding the average build out rates for Goffs Oak over the 15 year plan period. Developments in close proximity to the War Memorial average at 14 dwellings per year over the 15 year period. The build out rate increases to 64 dwellings per year when all development areas included

The build out rates for the proposed development will be determined through masterplanning.

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within the Goffs Oak Inset Map are taken into account.


The masterplanning of the area will enable a high frequency bus route that links Cheshunt with Flamstead End, Hammond Street and Goffs Oak. This could consolidate with the existing bus network, where the focus is on the A121.

Metroline currently operates the 242 service along Goffs Lane. Development may help to secure the long-term commercial viability of the existing service.

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Hertfordshire County Council notes that there are currently some pupil movements between Cuffley and Goffs Oak. Both areas have housing proposed as part of the relevant emerging Local Plans. Hertfordshire County Council will monitor the demand for primary school places through the forecast, but welcome close engagement between Broxbourne and Welwyn Hatfield to ensure a co-ordinated cross border approach to housing development in the area so additional school places required can be delivered in a planned way.

Noted. -


Hertfordshire County Council notes that there is no ‘School and Health Centres’ section within the Goffs Oak and St James chapter, as there is in other chapters.

Noted. ‘Schools and Health Centres’ section added.


The number of shops within Goffs Oak village has dropped in recent years.

Retailing responds to changes in market conditions.

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8.73 PO1420, PO1442 Section 8 – The proposed development will The proposal involves approximately 20% -


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Goffs Oak destroy Goffs Oak residents quality of life

additional dwellings over the plan period, on a small number of brownfield sites. Given the modest nature of these proposals, it is not clear on what basis the conclusion that this will destroy quality of life has been drawn.


Concern about how Goffs Oak residents will be kept informed

The Council’s Statement of Community Involvement (SCI) details how the Council seeks to make sure that residents and other stakeholders are kept informed about development proposals in the Borough.

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Concern that the woodlands lost as a result of the proposed development will not be replaced

Emerging policy NEB4 requires replacement planting if permission is granted to fell protected trees.

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New towns should be built instead of building new houses into already busy existing towns

The Local Plan proposed a mix of larger comprehensive developments such as Brookfield and the associated Garden Village with smaller developments and infilling. Planning a new town will take a number of years, a vast amount of land that landowners are willing to develop and a significant amount of initial investment. As identified in the National Planning Policy Framework (NPPF) “Local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide five years’ worth of housing against their housing requirement with an additional buffer of 5%” as well as address the undersupply accumulated from previous years. Strategic scale developments alone cannot meet the demand for a continuous supply of housing across the plan period.

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8.77 PO1599 Section 8 – Crossings within the Goffs Oak area The potential for a new crossing in the village Add requirement for


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Goffs Oak are dangerous, with the exception of the one safe crossing at Jones Road

centre will be investigated as part of the Goffs Oak Village Improvement Plan (Policy GO1). A new crossing at Newgagtestreet Road would provide a safe crossing to the new public open space.

pedestrian crossing of Newgatestreet Road to Policy GO6.


Concern that the proposed developments at Goffs Oak combined with the proposals at Cuffley which include a hotel restaurant food dump will bring additional lorries onto the B156 every day.

Whilst there may be some additional lorries during the construction of new development in Goffs Oak, this will be for a limited period and vehicle movements will be controlled through planning conditions.

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Object to the omission of site known as Pendine, St James, from the Plan. The site is well related to the proposed development allocations, can be accessed via St James’ road, is not located within a conservation area of area at risk of from flooding and due to its proximity to public transport and facilities and service is considered to be a sustainable location for further growth. It is envisaged that the site could provide circa 11 dwellings. The site should be considered to be deliverable with a realistic prospect that housing could be delivered within 5 years.

This site, together with the adjoining land on the eastern part of White House Farm, were both given careful consideration through the Local Plan process, including looking at various options to open up access through the area. However, the conclusion of these deliberations was that the necessary ‘exceptional circumstances’ to release land from the Green Belt were not considered to exist and therefore no amendment to the Regulation 18 draft Local Plan will be made.

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People should move to areas that they are able to afford.

Property prices are not a matter that can be considered through the Local Plan process.

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Object to the omission of site known as the former Nockhold/FJD Nursery from the Plan. The site has no recognisable constraints and has been identified as having the

The Council has recently completed an update on its Strategic Land Availability Assessment (SLAA). As part of this update, all sites included within the previous SLAA (April 2016) and those promoted to the Council during the

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potential for development in a number of the Council’s evidence base documents (Green Belt Review, Scott Wilson (2008), Strategic Land Availability Assessment, Goffs Oak Development Options Report). The site can assist in accommodating the sustainable housing growth and would continue to meet the objectives of the Green Belt after development has taken place.

2016 Call for Sites were assessed. The SLAA concluded that this site (CG-GB-17) was not suitable for development due to performing strongly against all purposes of the Green Belt, particularly preventing the coalescence of St James, West Cheshunt and Goffs Oak.

8.82 PO2016, PO2017, PO2018, PO2022


Objection to the omission of site referred to as land east of Newgatestreet Road from the Plan.

The Council has recently completed an update on its Strategic Land Availability Assessment (SLAA). As part of this update, all sites included within the previous SLAA (April 2016) and those promoted to the Council during the 2016 Call for Sites were assessed. The SLAA concluded that this site (CG-GB-51) plays a strategic role in preventing the coalescence of Hammondstreet and Goffs Oak.

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Unclear how the findings from the Goffs Oak Development Options Report have been reflected in the allocation of sites.

The judgements made in site selection are based on consideration of a number of evidence studies, including the Options reports, the Green Belt Topic Paper, the Strategic Land Availability Assessment, and the Sustainability Appraisal. This information is on the Council’s website at www.broxbourne.gov.uk/evidencestudies

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The implementation of policies GO3, GO4 and CH2 will result in the amalgamation and in-filling of the Green Belt separating Goffs Oak, St James, West Cheshunt and Rosedale.

To prevent the coalescence of the Borough’s different settlements, the Council has allocated a number of green spaces, as identified on the Policies Map, where development will not be permitted as prescribed in emerging policy ORC3: Local

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http://www.broxbourne.gov.uk/evidencestudies


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Green Space. Some of the green spaces identified will create parkland to provide local amenity space for the surrounding community.


Development of draft allocation sites GO2, GO3 and CH2 will result in the significant encroachment of land surrounding St James and erode the sense of open countryside and lead to an increased perception of on-going urbanisation and amalgamation with the western edge of West Cheshunt and Rosedale.

This refers to the proposed allocations north and south of Goffs Lane, and Rosedale Park. It is acknowledged that Rosedale Park will entail loss of some countryside, albeit countryside surrounded by existing residential development. The approach set out in the Local Plan is to require new developments to provide a series of interlinked open spaces in order to avoid coalescence between the separate residential areas and to improve the amenity of local residents by providing access to previously inaccessible Green Belt land. To that end a comprehensively masterplanned approach is proposed, to avoid piecemeal development of fragmented landownerships.

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The evidence base does not offer an explanation for the reason behind discounting ‘East of Cuffley Hill’

The Borough Wide Options and Scenarios Report , concluded that development at East of Cuffley, which includes Brook Farm (CG-GB-119) and Brook Field (CG-GB-113), “ would undoubtedly be an advantage in sustainability terms, it is not considered to outweigh the substantial damage to the Green belt from development in the already narrow strategic gap between the two settlements”.

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Broxbourne Borough Council has not given appropriate consideration to the suitability of Cuffley to accommodate growth. The Council’s approach contradicts that of Welwyn Hatfield Council, which proposes to

Through the selection of land to accommodate development, the Council has drawn upon a number of evidence studies to assist in its decision-making. The Borough Wide Options and Scenarios Reports indicate that development east of Cuffley would form

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provide housing within this settlement.

an unsustainable urban extension; the Green Belt Review (2008) states that this area performs well against all Green Belt purposes and the Strategic Land Availability Assessment considers the site plays a strategic role in maintaining a gap between Cuffley and Goffs Oak.

8.88 PO2145, PO2241, PO2143, PO2142, PO2146, PO2147, PO2149


Object to the omission of Land at Brook Farm, Cuffley, from the Plan. The site is in a sustainable location, as shown through Appendix A of the submission, and the development of the site would not be contrary to the purposes of the Green belt

The Council has recently completed an update on its Strategic Land Availability Assessment (SLAA). As part of this update, all sites included within the previous SLAA (April 2016) and those promoted to the Council during the 2016 Call for Sites were assessed. The SLAA (2017) concluded that this site forms a strategic gap between Cuffley and Goffs Oak and for this reason, did not consider the site to be suitable for development.

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8.89 PO2158, PO2159, PO2159 Section 8 – Goffs Oak

Object to the omission of Land off Poppy Walk (Longmead Nursery), from the Plan. The site is next to an existing developed site where the infrastructure is already in place and can provide much needed housing at a very short notice.

To inform the Plan, the Council has updated its Strategic Land Availability Assessment (SLAA). As part of this assessment, the Council has reassessed all current SLAA sites and those promoted in the 2016 Call for Sites to determine whether they are suitable, available and achievable for development. The SLAA concluded that this site (CG-GB-18(b)) is not suitable for development due to the following reasons: the site performs strongly against Green Belt Purposes 1 and 2, the 2005 Local Plan Inspector notes that 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 the gap which stops the coalescence of

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the settlement with Hammondstreet; and previous development of this site has been refused due to the materially detrimental impact the development would have on the character and visual amenity of the site and its setting and that is has no realistic means of vehicular access other than via an existing highway and that the greater use of this would be detrimental to pedestrian and vehicular highway safety and create a level of congestion that would be materially detrimental to residential amenity.


Support the de-designation of Land off Poppy Walk (Longmead Nursery) of a local wildlife site.

Not agreed. This wildlife site adjacent to the northern edge of St James’ (known as Longmead Farm Meadows, ref 80/046) is not considered worthy of dedesignation. Additionally the land is not proposed for release from the Green Belt. The land is therefore not considered suitable for development, as explained in the Strategic Land Availability Assessment (site ref CG-GB-18 (a).

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Object to the omission of Laurel Bank Farm from the Plan. The site is a brownfield site located within the Green Belt and is located within a sustainable location. There is no evidence or justification as to why this site has not been allocated in the Plan. The NPPF makes clear that residential development is appropriate providing that the test of openness can be met.

The Strategic Land Availability Assessment (SLAA) concluded that (CG-GB-84) this site is not considered suitable for release from the Green Belt through the Local Plan process.

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8.92 PO280 Section 8 – Developers building along B156 The Local Cycling and Walking Infrastructure -


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Goffs Oak should pay for an off road cycle lane for their section of new builds

Plan proposes a cycle route along Andrew’s Lane as a safer and more attractive alternative to the B156 and also from Cuffley Station to Goffs Oak village centre. It is indeed proposed that developers will contribute to this route.


The shops located within Goffs Oak are not big enough to serve the current population. Additional shop(s) need to be provided to support the increase in population.

There is the potential for a new shop or shops within the ‘North of Goffs Oak’ site allocation. Retail outlets are generally supportive of additional housing as it may result in improved turnover.

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8.94 PO36, PO185, PO114, PO595, PO576, PO596, PO577, PO578, PO579, PO580,PO581,PO582, PO583, PO584, PO585, PO586, PO587, PO588, PO589, PO590, PO591, PO592, PO593, PO594, PO496, PO763, PO1110, PO1897, PO183


Concern regarding the impact that air pollution, as a result of the increased traffic within Goffs Oak, will have on the residents and the environment

There are currently no grounds for believing that the proposed sites will lead to air pollution limits being exceeded in this area. Emerging policy EQ2 requires all proposals for major development to include air quality assessments as part of their proposals. The Council is preparing an Air Quality Strategy which will address the issue.

-


Policies WC1, WC2 and WC3 from the 1990’s Plan resulted in the redevelopment of the old and derelict nurseries in Hammondstreet and St James Village. Therefore horticultural holdings that remain should also be considered for housing development i.e. Tawe-Cheyne and Limes Nursery

The emerging Local Plan proposes a different strategy to earlier Local Plans, whereby sites are selected on the basis of their potential to contribute to sustainable patterns of development. The emerging plan resists development of sites which are poorly located in terms of place-making. Emerging policy GB2 seeks to address the untidy appearance of derelict glass houses by permitting self-build housing, subject to a number of conditions being met.

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8.96 PO1009 Section 8 – Concern that measures to discourage To support the Plan, the Council has produced No amendment to the


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Goffs Oak vehicles from using the B156 as a cut through have not been considered. Suggestions include the implementation of a priority lane, creating pelican crossings and installing speed cameras to ensure the thirty mile per hour speed limit is adhered to.

a transport strategy. During the production of the transport modelling, the Council undertook transport modelling on both the county-wide COMET model and the Broxbourne Transport Model which enabled the Council to not only assess the impact of its proposed development, but that of its neighbouring authorities. As part of this work, the Borough’s strategic and local road network, including the B156, were modelled. This modelling work identified areas when congestion was a great concern and informed the Council’s preferred package of mitigation measures.

Plan in response to this issue.


Concern that the children travelling from Cuffley to attend the schools in Goffs Oak will create extra traffic on Cuffley Hill.

Plans to expand Cuffley School will mean that few Cuffley children will need to travel to Goffs Oak. Proposals to increase the capacity of Woodside Primary school will reduce the number of children from Goffs Oak who need to travel to Cuffley.

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Concern over the omission of land from the Plan. Previously sought planning approval for the construction of 1 dwelling at land at Burton Lane. Green Belt policy designation for this area has been removed and the Government are encouraging small pockets of land to be used for development, therefore this plot of land should be included in the Plan or outline permission agreed.

This proposal is for a site too small in size for allocation through the Local Plan. If the applicant feels that it should be developed then the proposal could be tested through the planning application process.

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Paragraph 8.3

8.99 PO297 Paragraph 8.3

The following sentence; “The popular village centre is home to numerous local shops, pubs and restaurants but the streetscape would benefit from environmental improvements. There are also opportunities to improve the village green, local parks and footpaths” , is misleading. The village has 9 shops and one pub/restaurant.

Agreed. “The popular village centre is home to numerous a number of local shops, pubs and restaurants including a popular pub/restaurant…”


There is not a great range of shops within Goffs Oak

The Planning System cannot control the range of shops provided within a centre.

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Policy GO1: Goffs Oak Village Improvement Plan

8.101 PO297, PO296, PO1004, PO333,

Policy GO1: Goffs Oak Village Improvement Plan

The community should be involved and consulted.

During the preparation of the Goffs Oak Village Improvement Plan, the Council will seek to involve the community at the earliest possible stage. The involvement of communities and stakeholders in the preparation of planning policy documents is outlined in the Councils Statement of Community Involvement (SCI)

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8.102 PO1004 Policy GO1: Goffs Oak Village Improvement Plan

Flower beds and wooden benches should be provided in the centre of the village. Improvements to the grass verge should be made through the planting of additional scrubs and plants.

Opportunities to improve the public realm within Goffs Oak will be explored further through the preparation of the Goffs Oak Village Improvement Plan.

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Concern that the proposed development and the Village Improvement Plan will change the fabric of the village. This, coupled with the increase in traffic volume will result in none of the vestiges of the quiet, attractive village centre to

The Village has changed and will continue to change over the forthcoming Plan period. The Council, through the implementation of the Village Plan will seek to ensure that the distinct character of the village is maintained.

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remain.


Hertfordshire County Council states that this area is well served by bus services and that any street scene and pedestrian enhancements should not be at their expense.

Noted. The Council will consult with a number of stakeholders through the preparation of the Goffs Oak Village Improvement Plan.

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The Goffs Oak Village Improvement Plan is too limited – a wider area of search should be considered with the possibility that an area action plan prepared. The Councils evidence base appears to support such a suggestion, with the Green Belt Review recommending that Hammond Street, Goffs Oak and Roselands areas are selected for further study.

An Area Action Plan is generally only suitable if major changes are proposed, such as comprehensive redevelopment. The proposals in Goffs Oak do not reach this threshold and therefore the Village Improvement Plan is considered a more appropriate approach.

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Paragraph 8.4 – North of Goffs Lane

8.106 PO146 Concern that too many houses are being built. A more appropriate location for housing within the Borough would be located next to the main roads i.e. A10.

Selection of sites is based on a range of planning considerations. The rationale and justification for the selected sites is set out in the Borough-Wide Options and Scenarios Report (April 2016) and four Development Options Reports (April 2016), on the Council’s website at www.broxbourne.gov.uk/evidencestudies. The Local Plan proposes significant development in close proximity to the A10 at Brookfield. However, given the scale of the Borough’s unmet need, it is not possible to accommodate all needs in this location.

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8.107 PO162, PO597, PO60, PO847, PO1537, PO1859, PO1900

The closure of the Garden Centre and the Chelsea Garden Cafe will be a great loss to Goffs Oak Village. The

The Council acknowledges that through this proposal there will inevitably be a closure of the businesses currently located on the site.

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http://www.broxbourne.gov.uk/evidencestudies


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Chelsea Garden Café is a successful business that is always busy and the Plan must consider the retention of this successful business and meeting point.

However, as detailed in Policy GO2 a business centre will be created as part of this allocation.

8.108 PO320, PO997, PO847 The closure of these businesses will not only result in people travelling further afield, therefore going against the desire from the Council for people to shop locally, but will also result in a loss of local employment and income to the Village.

As part of this allocation, the Council is proposing to create a business centre that may accommodate a new café in addition to other related uses.

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8.109 PO822, PO834, PO25, PO847, PO835, PO1009

The proposed development is reliant upon access to the B156, which is gridlocked when there is congestion on the M25 and has traffic queuing from the Rosedale Roundabout between 7:00-9:30 in the morning. The development will add to the congestion on the B156.

To support the Plan, the Council has produced a transport strategy. During the production of the transport modelling, the Council undertook transport modelling on both the county-wide COMET model and the Councils own which enabled the Council to not only assess the impact of its proposed development, but that of its neighbouring authorities. As part of this work, the Borough’s strategic and local road network, including the B156, were modelled. This modelling work identified areas when congestion was a great concern and informed the Council’s preferred package of mitigation measures.

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8.110 PO24 The development is too large and will destroy the character of the village.

Not agreed. The proposed site allocations are in general self-contained and it is considered that they have the potential to make a positive contribution to the local area, including environmental improvements to underused land.

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8.111 PO24, PO2243 Concern that the development will At the back of the proposed development, the -


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merge Goffs Oak Village with St James.

Council has preserved a significant wedge of Green Belt. Maintaining this will prevent the coalescence of the two settlements and maintain the Green Belt edge.

8.112 PO290 The proposed development is located on Darke’s Moat in Goffs Oak, which has not been identified as being of historical significance. Darke’s Moat is of medieval origin and the site has been relatively undisturbed until recent history. The site should be preserved and there is a possibility that items of archaeological interest could be located in or around the site. Concern that English Heritage and the Royal Archaeological institute have not been informed of the proposed development and have not carried out an archaeological assessment of the site. There is also a concern over the mitigation measures that are to be implemented to preserve any items of archaeological significance and the integrity of the site.

This information has been passed to the site promoters with a request that further investigation be undertaken. This issue will be considered through a planning application. Policy HA2: Non-Designated Heritage Assets states that “The Council will engage with local communities to identify undesignated heritage assets that contribute to local distinctiveness and refer to existing information in the historic environment record. Where a proposal would adversely affect a non-designated heritage asset, regard will be had to the scale of any harm or loss and the significance of the heritage asset.”

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8.113 PO373 Concern that there will be no leisure places for residents to go to following the proposed development of InEx.

Plans for the proposed site allocation include space for incorporation of a cafe. The Council is committed to improving the range and quality of leisure facilities within the Borough during the Plan period.

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8.114 PO633, PO634 Historic England is concerned about the impact the proposed development will have upon the setting of Goffs Oak House which is a

The Council agrees that the proposed development should preserve and enhance the setting of the listed building. A planning application for the proposed allocations will

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grade II listed building and the grade II listed church in St James to the north east of the development. The proposed development should preserve and enhance the setting of this listed building. Historic England suggests that these heritage assets and the requirement to preserve and enhance their settings should be identified in paragraphs 8.4, 8.5, Policy GO2 and Policy GO3.

determined against emerging Policy HA7 which seeks to ensure that the setting of a nationally designated building is sustained and enhanced.

8.115 PO997 Concern about customer parking to visit the commercial development site along the frontage within Goffs lane

Parking requirements for the development will be considered as part of any planning application for this site, with reference made to emerging Policy TM4: Parking Standards.

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8.116 PO847 The Council should look for someone who wants to run a flower/tree nursery to go onto this site.

It is not the role of the Council to find an occupier for a site.

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8.117 PO913 Concerns about the impact construction of these properties (noise and disturbance, traffic, mess on the broads) will have on residents in close proximity to the site.


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8.118 PO1924 Thames Water comments that it does not envisage infrastructure concerns regarding the water supply capability or infrastructure concerns regarding wastewater infrastructure capability for this site.

Noted. -


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8.119 PO1416 Concerns that the action of the Council identifying Inex for development has resulted in number of shops to close, which has subsequently damaged the village.

That is not the case. The business was in administration prior to any decision to allocate the site for development.

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8.120 PO1769 Hertfordshire County Council comments that all areas of the site are within 400 metres walking distance to bus stops on Cuffley Hill, which are served by Metroline 242 and are furnished with shelters and real time information screens. Hertfordshire County Council recommend that stops at Cuffley Hill, near and opposite Ware Memorial should be upgraded to provide easy-access kerbing and bus cages as appropriate.

Noted. These points are addressed in the Broxbourne Transport Strategy.

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8.121 PO1537 The café, a market stall for fruit and vegetables, and some other small units should be retained following the development of InEx for housing.

As part of the proposed development, a business centre that could facilitate the relocation of the cafe as well as additional businesses is provided for within the plan. The Council can set the use class designation, however, are unable to influence what businesses occupy the units.

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8.122 PO1581, PO1583 The Green Belt land located to the north of In-ex, Greenleaf and Tawe Chain should not be impacted by development. A large of amount of wildlife may be found in this area. In addition, the mature trees found in this location should be preserved.

The Plan allows for this, with the open space protected as Local Green Space and Green Belt.

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8.123 PO1582 The current Green belt land stops urban sprawl

The Council considers that the development of the site will create a stronger Green Belt

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boundary around Goffs Oak Village that will last beyond the Plan period.

8.124 PO1715, PO1716, PO1718 Receivers of Brynfield Nursery and Landchain support the allocation of their site for residential development with an element of commercial use within the Plan. The site does not have any environmental constraints, with the exception of its Green Belt designation, and represents the opportunity to sensitively extend the village and maximise the use of underused land, close to all of the village’s main functions.

Noted. This is part of the proposed allocation north of Goffs Lane.

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8.125 PO1717, PO1718 Concern that the allocation in the Local Plan for a total of 80 dwellings on this site would not make efficient use of this Green Belt site. It is considered that the delivery of 126 dwellings at a proposed density of 23 dwelling per hectare across the site would make a more efficient use and is fully compatible with the local context.

The Council has undertaken a masterplanning exercise which demonstrates that the proposed level of development is appropriate given the edge of village location and the relationship to the surrounding area.

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8.126 PO1717 The inclusion of 20% starter homes and affordable dwellings is supported, subject to viability.

Note that the requirement for starter homes has been removed following a change in government policy.

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8.127 PO1717 It is proposed that the commercial building has residential units on top as the area is not considered to be a marketable office location and would ensure that there is no vacancy in the building that would detract from the

This detailed matter will be determined through the planning application process, ideally through pre-application discussions.

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wider development.

8.128 PO1717 The Public House and the adjoining properties to the south east of the site should be removed from the Green Belt.

This area is proposed to be removed from the Green Belt, as indicated on the Council’s policy map.

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8.129 PO1826 Hertfordshire County Council comment that there are no mineral or waste applications registered for this site. The site does lie within the sand and gravel belt, however the Institute of Geological Science (now BGS) data sheets show the area as ‘Sand and gravel either not potentially workable or absent.’

Noted.

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Policy GO3: South of Goffs Lane

8.130 PO321, PO2252, PO823 The development will generate more traffic on the B156 which is currently congested and gridlocked when there is congestion on the M25.

The transport strategy cannot plan on the basis of abnormal conditions, which would result in over-designing the network.

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8.131 PO375 On behalf of the owners of land which forms part of the residential development, Bidwells confirms that the client’s land is available for development. The allocation should be extended to include land to the south west of the site (behind Goffs Oak House), which is a county wildlife site. The location of the eight neutral grassland indicators are concentrated in the south and southwest corner of the proposed expansion, therefore the wildlife site designation should not be considered as a planning reason which justifies the exclusion

The Council note that the land identified within the allocation is available for development. In regards to extending the allocation, this would result in developing on wildlife site (Poyndon Farm, ref 80/020) According to Policy NEB2: Wildlife Sites, will not be permitted unless the local development needs significantly outweigh the nature conservation value of the site and the development provides appropriate avoidance/mitigation/compensation measures to offset any detriment to the

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of the northern area from the residential allocation. Planning permission for the residential development of the northern region of the proposed extension could be conditioned with a management plan for the remainder to ensure the protection of the habitat.

nature conservation interest of the site. The Council does not proposed to alter the Green Belt beyond the currently proposed boundaries.

8.132 PO633, PO634 Historic England is concerned about the impact the proposed development will have upon the setting of Goffs Oak House which is a grade II listed building and the grade II listed church in St James to the north east of the development. The proposed development should preserve and enhance the setting of this listed building. Historic England suggests that these heritage assets and the requirement to preserve and enhance their settings should be identified in paragraphs 8.4, 8.5, Policy GO2 and Policy GO3.

The existing modern development at Myles Court is located between the proposed site allocation and Goffs Oak House. The Council does not consider it necessary to repeat the heritage assets policies contained within Chapter 20. The Council agrees that the proposed development should preserve and enhance the setting of any listed buildings in close proximity of the site. Any planning application for this allocation will be determined against emerging Policy HE4 and HE6 (listing buildings and works affecting the setting of historic assets).

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8.133 PO678 Landowners of part of land allocated under Policy GO3 are supportive of the proposed development and consider the land to be highly suitable for residential development and in a good position in terms of impact the development would have on neighbours. Suggestion that the site could accommodate

Following a site visit the Council has decided to remove the field in the south-western corner of the site from the site allocation, due to the prominence of this field in the open valley landscape and consequent harm to the openness of the Green Belt, as set out in the Green Belt Topic Paper (2017). Consequently the Council Council has reassessed the capacity of the site and has concluded that the

Reduce proposed site area and number of dwellings from 45 to 30.


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approximately 50 dwellings, however the amount of land available for development could change if the option to include the current house, subject to feasibility, is carried forward.

number of dwellings proposed should reduce from 45 to around 30. The Council has also considered the potential of Lafiya House and concluded that the large garden would not be suitable for release from Green Belt.

8.134 PO1932 Thames Water comments that it does not envisage infrastructure concerns regarding the water supply capability or infrastructure concerns regarding wastewater infrastructure capability for this site.

Noted. -

8.135 PO1827 Hertfordshire County Council comment that there are no mineral or waste applications registered for this site. The site does lie within the sand and gravel belt, however the Institute of Geological Science (now BGS) data sheets show the area as ‘Sand and gravel either not potentially workable or absent.’

Noted. -

Paragraph 8.6


Expanding Woodside School onto open fields will destroy the character of Goffs Oak

Expansion of the school would entail development within the existing school grounds, and expansion of the playing fields to the east. Therefore the impact on the countryside and character of Goffs Oak is considered to be minimal. The existing Village Green will be retained.

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8.137 PO29, PO35, PO37, PO43, PO57, PO183, PO505, PO556, PO599, PO1147, PO1374, PO1473, PO1855, PO1874, PO1877

Paragraph 8.6

Expanding Woodside School will result in more traffic along Jones Road and the surrounding road network (Silver Street, the B156).

It is considered that there is sufficient scope to mitigate any increase in traffic through local junction enhancements, and perhaps the introduction of a School Safety Zone as recommended by the Broxbourne Transport

Proposed amendment to the Plan in response to this issue (see 8.139 below)


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Strategy. A Transport Assessment will accompany the school planning application in compliance with emerging Policy TM1: Sustainable Transport.

8.138 PO29,PO35, PO43, PO506, PO917, PO1147, PO1473, PO1855

Paragraph 8.6

Expanding Woodside School will worsen the parking problems

The impact that the proposed development will have on parking problems will be considered as part of any planning application for this site. Better school travel planning and encouragement of walking to school for local children are likely to form part of a solution for this area.

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8.139 PO33, PO37, PO41, PO43, PO57, PO117, PO182, PO281, PO325, PO334, PO338, PO340, PO517, PO759, PO505, PO557, PO599, PO680, PO682, PO846, PO800, PO1068, PO1146, PO1178, PO1203, PO1419, PO1465, PO1532, PO1540, PO1870, PO1874, PO1899, PO294, PO824, PO1427 PO2259 (petition)

Paragraph 8.6

Goffs Oak Community Association (GOCA) submitted a petition signed by 700 local residents objecting to any attempt to de-register the Village Green in Jones Road. The petition states: “The two fields in Jones Road are unique. They are registered under an Act of Parliament (the Commons Act) as a Town or Village Green No VG117. This gives local people full rights of access without permission at all times for legitimate sports and pastimes, including dog walking, and prohibits any building developments. We, the undersigned, strongly oppose any proposal to de-register these fields.” GOCA Covering letter The first page of the covering letter

The concerns of GOCA and the signatories to the petition, as well as other individuals who submitted feedback are noted and amendments to the emerging Local Plan proposed. The correct status of the registered Village Green is acknowledged. The importance of retaining the facility on the

Delete reference to relocation of the existing village green. Rename the proposed Newgatestreet Road open space and remove reference to a village green.


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to the petition provides background to registration of the village green in 2003. Background to the legislation including the Commons Act 1965 and the Commons Act 2006. The present village green provides easy and safe facilities to residents on the south side of the busy B156, whilst those to the north of the road have ready access to green open space behind the library. GOCA believes that expansion of Woodside School can take place within the existing land boundary of the school, with any additional expansion on land to the east. The proposed new Green at Newgatestreet Road is smaller than the existing Village Green, resulting in a net loss of open space. Schools planning has been poorly managed over the years. For example lack of schools in the Hammond Street area has caused traffic on Newgatestreet Road.

south side of the B156 is noted and agreed. A feasibility review of the option of extending the school playing fields to the east has been confirmed in discussions with Hertfordshire County Council. Given the Council’s proposals to retain the Village Green on Jones Road, the provision of any additional green space at Newgatestreet Road would result in a net increase. The proposals in the emerging Local Plan seek to address this point with the provision of a new primary school in the heart of the Rosedale Park development. Expansion of Woodside Primary School will mean that in future fewer children from Goffs Oak will need to travel to school in Cuffley.


Concern that children from outside the Borough will use the school if places are not filled, which will add to traffic problems.

Expansion of Woodside Primary School should reduce the number of local children who have to attend Cuffley School because of lack of spaces in Goffs Oak.

New section on schools and health centres to clarify this point.


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Concern over the current location of the village green; the village green is located behind the library and the playing fields between Jones Road and Silver Street are community assets that are used on a regular basis.

The registered village green is located to the east of Jones Road and north of Silver Street. The land located behind the library is designated as open space. The Local Plan proposes to increase the amount of open space through the opening up of currently inaccessible private land off Newgatestreet Road, whilst protecting the current open space.

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Concern over where the current users of the playing fields between Jones Road and Silver Street i.e. football clubs, will go once development commences.

The existing facilities will be retained as permanently accessible to the public so there will be no need for users to find another location.

See issue 8.139

8.143 PO186, PO1147 Paragraph 8.6

Concern regarding the choice to expand Woodside Primary School in comparison to other primary schools in the Borough.

Hertfordshire County Council has recommended expansion of this school on the basis of feasibility assessments and assessment of projected demand.

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8.144 PO338, PO340, PO681 Paragraph 8.6

Concern that additional land is not required for expanding Woodside School. A new school could be built on the existing grounds, similar to that at Goffs Oak school. An alternative suggestion was to build the new school towards the Silver Street side of the Village Green (common) and once finished demolish the old school and incorporate the land into what remains of the Village Green.

Expansion of the school would entail development within the existing school grounds, and expansion of the playing fields to the east rather than south as previously shown.

Amendment to Concept Diagram and Policies Map to reflect this change.


Concern regarding the ownership of Goffs Oak Village Green

The village green is currently owned by the Council and protected as a Registered Village Green.

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8.146 PO506 Paragraph The enlarging of the school will result Safety will be addressed as part of a school -


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8.6 in an increase in traffic accidents travel plan for the expanded school. The Transport Strategy recommends the creation of School Safety Zones.

8.147 PO556, PO1877 Paragraph 8.6

Expanding Woodside School will be disruptive to residents living close by.


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8.148 PO557, PO824 Paragraph 8.6

The proposed relocated Village Green is not adequate for the current users of the Village Green.

Concerns duly noted. A new public open space can be achieved at Newgatestreet Road without relocation of the village green and therefore this is not critical to achieving the objectives of the Local Plan.

See issue 8.139

8.149 PO557, PO1106, PO1146, PO1419, PO1465

Paragraph 8.6

Land to the east of Woodside School should be purchased to enable expansion and would not require the relocation of the Village Green.

Duly noted. This proposal will be carried forward.

See issue 8.139


The relocation of the Village Green will result in the loss of green space in the village.

Concerns duly noted. A new public open space can be achieved at Newgatestreet Road without relocation of the village green and therefore this is not critical to achieving the objectives of the Local Plan.

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Consideration for the provision of a new school should come prior to housing. Suggestion that land at the northern end of Newgatestreet Road would be an appropriate location for a new primary school

Hertfordshire County Council has recommended expansion of Woodside school on the basis of feasibility assessments and assessment of projected demand.

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8.152 PO800, PO1178, PO298, Paragraph The proposed new village green, Noted. Included within the emerging Policy is -


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PO1427 8.6 which is listed as 0.81 hectare, is smaller than the current village green.

the Council’s requirement for the minimum size of the new public open space to be 0.8 hectares.


Hertfordshire County Council comments that Paragraph 8.6 makes reference to the proposed relocation of village green adjacent to Woodside Primary School to the proposed site at Newgatestreet Road, which is referred to in Policy GO4. There is no policy regarding the expansion of Woodside School within this section of the Plan.

The expansion of Woodside School is included within emerging Policy INF10: New and Expanded Primary School, therefore it is not considered necessary to have a single policy for the proposed expansion. The Council will make reference to the expansion of the school in the ‘Schools and Health Centres’ section which will be added to this chapter.

Add reference to expansion of Woodside school in new section on Schools and Health facilities in this section.


Hertfordshire County Council comment that they are the landowners of the current village green and support the proposed relocation of the village green to Newgatestreet Road as this would facilitate the availability of land to enable Woodside Primary School to expand. The additional land would provide sufficient area and external play space for a 2FE primary school. Hertfordshire County Council note that this land will need to be enclosed with the playing fields made available for public use in line with a community use agreement.

Support noted. -


Hertfordshire County Council comment that it is not clear from the proposal map whether Woodside Primary School will remain within the Green Belt

Noted. The school is to remain within the Green Belt.

Amend Policies map to indicate that Woodside Primary School is to remain within the Green Belt


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8.156 PO1374, PO1855, PO1874 Paragraph 8.6

Many children travel from the Hammondstreet area to attend the two primary schools located in the residential area. Building a school in the Hammondstreet area would reduce the pressure on the two current primary schools decrease the number of journeys undertaken.

Hertfordshire County Council has recommended expansion of Woodside school on the basis of feasibility assessments and assessment of projected demand.

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The current access to Woodside School is poor. Drop-off and pick-ups must take place in the school grounds.

The access arrangements will be considered as part of any planning application for this site, with reference made to emerging Policy TM3.

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8.158 PO1473, PO1874 Paragraph 8.6

School children should be encouraged to walk to school.

The Local Cycling and Walking Infrastructure Plan sets out proposals to encourage walking to school. School travel plans are one way to encourage this. A school travel plan will be required as part of the expansion of Woodside School.

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The local infrastructure will not be able to cope with the proposed Woodside School expansion.

Not agreed. There is scope for improvements to the Jones Road/B156 junction. This, combined with school travel planning can ensure that the infrastructure can cope.

-


The expansion of Woodside Primary School will be inadequate to accommodate the education needs of the proposed development. There are no proposals for another school or college in the surrounding area.

The Council is working closely with Hertfordshire County Council to ensure that the educational needs arising from the proposed level of development can be met throughout the plan period. Hertfordshire County Council has said that the expansion of Woodside is sufficient to support the proposed developments.

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8.161 Letter submitted after consultation

Paragraph 8.6

Concern regarding the location of the village green in the proposed development

Concerns duly noted. A new public open space can be achieved at Newgatestreet Road without relocation of the village green and therefore this is not critical to achieving the

See issue 8.139


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objectives of the Local Plan.

8.162 Letter submitted after consultation

Paragraph 8.6

Concern during the construction period about loss of privacy, parking of contractors vehicles


-

Policy GO4: Newgatestreet Road

8.163 PO15, PO16, PO19 Policy GO4: Newgatestreet Road

25 dwellings is disproportionate for the size of the site and does not reflect the density of housing in St James

The Council has undertaken masterplanning to test appropriate design, layout and density. This has concluded that 25 dwellings is broadly appropriate. Goffs Oak is a more suitable basis on which to consider density at this site.

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8.164 PO15, PO16 Policy GO4: Newgatestreet Road

The dwellings will be out of character with the existing semi-detached and detached properties on Newgatestreet Road. This will ruin the village feel of Goffs Oak, in particular Newgatestreet Road.

As identified in the emerging Policy, the Council will prepare a development brief for this site. The development brief will detail the type of dwellings expected for this site and the constraints and opportunities for the site. Emerging Policy DSC1 places great emphasis on ensuring new developments are of a high standard of design and layout to reflect and promote local distinctiveness. Any planning application for this site will be determined, with reference to this policy.

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8.165 PO15, PO16, PO19, PO207, PO894

Policy GO4: Newgatestreet Road

Concern that an additional 25 dwellings will increase the traffic congestion on Newgatestreet Road. There is currently no parking

The vast majority of traffic on Newgatestreet Road is from existing development. Parking around the village centre will be addressed as part of the Goffs Oak Village Improvement

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restriction which has resulted in residents and village shoppers to park on both sides of the road, which prevents the free flow of traffic in both directions.

Plan.


The dwellings and the proposed new link road between St James Road and Newgatestreet Road will negatively impact the rural aspect of St James Road.

It is acknowledged that development in this area will result in a change in the character of the land. Careful masterplanning of the site can minimise the visual impact that the proposed development and enhance its setting within the context of the village landscape.

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The dwellings will be out of character with the existing large properties in St James hamlet. This will have a negative impact on the value of all local properties and ruin the village feel of St James hamlet

Planning applications for this site will be assessed with reference to emerging Policy DSC1, which states that all development proposals should enhance local character and distinctiveness, taking into account: existing patterns of development; significant views; urban form; building typology and details; height; roof form; fenestration detail; materials; building lines and other setbacks; trees; landscaping and features of local and historic significance. The value of a property is not an issue that can be assessed in the Local Plan process.

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Concern that the proposed village green will be a magnet for youth. This will lead to unwanted anti-social behaviour, safety risks to the local residents and increase in crime rate.

The new/additional village green will benefit from natural surveillance from surrounding new properties to deter anti-social behaviour. Fears about anti-social behaviour may be understandable but are not considered a reasonable basis for opposing provision of public open space.

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8.169 PO15, PO16 Policy GO4: Concern that the proposed Village The proposed Village Green will be created in -


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Newgatestreet Road

Green will become an eyesore due to it not being adequately maintained by the Council.

compliance with emerging Policy ORC1, which states that the arrangements for the maintenance and on-going management of open spaces and playgrounds must be clearly documented in the planning application.

8.170 PO15, PO16, PO19 Policy GO4: Newgatestreet Road

The 25 dwellings should be distributed onto other sides identified in Goffs Oak

The proposed dwellings on this site will act as enabling development for the new public open space.

-


The Village Green should not be created.

Not agreed. The intention is to create an additional public open space to serve the northern side of the village, which is currently remote from the designated village green on Jones Road.

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8.172 PO19 Policy GO4: Newgatestreet Road

The proposed development will not keep St James as a separate area. St James will already have housing backing onto it as part of the development proposed at Goffs Lane.

As part of the Plan, the Council has designated a number of open spaces around St James which are to be kept permanently free from development. This will prevent the coalescence of St James and Goffs Oak village

-


The proposed option for 145 houses along Newgatestreet Road will spoil the rural feel and open outlook of the Village.

This comment refers to development options contained within the ‘Goffs Oak Development Options Report’, an evidence base study used to inform the preparation of the draft Local Plan. Not all sites included within this document were taken forward into the draft Local Plan. Therefore this comment is misinformed.

-


Concern the development is only planned to create a boundary to the proposed Village Green, which will be unusable for half of the village residents.

The other half will be able to use the existing village green on Jones Road, which will be retained in its current state.

-


Object to the omission of CG-GB-31 (Oak House Farm) from the Plan. The site can accommodate 20-30

The Council has recently completed an update on its Strategic Land Availability Assessment (SLAA). As part of this update, all sites

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dwellings, with the only constraint listed in the SLAA being Green Belt. Possible problems of access are mentioned but Newgatestreet Road is a wide and straight thoroughfare which has the capacity to absorb additional traffic. The allocation of GO4 strengthens the case for additional allocations of land for housing along Newgatestreet Road

included within the previous SLAA (April 2016) and those promoted to the Council during the 2016 Call for Sites were assessed. The SLAA concluded that the site (CG-GB-31) performs a strategic role in preventing the coalescence of Goffs Oak with Hammondstreet.


An additional policy, GO6, which includes CG-GB-31 (Oak House Farm) and additional sites, should be included within the plan which proposes the preparation of a strategy for the area of West Cheshunt. The policy would set out proposals for development along Newgatestreet Road. CG-GB-31 could be considered offered for public recreational purposes in the overall strategy for the area if the site is not deemed to be suitable for residential development.

The area north of Goffs Oak was considered for allocation and discounted due to its remoteness from services and facilities and challenges around creation of unsustainable patterns of development. This is set out in the Borough-Wide Options and Scenarios Report, April 2016.

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The site owners are supportive of part of their landholdings being identified in Policy GO4. Confirm that the site is available and deliverable for development. Comment that the site is in a sustainable location for residential development and suitable location for a village green to serve the residents of Goffs Oak.

Noted. -


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The development of a village green at GO4 will facilitate the expansion of Woodside Primary School and meet an identified deficit in public open space. The landowners confirm that should the development of a new village green not be accompanied by residential allocation they would not support provision of a new public open space on their site.

Noted. -


The illustrative masterplan for the site shows that it is capable of accommodating 32 dwellings, which is in excess of the 25 dwellings included within the Policy.

The Council considers that the increase of the proposed capacity at this site to 32 dwellings will be an overdevelopment of this site as it will appear too dense in comparison to the context. The proposed capacity of this site for 25 dwellings has been based on the density of the surrounding area.

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Thames Water comments that it does not envisage infrastructure concerns regarding the water supply capability or infrastructure concerns regarding wastewater infrastructure capability for this site.

Noted. -


The proposed development of 25 dwellings is an unnecessary rebranding of the Green Belt. There are a number of brown field and semi-industrial alternative sites in the area and any proposed development on clean Green Belt land should be avoided.

Alternative brownfield sites have been carefully considered through the preparation of the Strategic Land Availability Assessment. Given the level of need, which significantly exceeds the availability of brownfield sites, it is considered that there are exceptional circumstances necessary to justify release of Green Belt, as set out in the Green Belt Topic Paper.

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8.182 PO1681, PO1682 Policy GO4: Newgatestr

Concern that the further opportunities the site offers, which

The Council has carefully considered options for expansion to the east. However, it was

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eet Road can boost the housing provision in Goffs Oak and provide a bigger village green, are not being utilised. The Council should extend the allocation to include the wider site: the land currently allocated for development should be for residential development of up to 70 dwellings, with a new Village Green created within Green Belt to the east.

considered that any benefits would be significantly outweighed by the harm to the fragile Green Belt gap, as set out in the Green Belt Topic Paper (2017). Therefore no change to the proposed site allocations is proposed.


Hertfordshire County Council comment that there are no mineral or waste applications registered for this site. The site does lie within the sand and gravel belt, however the Institute of Geological Science (now BGS) data sheets show the area as ‘Sand and gravel either not potentially workable or absent.’

Noted.

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North of Cuffley Hill

8.184 PO837, PO34, PO47, PO165, PO204, PO336, PIO825, PO601, PO850, PO1179, PO1150, PO1347, PO1541

Policy GO5: Cuffley Hill

The road infrastructure is unable to cope with current traffic. The development will result in additional traffic on the B156 which is currently congested and gridlocked when there is congestion on the M25. There is no ability to add additional road capacity for this area.

To support the emerging Plan, the Council has prepared a Transport Strategy. During the production of this transport strategy, the Council undertook modelling using both the county-wide COMET model and its own model (the Broxbourne Transport Model) to assess the impact that the proposed development would have on the strategic and local road network, including the B156. The modelling suggests that the B156 will be able to cope with additional traffic. It is not possible to plan on the basis of abnormal conditions such as accidents or problems on the M25.

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8.185 PO46, PO170, PO309, Policy GO5: Concern regarding the impact the The proposed allocation does not impact on -


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PO377, PO603, PO850, PO1179, PO1347, PO1348, PO1344

Cuffley Hill development will have on the wildlife habitat (the woodland area) and the number of species, which includes a number of types of birds, foxes, deer, snakes, that visit/inhabit the site.

Local Wildlife Sites, Local Nature Reserves or Sites of Special Scientific Interest. An ecological survey would be required as part of a planning application in order to assess the presence of wildlife on site and any mitigation measures that may be required. In initial ecological strategy submitted by the developers has been posted to the website.

8.186 PO46, PO170, PO1179, PO1541


There are a number of trees with preservation orders on the site.

The Council is aware that the site promoters cleared a significant amount of undergrowth and self-set trees from the site during September 2016. The Council undertook an urgent survey of the site and the site owners agreed to cease all further tree works. The Council has placed a new Tree Preservation Order covering all the trees of value on the site. This has superseded the original order. The Council is in dialogue with the site promoters to ensure that an appropriate arboricultural strategy is implemented.

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8.187 PO165, PO1179, Policy GO5: Cuffley Hill

Concern regarding the access for the site. Previous planning applications submitted for this site have been refused on access grounds.

Access to the site will be considered as part of any planning application for this site, with reference being made to emerging Policy TM3.

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8.188 PO170, PO337, PO339 Policy GO5: Cuffley Hill

Concerns regarding the removal of trees and hedgerows and the impact it would have on the privacy of neighbouring properties. Hedges and trees should be retained to ensure that the neighbouring properties privacy is preserved.

A planning application(s) for this site will be assessed against emerging policy DSC1 which states that “All development proposals must: (h) avoid detrimental impacts on the amenities enjoyed by the occupiers of neighbouring properties and land, particularly in terms of daylight, sunlight, outlook and overlooking’.

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8.189 PO309 Policy GO5: Cuffley Hill

Is the proposal for self-build sites? The Council are exploring opportunities for self-build within the Borough, however it is considered that this site will not be suitable

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for self-build housing.

8.190 PO366, PO339 Policy GO5: Cuffley Hill

50 houses are in excess of what the local infrastructure can sustain. A limited number of houses i.e. 20, should be built on the land.

All developments proposed will be required to meet the infrastructure needs that arise from the site. This can be achieved through on-site provision and through contributions to existing facilities located off-site, where appropriate.

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Trees and hedgerows should be retained to lessen the impact the development would have on the wildlife.

The Council is aware that the site promoters cleared a significant amount of undergrowth and self-set trees from the site during September 2016. The Council undertook an urgent survey of the site and the site owners agreed to cease all further tree works. The Council has placed a new Tree Preservation Order covering all the trees of value on the site. This has superseded the original order. The Council is in dialogue with the site promoters to ensure that an appropriate arboricultural strategy is implemented.

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Housing in the existing residential area is not desirable.

A number of options for alternative sites in the area were considered and discounted, as set out in the Goffs Oak Development Options Report (April 2016). Having considered all the options carefully, this location is considered preferable for development.

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The development will impact on the rural setting of the site.

The site is largely screened by trees and will therefore not affect the wider landscape, such as the Cuffley Brook valley. A significant proportion of the site is brownfield in nature.

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8.194 PO1179, PO758, PO1150, PO1179


Concern that owners of the land have paid a retaining deposit therefore the consultation process is irrelevant as it appears that this site is a ‘done deal’. The site preparatory works i.e.

It is commonplace for developers to purchase site options from the landowner if the ‘hope value’ of a site rises during the preparation of Local Plans as various technical studies are published. The Council took swift action to

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removal of trees, support this. address the issue of tree removal – see issue 8.186 above.


Thames Water comments that it does not envisage infrastructure concerns regarding the water supply capability or infrastructure concerns regarding wastewater infrastructure capability for this site. Thames Water comments that there are sewer crossings on this site which will need to be protected.

Noted. -


Concern that the development will lead to an increase in flooding due to front gardens being concreted over.

The Council’s emerging SuDS policy (W4) requires developments to incorporate SuDS schemes. These schemes will ensure that the water is held on site and returned to the environment.

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Concern that the development will result in the worsening of air pollution

Emerging policy EQ2 requires all proposals for major development to include air quality assessments as part of their proposals. These assessments will need to consider the potential impact of development on air quality at the site and immediate neighbouring areas in compliance with EU limit values or national objectives for pollutants.

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Countryside Properties (UK) Limited supports the allocation of Fairmead Nursery and Rosemead Nursery for residential development and comment that the subject site is viewed positively as it accords with the Local Plan strategy and will ensure the creation of a more robust and defensible long term boundary.

Noted -

8.199 PO1695 Policy GO5: Concern that the site is not being The Council’s masterplanning work indicates -


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Cuffley Hill used efficiently therefore Countryside Properties consider the overall number of dwellings to be provided should be increased to 65.

that around 46 units is more appropriate to the site.


Countryside Properties (UK) Limited welcomes flexibility in regards to affordable housing, but considers that if the site meets its full development potential there may be capacity to accommodate affordable housing onsite, subject to viability.

The Council’s policy position as set out in Policy H1 is that affordable housing should be provided on-site. Discussions around this would need to take place on the basis of compelling viability evidence.

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Nicholas Graham Ltd supports the allocation of the site known as CG Edwards for residential development at the proposed capacity of 20 dwellings. Supportive of the provision of affordable housing, and considers that an off-site contribution would be appropriate as identified in the Plan.

Noted. -



Noted.

-


Concern that the number of affordable and starter homes too low.

The provision of affordable housing identified within the Policy complies with emerging Policy H1, which has taken into consideration the affordable housing need identified in the Council’s Strategic Housing Market Assessment (SHMA).

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Policy GO6: Oakfield

8.204 PO4 Policy GO6: Oakfield

Addition to the homes being currently being constructed

It is no longer considered that the case for ‘exceptional circumstances’ for release from the Green Belt exists, as set out in the Green Belt Topic Paper.

Remove Oakfield from the Local Plan and retain in Green Belt.


The suggested path location leading to the proposed school is not shown.

It is understood that this connection is not feasible due to intervening landownerships

-


Concern regarding the changing development capacity of the site.

The Plan and relevant evidence base documents has identified the site as having the capacity to accommodate 8 dwellings. A recent planning application for the site was submitted for 7 dwellings.

-


The Green Belt land is part of the rural structure of the area

Agreed. The Green Belt Topic Paper sets out why the ‘exceptional circumstances’ necessary to release the site from the Green Belt do not exist.



Construction phase of the current development has resulted in major blockages on the narrow road.

As with any development, there is a temporary period of disruption during the construction phase. To help mitigate this disruption, planning conditions such as the requirement to produce a construction plan, can be implemented to minimise the impact of development.

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8.209 PO241, PO283, PO318, PO326, PO383


Planning application for the development of this site has been rejected due to it not complying with Green Belt policy. The re-tweaking of the planning application to address some technical reasons for its previous refusal should not override the decision.

Through the planning application process, it has become clear that the very special/exceptional circumstances required in Green Belt do not exist at this site. For this reason the site has been deleted from the pre-submission Local Plan.



The previously un-developed piece of land has not been identified in the Council’s evidence base as having

The site has been identified in two of the Council’s evidence base documents (The Goffs Oak Development Options Report and the

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potential for development. Strategic Land Availability Assessment), with the merits of developing this site for residential use being explored.

8.211 PO242, PO326 Policy GO6: Oakfield

The development of the site will result in the loss of Green Belt land.

Agreed. However where there are exceptional circumstances Green Belt release is permitted. In this case the exceptional circumstances do not exist.


8.212 PO242, PO243, PO819, PO831


The development will encroach into the Green Belt

Agreed. However where there are exceptional circumstances Green Belt release is permitted. In this case the exceptional circumstances do not exist.



The proposed development will have a detrimental impact on the house prices of surrounding properties due to them becoming overlooked, losing the peace and quiet they currently benefit from due to backing on to open countryside and loss of views over the open countryside.

The impact the proposed development can have on property prices is not an issues which can be considered through the plan-making process.

-


The proposed development/planning application, with the access to the footpath at the rear of Pollards Close, will cause further disruption for the residents of Doverfield due to the potential for the road to become congested with cars as part of the school run from Woodside Primary School.

Since publication of the draft Local Plan in summer 2016 it has become clear that the site does not offer the potential to provide additional access to Woodside Primary School. As set out in the Green Belt Topic Paper, further consideration suggests that the exceptional circumstances needed to release the site from Green Belt do not exist, and therefore it has been deleted from the pre-submission Local Plan.



Concern about the impact the development will have on the wildlife that is attracted to the site.

The proposed allocation does not impact on Local Wildlife Sites, Local Nature Reserves or Sites of Special Scientific Interest. Ecological survey would be required as part of a planning application in order to assess the presence of

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wildlife on site and any mitigation measures that may be required.

8.216 PO292, PO324, PO380, PO401, PO1213, PO1280, PO1285, PO519, PO480, PO482, PO483, PO927, PO1223, PO1225, PO1227, PO1229, PO1233, PO1237, PO1239, PO1241, PO1243, PO1245, PO1247, PO1254, PO1257, PO1259, PO1253, PO1250, PO1263, PO1266, PO1268, PO1270, PO1272, PO1275, PO1278, PO1282, PO1288, PO1290, PO1293, PO1295, PO1602, PO1603


Concern that the development will result in the loss of TPO trees, such as the Oak Trees present on site.

The site has been removed from the pre-submission Local Plan, and therefore there will be no impact on trees.

-


There is a clear Green Belt boundary in this location, therefore no realignment is necessary.

Agreed. Remove Oakfield from the Local Plan and retain in Green Belt.


The indicative area for the location of the residential development in the Concept Diagram is inaccurate.

Noted. Remove Oakfield from the Local Plan and retain in Green Belt.


The proposed development will have limited access

Green Belt, rather than access, is considered to be the main issue at this site.

-


The proposed development will add to the vehicle congestion currently experienced at Doverfield and the surrounding road network.

To support the emerging Plan, the Council has prepared a Transport Strategy. During the production of this transport strategy, the Council undertook modelling using both the county-wide COMET model and its own model (the Broxbourne Transport Model) to assess the impact that the proposed development would have on the strategic and local road network, including the B156. The modelling suggests that the B156 will be able to cope

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with additional traffic. It is not possible to plan on the basis of abnormal conditions such as accidents or problems on the M25.

8.221 PO380, PO401, PO1213, PO1280, PO1285, PO480, PO482, PO483, PO927, PO1223, PO1225, PO1227, PO1229, PO1233, PO1237, PO1239, PO1241, PO1243, PO1245, PO1247, PO1254, PO1257, PO1259, PO1253, PO1250, PO1263, PO1266, PO1268, PO1270, PO1272, PO1275, PO1278, PO1282, PO1288, PO1290, PO1293, PO1295, PO1602, PO1603


The proposed development will harm the openness of the adjacent Green Belt

As set out in the Green Belt Topic Paper (2017), the exceptional circumstances needed to release the site from the Green Belt through the Local Plan review are not considered to exist in this case.



The creation of the footpath connection is not reliant upon the development of 7 new homes.

Noted. Remove Oakfield from the Local Plan and retain in Green Belt.

8.223 PO380, PO383, PO401, PO1213, PO1280, PO1285, PO501, PO480, PO482, PO483, PO927, PO1223, PO1225, PO1227, PO1229, PO1233, PO1237, PO1239, PO1241, PO1243, PO1245, PO1247, PO1254, PO1257, PO1259, PO1253, PO1250, PO1263, PO1266, PO1268, PO1270, PO1272, PO1275, PO1278, PO1282, PO1288, PO1290, PO1293, PO1295, PO1602, PO1603


There are no exceptional circumstances to release this site for development, as identified in previous public enquiries.

As set out in the Green Belt Topic Paper (2017), the exceptional circumstances needed to release the site from the Green Belt through the Local Plan review are not considered to exist in this case.


8.224 PO1926 Policy GO6: Thames Water comments that it does Noted. -


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Oakfield not envisage infrastructure concerns regarding the water supply capability or infrastructure concerns regarding wastewater infrastructure capability for this site.


Hertfordshire County Council note that the proposed development of Oakfield will destroy a small area of woodland and that any loss of woodland habitat should be compensated through biodiversity offsetting.

Noted. Emerging policy NEB4 requires replacement planting if protected trees have to be removed.

-



Noted.

-


Concern regarding the accuracy of the map as it represents the plan devised for Pollards Close at the time it was built in 1969.

The proposals map has been prepared on the most up-to-date Ordnance Survey layers for the Borough.

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St James

8.228 PO18, PO208, PO820, PO832

Paragraph 8.9

Retaining the integrity of St James does not align with the extension of the travellers site, the village green proposal and Rosedale Park.

Not agreed. The proposals for new public open space as part of a Green infrastructure network will create a more permanent structure to the settlements and create a stronger sense of place. It is no longer proposed to extend the travellers site on St James’ Road.

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8.229 PO18 Paragraph St James is a busy cut-through road. It is anticipated that such usage will decline -


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8.9 with the proposals included in relation to Rosedale Park (Policy CH2) to close Andrews Lane to through-traffic, to make the road open for local access and for sustainable transport only.

8.230 PO18, PO208 Paragraph 8.9

The proposed developments will have a harmful effect on the area

The evidence base does not support this point.

-


It is important to ensure St James retains its status and does not become part of another estate.

Agreed. It is considered that the proposals set out in the Local Plan will achieve that objective.

-


Concern that there is unreasonable bias to preserving the St James Village. The impact that the proposed development will have on all areas of the village (Goffs Oak) should be viewed with equal importance.

Consideration of whether a particular location is suitable for development has been based on a wide range of planning factors, including local constraints and opportunities. The Council has attempted to apply these factors in an even-handed way in deciding which sites to allocate for development.

-


Concern that the application of a green ring around St James does not make sense in planning terms.

The proposals for a green space around St James’ complement the creation of parkland at Rosedale Park and are well supporting by the NPPF, particularly in its support for green infrastructure. The aim is to introduce a more pleasant, green setting for existing and future communities, with improved sense of place. This approach differs from much of the twentieth century development in the area, which has seen development of former glasshouse sites leading to progressive sprawl.

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Chapter 9: Hoddesdon

Issue Number

Comment ID(S)

Paragraph/Policy Number


General

9.1 PO108 Chapter 9 – Hoddesdon

Concern regarding the effect that development next to Woollens Brook, near Essex Road. This area is in a flood zone.

The Local Plan does not propose any development next to Woollens Brook. Any development that is located within a flood zone area is required to be considered against the provisions of Policy W5: Flood Risk.

-


Concern that the closure of the Spotlight Theatre and the Lowewood Museum will not improve the quality of the Borough of Broxbourne which the Council stated will be done through enhancing the four new town areas.

Any proposals to close recreational and leisure facilities are required to be considered against the provisions of Policy ORC2: Loss of Open Space, Leisure, Sport and Recreational Facilities.

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9.3 PO953, PO983, PO1095, PO1099, PO1100, PO1101, PO1097

Chapter 9 – Hoddesdon

Object to the omission of the site known as 303 Ware Road from the Plan. A number of reasons were provided for the sites inclusion within the emerging Plan as a small site housing allocation. These reasons were:

The Review of the Inner Boundary of the Metropolitan Green Belt (Prospect Planning, 2008) proposed no change to the Green Belt boundary other than in two locations, one of which is 303 Ware Road. The report found that the site does not serve the Green Belt purposes: due to being surrounded by Green Belt on all sides it does not check unrestricted sprawl; the

The Council has recently completed an update on its (SLAA). As part of this update, all sites included within the previous SLAA (April 2016) and those promoted to the Council during the 2016 Call for Sites were assessed. The Strategic Land Availability Assessment SLAA concluded that this site (HOD-GB-01) is not suitable for development due to the following reasons: the site performs a strong role against Green Belt Purposes 1 and thus merits retention, the site also performs a strongly role again Green Belt Purpose 2 in providing a barrier between the large urban area of Broxbourne and Hertford Heath and it considered that there are no strong defensible

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adjoining development is in closer proximity to the closest settlements therefore the sites development would not result in neighbouring towns merging together; removing the site from the Green Belt would create a more logical and defensible Green Belt boundary; the Green Belt does not relate to a historic town.

The development of the site allows for continued place creation, in a location recognised to be sustainable.

The site provides the opportunity for high quality design in a sustainable manner, with enhanced landscaping and biodiversity.

The removal of the site will only involve a minor realignment and will reflect the overall strategy in directing development to sustainable locations. There is a need to meet the OAN and C2 need and in providing for this site will reduce the reliance on windfalls further, or in respect of provision of C2, would assist in meeting that identified need.

The site was previously allocated for development, but was removed at second deposit

The Inspector for the 2005 Local Plan noted the sites sustainable location, the high density of the

Green Belt boundaries that would prevent further encroachment. This site was also assessed in the Council’s Green Belt Topic Paper (2017), which draws on the available evidence as well as the evidence of the emerging strategy underpinning the Local Plan to reach a balanced judgement as to whether there are specific locations where necessary exceptional circumstances exist to suggest that Green Belt should be released for development. For this site, the Topic Paper concluded that “since the Local Plan Inspector’s Report (2005), there is now a broader emphasis in national policy than housing needs in meeting ‘exceptional circumstances’ and therefore redevelopment should be pursued as permissible development in the Green Belt rather than through the Local Plan”.


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Hailey site and that the footpath which separates the site would form no more logical boundary than the northern fence/hedge of the garden to the dwelling at 303 Ware Road. The Inspector concluded that “if any Green Belt lands were needed, this site would appear to have several advantages….I consider that the site would be a logical extension to the developed area of Hoddesdon”.

9.4 PO1448, PO1444, PO1461, PO1456, PO1457, PO1463, PO1439


Object to the omission of site known as land north of Hertford Road. A number of reasons were provided for its inclusion within the emerging Local Plan as a housing allocation. These reasons were:

Hoddesdon is a sustainable location for growth and the High Leigh Garden Village allocation should be expanded to include this site.

The 2005 Local Plan Inspector concluded that “there were no material factors which needed to preclude the site from future consideration should releases of green belt be required when the Plan is reviewed (as outlined in Appendix A of the Review of the Inner Metropolitan Green Belt).

Unlike Brookfield, the site does not contain any local wildlife sites or scheduled monuments, lie within an landscape designations (landscape protection zone or AONB), is

The Council has recently completed an update on its Strategic Land Availability Assessment (SLAA). As part of this update, all sites included within the previous SLAA (April 2016) and those promoted to the Council during the 2016 Call for Sites were assessed. The SLAA concluded that this site was not considered to be suitable for residential development due to the following reasons: there are no clear Green Belt boundaries to the north of the site therefore this development could lead to encroachment within East Herts Green Belt, the development of the site will result in the loss of TPO trees and would potentially threaten the longer term protection of remaining protected trees and, it is considered that the creation of safe access for both pedestrians and cars along the B1197 would be difficult. This site was also assessed in the Council’s Green Belt Topic Paper (2017), which draws on

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adjacent to or contains a conservation area or listed building. The site is also not within a flood zone.

The site does not fulfil an important role in terms of openness of maintaining separation.

The independent assessment of the Green Belt confirmed that the site occupies a sustainable location and makes only a limited contribution to countryside character.

The site has not overriding constraints to development – it can be accessed from Hertford Road and is in single ownership.

The site can be brought forward immediately for development

The Review of the Inner Metropolitan Green Belt (Prospect Planning, 2008) recommended that “pending further work on identification of the amount of Green Belt land which will be needed to satisfy the Borough’s housing needs, it should either be identified as Reserve Housing Land and an approximate period identified as Reserve Housing Land and an approximate period identified when it would be brought forward, or safeguarded for the long term as an Area of Special Restraint (ASR)’

the available evidence as well as the evidence of the emerging strategy underpinning the Local Plan to reach a balanced judgement as to whether there are specific locations where necessary exceptional circumstances exist to suggest that Green Belt should be released for development. The Topic Paper concluded that this site has no clear demarcation line to which the Green Belt can be redrawn, that it would be difficult to integrate the site into the existing built-up area to provide additional services and facilities, the site is inaccessible in transport terms and its removal from the Green Belt could lead to the loss of a number of trees which would have an impact on the character of the wider area. Therefore, it is considered that this site does not present any exceptional circumstances necessary to justify its release from the Green Belt


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9.5 PO1457 Policy HOD5: High Leigh Garden Village

The site referred to as Land at Hertford Road should, if not allocated for development, be safeguarded for future development.

As detailed in Issue 9.4, the Council’s 2017 SLAA concluded that this site was not suitable for development and the Council’s Green Belt Topic Paper concluded that the site did not present the exceptional circumstances necessary to justify the release of Green Belt. As a result, the Council does not consider this to be an appropriate site to safeguard for future development. Furthermore, the Council’s Green Belt Topic Paper concluded that there is limited scope for Broxbourne to continue to accommodate significant new development in the Green Belt beyond the Plan period and that “on the basis of the work undertaken as part of this Local Plan review, the Council is satisfied that Green Belt boundaries will not need to be altered at the end of the development plan period”.

-


Concern that the potential policy wording and recommendations provided in the Review of the Inner Green Belt Boundary (Prospect Planning, 2008) for the site known as ‘Land North of Hertford Road’ have not been taken into consideration during the preparation of the Local Plan. The Council appear to have been selective in their approach to the application of the evidence base to inform the emerging planning policy.

The Council’s Green Belt Topic Paper (2017) drew upon available evidence as well as the evidence of the emerging strategy underpinning the Local Plan to reach a balanced judgement as to whether there are specific locations where the necessary exceptional circumstances exist to suggest that Green Belt should be released for development.

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Object to the omission of site known as ‘High Leighs Farm’, located to the west of the A10 at Hoddesdon. The site can be accessed via Lords Lane and Hertford Road and is adjacent to the Dinant Link Road roundabout. Reference is made to High Leigh Garden Village, a site on the eastern side of the A10 which has been granted outline planning permission. The promoter considers that the SHMA and its subsequent updates does not identify the borough’s full OAN, therefore the Council has not identified sufficient sites to meet its 5-year housing supply requirements. The promoter continues by stating that the Council has not identified development sites for years 6-10 or 11-15 of the Plan Period and believes that this land should be considered as suitable for allocation for housing use for the latter stages of the plan period.

The Council has recently completed an update on its Strategic Land Availability Assessment (SLAA). As part of this update, all sites included within the previous SLAA (April 2016) and those promoted to the Council during the 2016 Call for Sites were assessed. The SLAA conclude that this site (HOD-GB-17) was not suitable for residential development due to the following reasons: the site performs a strongly role against green belt purpose 1 and 3 and therefore strongly merits retention, the site is not considered to be in a sustainable location to support residential development due to it being severed from the urban area by the A10 and the development of the site would have a negative impact on an internationally designated special area of conservation (Broxbourne-Hoddesdon Woods). The SLAA also noted that a local wildlife site (Box Wood) was located within the site and as there are no exceptional circumstances in the public interest that would warrant development on the local wildlife site, the developable area would be significantly reduced.

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Greater emphasis should be placed on the tourist potential for Hoddesdon within the Local Plan. Hoddesdon and Broxbourne environs have much to offer as a tourist destination (woodland, wetlands, area of national and international significant and the Lee Valley Regional Park which has a range of leisure activities). Hoddesdon is an attractive market town offering a wide

The Council acknowledges that Hoddesdon and Broxbourne have a number of qualities and attractions that encourage visitors to the Borough. However, the Council are seeking to improve the visitor economy on a borough-wide scale, therefore do not consider it appropriate to place emphasis on tourist activities in one area.

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choice of restaurants. The town as also has good rail links to London to support the industry.

Tourism will be one of the issues that will be explored further through the review of the ‘Hoddesdon Town Centre Strategy’.

9.9 PO1494 Chapter 9 - Hoddesdon

Concern the provision of leisure facilities will not support the increase in population. Recommended that the John Warner Community Centre be expanded as part of the Local Plan.

As outlined in emerging Policy PO1, planning obligations will be used by the Council to deliver sustainable development. Planning obligations may take the form of financial contributions or actions (i.e. improvements to the highway, construction of a road/cycle path). The Council’s Infrastructure Delivery Plan (IDP) will provide the evidence required to support planning obligations through the Plan period. The Council is committed to improving the range and quality of leisure facilities within the Borough during the Plan period. The Rye Park Plan, which was adopted by the Council in November 2015, includes a number of projects which seeks to further enhance the Rye Park area. Project P of this Plan seeks to develop a business case for improvements to the John Warner Sports Centre.

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Concern about how the Council will improve the football club without compromising Barclay Park. Recommend that the football club move to the High Leigh Sports Centre, where adequate parking can be provided.

A user for the sports facilities at High Leigh is yet to be identified. In the meantime the Council will balance the needs of the sports clubs sited at Lowfield against maintaining the park on a case by case basis.

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9.11 PO1669, PO1670, PO1671, PO1672


Object to the omission of site referred to as ‘Broxbourne Landfill Site’. The promoter notes that a planning application for the development of this site has been submitted for full planning permission to create wetlands at the site, in addition to 42 homes. A number of reasons were provided for its inclusion within the emerging Local Plan as a housing allocation. These reasons were:

The promoters have carried out an assessment of Broxbourne’s housing land supply which concluded that despite the proposed release of Green Belt land and allocation of sites for housing, a shortfall in housing will exist. The development of this site will help to address this shortfall;

The site is considered to be deliverable in line with the tests of the NPPF;

The site is former landfill which is currently vacant, grade 6 agricultural land. It has little aesthetic benefits and is not accessible by the public;

The site is in a highly sustainable location and is uniquely place to provide a high quality extension to the existing built form of the surrounding area;

The 2016 SLAA concluded that the only viable uses for the site would be residential or to form an

The Council has recently completed an update on its Strategic Land Availability Assessment (SLAA). As part of this update, all sites included within the previous SLAA (April 2016) and those promoted to the Council during the 2016 Call for Sites were assessed. The SLAA concluded that this site (HOD-GB-14) was not suitable for development due to the following reasons: the Council’s Green Belt Review states that the site performs strongly against all purposes of the Green Belt and there is no opportunity to provide a stronger boundary; the Inspector from the 2005 Local Plan Inquiry stated that “Any residential development on this site would breach the primary Green Belt policy objective of retaining openness”; and, the development of this site will have a detrimental impact on the landscape of this area. Since the Local Plan consultation, the planning application (07/16/1144/F) for the creation of wetlands and 42 homes has been determined. The planning application was refused as the proposal constitutes inappropriate development in the Green Belt for which very special circumstances have not been demonstrated and the scheme, by reason of its scale and bulk, would have an unacceptable impact on the openness of this Green belt site.

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extension to the District Park. Due to Broxbourne’s weak housing supply position, housing sites are in high demand and it would therefore not be appropriate to release this site for open space;

The proposed development provides a unique opportunity for Hoddesdon to greatly enhance the ecological value of the site with associated education benefits;

The scheme at Broxbourne Landfill Site4 will be of high quality and sensitive development, in line with design criteria of the NPPF, draft Policy DSC1.


Hertfordshire County Council (Minerals and Waste) comment that for ‘Land east of Dinant Link Road’, it appears from BGS GIS layers that there are superficial deposits of sand and gravel across all but the northern part of the site. There may therefore be the opportunity to extract resources for use on the site during development should the site be allocated and be brought forward.

Noted. The Council is proposing to amend Chapter 28 to include a reference to the sand and gravel belt under the ‘Information for Applicants’ section within the text and include a map as an appendix showing the sand and gravel belt. Any proposal that falls within the sand and gravel belt are advised to contact the Hertfordshire County Council Minerals and Waste department to discuss the possibility of extracting resources for use on the site during development.

Amend information for applicants section 28 to cross-refer to the interactive local plan map.


Hertfordshire County Council (Minerals and Waste) comment that ‘Land east of Dinant Link Road’ is located in the urban area and near to ELAS161 Essex Road/Pindar Road in the adopted Waste Site Allocations Document

Noted. -


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9.14 PO1853 Chapter 9- Hoddesdon

Hertfordshire County Council (Minerals and Waste) comment that the site referred to as ‘Merck Sharpe and Dohme’ is within the sand and gravel belt and is previously developed land. There is nothing registered for this site.

Noted. -


Object to the omission of site referred to as ‘Land north of Turnford Surfacing Site’. The site a mirror image of the site that the Council has given a development brief for. The area has plenty of facilities (school, sports centre, large industrial estate, pubs, labour clubs) and the promoter intends to make a large contribution toward the bridge along with an additional 30 car parking spaces for the station.

The Council has recently completed an update on its Strategic Land Availability Assessment (SLAA). As part of this update, all sites included within the previous SLAA (April 2016) and those promoted to the Council during the 2016 Call for Sites were assessed. The SLAA concluded that this site (HOD-GB-06) was concluded to be unsuitable for development due to following reason: the site is located within Flood Zone 2 and Flood Zone 3a; the site performs strongly against Green Belt purposes; and, accessing the site is problematic – the site does not have any vehicle access and is currently landlocked between two different sites.

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9.16 PO2088, PO2094,


Object to the omission of site referred to as ‘Oaklands’.

The Oaklands site was granted conditional planning permission (07/14/0026/F) on the 29/01/2015. This planning permission has not yet lapsed. As identified in the National Planning Policy Framework, sites that have planning permission should be considered deliverable until permission expires. Due to the site not being at a strategic scale, the Council considers that it will not benefit from

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having a policy within the Plan. The site is to be included on the Council’s Brownfield Register which is a mechanism which can be used to ensure the delivery of this site.

Paragraph 9.1


Historic England welcomes the reference to the historic assets within the market town of Hoddesdon including the conservation area in paragraphs 9.1 and 9.2. Mention could also be made of the high concentration of listed buildings.

Paragraph 9.1 provides a geographic context of the Hoddesdon settlement rather than a detailed list of features. The existing reference to the conservation area provides an adequate sense of the historic environment for these purposes.

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Policy HOD1: Hoddesdon Town Centre

9.18 PO636 Policy HOD1: Hoddesdon Town Centre

Historic England suggests that the words ‘historic buildings’ and ‘historic character’ should be replaced with the words ‘historic environment’. This is the preferred term because it includes tangible historic assets such as listed buildings, archaeology etc. but also the less tangible elements such as cultural heritage and setting.

Noted. The term ‘historic assets’ will be replaced with ‘historic environments’. However duplication of the phrase would be repetitive therefore the change will only be made in relation to ‘historic character’.

Change ‘historic character’ to ‘the historic environment’ in part 6 of the policy.


Historic England request that the policy and its supporting text include a reference that the gateway development at and around Scania House at the northern end of the High Street will preserve and enhance the grade II* listed Church of St Paul.

The Council agrees that the proposed development should preserve and enhance the setting of the listed building. However, it does not consider it to be necessary to repeat the policies contained within the Plan’s ‘Heritage Assets’ chapter (29). It is considered that information regarding the gateway development and its preservation and enhancement of the grade II* listed Church of St Paul will be included the next iteration of the Council’s Hoddesdon Town Centre Strategy. This strategy will be a material consideration when

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determining any planning application for the development of this site.


Hertfordshire County Council (Public Health Service) recommend that Policy HOD1 rewords priority 4 to place emphasis on access to the town centre by sustainable and active travel

Agreed. The Council’s Transport Strategy which accompanies the Local Plan seeks to encourage as many journeys by bus, rail, walking and cycling so people have a safe, viable and attractive alternative to driving. The Council has prepared a Local Cycling and Walking Infrastructure Plan which details the current barriers to these modes of transport and proposes a range of physical and behavioural measures which are designed to encourage a shift in attitudes to walking and cycling. Section 6b of the Strategy details improvements to the walking and cycling infrastructure within the borough’s town/district centres.

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The Hoddesdon Society states that the Council should exercise its planning powers to ensure that is remains visually attractive. The Council should ensure that shop signage is in keeping with an historic market town and that owners of unsightly premises maintain their cleanliness and tidiness.

As identified in emerging policy HOD1: Hoddesdon Town Centre, the review of the Hoddesdon Town Centre Strategy will prioritise the protection and enhancement of historic character. Policy DSC8 covers shopfronts and fascias.

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The Hoddesdon Society comment that the recent flat development is of good quality and that the Council should insist that this is the case in the future.

Noted. Policy DSC1 seeks to ensure that all development within the borough is of a high standard of design and layout to reflect and promote local distinctiveness.

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The Hoddesdon Society comments that they would like to participate in the review of the 2010 Hoddesdon Town Centre Strategy.

It is anticipated that the Hoddesdon Society will be a key stakeholder in the production of the Town Centre Strategy.

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The Hoddesdon Society comments that there are pleased that the Council intend to enhance the natural, historic and built environment.

Noted. -


The Hoddesdon Society comments that Lowewood Museum is central in ensuring that knowledge of our heritage is safeguarded and improved. Lowewood acts as a community hub and centre of stability and identity for the increasing population. Planning contributions and additional community charges from new development should support such public facilities.

As outlined in emerging Policy PO1: Planning Obligations will be used by the Council to deliver sustainable development. Planning obligations may take the form of financial contributions or actions (i.e. improvements to the highway, construction of a road/cycle path). The Council’s Infrastructure Delivery Plan (IDP) will provide the evidence required to support planning obligations through the Plan period.

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The Hoddesdon Society support the improvements to Scania House area to enhance to the town

Support noted -

Paragraph 9.3


Concern that the plan has not mentioned the highly questionable and unethical building of houses on the Pound Close park. This area was given to the people for recreational purposes

The small development at Pound Close was to fund the new community centre and improvements to the recreational amenities. It is not appropriate to detail past developments in the Local Plan.

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Concern that the Council has not fulfilled its aims in regards to Pound Close Park

The small development at Pound Close was to fund the new community centre and improvements to the recreational amenities. It is not appropriate to detail past developments in the Local Plan.

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Paragraph 9.4


The site is currently an eye-sore and development of the site for housing is supported. There is the concern that the opportunity for leisure/restaurant use on the river front has not been explored.

Support noted. Through preparing the ‘Turnford Surfacing Site Development Brief’ a number of different development options were explored by the Council.

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Policy HOD2: Turnford Surfacing Site

9.30 PO638 Policy HOD2: Turnford Surfacing Site

Historic England note that the proposals for the redevelopment of the Turnford Surfacing Site are in accordance with the Development Brief. Given the close proximity of the site to the grade I listed Rye House gatehouse, and other listed buildings/structures as part of the Rye House moated enclosure and gatehouse scheduled monument, Historic England have particular concern about the impact of the proposed development on the settings of the Scheduled Monument and listed building structures. Historic England request that the need to protect and enhance the settings of Scheduled Monument and Listings should be referred to in paragraph 9.4 and Policy HOD2.

The Council agrees that the proposed development should preserve and enhance the setting of the listed buildings and scheduled monuments. However, it does not consider it to be necessary to repeat the policies contained within the Plan’s ‘Historic Environment chapter (29).

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9.31 PO439 HOD2: Turnford Surfacing Site

The Kings Arm and Cheshunt Angling Society request that access be provided to the towpath from the car park as part of this development, as lack of parking nearby has resulted in the decrease of use of area for angling.

Access to the towpath is addressed in the development brief.

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The Lee Valley Regional Park Authority notes the designation of land within the Park at the Turnford Surfacing Site for residential development and that the Council seeks this site’s redevelopment in accordance with the development brief produced in 2011. The Authority raised strong objections to this development brief in 2011.

Noted -

9.33 PO2072 HOD2: Turnford

The Lee Valley Regional Park Authority note that in drawing up PDF Area Proposals, a

Agreed that the current development brief should be revisited.

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Surfacing Site

Member Panel considered this site in detail. It was agreed that enabling some development on this site in order to mitigate the current problems could be beneficial. Draft proposals for the site seek to demonstrate how this area might be brought back into a Park compatible use. The Authority’s draft proposals state “The preferred location for a visitor hub would be adjacent to the River Lee Navigation, close to Rye House station on the ex Turnford Surfacing site to bring this important waterside site back into a Park compatible use”. The draft proposals state that high quality sustainable design will be sought for new visitor development proposals in this area that respond to the site’s waterside location, adjacent to Scheduled Ancient Monument and related heritage assets, its ecological potential and its proximity to protected sites of national and international significance. The draft proposals also state that pedestrian accessibility should be improved with a widening of the towpath and enhanced links through to Rye House Station and the relationship with the RSPB Rye Meads reserve enhanced with new interpretation and signage along the Toll Road. The Authority are mindful that the above proposals have not been subject to any viability work and this will be needed, as stated in the proposals, to test what is


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possible at this location.


The Lee Valley Regional Park Authority note that the current owners of the site made strong objections to the Authority’s draft proposals during the PDF consultation. Residential development has not yet come forward on this site. The Authority state that a solution is needed that brings forward development on this site that will benefit the wider area and made a positive contribution to the Park.

Agreed that the existing brief should be revisited.

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The Lee Valley Regional Park Authority note that in their response to the PDF Area Proposal consultation last year the Council suggested that there might be potential to scope out what might be “possible and deliverable to meet the aspirations of both authorities” and that this might include a mixed use scheme with the inclusion of commuter parking and some housing. The Authority comment that revisions to the existing brief would be helpful in this respect and seeks an amendment to Policy HOD2 to consider revising or updating the Development Brief to achieve a mixed use scheme which achieves visitor, environmental and ecological benefits for the Park.

Agreed that the existing brief should be revisited.

Amend policy to review to an updated development brief.


Hertfordshire County Council anticipate that the need arising for primary school places from the two sites included in Polices HOD2 and HOD3 can be met through the expansion of existing primary schools in Hoddesdon.

Noted. -


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The Environment Agency comments that the Turnford Surfacing site is a potentially difficult site as it falls completely within the floodplain. Careful consideration will be needed to match the land use to the level of flood risk including an appropriate allowance for climate change. The Council should ensure an 8m buffer strip and habitat enhancements.

The Council acknowledges that this site is located within the floodplain, and as required in the National Planning Policy Framework that an Exception Test was carried out. The Exception Test concluded that the site has wider sustainability benefits to the community the outweigh the risk of flooding and that the Council is “confident that the site can be safely development without making flood risk elsewhere worse”. The Council’s adopted development brief for the Turnford Surfacing Site states that “An 8 metre buffer strip shall be provided on the eastern side of the development to ensure adequate access for routine and emergency maintenance as well as to preserve flood flow route and enhance biodiversity”.

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The Environment Agency note that the site is adjacent to Rye Meads SSSI. There should be no disturbance/impact to this as result of any developed.

Agreed. Any application for the development of this site will be assessed against the provisions in Policy NEB1.

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Paragraph 9.5


Given the proximity of the grade I listed Rye House gatehouse as part of the Rye House moated enclosure and gatehouse Scheduled Monument , Historic England highlight the need to protect and enhance the settings of the Scheduled Monument and Listings and request that this should be mentioned in paragraph 9.5

Noted. However, in light of the conclusion reached as part of the 2017 Strategic Land Availability Assessment (SLAA) (HOD-U-31(a) and HOD-U-31(b)) the Council no longer consider it to be appropriate to pursue the redevelopment of industrial premises within Plumpton Road for housing.

Paragraph 9.5 There has been interest in redeveloping premises within the small industrial area at Plumpton Road for housing. The Council is not seeking to pursue comprehensive redevelopment of this area as at Delamare Road but is open


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to the potential to redevelop this area in similar ashion to the B3 Living Development at Salisbury Road. Policy HOD3: Rye Park The Council will continue to implement the Rye Park Plan. The opportunity to redevelop industrial premises within Plumpton Road for housing will be pursued.

Policy HOD3: Rye Park

9.40 PO1010 Policy HOD3: Rye Park

B3 Living comment that the weak bridge at Rye House and Rye Road being so narrow and congested with cars makes the Plumpton Road area fundamentally unsuitable for on-going commercial use.

The Council acknowledges that there are issues with the bridge at Rye House and Rye Road. The Council are formulation a scheme


Hertfordshire County Council anticipate that the need arising from primary school places from the two sites included in Policies HOD2 and HOD3 can be met through the expansion of existing primary schools in Hoddesdon.

Noted. The expansion of primary schools within Hoddesdon are detailed in Policy INF10: New and Expanded Primary Schools

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Hertfordshire County Council (Minerals and Waste) note that the Plumpton Road site is within the sand and gravel belt and is previously developed land. It is partially covered by planning application E/0005-56 which was permitted for extraction in 1956

Noted. -

Paragraph 9.8


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Concern regarding the increase in lorry movements due the serving of the proposed new retail units and the Rye House Energy Recovery Facility Complex in Hoddesdon which has permission for 76 lorry movements a day. All of this adds up to diesel pollution, traffic congestion, unsuitable roads and a major cumulative effect on the residents and communities of Broxbourne

The Rye House Energy Recovery Unit is not proposed by the Local Plan and is opposed by Broxbourne Council which is also concerned about increase in lorry movements.

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It is noted that the proposed location for Hertfordshire’s prospective new energy recovery facility is at Ratty’s Lane

Noted -


Hertfordshire County Council, as Waste Disposal Authority (WDA), notes that the proposed Energy Recovery Facility at Ratty’s Lane has been referenced in paragraph 9.8. It should be noted that this facility is designed to meet R1 “recovery” status and would be Combined Heat and Power “ready”. As Ratty’s Lane is within an Employment Land Area of Search, it should be noted that the waste uses acceptable within these areas.

This would be superfluous detail for the Local Plan. The County Council’s Waste Core Strategy excludes the Ratty’s Lane site from the Areas of Search to be considered for an ERF.

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The Hoddesdon Society are concerned that Hertfordshire County Council’s proposals for Hoddesdon to become a massive waste processing centre run counter to the Council’s objectives for the area. The pollutants will have medical implications and traffic congestion will have harmful socio-economic effects on the town.

Noted -


Support the employment allocation in respect of the subject site at Ratty’s lane and

Noted -


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the incorporation of the site within Hoddesdon Business Park. The developers states that they are developing contemporary, high quality energy facility which will serve as a benchmark for further economic regeneration in the Hoddesdon Business Park and the wider borough.


The SEF fully accords with the National Planning Policy Framework in that it delivers critical renewable energy infrastructure which supports the Government’s objective for a low carbon future.

Noted -

9.49 PO1698, PO1701

Paragraph 9.8

The developer comments that the site comprising the sustainable energy facility (SEF) at Ratty’s Lane, is also designated as a local wildlife site. The developer states that it is questionable whether the site meets the criteria for a local wildlife site. Firstly, the site has been developed out in accordance with the planning consent, with significant built form and therefore it is not reasonable to include these buildings and structures within the local wildlife designation. In this regard, at the very least the extent of the local wildlife site designation should be reduced to exclude the building footprint and hardstanding area. Secondly, it is noted that this is one of only two Local Wildlife sites within employment allocations in the Borough, which highlights that the Local Wildlife Site designation is incompatible with the local planning authority’s overall vision for these employment areas.

The planning permission for the development is cognisant of the Local Wildlife Site designation and therefore continues to protect that site. The agreed boundary was amended following the publication 2005 Local Plan but this amendment was not shown on the draft Local Plan policies map (summer 2016). The amendment will be made to the pre-submission Local Plan policies map.

Amend policies map boundaries of wildlife site 72/009.

9.50 PO1701 Paragraph The developer notes that the primary The intention to develop the Local Wildlife Site -


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9.8 purpose of the local wildlife site designation relates to the receptor site for the Great Crested Newts (GCN). The developer states that ecologists have been monitoring the site and have identified that the site does not benefit from necessary characteristics required to provide a permanent benefit from necessary characteristics required to provide a permanent home to maintain a population of GCN. The site is of limited value for GCNs mainly due to the proximity of existing development. The developer notes that the GCN population will not cross the river as this is a barrier, which has resulted in a small population of newts on the site which are in decline due to the unsuitable habitat. The developer states that the ideal permanent home for the GCNs is generally a complex of ponds surrounded by good foraging habitats with migration routes out into the wider countryside, which will provide access to more ponds in a wider landscape. This will maintain the population at a favourable level and provide the necessary conditions for the species to expand. The developer states that in light of the above, it is considered that in the long term this site is not a suitable location for the GCN population. Therefore, it is considered that the undeveloped part of the site will come forward for development to make a positive contribution towards the

is noted. However, the Council and the Herts and Middlesex Wildlife trust do not have sufficient evidence or a mitigation strategy to consider de-designation. It is considered that any such proposal is best pursued outside the local planning process and ultimately through the submission of a planning application with a detailed evidence base and an appropriate mitigation strategy. Should the Council with the advice of the Herts and Middlesex Wildlife Trust then be persuaded that it is right in principle to develop the with appropriate mitigation that would be material to the consideration of a planning application.


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Hoddesdon Business Park and would be the most appropriate and sustainable use of the site.


Hertfordshire County Council (Minerals and Waste) comment that the site referred to as ‘Land at Ratty’s Lane’ is covered by a permitted County Matter application (7/0510-00) for a sustainable energy facility including an advanced thermal treatment facility. A subsequent application was permitted (7/07029-13) in March 2014 to revise the layout and design of the approved anaerobic digestion facility element which is being constructed. The site is a safeguarded waste facility by HCC.

Noted. -

Policy HOD4: Hoddesdon Business Park

9.52 PO105 Policy HOD4: Hoddesdon Business Park

Concern regarding building on the land next to new Essex Road. The site is a flood area, home to wildlife and acts as a wildlife corridor, vital habitat and sanctuary.

The site is subject to an adopted development brief ‘Essex Road Gateway Development Brief’. The development brief acknowledges the environmental constraints of the site, including flood risk, Any development that is located within a flood zone area is required to be considered against the provisions of Policy W5: Flood Risk. The site is not designated as a wildlife site The Essex Road gateway development has an adopted development brief.

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9.53 PO106 Policy HOD4: Hoddesdon

There is no point building a business hub on land next to new Essex Road as it will be

The Council is considered the development options for this site.


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Business Park unoccupied like many of the offices and buildings around the Hoddesdon industrial area.

The ‘Essex Road Gateway Development Brief’


Kings Arms and Cheshunt Angling Society request the access to the towpath be provided within this as current restricted access route via Ratty’s Lane has resulted in decreased use by anglers and other towpath/canal users.

The Council proposes to include a new objective on health and wellbeing within the next iteration of the Local Plan. Through this objective, improving the access to both water sports and land sports will be explored.


The Canal & River Trust note that an early review of the plan for this site is proposed. The existing plan makes no reference to the Canal & River Trust, who own and manage the River Lee Navigation and its towpath, which lies directly alongside the site, and will be significantly impacted upon by the Energy Recovery Facility currently being proposed. The Canal & River Trust states that the plan should be consistent with the draft Local Plan’s policy NEB2, which requires that the landscape value of green infrastructure be protected and enhanced through new developments


Concern regarding heavy traffic access to this area. Essex Road is narrow and not well suited to the levels of HGV traffic.

The Hoddesdon Business Park Improvement Plan


The LEP supports this policy. Support noted. -


Hertfordshire County Council notes that the Waste Site Allocations document includes two designated Employment Land Areas of Search within the borough of Broxbourne: ELAS160 Eleanor Cross Road in Waltham

Support noted. -


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Cross and ELAS161: Pindar Road in Hoddesdon. The County Council supports the inclusion of these ELAS within the proposed Hoddesdon Business Park and Waltham Cross Business Park employment designations. Hertfordshire County Council states that waste uses are acceptable within employment land areas.


The Hoddesdon Society comments that the access road is inadequate and improvements to The Sun Roundabout and Essex Road area are necessary.

Funding has been secured to improve access to Essex Road and the Sun Roundabout, as set out in the Transport Strategy.

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The Hoddesdon Society raises concern regarding the effects of the proposed High Leigh dumbbell roundabout on traffic flow.

This site has planning permission. -


The Hoddesdon Society states that there appear to be no concrete proposals for improvements to sustainable transport links to the business park.

When the new Essex Road bridge is implemented, it is anticipated that the existing alignment of Essex Road will be a footpath and cycleway.

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The developer for the sustainable energy facility at Ratty’s Lane quoted a number of documents that form part of the Local Plan Evidence base to support their development. These included:

The Broxbourne Borough Local Plan Employment Land Study (July 2016) – the employment land study report identified two main reservoirs of employment land located at Hoddesdon Business Park , and the Britannia Lea Road and Lea Road Industrial Estate. The report states that Hoddesdon and Hertford Road and Waltham Cross/Lea Road

Noted.


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are then borough’s most important employment sub-areas. The study states that the Hoddesdon Business Park forms a large and coherent tract of industrial land serving the north of the borough, which also contains wider industrial uses such as waste management, utilities/power generation and railway depot and servicing. Areas.

Hoddesdon Business Park Improvement Plan (2013) – The main strategy is to continue the success of the business park by limiting impediments and re-developing parts of the park to create more jobs when opportunities arise. The subject site is located within Ratty’s Lane campus which comprises 20 hectares of land. The Plan notes that the sustainable energy facility at Ratty’s Lane, which will employ 30 staff once operational, may support the re-branding of this area as an Energy campus. The Plan seeks to extend the boundary of the Business Park to include the subject site and states: “The Council proposed to extend the designated boundary of Hoddesdon Business Park to incorporate the approved development proposal for a sustainable energy facility in Ratty’s


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L:ane…This will be taken forward through the Broxbourne Local Plan which is currently being prepared”.

Local Plan Sustainability Appraisal Scoping Report (Lepus 2013) - The Sustainability Appraisal highlights that in comparison with regional averages, recycling rates in Broxbourne are unfavourable and states that the Local Plan should encourage continued improvements in waste reduction and disposal management.


The developer states that the subject site is allocated for employment use in the Proposals Map which accompanies the draft Local Plan. The developer notes that the Policy ED2: Loss of Employment Uses – Rest of the Borough – relates to the subject site. The developer supports the employment allocation and considers it to be wholly appropriate in light of planning consent which has been implemented for the SEF subject site.

Noted


The developer states that the site is on the eastern boundary of the Hoddesdon Business Park, which Policy HOD4 relates to. As detailed above, the Business Improvement Park acknowledges the role of the subject site and the delivery of the energy facility with the potential to rebrand this area an Energy campus.

Noted -

9.65 PO1851 Policy HOD4: Hoddesdon

Hertfordshire County Council (Waste and Minerals) comment that Hoddesdon

Noted -


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Business Park Business park is formed of three parcels of land. The site is previously developed land in the sand and gravel belt. Part of the site to the west of the railway line is designated as Employment Land Area of Search in the Waste Site Allocations document, adopted July 2014. The Hoddesdon Household Waste Recycling Centre located within the ELAS. This is a safeguarded waste facility by HCC. In addition to a check of the waste planning history shows that this parcel of land contains three records of waste applications, one at Global house, Geddings Road (7/0612-06), which was permitted in 2006 and another at Bingley Road (7/0296-05), which was refused in 2005.With regards to mineral applications this parcel of land contains a record at Dobbs Weir (E/1394-65) for the extraction of sand and gravel permitted in 1966. Hertfordshire County Council (Waste and Minerals) note that within the smaller of the three parcels of land that form this site allocation, there is a metal waste transfer station and end of vehicle facility on Land at Bridge Works, Rye Park Industrial Estate. This is a safeguarded waste facility by HCC. Within the parcel of land to the east of the railway line that forms this site allocation, it should be noted that whilst Land at Ratty’s Lane is not covered by this employment allocation, the access to the sustainable


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energy facility including an advanced thermal treatment facility, which is a safeguarded facility by HCC, is located within the employment land allocation. The Rye House rail aggregate depot is also located within the employment allocation on land to the east of the railway line. This facility is safeguarded by HCC under the Minerals Local Plan, adopted March 2007. TES oil and water plant, Essex Road, a hazardous waste transfer station is located within this part of the site and is a safeguarded waste facility. Froom & Co Ltd waste transfer station and chemical treatment facility, Essex Road is also an operational waste facility which is safeguarded by HCC. There a number of County Matter applications that falls within the area to the south of this employment designated site. Charlton Mead Lane has record of three applications. Application 7/0641-96 was refused in 1998 for a waste facility, application 7/0449-97 was permitted in 1998 for a waste facility and 7/0232-99 was permitted in 1999 for a waste facility. Part of application E/0247-48 covers the site at Dobbs Weir which was permitted for extraction of sand and gravel. At the same site two further applications at the larger Dobbs Weird site fall entirely within the employment designation. These are E/1201-56 and 7/1021-80 which were permitted for the extraction of sand and gravel.


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Paragraph 9.9

9.66 PO939 Paragraph 9.9 Concern that the final sentence of paragraph 9.9 appears to suggest that the outer limit of development has been established by the High Leigh permission and the granting of planning permission for 14 dwellings north of Kennedy Avenue. It is not considered to be appropriate to preclude the possibility of sometime in the future and beyond this current Local Plan review looking at further development to the south which would still retain development east of the A10(T). It is recommended that Paragraph 9.9 is amended to rear: “It is framed by a network of open spaces and habitats and is subject to a comprehensive package of planning obligations that will help to create a truly sustainable community. The High Leigh planning permission and a subsequent planning permission for 14 new homes to the north of Kennedy Avenue has established the outer limits of development within the plan period in the western part of Hoddesdon”

Comments noted. However, it is not proposed to amend the wording. Areas outside these boundaries are protected by Green Belt which by its nature is intended to be permanent.

-

Policy HOD5: High Leigh Garden Village


Concern that the development is taking place on Green Belt land.

The Council has tried to utilise all brownfield land as far as possible, however, these sites cannot accommodate the entirety of the borough’s identified development. Development of Green Belt land is therefore necessary to meet the borough’s identified development need. The adoption of a strategy where no Green Belt land was built on would

No amendment to the Plan in response to this issue.


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result in a severe undersupply of housing and long-term stagnation of the borough.


Concern that the development will spoil the area and cause habitat destruction for the wildlife.

High Leigh Garden Village has been granted outline planning permission. As part of the permission the Council attached the following conditions to ensure the biodiversity value of the site was protected and enhanced:

A requirement that a Strategic Wildlife and Habitat Mitigation and Enhancement Strategy to be submitted for approval prior to the commencement of site clearance on the first residential development zone.

Detailed Wildlife and Habitat Implementation Plan for each development phase (where relevant). The strategy should include: a) a programme of updating relevant protected species surveys; b) measures to comply with wildlife legislation afforded to protected species, including consideration of timing of works and derogation licensing; c) measures for the protection, enhancement and management of retained habitats of wildlife interest; d) details for the provision and management of proposed habitats of wildlife interest; e) scheme for the control of any plant species included on Schedule 9 of the Wildlife and Countryside Act; f) Outline scheme of monitoring and responsibility for implementation.

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A planning application for the discharge of this condition has been received by the Council (07/16/0899/DRC).


The developer notes that outline permission (07/13/0899/O) exists for 523 new homes, a residential care home, a new primary school, a community hub containing a shop, hotel restaurant, gym and open space, numerous green spaces and a network of walking and cycling routes This consent limits the maximum number of dwellings within the red line application site to 523, which reflects the indicative layout prepared and submitted at that time for which has in turn, been used to define development areas and phasing plans which are the subject of conditions within the consent. The developer comments that whilst planning permission has been granted, it is entirely appropriate to ensure that there is flexibility in any policy that may apply to site, which would be consisted with Paragraph 153 of the National Planning Policy Framework. Increasing numbers on sites already committed will take pressure off more contentious sites such as sites within the Green Belt and as such it is hoped that the Council acknowledge the need for flexibility in considering matters in the context of the High Leigh Garden Village site. The developer comments that such circumstances could exist where housebuilders purchasing tracts of land

The comments are noted but it is not proposed to ament the paragraph or the policy. It is a matter of fact that a new planning application(s) could be submitted but the outline planning permission establishes the current parameters for development of the site.

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following the grant of outline consent could seek to submit new full applications based on their approach to new designs or layout or indeed responding to new regulations. Whilst the reference to the outline application is factually correct in Policy HOD5, it should not preclude the opportunity for new submission to be made. The developer notes that other circumstances which could cause the landowner or subsequent owners to re-assess capacity is where a review of the non-residential components of the outline consent merits the substitution of such non-residential elements with new housing which consequently could affect the total number of dwellings coming forward. The developer requests that a new paragraph (9.10) us added to ensure that there is sufficient flexibility in the plan for it to adapt to circumstances that may arise. The new paragraph: “The reference to the 523 dwellings on the site derives from illustrative masterplanning work undertaken at the outline planning application stage. Where any new applications are submitted, the proposals will be acceptable having regard to other relevant planning policies within this plan including Polices DS1 and 2 and relevant Development Management Policies e.g. such


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proposals could come forward in the context of new government policy or the adoption of new supplementary planning guidance”.


The developer requests that Policy HOD5: High Leigh Garden Village is amended to ensure that is sufficient flexibility in the policy for it to adapt to circumstances that may arise. Policy HOD5: High Leigh Garden Village should be amended to read: “The Council will work with landowners/developers to deliver High Leigh Garden Village following the granting of planning permission 07/13/0899/O. Where alternative proposals come forward then such proposals will be assessed against relevant policies in this plan”.

See above. -


Thames Water has concerns regarding Water Supply Capability in relation to the site. The water supply network in this area is unlikely to be able to support the demand anticipated from this development. Thames Water state that it will be necessary for them to undertake investigations of the impact of development and completion of this may take several weeks. In the event of an upgrade to their assets being required, up to three years lead in time will be necessary. Thames Water request that the following paragraph is included in the Development Plan:

Concerns noted. High Leigh Garden Village has been granted outline planning permission. As part of the development management process, Thames Water were consulted on this application. In their response to this application, Thames Water confirmed that the entirety of the development can be serviced from the water main within Hertford Road. They advised that if applicants wish to service the southern part of the development from the water main in Lord Street, there is sufficient capacity from the existing main to service phase 1 of the development and that any further houses will necessitate the up-grading of the main within Lord Street.

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“Developers will be required to demonstrate that there is adequate water supply capacity both on and off the site to serve the development and that it would not lead to problems for existing or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing water infrastructure”.


Thames Water has concerns regarding Wastewater Services in relation to this site. The wastewater network capacity in this area is unlikely to be able to support the demand anticipated from this development. Upgrades to the existing drainage infrastructure are likely to be required to ensure sufficient capacity is brought forward ahead of development. Thames Water state that where there is capacity constraint the Local Planning Authority should require the developer to provide a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered. At the time planning permission is sought for development at this site Thames Water are also highly likely to request an appropriately worded planning condition to ensure the recommendations of the strategy are implemented ahead of occupation of the development.

Concerns noted. High Leigh Garden Village has been granted outline planning permission. AS part of the development management process, Thames Water was consulted on this application. The applicants have advised that the development would be sewered through Lord Street which is likely to necessitate the need for pumping from large parts of the development. Sewage will ultimately drain to Rye Meads Sewage Treatment Works. In their response to this application Thames Water stated that the sewerage infrastructure capacity in the area is acceptable and raised no objection.

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Thames Water note that it is important not to underestimate the time required to deliver necessary infrastructure i.e. local network upgrades can take around 18 months to 3 years to design and deliver.


Thames Water note that a flow pressure test carried out in 2015 determined that reinforcement would be required to the water supply network to serve this site. There are sewers crossing this site which will need to be protected.

These matters have been/are being addressed through the planning permission for the site.

-


The LEP supports this policy. Noted. -


Hertfordshire County Council comments that High Leigh Garden Village will impact upon what are presently small isolated areas of open countryside. There are locally valuable hedgerows and wooded areas still present which should be maintained and enhanced as far as possible.

High Leigh Garden Village has been granted outline planning permission. Details of ecology and landscape are addressed in the planning permission.

-


Hertfordshire County Council notes that the proposals for High Leigh Garden Village include a new primary school site.

The creation of a new primary school at High Leigh Garden Village is also detailed in Policy INF10: New and Expanded Primary Schools.

-


The policy is supported as this location in the north of the Borough provides a logical and sustainable location for development. It will create a new, more robust western Green Belt boundary.

Support noted. -

9.78 PO1457 Policy HOD5: High Leigh Garden

Hoddesdon is recognised to be a suitable and sustainable location for development and therefore the allocation at High Leigh

The Council acknowledges that Hoddesdon is an sustainable area for growth, however considers that the expansion of the High Leigh Garden

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Village Garden Village should be expanded to provide residential development beyond that already identified. Regard should be had to the ability of the site referred to as ‘Land north of Hertford Road’ to connect to the High Leigh Garden Village so that it may form an integrated expansion of Hoddesdon.

Village allocation will have a detrimental impact on the Green Belt


The Hoddesdon Society comment that the High Leigh development appears to have addressed some issues but raise concern that the use of design codes is not enshrined in the Local Plan

One of the conditions (14) attached to the outline planning permission for High Leigh Garden village is:

a) Prior to the commencement of development a Public Realm Design Code shall be submitted and approved by the Council. The Public Realm Design Code shall be prepared in accordance with the principles and parameters established in the Design and Access Statement and the Design Codes Specification.

b) Concurrently with the submission of the Public Realm Design Code a Character Area Design Code for Development Zone A shall be submitted to the Council. The Character Area Design Code should be prepared in accordance with the principles and parameters established within the Design and Access Statement, the Public Realm Design Code and the Design Codes Specification.

c) Prior to the submission of the first of the Reserved Matters for Developments Zones B to F, a Character Area Design Code for the relevant Development

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Zone shall be submitted to and approved in writing by the Local Planning Authority. Each Character Area Design Code should be prepared in accordance with the principles and parameters established within the Design and Access Statement, the approved Public Realm Design Code and the Design Codes Specification and with reference to the Design Code for Character Area A.

A DRC application for ‘details of public realm design code pursuant to condition 14) has been received and approved by the Council. Furthermore, should any further planning applications come forward for this site they will be considered against the provisions of Policy DSC1: Design and Sustainable Construction, which seeks to ensure that all development proposals are of a high standard of design and layout to reflect and promote local distinctiveness. For larger developments this may


The Hoddesdon Society state that when planning permission was given for High Leigh, approximately 50% was open space and the power lines were to be buried. They hope that the Council insist that the developer sticks to the original plans.

The outline planning permission for this site contained a number of conditions, such as

9.81 PO1483 Policy HOD5: High Leigh Garden

The Hoddesdon Society would like to see good links to the town with both cycle and walkways.

As part of the Section 106 agreement for this site, contributions were sought for the creation of a pedestrian and cycle bridge/raised

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Village boardwalk from Paddick Close. This will provide connections. Furthermore the Local Cycling and Walking Infrastructure Plan proposes a connection along Long Street.


Hertfordshire County Council (Minerals and Waste) note that comments provided in respect of the application in November 2013 related to two county matter applications in this area, namely Bramble Lane – E/0576-53 permitted for sand and gravel extraction and High Leigh E/2478-48 permitted for sand and gravel extraction, both infilled in the 1950s. The south of the site is also adjacent to a historic landfill designated by the Environment Agency with municipal and inert material.

Noted. -


The Environment Agency comment that the Woollens Brook runs through the site and so any development must enhance the river and its riparian zone for biodiversity, as well as public access. Restoration options must be considered as part of the development. A buffer strip of at least 8m must be left alongside the river channel and the river must not be culverted as part of the development. Habitat corridors to the river channel must be maintained.

The proposed development has planning permission and this permission enshrines the protection of the Woollens Brook.

-


The Broxbourne Woods Area Conservation Society state that the development should restricted/controlled by the Planning Authority, especially regarding access and parking facilities.

The proposed development has planning permission. That permission proposes to improve access to Broxbourne Woods.

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Figure 18


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9.85 PO1011 Figure 18 – High Leigh Garden Village Concept Map

Concern that land west of Paddick Close has not been considered for development. The site is bisected by the power cables but nevertheless could be accessed from the east (or west).

This SUDS ponds for the development will be located within this area. These now have reserved matters consent.

-

Paragraph 9.10


support. Noted. -

Policy HOD6: Barclay Park

9.87 PO640 Policy HOD6: Barclay Park and Spital Brook

Historic England welcome policy HOD6 and paragraph 9.10 and proposals to improve and extend the historic landscape of Barclay Park.

Noted. -

9.88 PO1788 Policy HOD6: Barclay Park and Spital Brook

Hertfordshire County Council supports the aim to improve and extend Barclay Part and protect the Spital Brook Valley from development, particularly given its location east of Hoddesdonpark Wood.

Noted -

9.89 PO1950 Policy HOD6: Barclay park and Spital Brook

The Environment Agency state that as part of the improvements, the river channel should be enhanced or re-naturalised as appropriate. There is also potential for wetland creation (priority BAP habitat) and flood storage.

This will be explored depending on the availability of funding.

-

Paragraph 9.11


Hertfordshire County Council notes that the settlement of Hoddesdon is located within the Hoddesdon EPA.

Noted -


Hertfordshire County Council note that Paragraph 9.11 refers to Sheredes school. From 1 September 2016 this school has

Noted. References to Sheredes School will be changed to Robert Barclay Academy.

Amend paragraph to refer to Robert Barclay Academy.


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been renamed the Robert Barclay Academy.

Paragraph 9.12


Hertfordshire County Council comment that the wording of paragraph 9.12 regarding primary schools places is incorrect. Hertfordshire County Council are the local authority with responsibility for education provision within the borough of Broxbourne. Initial property feasibility has shown that within Hoddesdon there is capacity to permanently expand two existing primary schools. Hertfordshire County Council note that Cranbourne Primary School has capacity to expand by 1FE to become a 2FE school and St Catherine’s Primary School has capacity to expand 1.5FE on a permanent basis to become a 3FE school.

Noted. The Council will change the wording to reflect the current position of Hertfordshire County Council in regards to primary school provision in Hoddesdon.

Amend text to refer to expansion of Cranborne and St Catherine’s.


Hertfordshire County Council has carried out feasibility work which confirms that it would be possible to build a 2FE primary school on the current site of The Rivers Education Support Centre (ESC). The site was previously occupied by Ryelands Primary School. Based on the level of housing proposed in Hoddesdon, Hertfordshire County Council anticipates that the establishment of a new primary school on this site is unlikely to be required during the current Plan period. There are therefore no proposals to establish a new school on the formers Ryelands Primary School site on Essex Road.

Noted. The Council will remove references to the re-opening of Ryelands Primary School

Delete sentence regarding re-opening of Ryelands.


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Hertfordshire County Council notes that High Leigh Garden Village includes a site for a primary school to meet the anticipated 1FE of demand arising from that new development. HCC comment that they are in the process of considering options for the provision of primary school places within this area of Hoddesdon. The options being considered include the relocation and expansion of an existing primary school into High Leigh Garden Village. Hertfordshire County Council state that if this were to happen it is possible that the current site of the relocated school would be redeveloped for housing.

Noted. As indicated in the Regulation 18 Local Plan the Council’s preferred option is to relocate Westfield Primary School into High Leigh Garden Village and for this to be expanded to a two form of entry school. Relocation would enable the Westfield Primary School site to be developed for housing.

-


Hertfordshire County Council note that children from Hoddesdon attend secondary schools located within the Hoddesdon EPA

Noted. -

Paragraph 9.13


NHS England/NHS East and North Herts CCG states that their community provider has highlighted that there are considering disposing of the Hoddesdon Clinic. In partnership with Hertfordshire Police and are keen to look at alternative options within the locality where they would like to deliver a wider range of services within a new fit for purpose health facility.

Whilst there have been discussions regarding comprehensive redevelopment of the community facilities in this location, to date those have not resulted in firm proposals. It is considered that this matter can be resolved outside the Local Plan process.

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Concern that more healthcare provision will be needed in the Hoddesdon Area. The re-location of the Amwell Street surgery is not likely to cope with increased demand from the growing population

The Council is working healthcare providers to ensure that there is sufficient provision of healthcare facilities across the borough.

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Chapter 10: Park Plaza Issue No.

Policy/ Para. no.

Commt. ID(s)

Issue Officer Response Proposed amendments

10.1 10 10.2 10.6 PP1, PP2, PP3

PO528 PO961 PO222 PO1060 PO1061 PO1063 PO210 PO2180 PO1029 PO704

Development can only be supported if the potential for a significant increase in traffic at the already congested jct25 on the M25, the A10 and the surrounding road network can be mitigated as development proceeds. This will require traffic modelling, significant planning, public transport and road improvement schemes, e.g. junction improvements at the A10/A121 roundabout. East Herts DC LB Enfield Conservators of Epping Forest Concern especially about the double impact of Park Plaza alongside LB Enfield’s near contiguous development of land in the North East Enfield Area Action Plan. Conservators would object to any resurrection of the Enfield Northern Gateway Access Route proposals or any other proposals seeking to re-direct Jct25 traffic, including Park Plaza traffic, to the A121 and Jct26, because of the knock-on effect on roads through Epping Forest. Highways England Amend PP1, PP2 and PP3 to provide specific guidance for promoters of the sites concerning transport and road improvements

Designs have been produced and tested through both the Broxbourne transport model and the Hertfordshire COMET model, demonstrating that the options work. This is set out in the Broxbourne Transport Strategy available for consultation in November/December 2017. Broxbourne Council will closely monitor the situation in respect of Enfield Council’s proposals and is working together with the Conservators through the Six Authorities Liaison Group and the Co-Op Board to ensure co-ordinated exploration of the issues. The Council has recently completed its transport modelling and has indicated its intention to supply any available data to assist in the process of assessment of impacts. The Council is part of the wider MoU group on Epping Forest in relation to air quality impacts. Advice noted.

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10.2 10 PO1762 PO1520

Transport improvements required: Herts County Council

A shuttle bus as a requirement of development

Developer contribution to fund a public bus service with good frequency to key destinations, including current Park Plaza East and Waltham Cross road and bus stations, to prevent businesses establishing private hire shuttle bus arrangements that will undermine the public network.

Bus routes should be served with easy-access kerbing, bus cages and shelters, and real time information.

Good walking and cycling connections to rail stations and nearby areas.

Herts LEP

Station at Park Plaza

Mitigations are set out in the Broxbourne Transport Strategy.

-

10.3 PP1, PP2 PO2218 PO2219 PO2213

Herts County Council Public Health Development designs in these areas should consider potential for worsening air quality in the area arising from more traffic on the adjacent A10, and consider how to mitigate this from the outset.

The Council’s Transport Strategy provides for access by sustainable transport. The Local Plan proposes landscaping including set-back from the M25 and A10.

-

10.4 10 PO528 East Herts DC As this is a gateway development the whole site should be planned comprehensively, rather than referring to lapsed planning permissions.

The policy has been amended accordingly.

Amend policy to remove reference to lapsed permission.

10.5 10 PO560 PO2194

Park Plaza should be for high-tech business, e.g. IT, not retail sheds like Homebase or Wickes, that are better off in the High St, and where the jobs are minimum wage.

Park Plaza West is suited to high value businesses. The plan identifies Park Plaza North for retail and other relocations.

-

10.6 10 PO961 Give priority at Park Plaza for businesses relocating from the New River Trading Estate and Delamare Rd, as these have established local customers.

The plan identifies Park Plaza North for such relocations.

-

10.7 10 and PO1589 Unwarranted development: Not agreed. Park Plaza West has -


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10.2 PO903 PO209 PO1447

An unacceptable erosion of the Green Belt barrier between London and Herts.

Sceptical that high tech companies will relocate there.

Park Plaza East is enough

been identified as a key site in the LEP Strategic Economic Plan as well as the LSCC Vision as well as the Ambition Broxbourne Programme. The site is considered to be highly attractive and accessible.

10.8 10.2 And PP1

PO1986 PO1520

PP1 should be modified to clarify that employment sectors encouraged include life sciences, creative industries and biotechnology. Proposed alteration to para. 10.2 to expand list of employment sectors to be encouraged: Master planning of Park Plaza West indicates the potential for this site to accommodate up to 100,000m2 of business floorspace and the site will be promoted to the types of industries that are prevalent and seeking space within the London Stansted Cambridge corridor, for example life sciences and bio-technology, creative industries, digital and media technologies. Herts LEP Would welcome promotion of Park Plaza West for life sciences and digital and media industries in accordance with the London Stansted Cambridge Consortium objectives, and supported by the LEP’s Growth Deal 3 submission (July 2016).

Agreed . Amend paragraph to include reference to biotechnology and creative industries.

10.9 10.3 PO1912 Thames Water This part of the New River is embanked and in poor condition; major refurbishment is planned in 2020-2025.

Noted. The Council would like to see the proposed cycle path constructed at the same time.

-

10.10 PP1 PP2 and supporting text

PO641 Historic England Park Plaza is near listed buildings: Theobalds Farm, barn and cob outbuilding, all Grade II listed, Theobalds Park College which is Grade II*, and a Grade II listed classroom block to the west, and the scheduled monument and group of listed

Unnecessary to state all listed buildings in the vicinity – this will be picked up through masterplanning and preparatory work on the planning applications.

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buildings and structures to the north that are part of Theobald’s Palace at Cedars Park. PP1 and PP2 should refer to the importance of preserving the nearby listed buildings/structures and the scheduled monument and enhancing their settings.

10.11 PP1 PP2 PP3

PO1845 PO1846 PO1847

Herts County Council Minerals and Waste a) Park Plaza West is in the sand and gravel

belt; there have been no previous mineral workings, and there may be the opportunity to extract resources for use on site during development.

b) Park Plaza South and North are previously developed land in the sand and gravel belt with some previous granted permissions for extraction.

c) Site D is previously developed land with some previous permissions granted for extraction.

Noted -

10.12 PP1 PO2105 PO2096 PO2100 PO2101 PO2103 PO2184, PO2095, PO2097, PO2099, PO2104, PO2106, PO2107, PO2109

Tesco Policy should include the site at Theobalds Sports Ground/Cheshunt Country Club because:

a) Site adjoins PP1 allocation b) Positive effect from development including

housing and community sports facilities complementing employment-led development; would increase housing and health scores in sustainability approval of Park Plaza West.

c) it complies with Draft Local Policy PP1 (Park Plaza West) and

d) the previous approved scheme at the site (Application Ref: 07/10/0019/F) sets a precedent for development at this location.

Not agreed. The Country Club site is located on the far side of a robust Green Belt boundary (the New River). Any positive effect would be outweighed by the negative effects on the Green Belt and countryside.

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e) Similar to other Green Belt sites which are being released for development

10.13 PP1 10.7

PO1986

Developer Supports development of Park Plaza West, but proposes alterations to PP1:

a) The nature of points 1-10 is unclear. Suggest that based on the following principles be added after design codes at the end of the 2nd sentence

b) Point 4 requires 12.5ha in the southern end of the site to be laid out as public open space – see also Fig 19 Park Plaza West Concept Maps and Policy ORC3. A Local Green Space designation would not be consistent with NPPF para. 77, and a separate designation for this part of the site is unnecessary and arbitrary anyway. It is proposed instead that the site be developed with a well-designed landscape, delivering a substantial landscaped area (size to be unspecified) at the south of the site as part of the business park, that would be accessible via public footpath but not formal ‘public open space’. Propose re-wording point 4 of PP1 to read, Generous and well landscaped setting will be provided and include a large area of publicly accessible space as part of the business park in the southern end of the site.

c) Propose that Fig 19 Park Plaza West Concept Map, the proposals map, and Inset Map 1 relating to the Park Plaza area and the Borough key map should be updated to remove the words ‘Local Green Space’ and the designation for PP1 be extended to the

a. Agreed

b. Not agreed. The Local Green Space designation offers robust protections for this strategic gap, which would otherwise be at risk from encroachment.

c. Not agreed for the reasons set out above.

d. This is an historic landscape feature which is proposed to be a centrepiece of the aforementioned open space.

Policy PP1. ..This campus will be developed in strict accordance with a Master Plan and design codes based on the following principles:


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south to cover the entire area to be delivered as part of the business park development, including the landscape open space to the south.

d) Point 10 requires that Cecil’s Pond be restored; this is considered overly prescriptive as it has not been securely identified through historical documentation that it is a fragment of a water feature associated with Theobald’s Park, and it is poorly preserved, and its former landscape context largely lost. Propose revised wording: Further investigation into the significance of Cecil’s Pond should be carried out and an appropriate plan for conservation appropriate to its significance should be devised.

10.14 PP2 Park Plaza North

PO1131 PO1043

Policy PP2 is not explicit or flexible enough about the types of use that will be permitted. Suggested amendments: Co-op

a) Wickes and Homebase are A1 retail uses but this usage is not stated in policy PP2. Suggest revising PP2 to read: 1.Restricted to use classes A1 (non-food, bulky trades), B1, B2 or businesses requiring to relocate as a result of regeneration developments proposed within this Local Plan.

b) To compete fairly with other strategic employment sites outside the Borough and best meet occupier demands most successful business parks require ancillary and complementary uses, e.g. A3

The Council is satisfied with the wording of the Policy. There is no intention to introduce new A1 or B8 uses into this site.

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restaurant/café, C1 hotel, D2 gym, nursery). Amend the policy to increase flexibility. Suggest revising PP2 to read: Ancillary uses that complement and will best promote the site for business.

Wickes Excluding B8 is not justified; small scale B8 should be allowed at least because of their compatibility with industrial and retail uses – Wickes often trades alongside warehousing uses such as plumbers merchants and joiners. Also, the requirement for a master plan and a design code could delay the site coming forward and it should not be assumed that an application will be made in outline, or that it is within single ownership. Suggested re-wording: "Park Plaza North is allocated for a variety of small and medium sized enterprises as follows: 1. Restricted to Use Classes B1, B2 and B8 uses including trade counters; 2. Businesses ( including retailers) requiring to relocated as a result of the following regeneration developments proposed within this Local Plan : Brookfield (policy BR1), Cheshunt Lakeside (policy CH1) and Waltham Cross Northern High Street Redevelopment (policy WC2); The development of the site should result in a Landmark development building at the corner of the A10 and Winston Churchill Way. The site will be developed in accordance with a master plan and design code which will be incorporated within an outline planning application for the development. "

10.15 10.7 PO1990 Developer considers the draft Plan underplays current level of sustainable transport connections

Sustainable transport connections into Park Plaza West are restricted to

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benefiting Park Plaza West. Suggest re-wording this para. to read: Whilst there are suitable existing pedestrian and cycle connections from the Park Plaza area to Waltham Cross Town Centre, these could be enhanced by the removal of the existing level crossing.

poorly connected paths. It is not proposed to amend this reference.


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Chapter 11: Waltham Cross

Issue Number

Comment ID


Issue Officer Response Proposed Amendment to Plan

11.1 PO1821, PO1849

Waltham Cross Hertfordshire County Council (Spatial Planning) comment that The Waste Site Allocations documents include two designated Employment Land Areas of Search within the Borough of Broxbourne. The County Council supports ELAS160: Eleanor Cross Road, Waltham Cross within the proposed Waltham Cross Business Park employment designations. HCC note that waste uses are acceptable within employment land areas, and parts of ELAS160 have previously been used for waste. There are also records of applications for material extraction at ELAS160 permitted in the past.

Noted.

-

11.2 PO1821 Waltham Cross The County Council would not wish to see substantive loss of employment land within the Borough and this may need to be addressed in a review of the Britannia Road area within the Waltham Cross Area Action Plan.

The Waltham Cross Area Action Plan will address a number of areas, including employment land. In addition, the Council’s emerging Policy ED2 resists the loss of employment land within the Council’s designated employment areas, of which Britannia Road is one.

-

11.3 PO1849 Waltham Cross Hertfordshire County Council (Minerals and Waste) notes that Waltham Cross Business Park was not commented on in 2015. The allocation, which consists of two parcels of land on either side of the

Noted. -


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railway line, is located within the urban area and is previously developed land. Part of the site to the east of the railway line is designated as Employment Land Area of Search in the Waste Site Allocations document, adopted in July 2014 (ELAS160 Eleanor Cross Road). There is a waste site located on the eastern parcel of land known as Unit 23, Monro Trading Estate, permitted in 2005. On the eastern side of the railway line, the allocation covers the site of a previous waste site known as Porters, Britannia Road which has a record of permissions for a waste use in 1995, 1996, 2001 & 2003. Another record for a waste application is located adjacent to this one refused in 1972. There are records of applications for extraction at Eleanor Cross Road in the south of this allocation permitted in 1950 and 1973.

Policy WC1: Waltham Cross Town Centre

11.4 PO2122 Policy WC1: Waltham Cross Town Centre

Public Health Service (Hertfordshire County Council) recommends that Policy WC1 incorporates a further priority to improve the pedestrian and cycling environment, accessibility and connectivity to the wider Borough.

The Council’s Transport Strategy which accompanies the Local Plan seeks to encourage as many journeys by bus, rail, walking and cycling so people have a safe, viable and attractive alternative to driving. The Council has prepared a Local Cycling and Walking Infrastructure Plan which

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details the current barriers to these modes of transport and proposes a range of physical and behavioural measures which are designed to encourage a shift in attitude to walking and cycling. Section 6b of the Strategy details improvements to the walking and cycling infrastructure within the borough’s town/district centres

11.5 PO1772, PO1771


Hertfordshire County Council comments that although there are no services that currently operate on Waltham Cross High Street, a large number of services terminate at Waltham Cross bus station, within 400 metres acceptable walking distance. It would be appropriate to seek contributions to improve the facilities at Waltham Cross Bus Station, in keeping with proposed Policy INF8

The Area Action Plan will look at potential for significant investment in sustainable transport.

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Historic England requests that any proposals for the High Street will need to protect and enhance the following assets and their settings:

Grade I Listed Eleanor Cross Scheduled Monuments

Grade II* Harold House Recommends that both the above should be mentioned in paragraph 11.4 and in Policy WC1

While it is not necessary to repeat the Heritage Assets policies here (Chapter 29). It is not considered that adding points of detail here would provide additional protection or significantly enhance the function of this section.

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11.7 PO548, PO544


The Waltham Cross and Cheshunt Chamber of Commerce support the reference made to the Waltham Cross Town Centre Strategy within

The Council has begun work on implementing that Waltham Cross Town Centre Strategy, one scheme being the new town square (the Roundel). The

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the Plan, cementing its place in the planning process. Request that the strategy is expedited as a matter of urgency as the delivery of the regeneration package would mitigate both the provable adverse effects of the retail offer at Brookfield as well as the pending town centre status of Brookfield within the Local Plan Retail Hierarchy.

Council will continue to work to improve Waltham Cross Town Centre, working with the necessary stakeholders. The Council will further look into Waltham Cross as part of the proposed Waltham Cross Area Action Plan.


The Council should try to attract better retailers, such as Primark and Matalan, to Waltham Cross

One of the roles of Council’s Waltham Cross Town Centre Strategy is to enhance the retail offer of the town centre and attract investment. The Council believes that this can be achieved through enhancing the town centre’s streets and spaces to ensure the town centre environment is attractive to retailers. However, it should be noted that it is not within the Council’s remit to control which retailers occupy shops within the Borough’s retail centres.

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Paragraph 11.5

11.9 PO1590 Paragraph 11.5 The homes planned for in the Northern High Street Redevelopment would be better placed at Park Plaza in a mixed –use development similar to that planned at Delamare Road, with a footbridge over the railway lane to Park Lane provided. Vehicle access to the site would be via the current junction with the A10

The proposals provide an opportunity to regenerate the Northern High Street which would be lost if the development proposals were to focus exclusively on Park Plaza.

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11.10 PO1590 Paragraph 11.5 Houses constructed as part of the Northern High Street redevelopment should not be as ugly as those constructed opposite Wickes, which look like a prison.

The design details of residential development on this site will be determined through the planning application process, with reference made to emerging Policy DSC1. This policy seeks to ensure a high standard of design and layout to reflect and promote local distinctiveness for all development is achieved.

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11.11 PO1449 Paragraph 11.5 Wickes and Homebase should not be relocated as this would further isolate these outlets from the High Street. Park Lane should be blocked off at the junction with Sturlas Way. This would make the DIY stores more accessible from the High Street. The increase in footfall would generate enough business to sustain the proposed new High Street shops.

Wickes and Homebase are typical ‘out of town’ uses and the majority of customers arrive by car because of the bulky nature of the goods on sale. Better connections to the town centre would not substantially change this. The sites they occupy offer a significant opportunity to improve the vitality and viability of the town centre by providing a bigger pool of local residents and improving the High Street frontage.

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11.12 PO306 Paragraph 11.5 The relocation of Wickes and Homebase to Park Plaza North should not result in their closure

The Council is working with Wickes and Homebase to ensure that they are successfully relocated to Park Plaza North.

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11.13 PO306 Paragraph 11.5 The relocation of Wickes and Homebase should be supported by the provision of direct bus services servicing the stores from Waltham Cross and Cheshunt Old Pond

The Council has identified a number of new bus routes that will be created during the Plan period.

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11.14 PO314 Paragraph 11.5 The resiting of Homebase, Wicks and other small businesses will be a massive expense

This will be a commercial decision for those stores. It is considered that Park Plaza North offers a better location from the business perspective.

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11.15 PO314 Paragraph 11.5 The flats proposed for this area can be built elsewhere and lessen the traffic from there to Brookfield.

It is considered that this development offers significant potential for non-car modes of travel, taking account of the proximity of the site to the town centre, rail and bus stations.

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11.16 PO1590, PO1329, PO1326, PO1321, PO1449,

Policy WC2: Northern High Street Development

Object to the proposed relocation of Wickes and Homebase, due to the following reasons:

The two shops bring a lot of trade to the area relocating them would be detrimental to the town centre

Provision of limited free parking which is used by shoppers using other shops within the area. Removal of free parking could deter shoppers from visiting the area

In their current position, Wickes and Homebase provide a dead façade to the street frontage and a closure to the High Street. The redevelopment of this site will enable the creation of a new retail frontage that will enhance the vitality and viability of the town centre. There is plenty of parking provided at the Pavilions and other car parks in the area.

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11.17 PO1042, PO1045

Policy WC2: Waltham Cross Northern High Street

Wickes supports Policy WC2 but with amendments and on the proviso that a relocation site is secured at Park Plaza North. Wickes considers it necessary to include specific texting within the policy which identifies Park Plaza North as providing a suitable and available site to which it can relocate. The following text is suggested: “The Council will proactively work with the existing DIY retailers to secure a

The Council supports the relocation of Wickes and Homebase, and has been working with the DIY retailers to ensure that the transition to Park Plaza North is as smooth as possible.

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relocation site at Park Plaza North, as promoted under Policy PP2”.

11.18 PO1049 Policy WC2: Waltham Cross Northern High Street

Sainsburys supports proposals to enhance Waltham Cross Northern High Street and introduce residential development within the town centre as this should enhance the vitality and viability of the local shopping parades.

Noted -


Hertfordshire County Council (Minerals and Waste) comments that the site is located within the urban area and is previously developed land. HCC GIS layers have been checked and nothing is registered for this site

Noted -


Thames Water has concerns regarding Water Supply Capability for the site. The water supply network in this area is unlikely to be able to support the demand anticipated from this development. It will be necessary to investigate the possible impacts of the development. It should be noted that in the event of an upgrade to Thames Water assets being required, up to three years lead in time will be necessary. Thames

The proposed development of the Northern High Street is anticipated to come forward in the last five years of the Plan. This will provide sufficient lead-in time to enable the necessary upgrades.

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Water asks for the following paragraph to be included within the Plan: “Developers will be required to demonstrate that there is adequate water supply capacity both on and off the site to serve the development and that it would not lead to problems for existing or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing water infrastructure”.


Thames Water has concerns regarding the wastewater services for this site. The wastewater network capacity in this area is unlikely to be able to support the demand anticipated from this development. Upgrades to the existing drainage infrastructure are likely to be required to ensure sufficient capacity is brought forward ahead of the development. Local Planning Authorities should require the developer to provide a detailed drainage strategy informing what infrastructure is required, where, when and how it will be delivered. The recommendations of this strategy will requested to be included within an appropriately

The proposed development of the Northern High Street is anticipated to come forward in the last five years of the Plan. This will provide sufficient lead-in time to enable the necessary upgrades.

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worded planning condition at the time of planning permission to ensure their implementation ahead of the occupation of the development. It should be noted that the time required to deliver necessary infrastructure should not be underestimated i.e. local network upgrades can take around 18 months to 3 years to design and deliver.


Thames Water notes that there are sewers crossing this site which will need to be protected

Noted. This will be addressed through the planning application process.

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Hertfordshire County Council (Property Services) notes that an additional 300 new homes included within Policy WC2 equates to 0.6FE of primary school demand

The plan provides for expansion of primary schools in the area to meet demand.

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133,135 and 137 High Street should be removed from Policy WC2 as the owner wishes to redevelop the site.

This is not accepted. Policy WC2 requires the comprehensive development of the site. It opposes incremental development.

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Historic England requests that proposals for the Northern High Street will need to protect and enhance the following heritage assets and their settings:

Grade II listed 207 High Street

Grade II Listed 226/228 High Steet

References for both should be included in paragraph 11.5 and policy WC2

The Council does not consider it to be necessary to repeat its Heritage Asset policies (Chapter 29) for each site allocation when a heritage assist is within or in close proximity. Any planning applications for this area will be determined with reference to emerging Policy HE1, which seeks to protect and enhance the Borough’s heritage assets.

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Concern that the local road infrastructure (A10 and Lieutenant Ellis Way) will be able to cope with the increase in traffic flow.

Mitigations for the A10 have been designed and tested through transport modelling. The road network within Waltham Cross will be considered through a transport strategy to support the proposed Area Action Plan.

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Money from the new homes should be invested in local sporting centres and clubs.

Planning obligations will be sought from the new developments for a range of items so long as they are directly related, proportion, and reasonable.

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The reference to the Council using compulsory purchase powers within Policy WC2 is inappropriate. It is not a matter of planning policy to make reference to powers which may be available under entirely different legislation.

This inclusion provides the necessary clarity that implementation of the plans may entail use of these powers.

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There should be a good proportion of homes for rent within the Waltham Cross redevelopment

Policy H3: Housing Mix sets out the requirements, and stipulates that there developments included at strategic housing allocations, including Waltham Cross Northern High Street, “must be inclusive, providing for a mix of occupiers and tenures and the entire range of ages.”

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The northern part of the Cross is neglected. It should be developed into housing or into permanent market stalls that would be undercover. The market stalls could be used for craft fairs etc.

The Council does not consider that there are at present other realistic redevelopment opportunities in the town centre suitable for inclusion in the Local Plan. However it may be that others emerge through work on the Area Action Plan. Local improvements are beyond the scope of the Local Plan but may follow from work to implement the Town Centre Strategy.

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Paragraph 11.6

11.31 PO1366 Paragraph 11.6 Hertfordshire County Council Property (Development Services) notes that the SLAA sites included in Appendix A for Waltham Cross total 390 units, which results in the demand for 0.8FE of primary school places.

Noted. The Council will continue to work with Hertfordshire County Council to ensure the educational needs of the Borough are appropriately planned for.

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11.32 PO2192 Paragraph 11.6 TfL Property supports the development of new homes within the area as identified in Para 11.6 in the Plan and the role the Bus Station can play in delivering these.

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Royal Mail request that WX-U-19 (Royal Mail Sorting Office) is removed from the Strategic Land Availability Assessment as the site will no longer be available for redevelopment within the plan period and, as such, the Council cannot rely on this site to deliver development needs. Royal Mail asks to be engaged with the Council if development proposals in the future would impact on usage of the highway and allocation next to or adjacent to the Delivery Offices that come forward for redevelopment.

Noted. Amend text to clarify that the Royal Mail depot is not currently available for redevelopment.

Policy WC3: Waltham Cross Renaissance Area Action Plan

11.34 PO1888 Policy WC3: Waltham Cross Renaissance Area Action Plan

TfL welcomes the approach suggested in paragraph 11.7, however suggests that references are made to working collaboratively with TfL and other relevant stakeholders to take this forward and ensure the development and regeneration opportunities associated with Crossrail 2 (and their delivery) are not missed.

Support noted. The policy already refers to working with Transport for London and Network Rail and this reference is considered sufficient for current purposes.

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Enfield Council strongly supports Crossrail 2 and believes it will provide the catalyst for economic development in the Upper Lee Valley Corridor. The Crossrail delivery timeline falls within the Draft Local Plan timeline, but the Draft Plan needs to take a longer term strategic position on associated Crossrail 2 service in the early 2030s, all with a view to an early review of the Local Plan once Crossrail 2 is confirmed after the hybrid bill process.

Noted. The proposed Waltham Cross Area Action Plan should provide the opportunity for an early review.

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Historic England requests that proposals for major residentially led re-generation around the main railway station will need to protect and enhance the following heritage assets and their settings:

Grade II Listed Church and railings to the east of the station

References to these assets should be included within paragraph 11.7 and policy WC3

The Council does not consider it to be necessary to repeat the Heritage Asset policies (Chapter 29) within all site allocation policies. Any planning application for development at this site will be determined with reference to emerging Policy HA1, which seeks to protect and enhance the setting of historic assets.

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Paragraph 11.9

11.37 PO1367 Paragraph 11.9 Hertfordshire County Council notes that Paragraph 11.9 suggests that there is a shortage of primary school places in Waltham Cross. Current forecasts confirm that there is little available capacity in the primary school across Waltham Cross. Any

The Council will continue to work with Hertfordshire County Council to ensure that education provision within Waltham Cross is appropriately planned for. Policy INF10 identifies the new primary schools that will be provided and the expansion of existing primary schools.

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proposed new housing will require additional provision to accommodate demand. Initial studies suggests Four Swannes Primary School could expand by 1 or 2 FE, and Holdbrook Primary School could expand from 1FE to 2FE with the use of a Borough Council owned recreation ground close to the site as a detached playing field. A new school is also proposed at Albury Farm which could accommodate the demand for school places arising in the northern part of Waltham Cross

Paragraph 11.10

11.38 PO147 Paragraph 11.10 The North and East Herts Clinical Commission Group should fund appropriate care i.e. minor illnesses and minor injuries with 24/7 diagnostics. At present, people from the Lower Lee Valley area have to travel a long way for full facilities

The Council will continue to work with North and East Herts Clinical Commissioning Group to address healthcare demands within the Borough. When a strategic allocation is expected to provide a facility as part of the development, this will be detailed within the Council’s Infrastructure Delivery Plan. There may be an opportunity for such as facility within the Waltham Cross Northern High Street development.

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Chapter 12: Wormley and Turnford

Issue No.

Comment ID(s)


Issue Officer Response Proposed Amendment

Wormley and Turnford

12.1 PO1126 Wormley and Turnford

Additional housing will bring more vehicles to the already busy road of Wormley

Transport modelling indicates that the works to improve capacity on the A10 will alleviate some pressure on the Old Cambridge Road.

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12.2 PO1476 Wormley and Turnford

Object to the omission of the Derwent Turnford (BWT-GB-02) site from the Plan. Concern that if the site is not considered in conjunction with the proposed school site, where current access to the site is obtained, it will become a redundant wasteland in the future. The site is considered in the Council’s evidence base document, “West of Wormley Area Development Options” (April 2016), which states that the site does not serve an amenity role beyond attractive appearance and visual break. The sites, and the proposed secondary school site, are included within Area 2, but this is not pursued in the Plan.

The site has been assessed through the Council’s Strategic Land Availability Assessment (SLAA), which concluded that the site is not suitable for residential development, however the site could provide vehicular access to the site and playing fields for the secondary school proposed to the north of the site. The Derwent site may provide some ecological mitigation options , particularly in light of the Wormley Brook crossing the site.

Amend paragraph 12.2 to clarify proposed access to the site from the south. Amend policies map to clarify that the whole area is to remain in the Green Belt.

Paragraph 12.2

12.3 PO1369 Paragraph 12.2 Hertfordshire County Council Property Services welcome the provision of a new secondary school site within the Cheshunt EPA at Church Lane, Wormley. HCC notes that they are still undertaking feasibility work on this

Support noted. The Council’s supporting text for INF9 (paragraph 17.28) states that the new secondary school is likely to be required by the middle of the Plan period. This supporting text will be amended to take into account the findings of HCC’s feasibility work for the site.

Amend paragraph 17.34 to reflect the fact that the school may not be required until towards the end of the plan period.


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site and that it is likely the site will not be required until towards the end of the Plan period.

12.4 PO1370 Paragraph 12.2 Incorrect reference to Policy INF8 in the text. Policy INF9 refers to the reserve secondary school site.

Noted. The Council will amend the reference on the Policies Map from INF8 to INF9.

Amend policy number

Paragraph 12.3

12.5 PO61, PO231, PO699, PO857

Paragraph 12.3 Support the creation of a train station at Turnford off Groom Road. Students at Hertford Regional College, commuters and shoppers at Brookfield will be able to use this station. It should reduce the pressure on Broxbourne and Cheshunt station in terms of parking and vehicular traffic going to and from those stations.

Support noted. -


Land off Fairfield Drive, adjacent to the railway, is accessible from both sides off Macers Lane and Fairfield Drive and should be considered as a possible site for the new station

The Council has been working with Network Rail to identify a suitable location. As a result of this work, the Council has identified a site between Hertford Regional College and Groom Road.

Amend paragraph and policies map to show new proposed location.

12.7 PO699 Paragraph 12.3 The proposed new station should be built prior to the proposed Crossrail 2.

This is yet to be determined but the implications of 4-tracking and crossrail 2 are currently under consideration.

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12.8 PO61, PO231

Paragraph 12.3 A shuttle service between the proposed station and Brookfield should be provided

Early discussions with Bus Companies have suggested that a ‘Town Service’ joining the stations and major development site The Council is currently exploring the feasibility of creating a new train station at Turnford. Subject to the development of the new train station coming forward, public transport links

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between it and major designation spots within the Borough will be explored.

Paragraph WT1: Wormley Conservation Area Improvement Plan

12.9 PO645, PO646

Policy WT1: Wormley Conservation Area Improvement Plan

Historic England welcomes proposals for a Conservation Area Improvement Plan for Wormley Conservation Area as it is on the Heritage Risk Register. The status of the conservation area should be mentioned in Paragraph 12.4

Noted and agreed. In this case, the Conservation Area is on the Heritage Risk Register and would benefit from additional support within the Plan.

Add mention of this to paragraph 12.4

12.10 PO859 Policy WT1: Wormley Conservation Area Improvement Plan

Concern regarding the time scale for the improvement Plan.

There is no timescale for the Wormley Conservation Area Improvement Plan. The Council will produce this document as early as possible following the adoption of the Plan.

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Policy WT2: Macers Estate

12.11 PO1371 Policy WT2: Macers Estate

Hertfordshire County Council Property (Development Services) notes that Policy WT2 refers to new homes within Macers Estate but does not provide a number. Additional housing may impact upon the demand for school places in the area.

The Council will continue to work with Hertfordshire County Council to ensure that education provision within the Borough is appropriately planned for.

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12.12 PO646 Policy WT2: Macers Estate

Historic England requests a reference that improvements on the Macers Estate will need to protect and enhance the character and appearance of the adjacent Conservation area in paragraph 12.5 and WT2.

This is already mentioned in amendments to paragraph 12.4 on the Conservation Area and it is considered unnecessary to mention it again in the following paragraph.

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Paragraph 12.6

12.13 PO2004 Paragraph 12.6 Enfield Gospel Hall Trust Meeting The Council has recently completed an update -


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Hall site on Halfhide Lane, Turnford should be added to the Plan as a site suitable for housing.

on its Strategic Land Availability Assessment (SLAA). As part of this update, all sites included within the previous SLAA (April 2016) and those promoted to the Council during the 2016 Call for Sites were assessed. The SLAA concluded that this site (CG-U-41) was suitable to “accommodate facilities such as a household waste centre, fire station, sorting office, due to the following reasons:

Employment uses will be able to benefit from the close proximity to the A10

Employment uses will be in keeping with the proposals for Brookfield Riverside, which seek to establish commercial/retail uses to the west of this site.

The SLAA considered the site to be less suitable for residential development “due to it being severed from the existing residential area by the A20 slip road”, but noted that if the site is not considered to be necessary for economic development uses it could come forward for residential development. This position is to be review through subsequent iterations of the SLAA.

12.14 PO42 Paragraph 12.6 Concern that the New River Arms development will mean more flats are to be built in the area and there will be no more greenery.

Planning permission for the New River Arms was approved on appeal. As part of the conditions, a landscaping scheme is to be provided that shows how the existing features are to be retained, new features proposed and the treatment thereof.

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Paragraph 12.7


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12.15 PO1372 Paragraph 12.7 Hertfordshire County Council Property (Development Services) notes that the new care home at the former Wormley Primary School site will provide 75 beds.

Noted -


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Chapter 13: Lee Valley Regional Park

Issue No.

Comment ID(S)


Issue Officer Response Proposed amendment to the

Plan

General

13.1 PO534 Chapter 13 – Lee Valley Regional Park

East Herts Council supports the Borough Council’s engagement with the Regional Park Authority and ambitions to protect the valuable wildlife and recreational asset with its links into East Herts and beyond.

Noted. -


The Canal and River Trust note Chapter 13: Lee Valley Regional Park and references to support and collaborate with the Park Authority. The Trust considers it to be beneficial to include similarly supportive references to collaboration between the Canal and River Trust and the Council, given the non-footloose nature of our waterway within the borough, and its opportunities for recreation and landscape. The Trust would also welcome encouragements for developers to seek pre-application advice from the Canal & River Trust as a statutory consultee for waterside developments.

Agreed. Sentence added and footnote inserted regarding the Canals and Rivers Trust as a Statutory consultee on planning applications affecting the waterways.


The Lee Valley Regional Park authority welcomes the inclusion of Section 13 and the inclusion of policies for the Regional Park as a whole (LV11), for the Lee Valley White Water Centre (LV2), the Lee Valley Leisure Pool (LV3), and Spitalbrook (LV4). The site specific policies are helpful as they focus on key areas for future change and investment as identified by draft PDF Area proposals. The Authority does seek amendments to these policies.

Support noted. The Council will consider the proposed amendment to these policies below.

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The Lee Valley Regional Park Authority states to be consistent with the Greater London Plan the Regional Park could be designated as a Strategic Cultural Area; this would reflect the Regional Park’s importance as a piece of strategic green infrastructure comprising a diverse range of leisure facilities and open spaces which cuts through administrative boundaries and is designed to serve the people of London, Hertfordshire and Essex.

The SCA designation refers to the London Plan’s attempt to take pressure of central London tourist attractions and is not considered appropriate in this context.

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Paragraph 13.1

13.5 PO2067 Paragraph 13.1 The Lee Valley Regional Park Authority state that Policy LV1 ‘Lee Valley Regional Park’ and the supporting text should include reference to the Authority’s statutory duties in relation to the development of the Park and the statutory planning process. The Authority recommend the following amendments to Paragraph 13.1 The Lee Valley Regional Park connects central London at the River Thames with central Hertfordshire. Established by Parliament in 1967 the Regional Park was created to meet the recreation, leisure and nature conservation needs of London, Hertfordshire and Essex. In total it covers 4,000 hectares, a large part of which Much of the Park is contained within Broxbourne, including and most of the land between the River Lee and the West Anglia railway lies within the Park. In total, 42932 hectares of the Lee Valley Park land lies within Broxbourne.

Agreed. The Council will amend Paragraph 13.1 to insert a reference that reflects the Park’s statutory duties in relation to the development of the Park.

Paragraph 13.1 The Lee Valley Regional Park connects central London at the River Thames with central Hertfordshire. Established by Parliament in 1967 the Regional Park was created to meet the recreation, leisure and nature conservation needs of London, Hertfordshire and Essex. In total it covers 4,000 hectares, a large part of which Much of the Park is contained within Broxbourne, including and most of the land between the River Lee and the West Anglia railway lies within the Park. In total, 42932 hectares of the Lee Valley Park land lies within Broxbourne.

Paragraph 13.2

13.6 PO2067 Paragraph 13.2 The Lee Valley Regional Park Authority state that Policy LV1 ‘Lee Valley Regional Park’ and the

Whilst these points are noted, it is considered that the information

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supporting text should include reference to the Authority’s statutory duties in relation to the development of the Park and the statutory planning process. The Authority recommend the following amendments to Paragraph 13.2 The Park is a wonderful amenity for the residents of Broxbourne. It is home to the Olympic legacy facility of the Lee Valley White Water Centre, the River Lee, the Lee Navigation and a network of lakes, woodlands, wetlands, paths and wildlife habitats, including the Turnford and Cheshunt Pits SSSI which form part of the Lee Valley Special Protection Area (SPA) and Lee Valley Ramsar site. Visitor accommodation is available at the Lee Valley YHA in Cheshunt and Dobbs Weir Lee Valley Caravan Park. The Council is fully supportive of and will continue to work with the Lee Valley Regional Park Authority to improve the Park as a local and regional amenity, as a recreational resource, as a public amenity and as a habitat for wildlife.

contained within the Plan is sufficient for planning purposes.

Paragraph 13.3

13.7 PO2067 Paragraph 13.3 The Lee Valley Regional Park Authority state that Policy LV1 ‘Lee Valley Regional Park’ and the supporting text should include reference to the Authority’s statutory duties in relation to the development of the Park and the statutory planning process. The Authority recommend the following amendments to Paragraph 13.3 The Park Authority has produced a framework for the

Whilst these points are noted, it is considered that the information contained within the Plan is sufficient for planning purposes.

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plan for the development and use of Park area within Broxbourne, the Park Development Framework and has consulted on that plan. The current Lee Valley Regional Park Development Framework was adopted in July 2010, with Thematic Proposals adopted in January 2011, and consists of two parts: Part one: outlines the policies and objectives for the Regional Park, providing the strategic policy framework for its future use and development. Part two: consists of particular proposals for the future use and development of individual sites and areas that collectively form the totality of the Regional Park. The Council is supportive of the majority of the proposals within the Plan and this Local Plan contains policies below that make specific provision for the key proposals.

Policy LV1: Lee Valley Regional Park

13.8 PO441 Policy LV1: Lee Valley Regional Park

Kings Arm and Cheshunt Angling Society have raised queries, passed comment on to the LVRPA plans for areas adjacent to if not within the borough boundaries. The Society wants the Council to be supportive of the LVRPA, but states that it needs to be critical of their plans as some of them are so fanciful a reality check is needed, especially as residents are paying for Park activities via precept within their council tax.

Noted.

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The Lee Valley Regional Park Authority state that Policy LV1 ‘Lee Valley Regional Park’ and the supporting text should include reference to the Authority’s statutory duties in relation to the

Brief supporting text added. With this, the text is considered sufficient for planning purposes.

Footnote added to include reference to the Park Act.


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development of the Park and the statutory planning process. The Authority recommend the following amendments to Policy LV1: Lee Valley Regional Park The Council supports the Lee Valley Regional Park Development Framework, and this will be treated as a material consideration in the determination of planning applications in this area. The Council will support the Lee Valley Regional park Authority in the continuing improvement of the Regional Park.


The Lee Valley Regional Park Authority considers that the London Plan’s designation of the Regional park as a Strategic Cultural Area deserve reference within this policy. This would confirm the Regional Park’s diverse leisure offer within the Borough.

The Strategic Cultural Area is a policy specific to the London Plan with the aim of taking the pressure off central London tourist attractions. This London Plan policy is not considered to add any additional weight or guidance to the Broxbourne Local Plan.

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Hertfordshire County Council (Public Health Service) state that they have already responded to the Lee Valley Park Authority’s consultation on its Development Framework, outlining the need to prioritise pedestrian and cycle access routes into the Park over vehicles, in keeping with the Park’s values as a leisure and recreation amenity, and to promote physical activity within the local community.

Noted. -

13.12 PO1676 Policy LV1: Lee Valley Regional park

Support for the policy and the overall vision of the Council to improve assets such as the Lee Valley Regional park. The proposals for the site referred to as the ‘Broxbourne Landfill Site’ aim to improve accessibility to the park by upgrading the existing pedestrian route which runs along the north-east boundary of the site.

As stated Chapter 9 – Hoddesdon (Issue No. 9.), the Council does not consider the site referred to as the ‘Broxbourne Landfill Site’ to be suitable for residential development.

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Natural England supports this policy and will likewise continue to provide support where necessary.

Support noted. -


The Environment Agency state the Council should follow the recommendations outlined in the Lee Valley Biodiversity Action Plan (which is currently being written) and developed in consultation with Lee Valley Regional Park Authority.

Noted. It is understood that the Biodiversity Action Plan has yet to be published.

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Paragraph 13.4

13.15 PO390, PO393

Paragraph 13.4 The Lea Valley Growers Association states that the White Water Centre is a major polluter of the Broxbourne Borough Countryside and not a viable alternative to community facilities such as the Broxbourne Leisure Pool. The prohibitive entrance fees are far beyond the financial means of the majority of families and Broxbourne Borough residents. The centre displaced a valuable community picnic and parking area for residents with a facility that contributes heavily to the Park’s yearly CO2

emissions of 4,500 tons, which would require the annual planting of over 23,000 trees to offset. The Lee Valley Growers Association state that an adoption of a planning policy that requires developers of commercial and residential projects to collaborate with glasshouse growers to use the waste heat and Co2 to grow healthy, sustainable and carbon negative fresh produce would be beneficial.

As set out in the Local Plan, the Council is working with the Park Authority to investigate ways to improve the Leisure Pool site.

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Policy LV2: Lee Valley White Water Centre

13.16 PO74 Policy LV2: Lee Valley White Water Centre

Sport England is supportive in principle of the development of an ‘adrenaline hub’ around the White Water Centre if this would respond to an identified facility need as this would offer potential to help to grow and sustain participation in the types of sports that an adrenaline hub would cater for as well as complementing and improving the sustainability of the existing facilities.

Support noted. -


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The Lee Valley Regional Park Authority state the further detail should be included as part of Policy LV2: Lee Valley White Water Centre, to allow the development of a masterplan with the Epping Forest District Council for the future development of the White Water Centre and most up to date vision for the site. The Authority recommend the following wording for Policy LV2: Lee Valley White Water Centre The Council supports the development of an adrenaline hub at and around the Lee Valley White Water Centre within the area indicated on the Policies Map as the major family leisure destination within the south east. Its offer will be diversified into ‘extreme’ sports.

As yet it appears that the Park Authority’s position on this is at an early stage and a considerable amount of work needs to be before anything other than outline support in principle can be offered.

Paragraph added.


The Lee Valley Regional Park Authority state that it is developing the Lee Valley White Water Centre as the major family leisure destination in the south east and that working with their leisure trust, Vibrant Partnerships, the will diversify its offer into ‘extreme’ sports. The Authority notes that the centre attracts more than 330,000 visits. The centre is home to British Canoe’s national performance centre for canoe slalom and intends the regional and national event programme will be integral to their plans. The Authority continues by stating that that the centre’s offer reflects two phases of development. The first involved the creation of the centre as an Olympic Venue; this operated for less than two years until the completion of the second or ‘legacy phase’ in 2013. Both phases of development extended the visitor offer focused entirely on paddle sports with

Whilst these points are noted, it is considered that the information contained within the Plan is sufficient for planning purposes.

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recent innovations such as the new beach. The Authority within Lee Valley Leisure Trust, trading as Vibrant Partnerships, is looking at plans for a third phase of development to secure the centre’s reputation for adrenaline sports. Working with its partners the Authority has identified land on adjacent sites for further investment within an ‘opportunity area’. The Trust is scoping the market to look at new attractions which could include zip wires, wave machine and extended beach area.

Paragraph 13.5

13.19 PO391, PO392, PO1472

Paragraph 13.5/Policy LV3: Broxbourne Leisure Pool Site

The Lea Valley Growers Association state that the residents of Broxbourne Borough have lost numerous leisure resources over the years including the excellent Broxbourne Leisure Pool, which was a much loved and well used community facility The Lee Valley Growers Association strongly objects to housing development within the taxpayer funded Lee Valley Regional park. Such developments would be contrary to the Lee Valley Regional Part Act 1966 and require approval from the Secretary of State. The Lee Valley Growers Association believe that the Authority will not be able to demonstrate the special circumstances needed for house building within the Green Belt, and as such would be mindful to oppose such a development by way of a judicial review.

Noted. -

13.20 PO391, PO392, PO1472

Paragraph 13.5/ Policy LV3: Broxbourne Leisure Pool Site

The Lee Valley Growers Association would support the development of affordable agricultural tied properties at this site in line with the Council’s support for rural housing.

Noted. The most suitable type of development for this site will be determined through the masterplanning process that will inform the updated development brief.

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Policy LV3: Broxbourne Leisure Pool Site


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13.21 PO109 Policy LV3: Broxbourne Leisure Pool Site

Funding should be committed to reinstate the Open Air Swimming Pool. Residents currently have to travel to London Boroughs to find an open air swimming pool which creates unnecessary and longer car journeys.

There are currently no plans to reopen the pool.

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The Lee Valley Regional Park Authority state that Policy LV3 identified that there could be potential for housing at the site of the former leisure pool in Broxbourne. Supporting text identifies that the Council’s adopted development brief previously ruled out housing, however, the policy identifies that the adopted brief will be updated to identify potential for housing “to enable the wider development and improvement of the site”. Officers consider that although large parts of the site lie within Flood Zone 3 there is considerable scope for its development given that it previously was identified as a ‘major development site’ in the Green Belt.

The site is heavily constrained and a significant amount of further work would be needed before significant development could be accepted.

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Hertfordshire County Council notes that Policy LV3 includes the potential for residential development at the Broxbourne Leisure Pool Site. The County Council states that it would be useful to have an indication of the scale of housing to be able to assess the impact upon HCC services, particularly school places.

No dwelling numbers have been proposed as part of this Local Plan.

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The Environment Agency comment that this is a potentially difficulty site as it falls completely within the floodplain. Careful consideration will be needed to match the land use to the level of flood risk including an appropriate allowance for climate change.

Noted. -


The Environment Agency state that enhancements must be made to the watercourse to provide a net gain in biodiversity. There is potential for ponds and wetlands to be created on site.

Noted. The opportunities to improve the watercourse at this site will be explored through updating the development brief. The adopted development brief explores the option to create a new

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wetland habitat incorporating a network of wet meadows, ditches, ponds and wet woodland. This development option will be revisited as part of updating the development brief.

Policy LV4: Spitalbrook

13.26 PO442 Policy LV4: Spitalbrook

Kings Arm and Cheshunt Angling Society agree with the need to regenerate the area but needs improved vehicular access to and across the site. There are opportunities to open up the area for angling use as part of this site.

This will be revisited as part of updating the development brief.

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The Lee Valley Regional Park Authority state that whilst the inclusion of a policy relating to Spitalbrook is welcomed the following amendments are needed to ensure the policy reflects PDF Area proposals for the site and the Spitalbrook Environmental Strategy and masterplan commissioned and adopted by the Authority in November 2012. The Authority recommend the following wording for Paragraph 13.6: The Spitalbrook are to the north of Nazeing Road in Broxbourne had been identified as the original site for the Lee Valley White Water Centre. However, this was abandoned because of contamination from historic landfill. The now sites as a largely inaccessible area of un-reclaimed dereliction and scrubland. Spitalbrook has clear potential for regeneration and involving the restoration and enhancement of existing and the creation of new, wildlife habitat together with new public access provision for recreation and nature conservation purposes. These changes will only be financed if parts of the site can be released as

Noted. Clarification added to policy


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‘enabling development’. Although the land is designated green belt it had been considered in 2004-05 for the site of the Olympic White Water Centre; a precedent for major development has been established in this regard. with limited expenditure on land reclamation.


The Authority recommends the following wording for Policy LV4: Spitalbrook The Council will work with the Park Authority and the site owners other stakeholders to restore, manage and protect habitats at Spitalbrook as a site of special biodiversity interest with visitor access. This could be delivered through enabling development on the site linked with the opportunities which Cross Rail 2 could realise and put in place a reclamation scheme for the Spitalbrook area.

Noted. Clarification added to policy and supporting text.


Hertfordshire County Council supports the aim to work with LVRP to secure a reclamation scheme for the Spitalbrook site. The existing undisturbed rough grassland and scrub is likely to represent a locally valuable ecological resource in the context of the Lee Valley and this aspect should be recognised in any proposals.

Support noted. -


The Environment Agency is supportive of new wildlife habitat creation at this site.

Support noted. -

Paragraph 13.7

13.31 PO1375 Paragraph 13.7 Hertfordshire County Council anticipates that the demand for primary schools places arising for the 114 dwellings proposed on this site could be met in existing schools in Waltham Cross.

Noted. -

Policy LV5: Lee Valley Park Gateways

13.32 PO443 Policy LV5: Lee Valley Park Gateways

Kings Arm and Cheshunt Angling Society state that this is critical for existing users and must include protecting existing vehicular access routes as in the

Noted. The draft Local Plan sets out the general principles. If Level Crossings need to be closed for safety

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event of an emergency arising with a use of the park, the inability to get an ambulance to a casualty could have a fatal impact to them. Also owners or users of properties between the railway line and canal have to be protected from being unable to gain access to them due to Crossrail 2 changes.

reasons then there will need to be detailed plans would out for each closure, and consultation on each one. In each case Network Rail will lead on this as the relevant body.


Kings Arm and Cheshunt Angling Society would welcome additional access points, particularly vehicular ones as it would enable the less able to access the park easier.

At present there are no plans for additional vehicular access points. As identified in the policy, the Council will work with the Lee Valley Regional Park Authority to improve public access routes into the Park.

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Hertfordshire County Council (Public Health Service) state that they have already responded to the Lee Valley Park Authority’s consultation on its Development Framework, outlining the need to prioritise pedestrian and cycle access routes into the Park over vehicles, in keeping with the Park’s values as a leisure and recreation amenity, and to promote physical activity within the local community.

Broxbourne Council’s Local Cycling and Walking Infrastructure Plan (2017) also addresses this point.

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Natural England broadly supports policies which encourage access to nature and green space. However, Natural England notes that given the level of environmental protection that the Lee Valley enjoys, all proposals within or in close proximity to Special Protection Area (SPA)/Ramsar/Site of Special Scientific Interest (SSSI) should be mindful of impacts on the species for which designation are notified and may require a Habitats Regulation Assessment.

Support noted. The Council is working with Natural England to prepare a Habitats Regulations Assessment which includes assessment of the impacts of development on the SPA.

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Chapter 14: Countryside

Issue No.

Comment ID(S)


Issue Officer Response Proposed amendment to the

Plan

General

14.1 PO1376 Chapter 14 - Countryside

Hertfordshire County Council (Development Services) has no comments to make on this chapter.

Noted -

Paragraph 14.2


Concern that there is Green Belt development The Council has tried to utilise all brownfield land as far as possible, however, these sites cannot accommodate the entirety of the borough’s identified development. Development of Green Belt land is therefore necessary to meet the borough’s identified development need. The adoption of a strategy where no Green belt land was built on would result in a severe undersupply of housing and long-term stagnation of the borough.

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Policy CS1: Cheshunt County Club

14.3 PO75 Policy CS1: Cheshunt Country Club

Sports England state that the site provides playing fields that have been used by the community for many years. Future proposals for the site should be specifically required to safeguard the playing fields for community use or ensure that acceptable off-site mitigation is secured in accordance with the Plan’s policies and paragraph 74 of the NPPF. Sport England request that the supporting text to the policy is amended to recognise and address this.

Agreed. The Council agrees that a reference to the current leisure/recreational use of the club will be beneficial within the supporting text. However, the Council believes that there is no need to make reference to the need to safeguard or ensure that alternative provision is provided within the supporting text. Any proposals to close recreational and leisure facilities are required to be considered against the provision of Policy ORC2: Loss of Open Space, Leisure, Sport and Recreational Facilities. It is acknowledged that this policy requires some amendment to ensure that the impacts of closures or reductions in services

Paragraph 14.3 The only significant development issue is the future of the Cheshunt County Club at Theobalds Park which is owned by Tescos. The site currently has a number of facilities, including a pavilion and sports pitches.


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are properly examined.

14.4 PO2095, PO2097, PO2099, P02104, PO2106, PO2184, PO2107, PO2109

Policy CS1: Cheshunt County Club

Policy CS1 is too ambiguous and should be deleted. The promoter considers the provides a window of opportunity to discuss the future of the site and states that it is important to acknowledge the Council’s aspirates to secure a sustainable future for the Club which is compatible with the countryside location The promoter considers that the most sustainable approach for the development of this site is for its inclusion within the allocation for Park Plaza West (PP1) for up to 200 new homes to act as enabling development to for the proposed new and significantly enhanced community sport facilities to be provided at Theobalds Sports Ground. A number of reasons were provided for the sites inclusion with PP1 for residential development. These reasons were:

The surrounding areas of Cheshunt, Waltham Cross and Churchgate ensure that the site benefits from good access to schools, public transport, local facilities and employment opportunities.

The principle of developing the site has been establish through of planning application 07/10/0019/F (Renewal of Planning permission 07/0504/06/F/WX for the redevelopment of existing sports and social club to provide training academy with ancillary overnight accommodation and associated parking facilities). The

The Council has recently completed an update on its Strategic Land Availability Assessment (SLAA). As part of this update, all sites included within the previous SLAA (April 2016) and those promoted to the Council during the 2016 Call for Sites were assessed. The SLAA concluded that this site (WX-GB-03) is not suitable for development due to the following reasons: the site performs a strong role under Green Belt purpose 1 and therefore merits retention; it is considered that the site does not have strong Green Belt boundaries that would last beyond the Plan period or prevent further encroachment; and, the site is not considered to be in a sustainable location for residential development as it is currently severed from local facilities by the A10. The site was also assessed in the Council’s Green Belt Topic Paper (2017), which draws on the available evidence as well as the evidence of the emerging strategy underpinning the Local Plan to reach a balanced judgement as to whether there are specific locations where necessary exceptional circumstances exist to suggest that Green Belt should be released for development. For this site, the Topic Paper concluded that site scores poorly on a number of criteria including transport and sustainable place-making and that it is located on the ‘wrong’ side of the clear Green Belt boundary provided by the New River. The Topic Paper continues by stating that the site “is closely related to the Theobalds Park area of woodland and

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following very special circumstances for development in the Green Belt were considered to be acceptable to the Council

o The overwhelming need for the facility

o The functional requirement for the proposal to be sites as close as possible to existing office locations of the applicants

o The lack of alternative, suitable locations in the area for this training facility

The site can deliver a range of significant positive impacts relating to social, economic and environmental factors, especially in contributing to the housing development needs of the borough.

The proposals for the site will achieve the objectives set out in Paragraph 2.2 of the draft Local Plan. Therefore it is consistent with the Local Plan strategy

Development at the site will represent sustainable development.

The development will provide a footbridge/cycleway from the Theobalds Site to the Park Plaza West site. This should be included in Policy PP1.

The site and proposals do not include any significant retail or town centre us offer and therefore there will be no detrimental impact

The Country Clubhouse is considered to

countryside. The draft Local Plan Policy CS1 proposes that ‘the Council will work with the landowner to secure a sustainable future for the Cheshunt County Club that is compatible with its countryside location’. It is not considered that removal of Green Belt designation is necessary in order to achieve this objective.”


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be of low quality and is relatively poor in condition. The inclusion of the site by the Council within draft Policy CS1suggests the need for development.

The site and proposals will not have any additional impact on surrounding roads as there is already an established recreational use on site and it is currently operational. The site will be able to benefit from the transport improvements proposed as part of Park Plaza West development. Ensuring the site is well integrated and connected to the Park Plaza proposals is a priority.

The site makes a limited or no contribution to Purpose 1, 24 and 5 of the Green Belt. It makes a Partial/Limited or No Contribution to Green Belt Purpose 3.

The site has clearly defined and permanent boundaries

The site is considered to have a mixed level of openness:

o Mixed/Low Level of Visual Openness – due to limited views as the site is relatively flat on lower ground and mainly enclosed by landscape (strong existing planting)

o Mixed level of physical openness – due to the presence of limited built development on site combined with close by prominent urban influences including the B198 and A10

The site and proposals would include


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the enhancement of the recreational activities currently on site. The enhanced sports facilities will cater for seniors and juniors and replace existing provision which in poor condition. Paragraph 89 of the NPPF states that the provision of appropriate facilities for outdoor sport and outdoor recreation are appropriate development within the Green Belt. The proposals would also enhance the site and potentially provide opportunities for improved biodiversity along the New River.

The development proposals for the site would represent sustainable place making.

o Place Creation – proposals would seek to deliver high quality design. A landscape-led approach to the site has been adopted to respect the site and surrounding characteristics.

o Strong connection to existing place and/or creation of new place - the proposed mix of land uses and quantum of development provide the opportunity for high quality place-making which maintains the hub of activity through the sports facilities as well as providing an new residential environment.

o Strong mix of uses and facilities – the site would seek to deliver


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residential land uses, community sport facilities and an element of retail/community space on site. The level of development aims to meet local needs and support and complement Park Plaza West.

o Inclusion and/or accessibility to shops – the scheme will provide an element of retail space that would be designed to meet local needs

o Inclusion and/or accessibility to schools – the nearest secondary school is 520m away and the nearest primary school is 920m away.

o Inclusion of and accessibility to sports, recreation, open space and countryside – the proposals have been designed to include enhanced sports facilities which would provide excellent access to recreation space

o Inclusion of other services and/or accessibility to other services – the adjacent development at Park Plaza West will offer accessibility to a range of other services.

Design, landscape and biodiversity- the site proposals will encompass high quality design which takes into account the design principles that are to be implemented at Park Plaza West. The site and proposals will meet the


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standard set out in local policy and the characteristics associated with the Green Belt will inform the level, layout and design of the landscaping scheme. The biodiversity at the site will be maintained and enhanced through a planting scheme along the eastern boundary.

The site is in single ownership. It has become surplus to requirements. The site can be brought forward in the short term.

There site is considered to be achievable. There are no known constraints in relation to access and the site is not at risk of flooding. Given the proximity of the existing urban area and existing activities on site, utilities provision is expected to be possible however detailed investigation or correspondence with providers has not been undertaken.

There are no key issues identified in terms of viability and therefore the site is considered to represent a viable development option.

In spite of its Green Belt designation, the Council has previously identified the site as being next to a broad “Employment Area of Search/4C Park Plaza West” in the Core Strategy (2010). This demonstrates that the site location is considered to be suitable and provides an opportunity for future development. It is close to existing settlements and planned employment


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activities at Park Plaza.

The proposals will strengthen the sustainability credential of Policy PP1: Park Plaza West, by introducing residential and community sport use

The site will provide residential development including affordable housing provision to meet local needs.

Developer contributions towards local services and infrastructure e.g. proposed Park Plaza railway station.

Paragraph 14.4


Concern that the Plan is over developing this area and losing important green areas forever. The whole plan shows a disregard for quality of life, whilst prioritising money.

The Council has tried to utilise all brownfield land as far as possible, however, these sites cannot accommodate the entirety of the borough’s identified development. Development of Green Belt land is therefore necessary to meet the borough’s identified development need. The adoption of a strategy where no Green belt land was built on would result in a severe undersupply of housing and long-term stagnation of the borough. The Council has sought to promote sustainable patterns of development in its review of the Green Belt boundaries, in accordance with Paragraph 84 of the NPPF.

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Paragraph 14.5


- - -

Policy CS2: Countryside Protection and Enhancement

14.7 PO444 Policy CS2: Countryside Protection

Kings Arm and Cheshunt Angling Society support the policy providing that access is not reduced below current level

Support noted. The Council does not anticipate there to be any reduction in access below the current level.

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and Enhancement

14.8 PO743 Policy CS2: Countryside Protection and Enhancement

Policy CS2, paragraph 14.5 and paragraph 5.24 of the Plan specify sites that will be protected and enhanced as a result of the garden suburb development, including Turnford Brook. The enhancement of Wormleybury Brook should be included in Policy CS2

Agreed. Wormleybury Brook added to policy CS2.

14.9 PO987 Policy CS2: Countryside Protection and Enhancement

Welwyn Hatfield Borough Council note that the Council’s Goffs Oak Development Options Report notes that the Goffs Oak area is characterised by a dispersed and patchy settlement pattern, and that this is partly a legacy of the horticultural glasshouse industry which sprawled across the area in the first half of the 20th century but has since largely died out. Dereliction has previously been addressed through housing redevelopment, resulting in Goffs Oak coming very close to coalescing with Cheshunt, a process which in turn would result in Cuffley only being separated by a few hundred metres from the edge of the London Urban Area. Welwyn Hatfield Borough Council welcomes the Council’s recognition of this reality, and support this policy’s intention to protect and enhance Green Belt land in the Goffs Oak area. The provision of public access and enhanced habitats in this area will give it greater value, and in turn aid its defensibility in Green Belt terms

Support noted.

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14.10 PO1790 Policy CS2: Countryside Protection and

Hertfordshire County Council supports the aim of this policy - the open countryside west of the Lee Valley is highly important to the urban corridor and the quality of the countryside

Support noted.

Clarification added that some of the areas identified will be addressed through the implementation of development


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Enhancement beyond. It includes biodiversity and landscape resources, some of which is of international importance (Special Area of Conservation). However, Hertfordshire County Council state that this policy requires further supplementary detail to demonstrate what and how it is to be achieved.

proposals set out in the Plan.

Paragraph 14.8


The Hoddesdon Society comment that should the Hertfordshire be developed as a hotel then the Council should aim to have dedicated access from the A10 to protect rural roads.

Full planning permission has been granted for the “Removal of a tennis dome and replacement with a two storey building to provide 72 hotel bedrooms, alterations to mansion to provide 23 hotel bedrooms, relocation of 20 parking spaces and lower ground extension to provide gym, dance studio and changing rooms and conservation of existing outbuilding to provide golf pro shop and spike bar”. As detailed in the Case Officer’s report for this application, the information submitted on traffic generation and car parking from the application was assessed by the Local Highway Authority which considered that White Stubbs Lane has sufficient capacity to accommodate the level of traffic generated. The Council’s highway engineer also raised no objection subject to a condition to cover details of the drainage on the site. In light of the above, the Council does not consider it necessary to create a dedicated slip road from the A10 to serve this development.

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Chapter 15: The New River Issue Number

Comment ID(S)


Issue Council Response Proposed Amendments to the Plan

15.1 PO690 15 The New River should be designated as a linear park that is managed by a partnership of interest parties, including the Lee Valley Regional Park Authority.

The New River is owned and maintained by Thames Water.

-

15.2 PO609, PO862

15 There are many areas along the New River where the pathways and river banks are in a poor state. Major investment would be required to improve and upgrade the New River pathways and banks. There are concerns that whilst Thames Water has sole responsibility these improvements will not occur.

The Council will continue to work with Thames Water and Hertfordshire County Council to improve and upgrade the New River Pathways.

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15.3 PO813 Paragraph 5.2 Deletion of the New River Green Chain The Council considers the New River is an asset which makes a valuable contribution to the character of those parts of the Borough that it passes through and provides a continuous green link with adjoining administrative areas. The Council will continue to ensure that the New River maintains an open character, amenity and wildlife value is protected.

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Policy NR1

15.4 PO862 Policy NR1 Historic England welcomes the proposals at paragraphs 15.4, 15.5 and policy NR1 to explore the potential for a Conservation Area along the course of the New River to provide an appropriate level of protection to the historic artefacts along it.

Support noted. -


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15.5 PO1913 Policy NR1 Thames Water Utilities Limited are concerned about the following statement: “The Council will commission a conservation area appraisal to assess the merits of extending the New River Conservation Area along the length of the New River”. Thames Water Utilities Limited note that the New River is an operational asset that is used for water supply, therefore there is concern that if the New River becomes a Conservation Area it may restrict certain regular operations that currently do not require consent such as general tree pruning.

The Council does not consider that maintenance of the New River would be compromised by the designation of some or all of it as a Conservation Area.

-

15.6 PO1954 Policy NR1 The Environment Agency comments that it would be good to state buffer zone creation/protection as part of this policy, and this should be specifically included within the New River Conservation Area Study, along with the possibilities of renaturalising modified river banks.

Creation of an arbitrary buffer zone is not considered appropriate. The New River is an historic asset and renaturalisation is not considered appropriate since it was never natural.

-

15.7 PO1989 Policy NR1 It is considered that the southern part of the New River is unlikely to be suitable for conversation area designation, including where it runs through open countryside from the south boundary, past Park Plaza West. There is no historical connection between the New River and this land beyond its physical presence and none of the surrounding areas are of special architectural or historical interest as defined in statute or national policy.

The entire length of the structure is considered historic and therefore a survey and appraisal will be undertaken, and additional requirements added to the policy.

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Policy NR2


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15.8 PO76 Policy NR2 Sports England comment that the proposals to improve walking and cycle path access to the New River and welcomed in principle as this will provide new and enhanced opportunities for physical activity in close proximity to the urban areas of the Borough.

Support noted. -

15.9 PO103 Policy NR2 The creation of a cycle path along the New River will need to be done sensitively with minimum removal of the green banks and local wildflowers.

Agreed. The Council will continue to work with Hertfordshire County Council and Thames Water Utilities throughout the implementation of the proposals to ensure that the path is sensitively designed and has minimal impact on the local environment and character of the surroundings or the New River.

-

15.10 PO331 Policy NR2 Supportive of the creation of a new cycle path along the New River however there is concern regarding the provision of safe cycle routes for cyclists to access this cycle path.

The Council’s Local Cycling and Walking Infrastructure Plan has identified this area as a strategic walking and cycling corridor, with a study ‘New River Path Hoddesdon to M25 Feasibility Study’ being undertaken to examine the practicalities of implementation of a shared cycle/footpath.

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15.11 PO812 Policy NR2 The current path along the New River does not allow both cyclists and walkers to use the path at the same time. Concern that to allow cycling along the New River it would be necessary to widen the path which would entail the removal of historic iron kissing gates and massive widening of the banks. The iron railings that run along the east side of the New River would have to be removed in some places.

The New River Feasibility Study draws attention to the differing widths of the path and various constraints along the route. More detailed analysis and consultation will be needed before any specific proposals are implemented. The kissing gates are considered to be of limited historic value and their retention would conflict with wider aspirations for the corridor.

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15.12 PO2073 Policy NR2 The Lee Valley Regional Park Authority supports Policy NR2. The Authority notes that the New River runs alongside and close to the Park boundary at Broxbourne Meadows, Admiral’s Walk Lake ad at the Turnford Surfacing, Rye House and Rye Meads area. The Authority requests that the promotion and improvement of links with the Park should be mention in the supporting text to the Policy.

Support noted. The location of the Park Gateways are shown on the Policies Map.

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15.13 PO2125 Policy NR2 The Public Health Service comments that Policy NR2 is commendable in its aim to promote improved walking and cycle access. The detail supporting the policy should ensure that any development adjacent to the New River also provide appropriate connections and signage to the path so as to increase its use.

The New River Path has been identified as a strategic corridor within the Council’s Local Cycling and Walking Infrastructure Plan. The strategy provides detail on the priority interventions for this corridor, which includes creating access from the proposed new developments to the path and improved signage.

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Issue Number

Comment ID(S)


Issue Council Response Proposed Amendments to the Plan


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15.1 PO690 15 The New River should be designated as a linear park that is managed by a partnership of interest parties, including the Lee Valley Regional Park Authority.

The New River is an operational asset used by Thames Water.

-

15.2 PO609, PO862

15 There are many areas along the New River where the pathways and river banks are in a poor state. Major investment would be required to improve and upgrade the New River pathways and banks. There are concerns that whilst Thames Water has sole responsibility these improvements will not occur.

The Council will continue to work with Thames Water and Hertfordshire County Council to improve and upgrade the New River Pathways.

-

15.3 PO813 Paragraph 5.2 Deletion of the New River Green Chain The Council considers the New River Green Chain to be an asset, which makes a valuable contribution to the character of those parts of the Borough that it passes through and provides a continuous green link with adjoining administrative areas. The Council will continue to ensure that the new River Green Chain open character, amenity and wildlife value is protected.

-

Policy NR1

15.4 PO862 Policy NR1 Historic England welcomes the proposals at paragraphs 15.4, 15.5 and policy NR1 to explore the potential for a Conservation Area along the course of the New River to provide an appropriate level of protection to the historic artefacts along it.

Support noted. -

15.5 PO1913 Policy NR1 Thames Water Utilities Limited are concerned about the following statement: “The Council will commission a conservation area appraisal to assess the merits of extending the New River

The Council does not consider that maintenance of the New River would be compromised by the designation of some or all of it as a Conservation Area.

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Conservation Area along the length of the New River”. Thames Water Utilities Limited note that the New River is an operational asset that is used for water supply, therefore there is concern that if the New River becomes a Conservation Area it may restrict certain regular operations that currently do not require consent such as general tree pruning.

15.6 PO1954 Policy NR1 The Environment Agency comments that it would be good to state buffer zone creation/protection as part of this policy, and this should be specifically included within the New River Conservation Area Study, along with the possibilities of renaturalising modified river banks.

Creation of an arbitrary buffer zone is not considered appropriate. The New River as an historic asset and renaturalisation is not considered appropriate since it is not natural.

-

15.7 PO1989 Policy NR1 It is considered that the southern part of the New River is unlikely to be suitable for conversation area designation, including where it runs through open countryside from the south boundary, past Park Plaza West. There is no historical connection between the New River and this land beyond its physical presence and none of the surrounding areas are of special architectural or historical interest as defined in statute or national policy.

The entire length of the structure is considered historic and therefore a survey and appraisal will be undertaken, and additional requirements added to the policy.

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Policy NR2

15.8 PO76 Policy NR2 Sports England comment that the proposals to improve walking and cycle path access to the New River and welcomed in principle as this will provide new and enhanced opportunities for

Support noted. -


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physical activity in close proximity to the urban areas of the Borough.

15.9 PO103 Policy NR2 The creation of a cycle path along the New River will need to be done sensitively with minimum removal of the green banks and local wildflowers.

Agreed. The Council will continue to work with Hertfordshire County Council and Thames Water Utilities throughout the implementation of the proposals to ensure that the path is sensitively designed and has minimal impact on the local environment and character of the surroundings or the New River.

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15.10 PO331 Policy NR2 Supportive of the creation of a new cycle path along the New River however there is concern regarding the provision of safe cycle routes for cyclists to access this cycle path.

The Council’s Local Cycling and Walking Infrastructure Plan has identified this area as a strategic walking and cycling corridor, with a study ‘New River Path Hoddesdon to M25 Feasibility Study’ being undertaken to examine the practicalities of implementation of a shared cycle/footpath.

-

15.11 PO812 Policy NR2 The current path along the New River does not allow both cyclists and walkers to use the path at the same time. Concern that to allow cycling along the New River it would be necessary to widen the path which would entail the removal of historic iron kissing gates and massive widening of the banks. The iron railings that run along the east side of the New River would have to be removed in some places.

The New River Feasibility Study draws attention to the differing widths of the path and various constraints along the route. More detailed analysis and consultation will be needed before any specific proposals are implemented. The kissing gates are considered to be of limited historic value and their retention would conflict with wider aspirations for the corridor.

-

15.12 PO2073 Policy NR2 The Lee Valley Regional Park Authority supports Policy NR2. The Authority notes that the New River runs alongside and close to the Park boundary at Broxbourne Meadows, Admiral’s Walk Lake and at the Turnford Surfacing, Rye House and Rye

Support noted. The location of the gateways is shown on the Policies map.

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Meads area. The Authority requests that the promotion and improvement of links with the Park should be mention in the supporting text to the Policy.

15.13 PO2125 Policy NR2 The Public Health Service comments that Policy NR2 is commendable in its aim to promote improved walking and cycle access. The detail supporting the policy should ensure that any development adjacent to the New River also provide appropriate connections and signage to the path so as to increase its use.

The New River Path has been identified as a strategic corridor within the Council’s ‘Local Cycling and Walking Infrastructure Plan. The strategy provides detail on the priority interventions for this corridor, which includes creating access from the proposed new developments to the path and improved signage.

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Chapter 16: Gypsies, Travellers, and Travelling Showpeople

Issue No.

Policy/ Para. no.

Commt. ID(s)


16.1 16 PO1711 Welwyn Hatfield Borough Council Welcomes the intention to meet identified need for new Gypsy and Traveller pitches, however are concerned that the way need has been determined is not compliant with national policy and may be an under-estimate, in addition, are concerned that the associated policy wording is not compliant with national policy

The Gypsy and Traveller Needs Assessment (April 2017) updates the technical work to bring the Council’s evidence base into compliance with national policy.

-

16.2 16 PO1378 Hertfordshire County Council Property Development Services Welcomes proposal to increase the number of pitches in the Borough. Details of the relocation of the Halfhide Lane site are currently being negotiated

Support noted. -

16.3 16 PO2230 Broxbourne Woods Area Conservation Society Regarding the proposed new Traveller site at Hells Wood – it would be more sensible to leave or even extend existing sites in the Borough. Concerned about problems experienced with Traveller sites in the past. Broxbourne Woods National Nature Reserve does not want a site here – does not believe the travellers do either

The Local Plan proposes that the Halfhide Lane travellers site be relocated to Park Lane Paradise and not to Hell Wood. The Council is aware of the potential for residential development to create issues in respect of wildlife management and will consider any implications in the detailed planning of this site.

-

16.4 16.4 PO17, PO293, PO679, PO187, PO673, PO674, PO919, PO1433,

Various residents who strongly object to the proposed expansion of the existing St James Road gypsies/travellers site as they feel it will:

- Have a negative impact on property values

- Ruin the village feel of St James Road - Lead to increase in existing anti-social

behaviour, noise levels, safety risks to

Text and policies map have been amended to make clear that no further expansion of the site is required.

Text amended to clarify that limited scope to accommodate additional pitches for defined travellers within that community. No further expansion of the site is required.


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PO1437, PO1435, PO2162, PO2164 PO335

local residents, crime, flytipping - Add further traffic onto St James Road

which is a rural road with poor visibility and narrow bends

- Lead to the site escalating and becoming very large

- Encourage unauthorised expansion of the site which they say has already taken place (currently nine caravans when there was only permission for three – they say no notification was provided to them on this)

Also note that traveller sites are considered to be inappropriate development in the Green Belt.

16.5 16.4 PO17 The Council should shut down the existing site on St James Road and relocate the existing caravans onto the new site within the Brookfield development

The site is privately owned. -

16.6 16.4 PO20 There is currently a good relationship with the existing travellers and the residents of St James Road but that any expansion will put strain on these relations and add more traffic problems

The Policies Map has been amended to indicate that no expansion of the site is proposed.

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16.7 16.5 PO307 Concerns in relation to this consultation process and the planned relocation of traveller community to the end of Beaumont Road. Residents of Beaumont Road were not informed of the consultation meeting at Wolsey Hall. Feels questions were not handled appropriately at the meeting and residents were cut off and not given chance to ask supplementary questions. Summary leaflets received do not make clear that the plans include relocation of traveller community to the end of Beaumont Road. Consultation needs to be more effective.

Residents responded to the consultation and concerns have been listed to. There is a need to relocate the Travellers site and the site identified is considered to be the best available option.

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16.8 16.5 PO307 Concerns with regard to relocation of traveller community to the end of Beaumont Road. This will have a significant visual impact on the area and in terms of pedestrian and vehicular traffic. Clarification needed with regard to what screening, infrastructure and facilities will be put in place for travellers and existing residents.

The site will be fully serviced, with links into the Brookfield development. The site site in the gap between existing woodland blocks and will be screened.

-

16.9 16.5 PO307 If traveller community is relocated here there will be a significant increase to local vehicular and pedestrian traffic which means Park Lane Paradise will need upgrading and calming – there have already been accidents here as it is used as a rat run

Noted. These details may be addressed as part of any planning application.

-

16.10 16.5 PO307, PO7

There needs to be a proper consultation with the traveller families and the local community with a wider range of locations considered and clearer information on how the Council proposed to support the travelling community in the relocation, and with an indication of time scales/funding.

Consultation was undertaken as part of the update of the Gypsy and Traveller Needs Assessment (April 2017).

16.11 16.6 PO856, PO7

Queries the number of pitches that are needed – if there are currently 87 why do 40% more need to be found. This point needs greater details and explanation

Details are set out in the Gypsy and Traveller Needs Assessment (April 2017)

-

16.12 16.6 PO856 Concerned that travellers have been allowed to stay illegally here for a long period of time without formal authorisation

Some pitches have obtained certificates of lawfulness, whilst others have not. The proposals are intended as a practical way forward.

-

16.13 Policy GT1: Gypsy and Traveller Sites

PO7 It needs to be demonstrated that the Council has worked with the Gypsy and Traveller community in drafting this policy

Consultation was undertaken as part of the update of the Gypsy and Traveller Needs Assessment (April 2017).

-

16.14 Policy GT1: Gypsy and

PO7 Identified need should be expressed as a minimum need

Not agreed. -


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Traveller Sites


PO537 East Hertfordshire District Council Supports the Borough’s commitment to meeting the needs of Gypsies and Travellers in full, but 2014 Accommodation Needs Assessment pre-dates the latest Government guidance and therefore recommends an up-to-date study be undertaken to assess current and anticipated needs

The Needs Assessment was update in April 2017.

-


PO677 Three Rivers District Council The proposed allocation of 46 traveller pitches under Policy GT1 appears to be in response to your Accommodation Needs Assessment showing a need to provide 31 additional traveller pitches within the Borough over the plan period

The Needs Assessment was updated in April 2017.

-


PO994 PO7

Welwyn Hatfield Borough Council The policy states that new pitches ‘are not to meet the needs of extended family members not currently resident within the Borough of Broxbourne’. By definition in the Government’s 2015 Planning Policy for Traveller Sites, Gypsies and Travellers must lead a ‘nomadic habit of life’. Restriction of new pitches to people already living in Broxbourne would run counter to this definition, and mean that neighbouring authorities would find themselves having to meet the need of those who actually travel. Also, in the same way as for the ‘settled’ population, migration (and not just natural change in the population) must be a factor in establishing need for Gypsy and Traveller pitches. It is considered that this sentence should be removed. Resident of Wharf Rd agrees, and says it would be

The policy is written to ensure that local needs are addressed in accordance with the Council’s needs assessment. It is not proposed to amend this part of the policy.

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subject to legal challenges as a similar restriction does not apply to the resident population - see R (VC) v North Somerset Council (Equalities and Human Rights Commission Intervening) CO/3801/2015


PO994 Welwyn Hatfield Borough Council The Policy should have considered whether an uplift needs to be made for needs emerging from the county’s transit site at South Mimms. As a result, we consider that you may have underestimated your need for Gypsy and Traveller pitches and would therefore not be meeting your need in full.

The Council is addressing its needs and does not propose to make specific provision for a transit site.

-


PO2074 Lee Valley Regional Park Authority Objects to Policy GT1 Gypsy and Traveller Sites bullet point 4) and the policy map designation GT1, which seeks to establish an authorised Gypsy and Traveller site at Wharf Road in the Regional Park on Green Belt land, as it is inappropriate in terms of Green Belt policy, contrary to Park Plan and PDF proposals and undeliverable as much of the site lies in flood zone 3 and the Authority owns the majority of the proposed site. The Authority requests the removal of this bullet point 4).

This Council recognises that the Wharf Road site is becoming increasingly lawful. It has therefore advised the LVRPA that the establishment of a permanent site is the only practicable way forward and that in the absence of any agreement with the LVRPA to this end, current and future needs will be met through lawful development certificates, planning permissions and caravan site licences at Wharf Road. Officers and senior Members from both the Council and the Park Authority have met to discuss this and discussions are ongoing. Despite these discussions, to date no satisfactory alternative has been identified.

-


PO7 Resident comments – unclear how site at Wharf Road will be funded/managed, whether there will be a choice of tenure/site, how/whether the families at Wharf Road have been consulted on

In the absence of agreement with the LVRPA, liaison has not taken place with the travellers and the status quo is likely to persist. Should there be agreement, the

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this. Council is looking to the travellers to meet the substantive costs of establishing a permanent site, although other funding sources may be considered. It is anticipated that the site(s) will be managed by the travellers

16.21 16.9 PO912, PO914, PO915

JEA Manning & Sons Ltd Notes that the Council recognises the existence of their client’s travelling showpeople’s site on land south of Goffs Lane, and has allocated the land as such in the accompanying Proposals Map. Access from the proposed new site would be via the client’s site – therefore request that access arrangements are discussed in due course.

Noted. -

16.22 16.9 PO788, PO982, PO1035, PO908, PO1205, PO1206, PO795, PO1034, PO979, PO793

The site to the south (Hollowleys Nursery) is in private ownership and would require CPO to purchase. The landowner does not wish to vacate and has never agreed to do so. The statement in the Plan requires correction

Noted. Text and policies map amended to clarify that the need for Travelling Showpeople can be met within the land owned by the current site operators.

16.23 Policy GT2: Extended Travelling Show-people Site

PO796, PO981

Plan appears to support giving planning permission to land occupied by private individuals not connected to the travelling showpersons with a clear family connection to the Borough of Broxbourne



PO908, PO2166, PO979

More suitable alternative travelling showpeople’s sites could be found at Maxwells Farm on the A10, Goffs Oak travellers site or the site close to Broxbourne Zoo, or by expanding the current site into Bonneygrove Field on the opposite side of

Alternative sites are problematic and the site owner does not wish to relocate.

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Lieutenant Ellis Way


PO1207 Hollowleys nursery - believes the site to be brownfield land, Policy states that it is Green Belt. If it is Green Belt why would it be suitable for caravans, lorries, fairground equipment and so on

The site is an established use dating back to a permission granted in 1985.

-


PO1586 Concerned about the proposed expansion of this site, believe there is no scope for expansion here



PO2166, PO795, PO793

The former Hillside Nursery site is privately owned and not available as an extension to the travelling showpeople’s site.



PO795 The current Travelling Showpeople site on the western corner of Lieutenant Ellis Way and Goffs Lane has previously been indicated as a possible site for 45 residential dwellings. In this case the Showpeople should find alternative accommodation for themselves and there is no obligation on the Borough to find an alternative site

HGV access not possible to the alternative site.

Text and policies map amended to clarify that the need for Travelling Showpeople can be met within the land owned by the current site operators.

16.29 16.10 PO286 Would be best if Travellers could be kept together as a community

Agreed. The plan proposes to do so at the existing site.

-

16.30 16.10 PO1037, PO793

Objects to suggestion that a CPO might be used for owners of privately owned sites

This is a misreading of the paragraph. -


PO7 There is a pressing need for more transit sites especially given the need for Gypsies and Travellers to still travel for work

The Gypsy and Traveller Needs Assessment (April 2017) found no evidence of such a need.

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Chapter 17: Infrastructure

Part 1: Issues raised through the Regulation 18 Draft Local Plan consultation

Issue No.

Policy/ Para. no.

Commt. ID(s)


17.1 17 PO78 PO710

Sport England and Enfield Council Concerned over the omission from the infrastructure chapter of a section on open space, sport and recreation which forms an important part of community infrastructure

Agreed. A section will be added on Open Space and Green Infrastructure.

Section added on Open Space and Green Infrastructure

17.2 17 PO98 PO845

Concerned that if the 7,000 new homes indicated in the Local Plan are approved it will have a major effect on infrastructure that is already under pressure

This is addressed through the Infrastructure Delivery Plan as stated.

-

17.3 17 PO99 There is no assessment of the effects of neighbouring authorities’ Local Plans which total 105,811 new homes in the area – has the Council taken into account the effect these will have on local services and infrastructure

The cumulative effects of development in the surrounding area have been taken into account as part of the work on the Infrastructure Delivery Plan.

-

17.4 17 PO102 Feels that the central government should provide all of the funding for new services and infrastructure associated with new homes being built in the area

Central government (mainstream) funding provides a significant proportion of funding but there remains a significant gap.

-

17.5 Policy INF1: Infrastructure

PO995 PO539

Welwyn Hatfield Borough Council Notes the Plan is not currently accompanied by an Infrastructure Delivery Plan nor any real detail on the schemes that will support the growth proposed in the Plan other than the naming of certain locations where improvements may come forward East Herts District Council also recommends an infrastructure delivery plan to support the Local Plan.

An Infrastructure Delivery Schedule has been published alongside the draft local Plan.

-


PO180 Hertfordshire County Council – Spatial Planning GI strategies are also required at a site specific level and proposals should be integrated within masterplans and development briefs for key growth points

This is a matter for detailed site-specific work rather than the Local Plan itself.

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17.7 17.3 PO1030 Conservators of Epping Forest – City of London Developments in Broxbourne will likely have significant impact on the M25 J25 and also on the A121. Traffic model data should be shared with the London Borough of Enfield, Epping Forest District Council and Essex County Council

Broxbourne is part of the oversight group for the Epping Forest Memorandum of Understanding and has made its transport modelling data available for these purposes.

-

17.8 17.7 PO1653 Crest Nicolson Objects to paragraph 17.7 – paragraph refers to the major developments at Brookfield and Rosedale Park and makes reference to possible further improvements to local roads and junctions between Brookfield and Goffs Oak – it should also make reference to the other site allocations west of the A10 so that it is clear that contributions would also be sought from these developments toward such improvements

The paragraph does not imply that contributions will be sought exclusively from the two developments.

-

17.9 Policy INF2: Road Infrastructure

PO51 PO96 PO128 PO227 PO1722 PO300 PO368 PO384 PO2246 PO937 PO863 PO938 PO947 PO1141 PO159 PO1418 PO1564

Road improvements are needed to tackle current congestion and extra congestion that will be caused by further development in the area. Specific improvements proposed for:

a) B156 between Dark Lane and Cuffley Railway Station b) A10 between M25 and Turnford c) A10 junctions at Church Rd and College Rd –

roundabouts/flyovers or tunnels, so that A10 traffic does not have to stop for traffic lights

d) Access to A10/M25 from Park Plaza e) Southbound A10 sliproad at Turnford f) Improvement of roads serving new developments of

500 dwellings or more g) Roundabout at Winston Churchill Way – traffic lights,

box lines etc., as it is dangerous Local Plan makes no mention of upgrading the B156. Two mile stretch of road between Dark Lane and Cuffley Railway Station needs to be improved

This topic is addressed by the draft Broxbourne Transport Strategy (September 2017).

-


PO227 Cycle paths should be added on the side of the A10 Details of proposed cycle paths are contained in the draft Local Cycling and Walking Infrastructure Plan

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(September 2017).


PO300 More work needed on ensuring a robust road infrastructure to support the plans for development at Brookfield and around access to M25 from Park Plaza as both are already traffic bottlenecks at times of heavy demand

This topic is addressed by the draft Broxbourne Transport Strategy (September 2017).

-


PO527 East Hertfordshire District Council The 2015 Broxbourne Borough Council JMP Forecast Report does not take into account the cumulative impacts of development from all the proposed site allocations, nor does it take into account the planned growth of neighbouring authorities

A number of runs of the Broxbourne Transport Model have been carried out to assess the cumulative impacts of development. In addition. The COMET county-wide transport model has also been run. The results are set out in the Transport Modelling technical report which accompanies the Broxbourne Transport Strategy.

-


PO648 Historic England The northern extension of Brookfield Lane West to the Turnford Interchange on the A10 will need to take into account the impact on Hell Wood Moated Site and Enclosure, and its setting – unclear from the proposals map where this proposed extension is going

The road will run to the east of the Moated site. Appropriate mitigations will be provided.

-


PO777 Transport for London – Planning Department Highway improvements or management measures may be required at locations within London to mitigate the impact of development generating new traffic on the A10 corridor – this is of concern to TFL

All data is being shared with the relevant stakeholders. Highways England’s VISSIM model covers both sides of the junction.

-


PO568 No account seems to have been taken of actual and proposed developments to the north – in Buntingford, to the north of Ware, and at Gilston Park (north of Harlow) which will impact on the A10

Account has been taken through the COMET model run, a report on which is available alongside the Broxbourne Transport Strategy (September 2017).

-


PO1895 Transport for London Support for Crossrail 2 and the associated growth agenda needs to be strengthened and clarified in the Plan

The current wording is considered to demonstrate that support.

-

17.17 Policy INF2: Road

PO1062 Regarding M25 J25, the Infrastructure Delivery Plan needs to include an appropriate level of information about the design,

This is included in the Transport Strategy (September 2017) . The

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Infrastructure costs, funding sources, governance and timing of necessary improvements

Council supports Highways England’s design option 2.


PO1319 M25 J25 – cameras need to be installed on the traffic lights to stop drivers driving through red lights, also a box junction to prevent cars from blocking access around the roundabout

The details are being worked out by Highways England which operates this part of the network.

-


PO1450 Proposes that Winston Churchill Way be permanently closed which would result in improved traffic flow along the old Cambridge Road to Cheshunt and Broxbourne to the north

The draft Transport Strategy (September 2017) sets out an appropriate balance between north-south and east-west traffic movements. There is no need to close Winston Churchill Way.

-


PO2191 Car access should not be allowed along Park Lane from Sturlas Way as the traffic congestion along here is bad enough already

Assessment of this will be undertaken in the context of the Waltham Cross Area Action Plan.

-


PO1724 Consideration should be given to providing slip roads at the west end of Theobalds Lane (one way?) at A10 junction to assist in accessing A10/M25 and London and Brookfield Centre

This should be assessed as part of the planning application for the Cheshunt Football Club proposals.

-

17.22 17.8 PO649 Historic England Mention should be made in this paragraph of the Grade II listed Broxbourne station as well as a number of other listings, a Conservation Area and Areas of Archaeological Potential located along the route

The detail provided is considered sufficient. The location of the historic assets is apparent from the Interactive Map. Further consideration will be given to the historic environment as part of the proposed Broxbourne station development plan.

-

17.23 17.8 PO1747 Hertfordshire County Council – Spatial Planning The increase in passenger numbers created by Crossrail 2 will also put increased pressure on transport provision to and from the stations at Broxbourne, Cheshunt and Waltham Cross

The transport strategy looks at providing for an increase in passenger numbers by providing additional bus capacity and better cycle and foot connections. Some limited additional car parking capacity is anticipated but not so much as to cater for latent demand

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from further afield.

17.24 17.8 PO1480 Network Rail Are keen to close the existing level crossings in the area

The Council is working with Network Rail to minimise the impacts on the local community.

-

17.25 Policy INF3: Crossrail 2/four tracking

PO447 Kings Arms & Cheshunt Angling Society Your support must not come at the cost of overriding commitments in LV5 and GT1 to protect vehicular access

Noted. -


PO1886 PO1882

Transport for London and GLA Recognising the need for investment to realise wider benefits around Crossrail 2 stations – including homes and jobs – the policy wording could be strengthened and expanded so as to recognise these opportunities and outline an approach to take them forward for delivery

The supporting text already recognises these points. It is not considered appropriate to over-emphasize this before the feasibility work on Spitalbrook and the Waltham Cross Area Action Plan is undertaken. Other opportunities are somewhat limited.

-


PO1527 Hertfordshire Local Enterprise Partnership Supports this policy but feels that much more needs to be explored in anticipation of Crossrail 2 including the economic benefits, enhanced levels of investment that can be anticipated, increase in development values, sustainability benefits

The supporting text already recognises these points. It is not considered appropriate to over-emphasize this before the feasibility work on Spitalbrook and the Waltham Cross Area Action Plan is undertaken. Other opportunities are somewhat limited.

-

17.28 17.10 PO27 Parking at Cuffley Station is difficult – extra parking will be needed

This is a matter for Welwyn Hatfield and the car park operator. However it should be noted that increased levels of parking could attract latent demand from further afield, resulting in greater congestion on local roads.

-

17.29 17.10 PO871 Extending the existing station car park upwards would alleviate the parking problems in Russells Ride and surrounding areas, and the car park could possibly be used by visitors to the Lea Valley Park also

However it should be noted that increased levels of parking could attract latent demand from further afield, resulting in greater congestion

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on local roads.

17.30 17.11 PO175 It should be noted that any new station at Turnford is likely to be served by Crossrail 2 trains only

-

17.31 17.13 PO525 East Hertfordshire District Council Until the Transport Strategy and indeed the County Council’s COMET model have reported (early 2017 and late 2016 respectively), the implications of the Plan on the strategic road network, and whether any mitigation solutions can be identified will be unknown

COMET modelling was undertaken in 2017 and published alongside the transport strategy. East Herts Council is aware that Broxbourne Council is similarly concerned that the impact of the full extent of development planned in in that District should be fully tested and mitigations agreed.

-

17.32 Policy INF4: Rail Stations

PO32 Is there a possibility that Turnford Station could become a reality?

Initial discussions with Network Rail suggest that it is feasible. However, a business case still needs to be prepared, detailed feasibility work completed and funding secured.

-


PO890, PO2062

The Wormley and Turnford Society The proposal for a station in Groom Road seems totally unsuitable due to lack of space for parking and access

The Council has identified an alternative access point and is currently exploring this with stakeholders.

Station site moved further north on policies map.


PO1893 Transport for London At both locations (Turnford and Park Plaza), Network Rail and TfL would need to be presented with a strong and clearly justified case for a new station

Agreed. The Council is preparing such a case.

-


PO2077 Lee Valley Regional Park Authority Supporting text at 17.11 should be amended to make reference to the Regional Park and note that a new station at this location could benefit the Park

Agreed that the potential for this should be explored.

Amend paragraph to refer to possible access to the Park.


PO1214 Consideration should be given to reducing the proportion of new housing planned for the south of the Borough – Broxbourne station is much better fitted for expansion than Cheshunt station

There are significant constraints at Broxbourne station. This will be explored further as part of the next plan review.

-


PO1453 No need for new station at Park Lane – it would be too near Theobalds Grove Station which would adequately serve Park Plaza

Theobalds Grove is 10-15 minutes’ walk from Park Plaza and this would reduce the significant benefits of

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having station access in the immediate vicinity.


PO1731 Picketts Lock is seriously under used because of the failure to provide a rail link that was proposed at the time of the development

Noted. -


PO2187, PO2001

The Enfield Gospel Hall Trust The strategic approach to delivering a new railway station at Turnford needs to be capitalised upon by ensuring potential development sites nearby are maximised

Noted. -

17.40 Policy INF5: Level Crossings

PO448 Kings Arms & Cheshunt Angling Society We support this providing suitable alternative access points are provided at the same level i.e. if vehicular access is currently possible alternative must be provided

The Council will encourage this wherever feasible. If not feasible then the best possible alternatives will be pursued.

-


PO2076 Lee Valley Regional Park Authority Supporting text at paragraph 17.14 should be amended to include reference to the need to maintain access into the Regional Park for residents and visitors and to minimise disturbance to its ecology

Agreed. Amend paragraph to insert reference to maintaining access to the Park.


PO147 Network Rail Documents submitted on level crossing safety considerations.

Noted -

17.43 17.15 PO1654 Crest Nicolson Objects to paragraph 17.15 which states “The Rosedale Park development will provide for bus services to be extended into it” – this is dependent on the bus company agreeing to extend its existing route, therefore the sentence should be revised to read “The Rosedale Park North development will provide the opportunity for bus services to be extended into it”

The text is worded in such a way as to make very clear that Crest Nicholson will be expected to contribute towards bus provision.

-

17.44 Policy INF6: Bus Transport

PO59 PO874, PO1215, PO700 PO1422

Transport infrastructure needs to be joined up so that anyone arriving at a train station can get a bus to wherever they are going – unacceptable for a busy station like Cheshunt to have only two buses an hour during rush hour. The bus companies should look at a regular service to transport commuters to Cuffley and Cheshunt railway stations. The no. 310, which

A new ‘town’ bus service is proposed as part of the transport strategy. Diversion of the 310 would result in unacceptable delays.

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runs north to south through the Boorugh, should call at railway stations, particularly Broxbourne.


PO138 PO287 PO148

Need evening bus services – at the moment the last 251 from Hammond Street to Upshire leaves at 19.05; and the bus from Goffs Oak to Potters Bar has stopped running after 7pm.

The viability of subsidies towards rural services in the evening is the major determinant of the approach taken by Hertfordshire County Council.

-


PO251 TfL Property Welcomes the potential of wider redevelopment opportunities to deliver a significant mixed-use development with the adjoining Royal Mail site, however it also recognises the importance of maintaining the current and future operational needs of the bus station

The site has been removed from the Strategic Land Availability Assessment (April 2017) and it is not considered that anything in the Local Plan would jeopardise those operational needs.

-


PO526 East Hertfordshire District Council Until the Transport Strategy is released the options for improved public transport networks and their feasibility are uncertain, therefore at present the Plan is considered to be uncertain in sustainability terms and subject to possible objection by this Council

The transport strategy has been shared in draft with East Herts Council and other key stakeholders in advance of the public consultation.

-


PO692 PO1429

A new express bus through the Borough needs bus priority measures to be put in place. Need more bus lanes or roads for buses in the Borough.

Past experience on the A1170/B176 shows that bus lanes result in a significant reduction congestion bottlenecks. An express bus has been considered but is not considered able to serve a sufficient number of destinations without unacceptably long journey times.

Remove reference to express bus service.


PO872 The A10 is not wide enough for a designated fast bus lane and there is not room for expansion in all the sections so this proposal will just reduce the flow of traffic

Agreed. An express bus forms no part of the draft Transport Strategy (September 2017).

Remove reference to express bus service.


PO1894 Transport for London As manager of the facility, TfL London Buses would need to agree to proposed designs for the new or enlarged bus station at Waltham Cross

Noted. -

17.51 Policy INF6: PO1752 Hertfordshire County Council – Spatial Planning The recently Noted. Broxbourne Council -


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Bus Transport

established Intalink Quality Partnership infrastructure sub-group is now the most appropriate forum for bus operators and local authorities to work together in developing network upgrades to support operations

representatives attend the Inalink meetings. The Council has also met with operators separately.


PO2212 Allowing local petrol stations, such as that in Cuffley, to be closed and sold for housing only increases unnecessary car journeys, people will not use buses unless car use is discouraged

The Council considers that the draft transport strategy strikes an appropriate balance.

-


PO1749 Herts County Council Consider adding schemes identified under the Lea Valley Green Route in the IDP as well as schemes already in INF6: Bus Transport

The Green Route has informed the thinking behind the draft transport strategy.

-


PO2002 The Enfield Gospel Hall Trust As with the proposed railway station at Turnford, we strongly support the inclusion of plans for a new bus terminus, increasing the accessibility to Turnford and Brookfield

Noted. -

17.55 17.18 PO110 British Horse Society Would like assurance that the need for safe off road paths for horse riders and carriage drivers will be recognised in the Plan, that all new tracks planned for the area will be multi user routes that include horse riders, and that all road crossings, bridges etc will be suitable for horse riders and other vulnerable non-motorised users

The Council seek to ensure this wherever appropriate in conjunction with the County Council’s Rights of Way team.

-

17.56 Policy INF7: Walking and Cycling Strategy

PO118, PO332

Why will it take five years to produce the strategy – this seems very unambitious given the challenges of obesity and global warming, couldn’t you produce it in one year?

The Council decided that a more ambitious approach was necessary and therefore has published a draft Local Cycling and Walking Infrastructure Plan.

Amend section to refer to the draft Local Cycling and Walking Infrastructure Plan.


PO120 Broxbourne should encourage car pooling schemes like Zipcar and Drive Now

Car pooling is supported in Section 30: Transport and Movement.

-


PO1012 Where practical paths could be made dual purpose (like the current pedestrian/cycle path alongside the A1170 at Turnford), whilst opening up existing paths for cycling (such as by removing the multiple barriers along the east end of the

Agreed, depending on the location. See the Local Cycling and Walking Infrastructure Plan for further information, including proposals for

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old Andrews Lane) removal of the barriers at Andrews Lane.


PO2079 Lee Valley Regional Park Authority This work needs to be informed by the LVRPA’s recently commissioned Cycling Strategy which is due to report in the autumn

The Park Authority’s Cycling Strategy was reviewed in preparing the Local Cycling and Walking Infrastructure Plan.

-


PO1747 Hertfordshire County Council – Spatial Planning A strategic approach to walking and cycling is a vital part of a sustainable transport strategy and needs to be set out as part of the Plan process to ensure suitable improvements and opportunities to improve or add infrastructure are identified and secured through the IDP in a planned and complimentary way

A strategic approach is set out in the draft local Cycling and Walking Infrastructure Plan.

-


PO2126 Public Health Service, Hertfordshire County Council Is keen to see the Walking and Cycling Strategy come forward at the earliest opportunity so as to ensure that opportunities are not missed within developments coming forward over the short term

The Council decided that a more ambitious approach was necessary and therefore has published a draft Local Cycling and Walking Infrastructure Plan.

-


PO1584 PO148

The Local Plan should consider a more extensive cycle path expansion plan

Agreed. See the Cycling Network Plan in the draft Local Cycling and Walking Infrastructure Plan

-

17.63 17.19 PO449 Kings Arms & Cheshunt Angling Society Cycle route along Lee Navigation does not include towpath, due to adverse interactions between cyclists and other towpath users including boaters, policy must try to keep towpath and cycle routes separate where possible

A ‘code of conduct’ similar to that operated by the Canals and Rivers Trust on the River Lee a possible way to address this, as set out in the draft Local Cycling and Walking Infrastructure Plan.

-

17.64 Policy INF8: North to South Paths

PO288 What happened to the plan to put in a path from Goffs Oak to Cheshunt station?

Andrews Lane/Church Lane is proposed as such as corridor in the draft Local Cycling and Walking Infrastructure Plan

-


PO1183 Canal and River Trust There is no reference to improvements to the River Lee Navigation towpath here, which we feel should be included to ensure that any riverside development

There are no site allocations proposed adjacent to the towpath. In such cases negotiations would take

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in the Borough throughout the plan period will make a contribution to the Trust’s enhancement projects where we consider these necessary

place through the S106 process.


PO2081 Lee Valley Regional Park Authority Work on the feasibility of a new route along the eastern side of the West Anglia railway will need to consider existing networks already available for walkers and cyclists which are extensive, the need to minimise disturbance to nature conservation sites and the issue of connecting routes across the railway from the residential communities to the west

Agreed. This has been taken into account in the preparation of the Cycling Network Plan.

-


PO2127 Public Health Service, Hertfordshire County Council Promotion of improved walking and cycling paths is fully supported, hopes these will occur in tandem with adjacent development to maximise healthy behaviours at the earliest opportunity

Support noted. The intention behind the approach taken is to maximise the opportunities presented by developments to maximise healthy behaviours.

-

17.68 Utilities PO116 Concerned about the extra demand on water and sewage and ensuing chaos on the roads from the work going ahead which would mean never ending roadworks

Some disruption from utilities works is inevitable but this can be scheduled and disruption kept to a minimum.

-

17.69 Utilities PO898, PO902

National Grid Has two high voltage overhead lines within the Borough which form an essential part of the electricity transmission network and can provide advice and guidance to the Council

Noted. -

17.70 Utilities PO899, PO902

National Grid Has a high number of gas distribution apparatus within the Borough and can provide advice and guidance to the Council

Noted -

17.71 17.21 PO1903 Thames Water Utilities Limited Where development is being proposed within 800 metres of a sewage/waste water treatment works, the developer or local authority should liaise with Thames Water to consider whether an odour impact assessment is required as part of the promotion of the site and potential planning application submission

Noted -

17.72 17.21 PO1908 Thames Water Utilities Limited Paragraph states “Broxbourne’s water supplies are provided by Thames Water.

This issue is addressed in further detail in the Infrastructure Delivery

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The company has indicated that all new development can be supplied” – this is true from a treatment perspective but there are concerns about the network’s ability to serve developments

Plan.

17.73 17.22 PO1909 Thames Water Utilities Limited Paragraph states “Sewerage in the north end of the Borough drains into Rye Meads sewage works. The middle and south ends of the Borough drain into Deephams sewage works in Enfield. It is understood that both sewage treatment works are currently being upgraded and that there is capacity to accommodate all the new development within this Plan to at least 2026” – this is correct based on past assessments, but growth forecasts for these sewage works catchments are currently being reviewed and updated

The Hertfordshire Water Study 2017 indicates that there are no ‘showstoppers’ within the Study area – no locations where issues concerning the provision of infrastructure will render growth difficult if not impossible.

-

17.74 Education PO63 There are at least 100 free secondary places in Cheshunt alone because at least two of your schools are ‘failing schools’

There is some spare capacity in existing schools at present. The reserve school site at Church lane is proposed as a fall-back in the event that this capacity is used up.

-

17.75 Education PO553 Currently Cheshunt school is running at 38% capacity and under threat of closure yet new houses are being built on the site and on the old St Marys school site, to close Cheshunt is madness as then Goffs and St Marys will be over subscribed

Cheshunt School has been relaunched as Goffs Churchgate Academy. There are no plans to close the school.

-

17.76 Education PO1381 Hertfordshire County Council Property (Development Services) Documents submitted on school places.

Noted -

17.77 Education PO2229 What have you planned for Sheredes Secondary School – 8 and 9 appear very close?

It is understood that the school has plans for gradual upgrades of a relatively small-scale nature.

-

17.78 Education PO1493 Hope other schools in Hoddesdon, besides The Broxbourne School, can benefit from contributions from developers.

Contributions will be sought as appropriate given the national policy test that they should be ● necessary to make the development acceptable in planning terms;

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● directly related to the development; and

fairly and reasonably related in

scale and kind to the development.

As stated in paragraph 204 of the national planning policy framework.

17.79 17.25 PO1128 Where is the Broxbourne Academy school moving to? The school is being redeveloped on site as stated in the text.

-

17.80 17.27 PO1382 Hertfordshire County Council Property (Development Services) The County Council’s strategy for secondary school places is contained in section 3 of Appendix A

Noted. -

17.81 Policy INF9: Reserve Secondary School Site

PO6 Wormleybury Management Limited Will access to the new school be gained from Church Lane?

Feasibility work carried out by Hertfordshire County Council has indicated the potential to achieve access from the A10 link road south of the Derwent Turnford site. Therefore Church Lane would be needed as a secondary access only.

Clarification of primary and secondary access points added to Local Plan and concept diagram.


PO221 Herts and Middlesex Wildlife Trust This site is not capable of being compliant with NPPF and therefore alternative less ecologically damaging sites should be selected

Hertfordshire County Council has undertaken a survey of alternative sites and as a result of this work it has been concluded that there are no less damaging but nevertheless deliverable sites. The Council has been working with Land Use Consultants Ltd to prepare an ecological mitigation strategy for Church Lane and this is being prepared with input from the Herts and Middlesex Wildlife Trust. Preliminary conclusions from this work demonstrate that it is possible to accommodate sufficient mitigation

Reference to mitigation has been added to the policy.


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on-site, including


PO651 Historic England The site is located between the Conservation Area and Wormleybury Registered Historic Park – consideration should be given to locating the proposed school site slightly further south

It is anticipated that the majority of the northern part of the site will be used for ecological mitigation and will therefore be left undeveloped.

Reference to mitigation has been added to the policy.


PO735 Wormleybury Management Limited Measures to improve accessibility and safety and measures to deal with the anticipated transport impacts of the development in this location must be drawn up

The primary vehicular access will be provided from the A10 link road to the south. It is likely that the main pedestrian and cycle access point will be along Church Lane.

Clarification of primary and secondary access points added to Local Plan and concept diagram.


PO734, PO736, PO749, PO2201, PO739, PO2200 PO221

Wormleybury Management Limited Concludes that neither the allocation of the garden suburb or the safeguarding of the secondary school site are in accordance with national policy and guidance and should be removed from the plan. Policies and paragraphs in the Plan should support the allocation but they fail to do so. Asks the Council to delete the allocation of a site for a new secondary school in the Green Belt immediately to the east of the A10 off Church Lane because:

a) It would destroy the nature value of a local wildlife site (Herts and Middlesex Wildlife Trust agree – PO221)

b) The loss of green space here would bring development right up to the A10 and next to Wormleybury Estate

Regarding point a), survey of alternative sites have revealed no deliverable alternative, but accept ecological mitigation appears achieveable on-site. A significant proportion of the site will be retained and enhanced for wildlife. Regarding point b), the area will be retained in the Green Belt in order to prevent sprawl. The majority of the site will remain open, whether as part of the school grounds/playing fields or as ecological zones.

Site reinserted into the Green Belt.


PO1038, PO1039, PO1040, PO1041

Derrick Wade Waters The proposed redevelopment of Broxbourne School includes a significant degree of residential development which has been proposed as ‘enabling works’ to bring forward that redevelopment and we believe that similar criteria should be applied to the land south of Church Lane when looking at the site’s designation within the Local Plan context

Broxbourne School represents a different context, based upon the need to generate funding to rebuild an existing school. The site, if it is indeed needed at all, will need to be funded principally from mainstream funding, with contributions from developments in the area. The Church Lane site, including the

-


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Derwent Turnford site to the south, will be retained within the Green Belt.


PO2134 Public Health Service, Hertfordshire County Council This Policy should consider the proximity to the A10 and potential air quality issues in both the location and design of school premises

The location of the proposed school buildings, if indeed needed as a result of future educational need, have not yet been decided. However, there is sufficient area within the site to set the buildings back from the A10. The proposed ecological mitigation is likely to form an additional buffer between the school and the A10.

Site retained in Green Belt


PO1383 Hertfordshire County Council Property (Development Services) In order for this site to be deliverable and sustainable in terms of affordability it is requested that the majority of the site is retained within the Green Belt and that only the proposed build zone of the school is excluded

Agreed. This will help to avoid the risk of sprawl and enable control of the site through the planning application process.

Site retained in Green Belt


PO1556 PO861

Church Lane from High Road Wormley is very narrow, there is also going to be a building problem with so many trees and a large area of Green Belt will be lost

Primary vehicular access will be provided from the A10 link Road to the south, with Church Lane forming a secondary access and pedestrian/cycle access point.

Clarification of primary and secondary access points added to Local Plan and concept diagram. Site retained in Green Belt.

17.90 17.29 PO1384 Hertfordshire County Council Property (Development Services) Difficult to determine exactly when new primary school places would be needed – dependent upon when new housing comes forward, the forecast at that time, and the capacity of local schools to accommodate any demand arising from the new development

Noted. This is allowed for in the Infrastructure Delivery Plan.

-

17.91 17.29 PO1385 Hertfordshire County Council Property (Development Services) Both paragraph 17.29 and Policy INF10 need to be amended as there is only one primary school required in Brookfield Garden Village

This statement is supported by the capacity calculations and masterplanning work undertaken to date.

Plan amended to indicate that a single 3FE school will be required.

17.92 17.29 PO1386 Hertfordshire County Council Property (Development Agreed – this reflects discussions Clarification added that


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Services) The last bullet point of 17.29 needs to refer to land being identified to enable the expansion of Woodside Primary School

with the County Council and would mean that the registered Village Green to the south can be preserved.

land for expansion has been identified to the east.

17.93 17.29 PO1387 Hertfordshire County Council Property (Development Services) The new primary school at St Mary’s Academy is not required to meet local need from new housing as this will be accommodated in the new school at Rosedale Park

It is understood that the Academy, which is independent of County Council control, wishes to keep open the possibility of a new primary school on-site.

-

17.94 Policy INF10: New and Expanded Primary Schools

PO176 It is not clear if, where, and when additional schools will be built

Some flexibility is required and the timing will to a large extent be determined by the County Council’s capacity forecasts and the availability of funding. More detail on this is set out in the Infrastructure Delivery Plan.

-


PO322 Re Woodside School - if Goffs Oak Village Green loses village green status there will be no public open space in the area

Hertfordshire County Council has clarified that it has identified a site to the east of the school for additional pitches. Therefore there is no longer any need to identify the village green to the south of the school for expansion.

Clarification added that land for expansion has been identified to the east.


PO986 Welwyn Hatfield Borough Council Supports the planned extension of Woodside Primary School – in addition to the benefit of reduced vehicular trips along Cuffley Hill between Cuffley and Goffs Oak this in turns creates the capacity within Cuffley Primary School needed to support this Council’s own proposed growth

Support noted. -


PO708 Enfield Council Is pleased to see references to the provision of eight new or expanded primary schools and the aspiration to develop a new secondary school at Church Lane, Wormley

Noted. -

17.98 Policy INF10: PO1007 Concerned about safety of children walking to this new Agreed. It is understood that the Concept diagram and


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New and Expanded Primary Schools

school adjacent to the A10 carriageway - given that Holy Trinity School has a large area of waste land behind the current school and Albury Walk footpath/cycle track, would it not make more sense to extend Holy Trinity School rather than create this new one?

Cheshunt Club has reached an agreement with Hertfordshire County Council as landowner to undertake a land swap to bring the school site closer to Albury Ride, further away from the A10.

policies map, and text amended to clarify that the school will be located nearer to Albury Ride than currently shown.


PO1389 Hertfordshire County Council Property (Development Services) There are other primary schools within the Borough that may need to be expanded to provide additional spaces to meet the demand arising from new developments

Noted. The plan identifies the main known opportunities but this does not preclude others from coming forward.

-

17.100 Health Care PO113 A hospital is needed in this area as the nearest A&E is Barnet (not in Hertfordshire), Princess Alexandra (Essex) or Stevenage

It is understood that the NHS strategy is to rationalise A&E, maternity and other specialist hospital functions, and therefore has no plans to provide another hospital in the borough. This does mean that journey times will be longer for some patients.

-

17.101 Health Care PO115, PO175

With an additional 7,500 houses what provision is being made for hospitals, the hospitals made available are full to bursting now

This information is set out in the Infrastructure Delivery Plan. The Council is working with the Clinical Commissioning Group to identify the specific needs of the borough.

-

17.102 Policy INF12: Health Care

PO100 It has been suggested that a new hospital may have to be built at Harlow – this will require government funding and needs to be built prior to the building of new homes

Options for a new hospital are being explored by the relevant bodies.

-


PO260 PO262

NHS England/NHS East and North Herts CCG An options appraisal for Cheshunt and Waltham Cross is currently underway to look at how, and from where, health services can be best delivered to both existing patients and new residents especially as a result of the Brookfield Masterplan and proposed development in Waltham Cross. With the changes to the way primary care, community and

The Council looks forward to receiving a clear steer from the CCG on the basis of this work.

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mental health services are delivered, and until the results of the options appraisal/feasibility study have been fully considered, it should not be assumed that healthcare provision at Brookfield, Cheshunt Lakeside and Goffs Oak/Rosedale Park has yet been agreed by NHS England and East and North Hertfordshire CCG


PO261 NHS England/NHS East and North Herts CCG In line with NHS England’s Five Year Forward View and CCG Strategic Delivery Plans and in response to your consultation the request is for due consideration of the health agenda and sufficient flexibility to enable a contribution to be used off-site (although still for the new patients a particular development will generate), as well as on-site, should that prove more clinically effective.

Due consideration for the health agenda is being provided. However a clear steer from the CCG/NHS England would be welcomed.

-


PO313 With all the proposed NHS cutbacks I think you stand little chance of help with your health proposals

The success of healthcare planning depends on close working between the NHS and local Councils.

-


PO934 CODE Development Planners Ltd The policy’s reference to “new GP provision for … Goffs Oak/Rosedale Park” needs to be adequately evidenced

Agreed. This is being worked through with the NHS as part of the pre-application process.

-


PO951 It is essential that the type of healthcare provision provided (i.e. Urgent Care Centre, GP, Minor Injuries Unit, A&E) reflects the Borough’s proximity to other units within Hertfordshire and North London

Provision will reflect the wider context for provision in the area.

-


PO1127 Even with the plans for new surgeries is there enough room for everyone?

This will depend on the future demand forecasts prepared by the NHS and will require an ongoing process of partnership working over the plan period to identify and delivery new capacity as and when required.

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Part 2: Issues raised through the Regulation 18 Draft Local Plan consultation under this chapter of the Plan but shifted for consideration under more relevant chapters

Policy/ Para. no.

Commt. ID(s)

Issue Considered as: Issue No.

17.2 PO840 Adding another 24% of dwellings into Goffs Oak without road improvements would destroy the nature of the village

Chapter 8 – Goffs Oak 8.1

Part 3: Other proposed amendments

Policy/ Paragraph number Issue Proposed amendment

Policy INF9: Reserve Secondary School Site, and the map of schools proposals

Historic England Consistency is required between the map and the Plan – the map shows this as Policy INF8, also there is a discrepancy in the annotation for primary schools (INF9 on the proposals map and INF10 in the Plan)

Ensure map and policy numbering tally

Para. 17.30 Hertfordshire County Council Property (Development Services) Paragraph 17.30 appears to repeat some of the text in 17.29

Amend text

From water chapter Thames Water Utilities Limited

Add in specific policy on water supply and wastewater infrastructure

Companies are subject to a statutory duty to ‘effectually drain’ their area. This requires them to invest in infrastructure suitable to meet the demands of projected population growth. To fulfil their statutory duty, water and

New policy to be added to the Utilities section of the infrastructure chapter: Policy W ?: Water Infrastructure Planning permission will only be granted for developments which increase demand for off-site water and wastewater infrastructure where: 1) Sufficient capacity already exists; or 2) Additional capacity can be provided in time to serve the development. Where a capacity constraint has been


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sewerage companies must work with local planning authorities, so that proposed growth and environmental objectives are reflected in company business plans. This will help ensure that the necessary infrastructure is funded through the water industry’s price review mechanism. Amend policy in general accordance with that suggested.

identified, and the necessary improvements in off-site infrastructure are not programmed, planning permission will only be granted subject to the improvements being completed prior to occupation of the development. Supporting text to be inserted: The Council will seek to ensure that there is adequate water supply, surface water, foul drainage and waste water treatment capacity to serve all development proposed in this Local Plan. In addition, developers will be required to demonstrate that there is adequate waste water capacity and surface water drainage, both on and off site, to serve the development. It may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing wastewater/sewerage infrastructure. Where there is an infrastructure capacity constraint, the Council will require the developer to set out the improvements required and detail how they will be delivered.


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Chapter 18: Planning Obligations and CIL


Issue No.

Policy/ Para. no.

Commt. ID(s) Issue Officer Response Proposed amendments to the Plan

18.1 18 PO249 If all of the necessary funding and commitments are not in place the Draft Local Plan will not be sustainable or viable

18.2 18 PO2087 Although the Council has not yet adopted a charging schedule for the purposes of CIL the LVRPA would wish to see specific reference to the Regional Park in the schedule when this is drafted

Noted. Given the predicted shortfall for CIL funding for essential and necessary infrastructure such as roads, it is unlikely funding will be available for non-essential infrastructure. However the Regional Park is welcome to make a case for any essential infrastructure they consider should be a candidate for funds.

No amendment necessary.

18.3 18 PO1391 Supporting infrastructure should be provided in advance of, or alongside the development, unless there is existing capacity

Noted. Will include an amendment to this effect.

Amend paragraph 18.3 as follows: Supporting infrastructure and other planning obligations need to be provided in advance of, or alongside, the development to ensure that the development does not lead to any unacceptable adverse effects.

18.4 Policy PO1: Planning Obligations

PO450, PO451

Can local organisations submit bids for funding of improvements from CIL, e.g. provision of raised walkway around the Moat on one side to enable safe access for both anglers and visitors to Ancient Monument? If not, can we ask for Section 106

It may be possible to fund such a project under section 106. The land would have to be publically owned and accessible to all. The Society will need to submit a project bid, including designs and preliminary



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funding instead from specific developments? feasibility work, to the Council for consideration. It should be noted that there are also other options for funding this type of project such as the Heritage Lottery Fund.

18.5 18.10 PO1064 In accordance with DCLG guidance, any development contributions towards SRN improvements should be secured via S278 agreements, and not via S106 or a CIL Reg123 list

Noted. Amend 18.10 in accordance.

Amend 18.10 as follows: Contributions towards the Strategic Road Network will be secured by agreements under Section 278 of the Highways Act 1980. These will be negotiated directly with the relevant authority.

18.6 18.10 PO1392 Whilst it is acknowledged that this paragraph states that the Council is awaiting the outcome of the Government review, it should be noted that the CIL system provides transparency in the infrastructure delivery process.

Noted. The Council will await the Government’s Response to the CIL report published in February 2017.

-

18.7 Policy PO2: Community Infra-structure Levy

PO1015 The provision of affordable housing is of itself a part of the community infrastructure, and therefore affordable housing providers should not be required to pay CIL for those units

Noted. The exemptions are major reason why the CIL has not proved successful in achieving sufficient funding for infrastructure. The Council will await the Government’s Response to the CIL report published in February 2017 before deciding how to proceed.

Policy has been deleted in its entirety see below under Part 3 of this report.

18.8 Policy PO2: Community Infra-structure Levy

PO1531 Supports this policy but would also suggest that the Borough Council commits to putting the appropriate governance arrangements in place to manage CIL

Noted.


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Policy/ Para. No.

Commt. ID(s)


N/A


Policy/ Paragraph number

Issue Proposed amendment

18.1 Change ‘agreed’ to ‘accepted’. Amend paragraph as follows: They may be agreed between the Council, land owners and developers or they may be unilaterally proposed by a landowner and agreed accepted by the Council.

18.4 Delete last sentence in paragraph as unnecessary process detail, which should be decided on a case by case basis.

Amend paragraph as follows: …. Applicants should also consider how long-term costs can be avoided through careful layout

and design, for example avoiding left-over spaces. Such requirements will usually be secured through planning conditions rather than planning obligations.

Policy PO1 Remove ‘in planning terms’ as redundant and unnecessary

Amend policy as follows: Policy PO1: Planning Obligations Planning obligations will be used by the Council to deliver sustainable development. This may include (but is not limited to) measures to mitigate the impacts of development and to meet the costs of associated infrastructure, and other measures to make a development acceptable in planning terms, where possible, appropriate, and financially viable, in accordance with the Community Infrastructure Levy Regulations.

18.10 Delete references to 2016 and process detail as unnecessary

Amend para as follows: The Council is minded to introduce a CIL for Broxbourne, subject to the outcome of a Government review which is expected to report in summer 2016. An appropriate level of charge will be determined by a Borough-wide viability study and the items for which a CIL will be charged will be published on a ‘Regulation 123 list’. Should the Council adopt a CIL, policy PO2: Community Infrastructure Levy will


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apply.

Policy PO2 Policy does nothing more than detail process.

Delete policy in its entirety. Policy PO2: Community Infrastructure Levy The Council will charge a Community Infrastructure Levy (CIL) on development proposals, which will be set out in a CIL charging schedule. Following the introduction of a CIL, planning obligations under Section 106 of the Town and Country Planning Act will only be sought in relation to individual schemes where such contributions would be necessary to mitigate site-specific impacts and are not for items already covered in a CIL charging schedule.


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Chapter 19: Implementation

Issue No. Policy/ paragraph no.

Comment ID Issue Officer response Proposed amendments to

the Plan

19.1

19 PO996

Welwyn Hatfield Borough Council The Plan currently includes no information on how it will be monitored, nor the review mechanisms for how you will respond if monitoring identifies a significant issue (such as housing need not being adequately met). This is of concern given the potential issues we identify in response to Appendix A (Housing Trajectory) around the deliverability of SLAA sites. We therefore encourage you to include a robust monitoring framework for the plan at the Regulation 19 stage.

19.2

PO1055

We note that the plan includes an implementation section but no monitoring beyond a cross reference to the fact collecting AMR. Therefore it is unclear how the Council intends to ensure that events unfold as they should, what triggers for action need to be in place if they don’t and what those actions might need to be. For example, how will the Council link the implementation of permissions to the provision of the required infrastructure, and if it either does not come forward or does not mitigate as intend, what will the triggers to review the plan be?

19.3

PO1393

HCC Property (Development Services) has no comments to make on this chapter.

Noted -


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19.4

PO573

This chapter is very weak and does not explain fully how the Local Plan and its policies would be implemented. There are no contingencies to explain what would happen if certain key policies were not delivered. There is no reference to monitoring, and no key targets and indicators are shown within the body of the plan.

The previous (unadopted) Core Strategy included a chapter headed What If? This was an excellent way of setting out the areas of risk and what would be done if policies were not being delivered.

19.5 PO574

This should include a new Policy GO6 referring to a Strategy for the Area to the West of Cheshunt (see comments above).

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Chapter 20: Design and Sustainable Construction Part 1: Issues raised through the Regulation 18 Draft Local Plan consultation

Issue Number



20.00 General Comments (not attributable to a particular policy)

Confirmation required on whether or not all new buildings in the borough will be required to have solar panels and rainwater harvesting systems installed.

This requirement would not be feasible to impose on all new homes as it will depend on budgets and types of housing. Currently the installation costs of solar panels makes it difficult for it to be factored into the built costs for smaller units unless subsidised.

No amendment proposed.

20.02 20.2 Support is offered for the recognition that good design can encourage healthy lifestyles. Link provided to the document “Active Design” to be read and interpreted into relevant policies.

Noted See amendment for issue 20.04.

20.03 20.3 20.4

Welcome that para 20.3 and 20.4 stress on local distinctiveness in new development and the need for the same to respect or improve the character of the surrounding area.

Noted No amendment proposed.

20.01 DSC1-General Design Principles

Documents (BFL12) provided to be read and interpreted accordingly into relevant policies.

Noted. Will amend in accordance. DSC1-I(e) reinforce existing pedestrian connections and create new ones with a clear hierarchy of paths and streets that promote pedestrian friendly environments and active lifestyles. (f) provide coherent and logical layouts with active street frontages and good natural surveillance, creating local landmarks and marker features for a well-defined townscape. II. All major developments should demonstrate design quality by adhering to and performing positively against the BfL12


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Issue Number



Standards, in addition to following the Council’s Supplementary Planning Guidance Documents and its successor documents.

20.04 DSC1-General Design Principles

Disappointed that no specific requirement stated in policy for new development to encourage healthy and active lifestyles. Recommends that an additional criterion be added to the policy to address this, and recommended that policy should refer to Sport England’s Active Design Guidance.

Agree Amend paragraph as follows: 20.6 Quality design plays a critical role in driving and sustaining economic growth by providing the buildings and spaces needed to nurture and inspire users to thrive and prosper. Supporting a healthy lifestyle will be key to achieving this. Getting design right is also important for nature environmental reasons to minimise harmful impacts on, or depletion of earth’s natural resources. Good design is also key to achieving creation of ecosystems that support wildlife, and its interaction with people and new development. Add into Information for Applicants paragraph: Where Design and Access Statements are required to support an application they should explain how the design of the proposal reflects the principles in this policy. Amend Policy DSC1 by adding a further clause which states: “Active Design


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Issue Number



All developments will need to adhere to Sport England’s Active Design Principles (or its successor) and facilitate safe active travel for local trips. Add into Information for Applicants paragraph Active Design Active Design, developed by Sport England and supported by Pubic Health England, provides a set of principles for creating the right conditions within existing and proposed development for individuals to be able to lead active and healthy lifestyles. Planning applications will be assessed against how they support healthy lifestyles by facilitating participation in sport and physical activity. The Active Design guidance, which provides further details for each of the Principles along with a set of case studies, can be found on Sport England’s website.

20.06 DSC1-General Design Principles-1a

For greater clarity the policy should be reworded to say “local significance and historic environment” instead of “local and historic significance”.

Features of local and historic significance should be enhanced however if the policy is re-worded as suggested, it will suggest the requirement that all features of historic environment must be enhanced. This is not always essential.



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Issue Number



E.g. some sites in our borough have historic underground structures/pump housings etc which have minimal historic significance. Therefore it is considered appropriate to suggest that features of local and historic significance should be enhanced.

20.07 DSC1-General Design Principles-1b

Generally in agreement with the policy. Questioned the reasons required to justify retention of (existing) trees and habitats

This is best practice to ensure retention of natural habitat and biodiversity. Also, refer to national guidance related to biodiversity and trees (Habitats Regulation 1992, Wildlife and Countryside Act 1981)

No amendment required.

20.08 DSC1-General Design Principles-1b

Woodland Trust Trees should be acknowledged as being able to help combat climate change in this Policy. [added by JI from PO2014]

Agree Propose additional clause in DSC2 to read…

V. Opportunities to mitigate against flooding and climate change should be taken through retention / selection of materials and features such as trees and planting, water bodies, retention / filter beds, pervious paving and green energy features.

20.09 DSC1-General Design Principles- 1d

Recommends that drainage plans should be mandatory part of first planning application set with a view to early stage resolution of SUDS concerns. Any non-compliance should render builders liable to compensation demands from affected person.

This is already the case as practiced by DM officers (included in the council’s validation checklist) and is too much of detail to include in Local Plan policies. Regarding builders liability to affected persons, this is a legal matter and does not come under the remit of the Local Plan.


20.10 DSC1-General Design

Concurs with the wording. Noted No amendment proposed.


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Issue Number



Principles- 1g

20.11 DSC1-General Design Principles- 1h

Agree. However addition of text to policy “quantity and quality of surface water to watercourses, and avoidance of overshadowing to waterbodies”.

Comment seems irrelevant to policy reference.


20.12 DSC1-General Design Principles- V(iii)

Recommends caveating policy section to rule out planting of non-native invasive species especially near water courses.

Agree Amend new policy ‘Design Affecting the Public Realm’ (formerly part of DSC1) as follows: “maximise opportunities for urban greening and opportunities for climate change adaptation through planting. This should involve in a good proportion of native planting. In no case should non-native invasive species be used in sensitive landscapes including water–courses.”

20.13 DSC1-General Design Principles- 1h

Suggested that the word “significant” be added after “avoid”.

Impact on neighbours’ amenities is measured using specific tools as stated in the Council’s SPG. Therefore the need to clarify the degree of impact is not deemed as necessary.


20.14 DSC1-General Design Principles- 1k

Recommends rewording to emphasise that “provision should be made for the storage and collection of waste and recyclables, including recycling boxes, wheelie bins and compost bins and be positioned for easy access by refuse trucks. Also sufficient land should be made available in larger developments for the provision of neighbourhood recycling centres. “

This detailed requirement is stated in the Council’s Waste SPG that the Policy wording already refers to.


20.15 DSC1- General Design Principles

The amount of waste arising from the new developments, including the construction and demolition associated with them, as proposed

Noted. We consider it is addressed here in sufficient detail already.



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Issue Number



in the plan needs to be addressed here.

20.16 DSC1-General Design Principles- 1i

Requirement for “dual fronted units on corner sites” is unreasonable, unnecessary and impractical and should be deleted from policy

Agree that the wording may not apply to all scales of development. Clause to be deleted as also covered elsewhere.

Delete clause as follows: (i) design dual fronted units on corner sites

20.17 DSC2-Sustainable Construction- iv

Certain sensitive sites (e.g. Hazelmera Marina) may require the use of new aggregates to avoid detrimental impact (for eg. to water courses near development)

Policy is currently worded to say “…such materials re-used on site wherever possible “and is deemed to allow sufficient flexibility in case of sensitive sites. However it may be reworded as proposed

IV. Re-use and recycling of building materials such as bricks should be carried out, and such materials re-used on site wherever possible and (subject to site specific environmental and design considerations), in preference to natural aggregates or previously unused materials.

20.18 DSC2-Sustainable Construction

Supportive of the policy Noted No amendments required.

20.19 DSC2-Sustainable Construction

The amount of waste arising from the new developments, including the construction and demolition associated with them, as proposed in the plan needs to be addressed here.

Noted. We consider it is addressed here in sufficient detail already. No amendment necessary.

20.20 20.15 Suggested amendment to wording to read “ Prior to submitting any planning application the applicant is encouraged to consult with Hertfordshire Constabulary’s Crime Prevention Design Service in order to address any issues around crime, disorder and the fear or crime (as per paragraphs 58 & 69 of NPPF). This should be done at the earliest stage possible and ideally at pre-application.

Agree Wording to be amended to “20.15 Applicants are advised to consult the Hertfordshire Constabulary Architectural Liaison Officer for advice on crime prevention measures prior to the preparation of a detailed layout. Prior to submitting any planning application the applicant is encouraged to consult with Hertfordshire Constabulary’s Crime Prevention Design Service in order to address any issues around


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Issue Number



crime, disorder and the fear or crime. This should be done at the earliest stage possible, ideally the pre-application stage to avoid issues caused by later changes to the design.

New DCS4 Need a policy on long term management and maintenance as it is a difficult issue. Providing a policy will allow for a degree of certainty at the pre-application stage, rather than leaving it until; the time of the application.

LONG TERM MANAGEMENT AND MAINTENANCE Declining management and maintenance of

a site over the long term can cause considerable distress for residents, neighbours and site users. Responsible bodies and managers for sites can change, with new managers having little knowledge of the responsibilities arising from the grant of planning consent. The ability of the Council to address any unforeseen issues arising at a later date can be limited because of the time that has passed since the approval of the development.

Policy DSC4: Management and maintenance I. To ensure the long-term attractiveness of

open and public spaces and leisure and sports facilities, the Council will seek to ensure that a high standard of management and maintenance is planned for the development over the lifetime of the development, at the time of the application.

II. Applicants are required to submit a long


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Issue Number



term management and maintenance plan for the development, covering a range of reasonably foreseeable management and maintenance issues and contingencies, and proposing consequential remedial actions.

III. Once the plan has been agreed with the Council, compliance with the management plan will be secured as part of a legal agreement running in perpetuity with the site.

Information for Applicants The draft plan should be submitted at the

time of making an application. The maintenance plan will be included within the Section 106 agreement.

20.21 Policy DSC4: Comprehensive Urban Regeneration

Referring the promotion of land at Burton Grange in advance of the wider masterplan for the Rosedale area, recommendation has been made that the policy needs to allow for such exceptions to deliver housing in a short timescale and meet the urgent housing need.

While it is appreciated that policy needs to allow such exceptions for smaller sites to come forward in advance of wider masterplans, it is still a requirement that sufficient consideration should be given to how proposals in the smaller site would sit within the wider urban grain especially in terms of connectivity, landscape assets and continuity of frontages where appropriate. Applicants will be required to appropriately consider the existing urban setting and any definite

Policy to be reworded to … I. The Council will pursue the comprehensive development of the strategic development allocations within this Plan, and will resist piecemeal development of those areas that does not accord with agreed master plans.


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Issue Number



proposals for development in the immediate surroundings.

20.22 DSC4: Comprehensive Urban Regeneration

Policy supported Noted No amendment required

20.23 20.18 Welcomes reference to the need for the design of shopfronts to complement and enhance frontages which have historical character.

Noted No amendment required

20.24 Policy DSC5: Shop Fronts and Fascias

Suggests an additional clause in policy that states, “Historic shopfront features should be retained or restored”.

Agreed Policy to be reworded and renumbered to say … “I. Historic shopfronts should be retained or restored wherever possible. II. New and altered shopfronts must respect the …”




Whole chapter Too many references to Supplementary Planning Guidance throughout chapter which are unnecessary.

All references to Supplementary Planning Guidance deleted, where they do not add any further guidance to applicants.

Whole chapter Renumber all policies because of the sub-division of Policy DCS1.

Renumber all policies.

Policy DCS1 Move amenity sections to a new policy on protection amenity in the Environmental Quality section.

(h) avoid detrimental impacts on the amenities enjoyed by the occupiers of neighbouring properties and land, particularly in terms of daylight, sunlight, outlook and overlooking;

…. (k) make provision for the storage of bins and ancillary household equipment in

compliance with the Council’s Waste Supplementary Planning Guidance.


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Policy DCS1 Delete clause III. as unnecessary. Development Standards III. In order to ensure good quality residential development, proposals will be expected to comply with the development and amenity standards set nationally, in this Plan and the Council’s Supplementary Planning Guidance or its successor.

Policy DCS1 Policy is long and unwieldy. Divide policy up into small, more specific policies.

Policy DSC1: General Design Principles I. The Council expects a high standard of design for all development. All development proposals must:

(a) … (d) consider surface drainage requirements from the outset and work with the local

topography to create innovative SuDS; (e) reinforce existing connections and create new ones with a clear hierarchy of

paths and streets that promote pedestrian friendly environments and active lifestyles;

(f) provide coherent and logical layouts with active street frontages and good natural surveillance, creating local landmarks and marker features for a well- defined townscape;

(g) increase accessibility to open spaces, sports and play facilities where possible; (hj) avoid the creation of blank walls on public fronted elevations.

Building for Life

II. All major developments should demonstrate design quality by reference to the Building for Life standards, together with the Council’s Supplementary Planning Guidance Documents and its successor documents.

Active Design III. All developments will need to adhere to Sport England’s Active Design Principles (or

its successor) and facilitate safe active travel for local trips. See also policies on SuDs and Housing.

Policy DSC2: Extensions and alterations to existing development


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IV. I. All extensions and alterations to existing buildings will be required to respect the

character and design of that building.

II. Proposals for extensions/alterations to existing dwellings must satisfy the following criteria: ensure that (a) the scale, design and external appearance of the extension/alteration does must not unduly impact upon the parent building and wider setting.

Policy DSC3: Design Affecting the Public Realm V. Development proposals which create, or have a significant impact on, the public

realm should: (i) maximise legibility and permeability of the public realm through the layout of

buildings, landmarks and landscaping; (ii) seek to maintain flexibility of use, uncluttered spaces and easy movement

through the space through the use of public art, street furniture and infrastructure including signposting/way finding;

(iii) maximise opportunities for urban greening and opportunities for climate change adaptation through planting. This should involve native planting where possible. In no cases should non-native invasive species be used in sensitive landscapes including water–courses;

(iv) avoid creating ‘left-over’ spaces with no clear purpose or function; (v) ensure that long-term maintenance and management arrangements are in place

for the public realm.

Para 20.21

Amend as misleading not all signs require consent from the Council.

Amend para 20.21 as follows: Most signs require consent from the Council. Advertisements and signs vary greatly in their purpose. Many are essential, others provide information, or announce the location of a service or premises. Signs are usually displayed on the land or premises to which they relate, but directional signs can be located some distance away. Some signs and advertisements require advertisement consent from the Council. Amend para 20.24: Information for Applicants Both planning permission and Cconsent under the Advertisement Regulations is


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required for some any signage.

Para 20.22 & 20.25 Illumination needs to be included as it is a major factor to be considered in assessing the impact of a sign on an area

Amend para 20.22 as follows: The impact of signs varies greatly. Individually, they may cause little offence, unless they

are very large or carelessly located or inappropriately designed and illuminated. It is often the cumulative effect of many individual signs that causes the greatest negative visual impact.

Amend para 20.25 as follows; Applicants are advised to include details of neighbouring signs; proposed luminance levels and hours; and photos of the location, in with their applications.

Para 20.23 Unnecessary exception for rural areas Amend para 20.23 as follows: In the rural area, signs or advertisements may appear to be incompatible with the

surrounding rural landscape, however, the Council recognises that rural businesses also need to use signs for the reason listed above

Policy DSC 6 Needs to include additional restrictions on fascias and the height of signs.

Amend Policy DSC6 as follows: V. Fascia signage on buildings should fit entirely within the fascia panel. VI. In all cases, there will be a presumption against signage above ground floor level.

Policy DSC6 Remove ‘displayed on or close to a building’ as may apply to other signs as well

Amend Policy DSC6 as follows: I. Consent will not be given for advertisements that are harmful to visual

amenity or public safety. II. Particular regard will be had to the potential of the sign to distract motorists. III. The number, size, position, siting, and illumination of advertisements,

displayed on or close to a building, must respect the design, scale, features and setting of the building and the character and appearance of the immediate environment.

IV. There will be a presumption against internal illumination of signs in conservation areas.

Policy DSC6 Delete sub-clause on rural areas as unnecessary as covered above. Consequently remove sub-heading

Amend Policy DSC6 as follows: Proliferation


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as not required for just one clause. VI. A cluster or proliferation of signs will not be permitted. VI. In considering any application for advertisements and signs in rural areas, the Council will seek to protect rural amenity and character when considering applications for signage.

Para 20.26 Add in reference to further guidance. Amend para 20.26 as follows: Applicants are advised to consult the Council’s Supplementary Planning Guidance

Document for further information on acceptable advertisements and signs.


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Chapter 21: Housing


Issue No.

Policy/ Para. no.

Commt. ID(s)


21.1 21 PO1482 Would like design codes for housing to be enshrined in the Local Plan

The supporting text for Policy DSC1: General Design Principles references the use of design codes for larger sites. It states: Design codes may be required for larger developments and applications for self-build plots. No amendment necessary.

21.2 21 PO656 Historic England It would be helpful to include a paragraph at the start of the chapter on the importance of high quality design for housing, reflecting local historic character and promoting a sense of local identity and protecting and enhancing the historic environment

Agree with part of the statement although there is some overlap with the wording of 20.3. Will include a statement to this effect.

Amend paragraph 21.1 to read … This chapter sets out the Council’s approach to addressing the need for housing within the Borough up to 2031. A key objective of this Plan is to ensure that new housing is accessible and meets the needs of Borough residents. Housing demand is influenced by the proximity of Broxbourne to London. Demand is rising consistently and the numbers of people in need steadily increasing. The need for residential development places significant pressure on the borough’s places and spaces. To maintain the pleasant environment of the borough, new housing will need to respect its context, be sympathetic to local historic


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character and help build on local identity.

21.3 21 PO1316 Will the affordable rent homes be built at the same time as the larger, more profitable homes?

The particular phasing of the development is determined on a site specific basis. It is up to developers to manage their cashflow and on-site construction. No amendment necessary.

21.4 21.1 PO575 No mention is made in this chapter of the provisions of the Self-Build and Custom Housebuilding Act 2015 and the duty of the Borough Council to maintain a register of persons or associations of persons seeking sites on which to build housing

Self-build is covered in other parts of the Plan. There is no need to specifically mention the duty in the Local Plan as it does not have a policy function. No amendment necessary.

21.5 Affordable Housing

PO1158, PO718

I understand the requirement for affordable housing however there is a concern that landlords will make decisions without council consent – please advise about this process

This is not a matter for the local plan.

21.6 21.2 Policy H1: Affordable Housing

PO358 PO359 PO541 PO1632

Woodhall Properties Ltd Affordable housing should only be required for developments of 10 dwellings or more in accordance with Government guidance. These affordable housing requirements are contrary to Government guidance and will seriously impact on the viability of schemes of this size East Herts DC notes the 10 unit threshold introduced into national planning policy, through the Written Ministerial Statement dated 28 November 2014 and subsequent changes to the Planning Practice Guidance

Agree in part. Confusion about the status of, and weight to be given to, the 2014 Written Ministerial Statement has recently been clarified by the Planning Inspectorate. Councils are able to adopt policies that seek affordable housing contributions from smaller sites, sites of less than 10 houses and 1000m2, if their policies require it, and it can be justified through evidence. Our current evidence is not detailed enough to justify a threshold

Amend policy to state:

I. Affordable housing includes social/affordable rented housing, intermediate and shared ownership housing, and starter homes. The provision of affordable housing will be required on all new residential development on at the following threshold: developments of more than 10 units, and which have a maximum combined gross floorspace of more than 1,000 square metres (gross internal area).


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Home Builders Federation What are the exceptional circumstances that justify the Council levying affordable housing contributions from schemes of 10 units or fewer?

lower than 10 units so it would be untenable to require a contribution for smaller developments at this time. Amend policy partially in accordance.

II. 40% of the dwelling units in the development are required to be affordable.

III. Attempts to circumvent this threshold by fragmentation of a large site, and/or under-development of a site suitable for a higher density will be strongly resisted.

i. Sites of 0.5 ha or more and/or developments of 15 dwellings or more, 40% affordable dwellings will be required.

ii. Sites of 0.25 hectares or more and/or 5 dwellings or more, 20% affordable dwellings will be required.

IV. For residential development proposals for two or more dwelling units on sites capable of providing less than five dwellings (net) and under 0.25 ha, a pro-rata financial contribution, calculated in accordance with the Council's Affordable Housing Strategy, to off-site affordable housing will be required.

IV. The affordable split will be 6550% social/affordable rented and 3550% starter homes/intermediate and shared ownership housing, unless subject to regulatory identified requirements as regard the tenure mix in which case such regulation shall be applicable, including regulatory requirements, or market


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conditions indicate otherwise.

V. Affordable housing should normally be provided on site. Every proposal that includes affordable housing must should ensure that the market and affordable housing are integrated within the scheme, have the same external appearance and quality; and accord with all other development standards in this plan.

VI. Contributions towards the off-site provision of affordable housing in lieu of on-site provision will be an exception, and will only be accepted in relation to developments which the Council considers are unsuitable for the provision of affordable housing. Any contributions towards the off-site delivery of affordable housing will be negotiated in accordance with the Council's Affordable Housing Strategy, national policy requirements and funding arrangements at the time of the negotiation. Off-site contributions will need to be on a minimum of a 1:1 basis.

VII. Proposals to provide affordable housing (or financial contributions towards off-site provision) which fall short of the above requirements on viability grounds shall only be acceptable where they are accompanied by a full


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economic appraisal of the development costs and anticipated values.

21.7 Policy H1: Affordable Housing

PO540 East Hertfordshire District Council The Affordable Housing policy may need updating following the publication of secondary legislation regarding the delivery of starter homes, which is due to be published later this year

Noted. No amendment necessary.


PO944 Lands Improvement Holdings Landmatch s.a.r.l. The thresholds for 40% and 20% could be read as overlapping here and thus clarification is needed in the text of Policy H1

Noted. Policy to be amended as for issue: 21.6


PO946 Lands Improvement Holdings Landmatch s.a.r.l. In the case of Policy H1 we consider that reference to the potential need for a viability assessment is of sufficient importance for reference to it being made within the Policy

Noted. The viability assessment is included within clause VII.


PO935 PO1656

CODE Development Planners Ltd The housing split proposed here contains no flexibility and is, therefore, contrary to paragraph 50 of the Framework which states that affordable housing policies “should be sufficiently flexible to take account of changing market conditions over time” Crest Nicholson The following wording should be added to point II: “The mix of affordable housing will be assessed at the time of an application for planning permission having regard to identified requirements, market conditions and viability”

Partially agree. While a greater degree of flexibility could be useful given the changeable nature of housing markets and Government Policy, some definitive guidance is required as a starting point. The requirement for 20% starter homes has also been dropped, meaning that the Council can alter the mix to better reflect actual need.

Amend paragraph 21.3 as follows: The Council will negotiate the tenure, size and type of affordable units on a site by site basis having regard to housing needs, site specifics and other factors. In all cases the preference is for 650% affordable rent and 350% intermediate housing or shared ownership. Targets will only be varied where viability evidence demonstrates that the cost of bringing a site forward for development prohibits full on-site provision, or where there are exceptional circumstances to justify off-site provision in places where affordable housing is needed more.


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Amend Policy H1 to read as for Issue 21.6.


PO1019 B3Living Ltd Document submitted to demonstrate no evidence based support for Starter Homes Initiative..\..\..\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO1019\New Housing Minister Backpedals on Starter Home Commitment.pdf

Agree. See amendment under Issue 21.6 above.


PO1667 Constable Homes Ltd Documents submitted regarding Broxbourne Landfill Site ..\..\..\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO1667


21.13 Policy H2: Conversion of non-residential buildings to residential use

PO1633 Home Builders Federation Ltd Preventing the conversion of non-residential ground floor premises to housing is an unjustified restriction on secondary legislation (the General Permitted Development Order)

Disagree. The policy does not apply to the conversions to residential use that are permitted development. The only way that this right can be restricted is through the use of Article 4 Directions. No amendment necessary.

21.14 Policy H3: Housing Mix

PO1634 Home Builders Federation Ltd Requirement for a ‘minimum’ of 50% three bedroom homes lacks the clarity required from local plan policies and as such is contrary to the NPPF

Partially agree in part. On sites which are clearly unsuitable for family size dwellings, a case can be made for a lesser figure, based on the material considerations of the site and housing need at that time.

Amend Policy H3 as follows: I. On schemes in excess of 10 houses, a minimum of 50% of the dwelling units will need to be family size dwellings of 3 bedrooms or more. Amend as for issue 21.19.


PO1634 Home Builders Federation Ltd The Council should provide a policy with much greater clarity in terms of what is needed to meet the housing needs of older people

Noted. Please see proposed amendment below under 21.17


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PO271 PO268

Please include retirement homes and potential retirement village, with a dementia section.

Noted. This is inherent within the policy. No amendment necessary.


PO1634 Home Builders Federation Ltd The Council cannot set standards in an SPG – it must do so through its local plan

Agree. Amend policy in accordance.

Amend policy as follows: II. On schemes over 20 units, Oof the remaining (market) dwellings, 5% should meet the Building Regulations Requirement M4 (2): Category 2 – Accessible and Adaptable Dwellings, or its successor. a proportion, calculated by having regard to the latest relevant evidence at the time, must meet the standards set out in the Borough-wide SPG as being suitable accommodation for older persons.

21.18 Policy H3: Housing Mix – Information for Applicants

PO1634 Home Builders Federation Ltd Paragraph 21.8 states that “regard should be had to the requirements of the Council’s Affordable Housing Strategy” – applicants should not have to have regard for this, it is for the Council to transpose the requirements of its Affordable Housing Strategy into policies in its local plan

Agree. Amend policy in accordance.

Amend paragraph to state: Regard should be had to the requirements set out in the council’s Affordable Housing Strategy. Applicants should consult the Council’s website to view the latest evidence on housing needs and mix. Add in the following supporting text into Policy H1: Affordable Housing - Information for Applicants: The exact configuration of the

affordable units will be determined at the time of the application, having regard to the Council’s Housing Strategy and the most prevailing need at the time and the site context.

As a general rule, the Council will seek


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to achieve the following targets for the affordable housing mix:

1 bed 20% 2 bed 40% 3 bed 35% 4 bed 5%


PO1657 Crest Nicholson objects to this policy on the basis that it is too inflexible and fails to allow for future changes in the local housing market and government policy. Each planning application should be assessed on a site specific basis and should have regard to the latest SHMA or national planning policy guidance The policy should be revised to the following: I. On schemes in excess of 10 houses, a proportion of units will need to be family size dwellings of 3 bedrooms or more. The exact proportion of units will be established on a site specific basis having regard to the latest relevant evidence at the time. II. Of the remaining dwellings, a proportion, calculated by having regard to the latest relevant evidence at the time, must be suitable accommodation for older persons.

Partly agree. Additional flexibility would be useful in applying mix. The purpose of a policy is to offer clarity on a particular issue. Applications not in accordance with the district plan can be considered on their merits, having regard to the material circumstances prevailing at the time. For II. Please see proposed amendment under Issue 21.17 above.

Amend Policy H3 as follows: The Council will seek a mix of housing for each site that results in communities that are balanced and socially diverse. Developments proposed for strategic housing allocations, as shown on the policies map, must be inclusive, providing for a mix of occupiers and tenures and the entire range of ages.


PO988 B3Living New housing should meet needs of people moving for employment, and aspirations of residents who want to move. The waiting list is dominated by singles and couples who need smaller dwellings, possibly flats, and existing owned and rented stock has many elderly under-occupiers who may move

Noted. An important part of the mechanics of the housing market is providing housing of a suitable size for people to downsize into, freeing up larger homes for those wishing to upsize. The housing mix policy aims to reflect

Amend text of paragraph 21.7 to read: The Council's Strategic Housing Market Assessment (2013) estimated 75% of overall housing requirements (both market and affordable) are for 2 and 3 bed properties. The greatest demand for affordable housing


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to more appropriate housing if it is available. There is also a need for family houses for rent and sale.

these needs. Amend paragraph in accordance.

is for one and two bed properties. The highest demand for market housing is for 3 bed properties, market housing at or more at 55%.

21.22 Policy H5: Housing For Specific Needs

PO1395 Hertfordshire County Council Property Health and Community Services (HCS) OLDER PEOPLE Extra care/flexicare The Housing Learning and Improvement Network target of 25 units of extra care per 1,000 people aged over 75, would require an increase of 108 flats by 2020 in Broxbourne. Residential care HCS aims to use residential care beds to facilitate hospital discharges through intermediate care models. For Broxbourne, HCC predict a need for 112 additional residential care home rooms by 2025. Nursing Care There is a current shortage of capacity (particularly nursing dementia/older people with complex mental health issues) that is available for funded placements. For Broxbourne, HCC predict a need for 340 additional beds by 2025. LEARNING DISABILITY Accommodation for Independence HCS have a growing need for smaller flats for supported living schemes for Learning Disability clients. They should comply with Part

Noted. Amend paragraph 21.14 text to read: Accommodation for the elderly is moving towards more flexible forms of living which allow for continuing care in one place as care needs change. This type of housing will provide support for people who seek to downsize from family size housing earlier in their advancing years, yet wish to maintain their independence. Options where residents can enjoy their own self-contained small home or dwelling unit within larger developments offering a range of additional support options and facilities are particularly sought after. These include retirement villages, where residents have a small dwelling within a development offering varying levels of care and support. Other forms of accommodation for older or vulnerable people include residential care or nursing homes with higher levels of care and support. Forecasts currently indicate that Broxbourne requires 340 additional nursing care beds by 2025. A range of living options for those with specialist needs such as learning and physical disabilities, dementia and neurological health conditions is also required.


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M4 (2) of the building regulations (Accessible and Adaptable dwellings) and ideally be in small clusters and walking distance of shops and public transport. Supported Living and Residential Accommodation HCC wants to increase community living accommodation provision, for people with specific needs. PHYSICAL DISABILITY/SENSORY IMPAIRMENT Residential The number of adults with a moderate/serious physical disability is expected to increase by 10% by 2025. HCC wants alternative housing options to promote independence. Specialist Provision HCC has a gap in specialist provision to meet specific needs. MENTAL HEALTH Hertfordshire Partnership NHS Foundation Trust (HPFT) provides inpatient services for people with dementia and will be looking to the market to provide 80 beds. Residential Care Dementia diagnoses are projected to increase 15% by 2020 and 34% by 2025, and Mental Health prevalence to increase 6% over the next 10 years. HCC wants to increase alternative housing and support options.

It is important that dwellings for older and vulnerable people are located close to public transport options and key local services.


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Move-on Accommodation HPFT require accommodation for individuals with well-managed mental health. Demand is for one bedroom flats/studios.

21.21 Policy H5: Housing For Specific Needs

PO1025 B3Living Ltd Schemes for shared ownership for elderly ‘downsizers’ should be encouraged.

Agree. Communal or co-operative living for elderly people has become much more achievable in recent years and offers a range of benefits for elderly people. Amend text to read:

Amend paragraph 21.14 to read … These include retirement villages, where residents have a small dwelling within a landscaped development offering varying levels of care and support, and co-operative, mutually supportive, dwelling schemes with units within an apartment block dedicated to the retired.

21.23 Policy H7: Residential Moorings

PO458 Kings Arms & Cheshunt Angling Society There should be additional restrictions imposed requiring moorings not to be adjacent to the towpath, human waste and domestic waste disposal facilities to be in place on site, on site storage for tools and heating fuel and adequate parking space for residential mores.

Noted. Please see proposed amendment to the policy and supporting paragraph under 21.29 below.


PO1184 London Canal and River Trust More clarity is needed here, as it is difficult to judge what the harm would be, and what the intrinsic character of the river or canal is (particularly given the historic use of the canal was for boat traffic and the mooring of boats)



PO1185 London Canal and River Trust Feel that c) should be amended as “river or canal congestion” is not clearly defined, and to clarify whether “transport” refers to waterborne freight


21.26 Policy H7: PO1186 London Canal and River Trust Would also Noted. Please see proposed


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Residential Moorings

suggest two additional points, d) provision of appropriate services and amenities, and e) the potential impact on water resources (for new marinas or basins)

amendment to the policy and supporting paragraph under 21.29 below.


PO1186 London Canal and River Trust a) should mention the potential impact on the waterway’s role as a biodiversity, heritage and recreational asset and landscape feature



PO1186 London Canal and River Trust b) should change “detrimental impact” to “potential impact”



PO2082 Lee Valley Regional Park Authority Objects to Policy H7 - permanent residential moorings, with the associated secure provision and access requirements are not considered appropriate within the Park, which encompasses the entire length of the River Lee and the River Lee Navigation within Broxbourne

Agree. Given the increasing pressure for housing, demand for residential moorings is likely to increase. Permanent residential moorings can adversely affect the River Lee environment. They also reduce the opportunities for water based recreation such as canoeing, visitor moorings, rowing and the possibility of a water taxi service. Reword paragraph 21.21 and Policy H7 in accordance.

Paragraph 21.21 The River Lee, and the Lea Navigation complex fall within the Lee Valley Regional Park. They hasve a number of international wildlife designations and is are a highly valued element within the Borough landscape. Given the increasing pressure for housing, demand for permanent residential moorings is likely to further increase. Permanent residential moorings can have significant adverse effects on the amenity and environmental quality of the River Lee. They also reduce opportunities for water based recreation such as canoeing, visitor moorings, rowing and the possibility of a water taxi service. Permanent residential moorings, with the associated secure provision, and access requirements are not considered appropriate within the Regional Park.


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In locations away from the main course of the River Lee and the Lea navigation, applications for moorings within marina-type developments will be considered on their merits. Visitor and leisure moorings offer an attractive alternative way to enjoy the Regional Park, and are seen as compatible with the purpose of the Park. Applications for residential moorings will only be considered where they are compatible with waterways and their surrounding environment. Policy H7: Residential Moorings

Permanently moored vessels on the River Lee will be determined by the following criteria:

(a) the harm the proposal may have on the intrinsic character of the river or canal;

(b) whether there is any detrimental impact on the amenity of the area as a result of traffic generation or servicing needs;

(c) the potential impact on recreational users, transport borne freight and river or canal congestion.


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Policy H7: Permanent Residential Moorings I. Applications for permanent residential moorings within the Lee Valley Regional Park will be resisted.

Information for applicants

21.22

The Council expects mooring proposals to demonstrate adequate servicing, including provision for water, electricity, waste and sewage; secure access to the river bank; and demonstrate that the mooring and associated development and servicing do not impede other waterside uses, paths or access to the waterway.


PO1956 Environment Agency a) should add “including the riparian zone”


21.31 21.22 PO1187 London Canal and River Trust Not all residential moorings require the full list of services described


21.32 21.22 PO1957 Environment Agency You should expand this to ensure mooring also does not negatively impact biodiversity


21.33 21 PO2011 Woodland Trust Refer to the benefits of trees and the need for them, and for green infrastructure, within the Housing chapter.

Noted. The Council has tried to keep the plan succinct and has party achieved this by avoiding overlap with other sections.


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Trees are covered under other sections. No amendment necessary.


Policy/ Para. no.

Commt. ID(s) Issue Considered as: Issue No.

N/A



Whole chapter Rearrange sections and policies to go from the more general (and therefore more commonly used) to the more specific

Chapter rearranged and policies renumbered

New Policy H1 (II.): Conversion of non-residential buildings to residential use

Retail is too specific as we will also want to control the conversion of other commercial and high street uses.

Amend new policy H1: Conversion of non-residential buildings to residential use as follows: II. The conversion of premises into residential use will be resisted where the premise is a ground floor retail commercial unit within the Borough’s town, district, neighbourhood or local shopping centres.

21.2 Needs an introduction to levels of need to help paint picture.

The Council’s most recent assessment of affordable housing need (2016) suggests that an estimated 406 to 596 households are expected to fall into affordable housing need every year, with an identified shortfall of 232-438 affordable homes per annum.

21.2 Delete reference to commuted sum on smaller sites consequential to the changes above.

Experience indicates that smaller sites are sometimes deliberately under-developed in order to avoid on-site affordable housing provision. A proportionate commuted payment is therefore proposed from sites of less than 15


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dwellings in order to help fund off-site provision.

Policy H1: Affordable Housing To allow for a degree of flexibility in the mix of affordable housing which recognises the mix of the development and the Affordable Housing Strategy in force at the time, move to using units instead of dwellings and bedrooms.

Policy to be amended as for issue: 21.6

Policy H1: Affordable Housing To allow for a degree of flexibility in the mix of affordable housing, the Council will also seek a percentage of the bedrooms on the site instead of dwellings.


Policy H1: Affordable Housing Change 50% affordable rented and 50% intermediate shared ownership to 65 % affordable rented and 35% intermediate shared ownership now that requirement for 20% starter homes has been dropped and market take-up for intermediate tenure has grown significantly in recent years.


New paragraph Information for Applicants Add new paragraph into Information for Applicants to clarify any viability challenges will need to be met by applicants.

Add new paragraphs into Information for Applicants

Proposals which are unable to meet the 40% affordable housing requirement will need to be supported by a viability assessment. This assessment will be subject to independent peer review by an assessor appointed by the Council, and will be carried out at the expense of the applicant.

References to starter homes Remove all references to starter homes as no longer a Government policy requirement to provide 20% as part of the affordable housing requirement. It is possible that the definition of affordable housing will be changed to include starter homes but as this is only a proposal at consultation stage, it is too early to make

Amend Paragraph 21.3, 21.4 and Policy H1 by deleting references to starter homes.


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this change.

Houses in Multiple Occupation Add in potential for use of Article 4 Directions where monitoring suggestion over-concentration

Amend para 21.11 as follows:

Over concentration of HMOs within a particular area may result in a deterioration of the amenity of the local area due to the short term nature of their occupants and intensive nature of the use. The Council will strongly resist a concentration of HMOs in one location and will consider the use of Article 4 Directions if monitoring identifies this as an issue.

Policy H4: Houses in Multiple Occupation Delete requirement for 8m2 as inconsistent with standards

Policy H4: Houses in Multiple Occupation I. Proposals for Houses in Multiple Occupation for more than 6 people, will only be supported where the proposal is located close to town centres and is well served by Public Transport. II. All proposals must comply with the relevant development plan policies and design standards set out in this Plan, including the standards set below. III. The proposal must also satisfy the floorspace guidelines set out in the Council’s Broxbourne HMO Amenity Guidance, which includes bedroom sizes as set out below: One-person/one-room unit with separate kitchen 9

m2 One-person/one-room unit integrated kitchen 12m

2 Two-person/one-room unit with separate kitchen

13m 2 Two-person/one-room unit with integrated kitchen

16m 2 A minimum bedroom size allowable by officer discretion of 8 m2. There will be no more than two adults per bedroom


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Policy H4: Houses in Multiple Occupation The amenity guidance also includes guidelines relating to a range of matters in addition to floorspace e.g. number of baths/showers, heating etc.

Delete reference to ‘floorspace’.

Policy H4: Houses in Multiple Occupation HMO licences are currently required for properties with 3 or more storeys and 5 or more occupiers

Reword Information for Applicants to state: Houses in Multiple Occupation occupied by 5 or more people may require a licence from the Council’s Environmental Health Department.

Housing for Special Needs: Information for Applicants

Delete as unnecessary. The Council will welcome proposals which will contribute to a reduction in homelessness in the Borough.

Paragraph 21.17 Amend as limited housing supply is not the only reason 24 Limited housing supply and resulting increase in increasing


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for the increase in house prices house prices …….

Para 21.17 Amend to include other impacts of increasing housing occupancy

Annexes for family members, particularly elderly relatives, can help to meet social needs whilst reducing pressure on other types of accommodation. However, they can have implications for car parking provision, neighbourhood amenity, provision of amenity space, other infrastructure needs such as GPs, and impact on neighbours and the immediate locality.

Policy H6: Residential Annexes Amend so that annexes cannot be accommodated by staff.

II. Where planning permission is granted for a residential annexe, planning conditions will be imposed to ensure that the occupants of the annexe are an ancillary to the primary household, and related to the occupants of the main dwelling.

Policy H6: Residential Annexes Remove reference to Green Belt and rural areas as policy will apply everywhere.

Within the Green Belt and the rural area beyond the Green Belt, pPermission would be not be granted for later sub-division of a dwelling and annexe into two separate residential units….

Policy H6: Residential Annexes Amend ‘would‘ to ‘will' to amend tense error. Within the Green Belt and the rural area beyond the Green Belt, permission would be not be granted for later sub-division of a dwelling and annexe into two separate residential units, unless the proposal meets the planning criteria which would will be applied to new proposals for a separate dwelling.

21.27 Include Lee Valley Regional Park The River Lee and the Lea Navigation complex fall within the Lee Valley Regional Park. They have a number of international wildlife designations and are is a highly valued element of the borough landscape. Given the increasing pressure for housing, demand for permanent residential moorings is high and is likely to further increase. …..

Para 21.22 Delete in its entirety as policy has changed so no longer relevant.

Information for applicants 21.31 The Council expects mooring proposals to demonstrate adequate servicing, including provision for water, electricity, waste and sewage; secure access to the river bank; and demonstrate that the mooring and associated development and servicing do not impede other waterside uses, paths or access to the waterway.


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New Policy Need policy to protect specialist residential accommodation.

Add in introductory paragraph to read:

Specialist Residential Accommodation There is an ongoing need in the borough for specialist

residential accommodation, whether for students, the homeless or other disadvantaged groups. Once established, these facilities serve a valuable purpose in the community. They can be difficult to replace if lost as they often give rise to concerns on social issues and fears about the impact the use may have upon the amenity of their immediate environment. Nevertheless, there is a need for such provision within a socially mixed, balanced and caring society and the Council will seek to retain these facilities wherever possible.

H?? Loss of Specialist Residential Accommodation

The Council will oppose the loss of all forms of existing specialist residential accommodation within the Borough where a demonstrable need exists for its retention, unless it is satisfactorily demonstrated that adequate alternative provision has been, or is being made the applicant can demonstrate that no need currently exists for that type of accommodation.


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ASSESSMENT AGAINST EXISTING PLAN

CHAPTER 3: HOUSING

2005 Policy 2017 Plan Change

Policy H1 Residential Land Supply No No longer required, superseded by Government policy requirements

Policy H2 Maximising the Development Potential from sites

No Could be reincluded – check with DM if actually use it a lot

Policy H3 Strategic Housing Allocations No No longer required, superseded by Government policy requirements

Policy H4 Short Term Housing Allocations 2005 – 2008

No No longer required, superseded by Government policy requirements

Policy H5 Longer Term Housing Allocations 2008-2011

No No longer required, superseded by Government policy requirements

Policy H6 Protecting The Amenity Of Existing Residential Areas

Yes/Partly – (I)(a) doesn’t make sense so not included

(II) has been subsumed into Policy DSC1: General Design Principles and TM3 Access and Servicing.

Policy H7 Retention or Refurbishment of Existing Housing Stock

No – now included Reinclude -DM use

Policy H8 Design Quality of Development Yes Has been subsumed into Policy DSC1: General Design Principles and TM3 Access and Servicing.

Policy H9 Conversion Of Existing Residential Property To Self Contained Flats (previously H10)

No Yes – omission have now included.

Policy H10 Residential Conversion Of Non Residential Premises

Yes

Policy H11 Housing Densities In New Development On Unallocated Housing Sites


Policy H12 Housing Mix Yes - altered Being considered by DC

Policy H13 Affordable Housing Yes – but add in section on phasing Added in.

Policy H14 Securing Provision Of Affordable Housing


Policy H15 Affordable Housing: Ensuring Continuing Benefits



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Policy H16 Residential Care Homes Yes More general than 2005 policy

Policy H17 Sheltered Housing Yes in Policy H5 More general than 2005 policy

Policy H18 Hostel Accommodation Yes and No – see Policy H5 above. Is this necessary when other policies cover?

Add in sub-clause to Policy H5 about complying with other policies e.g. design

Policy H19 Loss of Specialist Residential Accommodation

No – now included with amendment Reinclude -DM use


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Chapter 22: Economic Development


Issue No.

Policy/ Para. no.

Commt. ID(s)


22.1 ED2 PO122 Royal Mail Is concerned that in the draft Local Plan there may be development such as housing close to the two Royal Mail sites in the Borough, which have vehicle movements in early mornings and late evenings. The vehicle movements would cause a loss of amenity to neighbouring developments. Therefore, this policy, about loss of employment sites, is very important to Royal Mail, which supports the wording as robust enough to safeguard the current use of the Royal Mail sites.

Noted. The Council is working on design and layout responses to address the issue of reverse sensitivity – where noise sensitive uses are introduced into a noisy environment. This is addressed on a site by site basis. No amendment of the policy is necessary.

22.2 ED2 PO1578 Campaign to Protect Rural England Herts The policy appears to conflict with the current permitted development rights for change of use of offices to residential use, a consistent source of windfall housing supply.

Planning permission is not required for this change and therefore the policies of the plan would not apply. The Council has also restricted permitted development rights in its employment areas and for certain office blocks by implementing an Article 4 Direction.


22.3 22.8 PO948 Agent on behalf of owners of High Leigh Garden Village site Object to the 18-month marketing period proposed for sites currently in B1, B2 and B8 use. 6 months or 12 months is enough for other planning authorities. Amend this to 12 months instead, as it will still take up to 18 months from the start of marketing to submit a planning application.

There is a range of marketing periods with most ranging between one-two years (2 years is more common in London), and a minimum of 1 year to 18 months (Chichester, South Bucks). Employment uses often employ local residents and are located in areas inherently suitable for



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employment use. This Council is committed to retaining viable employment uses in their current locations. Demand for employment sites in the Borough is high because of the location of the Borough just beyond the M25. The Council wishes to discourage speculative changes of use. We consider a minimum marketing period of 18 months can help discourage speculative application for changes of use as it has a higher financial commitment.

22.4 ED3 III. PO459 To protect access for anglers: a) Oppose creation of an adrenaline hub at the White Water

Centre if it results in a decrease in access for anglers. b) Support development of the leisure pool for recreational

use as increased footfall will benefit traders in the area, e.g. snack bars and cafes

c) oppose reduction in car parking as this will blight neighbouring streets. Free weekend parking should continue.

d) Support creation of a wildlife habitat in the mineral workings in the Spitalbrook area, provided that the LVRPA draft proposal is modified to allow vehicular access, particularly for the less able.

These concerns are noted. Should a planning application for this type of development be received, these concerns can be addressed at that time. This consultation is unable to affect any LVRA proposals.



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Policy/ Para. no.

Commt. ID(s)


22.10 PO2189 Create other opportunities for leisure other than heritage attractions, e.g. well-known restaurants such as Nando’s, also festivals, or an amusement park like Adventure Island in Southend.

Chapter 3 – Development Strategy 3.63




ED2 Delete all to reduce the potential for confusion with the ‘or’ and ‘and’ at the end of each sub-clause.

Development which would cause the loss of an existing employment use, will only be permitted where all the following criteria are met:

ED2 Add in ‘medium term’ after reasonable prospect to offer greater certainty

(a) The retention of the site or premises for Use Classes B1, B2 and B8 or sui generis employment use has been fully explored without success, and that there is no reasonable prospect of the site/premises being suitable and viable for reuse or any alternative employment generating use in the medium term; or …. Add the following sentence into paragraph 22.8 Information for Applicants Medium term is defined as at least 10 years from the date of the application.

Employment Areas -Para 22.4- 22.7

Wording on employment areas requires strengthening and the policy to protect existing employment areas has been omitted.

Amend plan to include:

Amend supporting text: Employment Areas

Employment Areas have been designated within the plan to enable business to carry out industrial type activities with certainty. Demand for space in Broxbourne’s employment areas is high, and the Council is keen to ensure that the space


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is used in the most efficient manner possible.

The protection of these Employment Areas is necessary for sustaining and growing business uses economic development in the Borough. There is a general presumption against the loss of office, industrial and warehouses units in the Borough’s Employment Areas. While the Council will always consider applications for changes of use, changes to non-employment uses will be resisted are less likely to be granted within Strategic Employment Areas. This is because the nature of these areas makes them particularly suitable for industrial uses which have limited locational opportunities as they are often incompatible with residential development.

Businesses often choose, or need to, vacate their premises. This

can leave buildings and sites vacant, and at risk of applications for non-employment use. however The Council recognises that frictional vacancies are to be expected as a normal part of the property letting cycle. To ensure that there is no oversupply in certain types of business units, the Council will monitor vacancy rates within these areas. Examples of exceptions to the loss of these employment units include supporting uses such as crèches and nurseries, training facilities and cafés.

The Council will welcome intensification of use and redevelopment of existing sites for employment uses. The Hoddesdon Business Park Improvement Plan established boundaries for the business park, a plan for overall improvements and a strategy for future development. It continues to provide a framework for development, and will be reviewed and updated within the first 5 years of the Plan.

New employment uses will be strongly encouraged within the


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Borough’s Employment Areas. Development for B1 and B2 uses are strongly preferred as they have higher jobs densities (jobs per sq.m of floorspace) and less adverse effects on the transport network.

New Policy ED2: Employment Areas I. Designated Employment Areas (as defined on the Policies

Map) are reserved for employment use, and other uses which support, or are wholly compatible with, the designation.

II. Within these areas, the Council welcomes proposals for redevelopment and intensification of sites for uses within the B1 and B2 use classes.

III. Wherever possible, new employment floorspace should be of a flexible design, able to adapt to the changing needs of occupiers, and be of energy efficient construction.

IV. Development must not prejudice the continued operation and viability of the Employment Area and neighbouring employment uses.

V. Within the employment areas identified on the proposals

map, the council will permit development, re-development or change of use for an employment use subject to the following criteria:

a) the proposal would not significantly affect the amenities enjoyed by occupiers of properties adjoining the employment area;

b) the proposal would not create an unacceptable impact on the local and/or strategic transport network;

c) the proposed use provides a complementary benefit to the employment area, and serve the needs of local workers;


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d) any retail element must be ancillary to the main business use;

e) the use maximises the employment potential of the area.

New paragraph: Information for Applicants Proposals for waste management and recycling must also have regard to the waste development local plan, prepared by Hertfordshire County Council in its role as waste planning authority. Proposals which provide a complementary benefit to the employment uses and which serve the needs of the local workforce include leisure uses such as gyms, childcare and small scale food outlets.

LIST OF CHANGES TO 2005 POLICIES

Loss of employment sites – rest of the borough (formerly EMP6 LOCAL EMPLOYMENT SITES)

Not taken forward criteria on redevelopment providing essential community benefits as there are lot of sites with potential for ‘essential community benefits’ and few

suitable for employment uses


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Chapter 23: Retail and Town Centres


Issue No.

Policy/ Para. no.

Commt. ID(s)


23.1 23 PO657 Historic England This chapter could helpfully include a paragraph on the protection and enhancement of the historic environment, including the retention and restoration of historic shop fronts

Noted. Will amend in accordance. Amend paragraph 23.5 as follows: The Council aims to provide a variety of retail uses in our centres. It also ensures that new proposals are appropriate, convenient and in-keeping with the locality. Protecting existing town centres is necessary to secure the vitality and viability of retail uses in these centres. As part of this duty, the protection and enhancement of the historic character of the town centre environment can assist in securing the vitality of retail and town centres. This includes the retention and restoration of historic shop fronts. Opportunities are also sought to improve the public realm and access to the centre by public transport where possible. Amend Policy RTC2: as follows: II. The following criteria will be used to consider the acceptability of new development proposal, including extensions, alterations, and changes of use in the Borough’s centres: (a) massing, scale, layout and appearance which should, whether the


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development re-ever possible, enhances the character, including the historic character of the centre, where relevant, and the public realm;

23.2 Policy RTC1: Hierarchy of Town and Local Centres

PO460, PO461

Kings Arms & Cheshunt Angling Society Hopes these will not prevent niche retailers having premises located close to passing trade sources, e.g. a small yacht chandlers situated near the canal makes more sense than it having to be in Hoddesdon Town Centre

Noted. The Council acknowledges that there will always be some retail uses that are better served by being locationally specific. These are considered on their merits at the time of application. No amendment necessary.


PO1140 Bayfordbury Estates Ltd Brookfield Riverside should be consistently referred to here as “Brookfield Riverside Town Centre”, and its position in the hierarchy as “Borough Town Centre”

Noted. We have dropped the reference to a borough centre and will cross reference the Brookfield Chapter at the front.

Amend Policy RTC1: Hierarchy of Town and Local Centres as follows:

Policy RTC1: Retail Hierarchy of Town and Local Centres

I. The Council will permit new retail development within the borough, town and district centres, as shown on the Policies Map, that is compatible with their function and position within the retail hierarchy as shown in Section 3: Development Strategy- Town Centres (?? Need to check correct cross reference at the end) below:

• Borough Centre: Brookfield Riverside;

• Town Centres: Hoddesdon Town Centre, Waltham Cross Town Centre, Brookfield Riverside;

• District Centre: Cheshunt Old


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Pond District Centre; and • Neighbourhood Centres; Local

Centres and Parades.


PO567 Brookfield Riverside is not a town centre – it is out-of-town and this description is unjustified – there is no reason for the Borough Council to create an extra source of traffic congestion and pollution in the Green Belt

Noted. The expanded Brookfield town centre will provide Broxbourne with a borough level identity. It will also ensure that the retail needs of residents met in full as required by the NPPF. The NPPF allows us to define our retail hierarchy as part of the plan-making process; and

allocate a range of suitable sites to meet the … development needed in town centres. It is important that needs for retail, leisure, office and other main town centre uses are met in full and are not compromised by limited site availability. Local planning authorities should therefore undertake an assessment of the need to expand town centres to ensure a sufficient supply of suitable sites;

allocate appropriate edge of centre sites for main town centre uses …. If sufficient edge of centre sites cannot be identified, set policies for meeting the identified needs in other accessible locations that are well connected to the town centre;

set policies for the consideration of proposals for main town centre uses which cannot be accommodated in or adjacent to town centres;


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Expanding Brookfield will also provide a sustainable retail and leisure option for local residents, one that minimises the need to travel.


PO1050, PO1051

Sainsbury’s Supermarkets Limited Brookfield Riverside site should not be promoted as a centre, or for retail development as it will have a significant adverse impact on existing centres, also the current out-of-centre retail park at Brookfield Centre should not be a preferred location for retail development

Noted. The Council considers the expanded Brookfield centre will provide Broxbourne with a borough level identity and sense of place. It will also provide a sustainable retail and leisure option for local residents, one that minimises the need to travel.


PO1881 Greater London Authority The Council may wish to ensure that potential implications from upgrading Brookfield Riverside to a ‘Borough Centre’ on the vitality and viability of nearby London centres are considered as part of its Retail Impact Study

Noted. We have removed the reference to a borough centre. Enfield has been included in the Brookfield Retail and Leisure Impact Study (February 2017). This study concluded that ‘the planned Brookfield development is unlikely to materially harm the trading position of existing retail facilities in the centre. The assessed impact is low (-5.6% at 2024) and the centre is still anticipated to see a significant increase in retail turnover of +31.2% between 2016-2024’. No amendment necessary.

23.7 23.15 PO977 Kentucky Fried Chicken (Great Britain) Limited Considers it inaccurate and unhelpful to associate hot food take-away (HFT) uses with anti-social behaviour (ASB), which is often simply a function of larger numbers of people being in public places having consumed alcohol in the

Noted. Amend paragraph in accordance. Amend paragraph 23.15 as follows: However, hot food take-away uses can be associated with increased incidents of anti-social behaviour, affect the balance of shops and services within town centres, and add to a litter nuisance. They also provide ready


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evening access to foods linked to increasing levels of childhood obesity.

23.8 Policy RTC4: Hot Food Take-Away Uses

PO1114, PO1115 PO1116, PO1121

McDonald’s The proposed policy is overly vague, and does not provide any specific parameters for practical use within a development management process. The policy provides no justification for using the development control system to restrict people’s food choices. It applies an over-generic approach to restrict development with little sound planning reasoning or planning justification. To restrict such a use with no consideration of the sequential approach is unsound and inconsistent with the NPPF, which seeks to promote economic growth.

Noted. Planning policies and decisions should take account of and support local strategies to improve health and wellbeing for all (paragraph 17). When preparing local plans, local planning authorities should work with public health officers and health organisations to understand and take account of the health status and needs of the local population and the barriers to improving health and well-being (paragraph 171).


PO1117 PO1118 PO1119 PO1120

McDonald’s Documents submitted to demonstrate lack of evidence for a link between fast food, school proximity and obesity ..\..\..\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO1117 McDonald’s Documents submitted to demonstrate limited access that children have to fast food during the school day ..\..\..\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO1118 McDonald’s Documents submitted to demonstrate lack of evidence that

Noted. In the absence of current compelling local of such a link, the reference to proximity to a school has been removed.

Amend Policy RTC4 as follows: Proposals involving the establishment of hot food take-away uses will be determined against the Council’s Supplementary Planning Guidance, and its successor documents, and against in accordance with the following criteria: (a) … (b) the proliferation and clustering of hot food take-away uses within the immediate area; and


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purchases in fast food outlets are any more or less healthy than purchases in other A class premises ..\..\..\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO1119 McDonald’s Documents submitted to demonstrate that only limited purchases of food are made at A5 uses on journeys to and from school ..\..\..\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO1120

(c) the proximity of the use to local secondary schools; and (d) the impact upon the quality of the local environment, including the amenity of neighbouring residents, in terms of noise, litter, smells and/or vibrations; and


PO1125 McDonald’s There is a lack of evidence to demonstrate whether fast food is located by schools, or whether schools are located by town centres

Noted. The Council will monitor the situation and review the evidence once collected.

Amend Policy RTC4: Hot Food Takeaway Uses.

Proposals involving the establishment of hot food take-away uses will be determined …against the Council’s Supplementary Planning Guidance, and its successor documents, and against in accordance with the following criteria:

(c) the proximity of the use to local secondary schools; and

23.11 Policy RTC4: Hot Food Take-

PO978 Kentucky Fried Chicken (Great Britain) Limited The policy as drafted is unlawful because it explicitly allows future Supplementary Planning Documents

Noted. Will amend in accordance. Proposals involving the establishment of hot food take-away uses will be determined


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Away Uses

(SPD) to add criteria to those listed against the Council’s Supplementary Planning Guidance, and its successor documents, and against in accordance with the following criteria:

(a) the contribution it makes towards the character, role, function, vitality and viability of the shopping centre, its night-time economy and the local area; and

(b) the proliferation and clustering of hot food take-away uses within the immediate area; and ….

Information for Applicants

23.16

Questions can …use.

23.17

Further information can be found in the Borough-Wide Planning Guidance (2004 & 2013).


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Whole chapter Remove all references to a borough centre and replace with town centre as Brookfield has been designated as a town centre.

Whole chapter Remove unnecessary references to Supplementary Planning Guidance

Policy RTC1 Amend to remove unnecessary references to process and duplication with the NPPF.

Amend Policy RTC1 as follows: The NPPF sets out a sequential test for retail uses, which applies the hierarchy, set out above. II. Retail development will not be permitted elsewhere in the Borough unless otherwise provided for in this plan or where: (a) a qualitative and/or quantitative need can be demonstrated which is not adequately met within the Borough at present: and (b) it is demonstrated through a sequential test, that the land and premises requirements of development cannot be physically accommodated within existing centres or on edge of centre sites or the existing centres cannot accommodate the development without damage to their historic or architectural character or overall environment: ... III. Changes of use within designated centres, as shown on the Policies Map, will only be permitted where there is no harm to the vitality and viability of the centre. Changes of use to residential at ground floor level in these areas will normally be resisted.

Policy RTC2 Remove duplication with NPPF Policy RTC2: Development within


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Designated Centres ... II. The following criteria will be used to consider the acceptability of new development proposals, including extensions, alterations, and changes of use in the Borough’s centres: (a) …; (b) the role of the shopping centre and services it provides, (c) the vitality and viability of the centre; (d) the provision of safe access, full and complete servicing arrangements, and parking; (e) any adverse impacts upon the centre or residents in terms of noise, fumes, smells, litter and general disturbance. III. Retail uses on the edge or outside of these main retail centres may be permitted provided that a sequential test justifying the proposal is submitted and accepted.

Comparison with 2005 Plan

Policies on particular types of frontages have gone as requested, as has the policy on developer contributions.

Policy on shop fronts and fascias included in design chapter.

No specific policy on residential use in town centres – subsumed into RTC2 – Development within designated centres.

No list of centres included.


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Chapter 24: Open Space, Recreation, and Community Facilities Part 1: Issues raised through the Regulation 18 Draft Local Plan consultation

Issue No.

Policy/ Para. no.

Commt. ID(s)


24.1 24.1 PO815 Spitalbrook Village Green Conservation Group What does the vague term ‘permeability’ mean here please?

Agree. Will amend to a more user friendly word.

Encouraging greater levels of walking and cycling through by increasing the accessibility of places throughout and permeability of and beyond the Borough is also an important planning tool in improving health outcomes for residents.

24.2 24.2 PO2220, PO804, PO805, PO809

Spitalbrook Village Green Conservation Group Objects to the deletion of ‘Community Open Space’ and ‘Wildlife Site’ from the designation of land to the rear of Meadway and seeks to have these terms re-instated.

There has been no change in the effect of the designation from the Adopted 2005 Plan. The 2005 Plan meant to apply the community use designation to land in public ownership. It refers to land owned by the Council or ‘other bodies’. This land is now owned by a private individual. The policy sought to prevent the loss of such places but did not and cannot confer a right of public access. Thames Water may have permitted informal access to the land but there is no right of public access to the land. The land still has value as an open space in terms of its amenity value so remains designated for this purpose. The same area of land remains designated as a wildlife site. No amendment necessary.


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24.3 24.3 PO234 The Council could consider planning restrictions on selling or building homes on new developments until new community facilities are opened to service these new homes

Because of the cost of infrastructure provision, certain components may not be provided or funded until a particular phase of a development has been completed. This is normally required by way of a condition on the planning application. No amendment necessary.

24.4 24.3 PO802 Spitalbrook Village Green Conservation Group Voice recording uploaded which they claim demonstrates collusion between the Council and a private developer to remove protections on the land to the rear of Meadway ..\..\..\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO802

No comment necessary. See response for issue no 24.2. No amendment necessary.

24.5 24.4 PO803 Spitalbrook Village Green Conservation Group Land to the rear of Meadway was designated a Community Open Space and Wildlife Site in the 2004 Borough Plan – why was signage advising these designations not erected and a boundary fence to the Wildlife Site not repaired?

The Council has no powers to erect signage on private land. Such signage may infer public access to the land in question, which, being privately owned, is not the case. No amendment necessary.

24.6 24.5 PO82 Sport England The justification for seeking community use agreements could be strengthened if reference were made to the context provided by the Council’s Leisure Strategy which includes a number of strategy recommendations relating to securing community access to educational sites and securing community use agreements

Agree. Amend plan in accordance. Amend paragraph 24.5 to read: The Leisure Facilities Strategy advocates the use of community use agreements to secure access to existing leisure facilities on land such as schools. Community Use Agreements will be sought to secure community use of sports facilities provided on sites which may are not usually normally be available for wider community uses.


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Community Use Agreements should be explored prior to considering new facilities where schools in the immediate vicinity clearly have sports and leisure facilities that are under-utilised.

24.7 Policy ORC1: New Open Space, Leisure, Sport and Recreational Facilities II.

PO83 Sport England A more positive approach should be taken to the principle of new leisure facilities, playing fields etc. For consistency with the Policy title, “sports” should be included to avoid any misinterpretation that the approach does not apply to sports facilities. The opening paragraph of II should be amended to read: “Proposals for new leisure facilities, sports facilities, playing fields, children’s playgrounds and allotments which meet a community need will be supported in principle subject to their design and location having regard to the following” …..

Agree. Amend plan in accordance. Amend ORC1: II to read: Policy ORC1: New Open Space, Leisure, Sport and Recreational Facilities “Proposals for new leisure facilities, sports facilities, playing fields, children’s playgrounds and allotments which meet a community need will be supported in principle, subject to their design and location, having regard to the following” …..The design and location of new leisure facilities, playing fields, children’s playgrounds and allotments should have regard to the following:

24.8 Policy ORC1: New Facilities

PO462 Kings Arms & Cheshunt Angling Society We would expect this to cover opportunities for angling to take place in new ponds or lakes created as part of development either for decorative or flood control purposes

The Council does not have any evidence which suggests that we have a shortage of angling facilities or that there is a significant unmet need for angling facilities among Broxbourne residents. This policy is aimed at facilities which meet the needs of the general population. No amendment necessary.

24.9 24.6 PO84 Sport England Reference should be made to the Leisure Strategy

Agree. Add in new paragraph with detail on the needs identified in the

Add in new paragraph before existing paragraph 24.5 as follows:


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earlier in the Plan to inform and justify the Plan’s approach to health and well-being and to set out the infrastructure requirements relating to open space, sport and recreation

leisure strategy.

The Broxbourne Leisure Facilities Strategy has identified a number of priorities for the Council in respect of its sports and leisure facilities. These include: retaining the existing built sports facilities in the borough; the need for replacement or remedial works on its artificial grass pitches; addressing the high demand for football pitches at particular times; an increase in cricket pitches to meet projected demand and additional rugby pitches.

24.10 Policy ORC2: Loss of Open Space, Leisure, Sport and Recreational Facilities II: (a) and (b)

PO85 Sport England Criterion (a) and (b) are repetitive and appear to overlap. It is suggested that criterion (a) and (b) are amalgamated and replaced with a criterion along the lines of the first bullet in paragraph 74 of the NPPF.

Agree. Amend plan in accordance. Amend criterion (a) and (b) into one criterion which reads: (a) an assessment has been undertaken, which clearly shows the open space, buildings, facility, or land to be surplus to identified need throughout the plan period; and (a) an assessment has been undertaken, by a suitably qualified and competent person, which clearly shows the facility, buildings or land to be no longer required in its current form;

(b) the facility or space is surplus to identified open space, leisure and recreational need throughout the period covered by this plan;

Policy ORC2: Loss of facilities (d)

PO85 Sport England Criterion should be amended to confirm that alternative provision should be equivalent or

Agree. Amend plan in accordance. Amend (d) to read: the development includes an equal or increased amount of alternative or


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better in terms of quality and quantity as stated in para 74 of the NPPF

enhanced open space, sports, recreation, leisure or allotment provision, the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location and accessible on the same basis as the original to local residents;

24.11 Policy ORC2: PO463 Kings Arms & Cheshunt Angling Society We would not be in favour of filling in any ponds or lakes which are not used due to silting up, but would suggest developer with suitable expert advice has to undertake suitable remedial works instead, i.e. de-silting and restocking to increase bio-diversity and bring it back into use


24.12 Policy ORC2: PO1792 Hertfordshire County Council – Spatial Planning Supports this Policy with respect to provision of appropriate compensation of the loss of open space, including allotments, which can have local wildlife value


24.13 Policy ORC2: Loss of Facilities

PO1398 PO1414

Hertfordshire County Council Property (Development Services) Objects to the inclusion of the HCC owned former East Playing Fields of St Mary’s High School as open space on the Proposals Map under Policy ORC2 Plans uploaded of former East Playing Fields of St Mary’s High School which are proposed for residential development ..\..\..\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO1414

Noted. Amend Policies Map to remove area designated as open space adjoining/to the east of the former St Marys School off Churchgate and Goffs Lane.

24.14 Policy ORC2: PO2188 The Enfield Gospel Hall Trust The purpose of the Local Plan is to Amend as follows:


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Loss of Facilities

The Plan needs to ensure that all of its policies are effective, for example the Policy relating to the loss of community facilities should be amended to reflect the varying catchment areas of different community uses

provide for the needs of local residents, however agree that immediate area may be too tightly defined. The phrase has been deleted and replaced with a ‘in a suitable location’. A suitable location has been defined under the Information for Applicants section as in reasonably close proximity to the original site.

For (c) and (d) a ‘suitable location’ is defined as being in reasonable proximity to the original site i.e. 30 minutes walking time.

Para 24.9 PO85 Sport England Paragraph should be amended to advise that the Council’s Leisure Strategy (or any subsequent review or update of it) be used for informing whether facilities (covered by the Leisure Strategy) are surplus to requirements.

Agree. Amend plan in accordance. Amend paragraph to read: A detailed justification of why the loss is necessary and how the existing need will be met must be clearly set out in a planning statement that accompanies the planning application. Applicants will be expected to reference the Council’s Leisure Strategy in the first instance as an indication of need for sports and recreational facilities throughout the plan period.

24.15 Policy ORC3: Local Green Space

PO806 Spitalbrook Village Green Conservation Group The New River Green Chain appears to have been deleted as a policy. We object to this as we feel it was a very valuable policy in relation to the land to the rear of Meadway as the New River forms an important corridor for bio-diversity, especially where it crosses in an aqueduct over the Spitalbrook stream, linking the New River with the Lee Valley Regional Park.

Noted. The Council considers that the objectives of this policy are covered in other policies. No amendment necessary.


PO807, PO808

Spitalbrook Village Green Conservation Group Does Local Green Space already apply to the land to the rear of Meadway, which is virgin green space having never been developed or used except for grazing and recreation of local people,

The land to the rear of Meadway does not meet the definition of Local Green Space as stated in paragraph 77 of the NPPF below as it is the Council’s view that the area does not have a particular


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excluding the children’s play area with swings etc.?

local significance. The Local Green Space designation will not be appropriate for most green areas or open space. The designation should only be used: ● where the green space is in reasonably close proximity to the community it serves; ● where the green area is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife; and ● where the green area concerned is local in character and is not an extensive tract of land. No amendment necessary.


PO1305 DLA Town Planning Ltd Designation of the land south of Andrews Lane as Local Green Space is neither appropriate nor in compliance with Government policy – it is not clear which community it currently serves, it is not demonstrably special to the local community

We believe that the land meets the criteria listed in paragraph 77 of the NPPF.

Amend designation of Local Green Space Lane on land south of Andrews Lane by returning to Green Belt or zoning as Countryside Protection and Enhancement.

24.18 Policy ORC4: Amenity Spaces

PO360 Woodhall Properties Ltd Undesignated amenity spaces should only be protected if they are of amenity value and fully accessible to the public for recreation purposes

Agree that the policy should satisfy both an amenity and a recreational or nature conservation function in order to be protected. Amend policy in accordance by requiring 2 of the 4

Amend Policy ORC4 to read:

Amenity spaces within the Borough which are not designated will be protected provided that it:


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criteria to be met (instead of just 1) in order to justify protection.

(a) continues to provide a visual break within the built up area; or

(b) forms part of a chain of open spaces throughout the built up area; or and

(c) hosts an element of semi-natural habitat useful in creating a stepping stone to another habitat or any other feature of value to wildlife; or

(d) is lawfully publicly accessible and used for formal or informal recreational purposes by local residents.


PO810 Spitalbrook Village Green Conservation Group Land to the rear of Meadway meets all the criteria a to d in Policy ORC4: Amenity Spaces

No public access is granted to the Land to the rear of Meadway as it is currently used for grazing horses. This policy is not intended to apply to land in not in public or communal ownership and therefore the policy does not apply.

No amendment necessary, other than those set out in 24.19 (? check no. at end) above.


PO1658 Crest Nicholson If this Policy is retained in the Local Plan the following additional criterion should be added: (e) is not private land and is publicly accessible

Agree in part. Amendments set out in 24.18/19 (? check) as above.

24.21 24.14/Policy ORC5 II.

PO1399 Hertfordshire County Council Property (Development Services) HCC are not looking to add any additional library service points within the Borough but would serve the additional population resulting from the proposed new developments through the development of existing service points using S106

Noted. Amend policy in accordance by adding in a clause about suitability of the building or site to the use.

Amend Policy ORC5 II. as follows: Development proposals should not result in a loss of premises currently in active and regular community use, unless the building or site is demonstrably no longer suitable for the type of use or the use is not viable, and


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or CIL funding. We are looking to relocate Cheshunt Library to a more suitable building and location.

alternative provision can be found in the catchment area of the use or facility borough or within reasonably close proximity.

24.22 24.16 PO1001 Plainview Planning Ltd Object to exceptional circumstances and provision of an alternative as too high a bar for community facilities. Suggests the following amended wording: “The loss of community facilities will be resisted unless the use is no longer required, viable or there is alternative provision in the vicinity”

Agree will amend text in accordance. The loss of community facilities will be resisted unless exceptional circumstances can be demonstrated which justify the loss can be justified through evidence of no unmet community need, or alternative, improved provision has been made as part of the development.

24.23 Policy ORC5: Community Uses

PO86 Sport England Paragraph 24.9 of the supporting text should be amended to advise that the Council’s Leisure Strategy (or any subsequent review or update of it) will be used in the first instance for informing whether facilities (covered by the Leisure Strategy) are surplus to requirements

Noted. Agree with sentiment. Have already amend paragraph 24.9 to reference the strategy (see 24…..above) No further amendment necessary.


PO999 Plainview Planning Ltd Suggests the following amendment to the Policy wording: “II. Development proposals should not result in a loss of premises currently in active and regular community use unless it is demonstrated that it is no longer practical, desirable or viable to retain them, or alternative provision can be found in the catchment area of the use or facility”

Agree in part. Policy already amended under issue no 24.21 (?check no) 24.9.

No further amendment necessary.


PO1400 Hertfordshire County Council Property (Development Services) While there are no plans to replace the fires stations at present, the fire station at Hoddesdon is very old and any opportunity to replace it with a more modern provision in the immediate area



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would be considered. Would continue to recommend the provision of sprinkler systems in all buildings and new developments to form part of an integrated safety provision


PO1401 Hertfordshire County Council Property (Development Services) Documents uploaded detail the current position on Children’s Centres and suggest a shortage of Free Early Education places from September 2017 in Goffs Oak, Wormley and Turnford and Waltham Cross



PO1402 Hertfordshire County Council Property (Development Services) High quality youth facilities need to be made available to serve the new development in Turnford/Wormley/Brookfield area if good transport links were available, but this could be an adaptable shared space with other community groups



PO2000 The Enfield Gospel Hall Trust We do not consider the Policy to be effective as there is no clarification as to what comprises the ‘catchment area’

Agree. Amend plan to remove. II. Development proposals should not result in a loss of premises currently in active and regular community use, unless alternative provision can be found in the borough or within reasonably close proximity in an adjoining borough. catchment area of the use or facility.

24.29 24.17 PO87 Sport England Paragraph should be amended to advise that the Council’s evidence base documents including the Leisure Strategy (or any subsequent review or update of it) should be referred to where

Noted. Amend plan in accordance. Amend paragraph 24.17 as follows: For the loss of any community building information should be submitted setting out why the proposed use is of overall benefit to the local community


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applicable to inform the value of community facilities that would be lost and where applicable to assess the community benefits of proposals that may result in the loss of existing facilities

and what measures have been undertaken to either retain the building for community use or, if there is evidence of ongoing or unmet need, find alternative provision within the Borough. The Council’s Leisure Strategy should be referenced if the use is included within the Strategy.

24.17 24.17 Plainview Planning Ltd Paragraph mainly replicates the policy text and could be considered superfluous

Paragraph has been amended above under issue 24.29 to be more specific and include a reference to need to reference the Council’s Leisure Strategy.

24.30 Policy ORC6: Equestrian Development

PO88 Sport England In recent years, Sport England has experienced an increasing number of proposals for redeveloping equestrian centres (many of which provide equestrian sports facilities) in the countryside into residential development which may result in the loss of strategically or locally important equestrian facilities. The impact of such proposals in terms of the community’s equestrian facility needs is often overlooked. An additional paragraph to the Policy along the following lines is suggested: “Development proposals involving the loss of equestrian facilities or their conversion to other uses will not be permitted unless an assessment has been undertaken which clearly shows that the facilities are surplus to requirements” This addition would be consistent with Government policy on sports and recreational

Agree. Amend plan in accordance. Amend paragraph 24.18 to state: Equestrian or horse related activities are popular forms of leisure and recreation in the Borough. Riding schools and stables can fit in well with agricultural activities and help to diversify the rural economy. Changes of use of riding schools and stables can result in the loss of strategically or locally important equestrian facilities, contrary to Government policies which aim to support and retain such facilities. The Council will support equestrian development that maintains environmental quality and the character of the countryside. Amend policy ORC6 by adding in a new


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buildings/land (which would include equestrian facilities) in paragraph 74 of the NPPF and provide a clear policy approach for assessing such proposals. The supporting text should provide a brief explanation of the need to resist the loss of equestrian centres which meet community needs and for an assessment of needs to be prepared to support planning applications involving the loss of such facilities.

sub-clause II as follows: II. Development proposals involving the loss of equestrian facilities or their conversion to other uses will not be permitted unless an assessment has been undertaken which clearly shows that the facilities are surplus to requirements. Add in new paragraph preceding 24.21 to read: Any application which results in the loss of an equestrian facility should be accompanied by an assessment of community equestrian need and the role of that facility in meeting that need. Amend paragraph 24.21 to read: In considering any proposal for equestrian development, the Council will expect freestanding stables to be well screened from the surrounding countryside and that new buildings for indoor use should be located closely to existing buildings.

24.31 Policy ORC6: Equestrian Development

PO1793 Hertfordshire County Council – Spatial Planning The Policy should also include a criterion “There would be no detrimental impact on a recognised Wildlife Site”

Agree. Amend plan in accordance. Amend Policy ORC6 by adding new criterion as follows: (h) There will be no detrimental impact on a recognised wildlife site.



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Policy/ Para. no.


Policy ORC 2 PO1398 PO1414

Hertfordshire County Council Property (Development Services) Objects to the inclusion of the HCC owned former East Playing Fields of St Mary’s High School as open space on the Proposals Map under Policy ORC2 Plans uploaded of former East Playing Fields of St Mary’s High School which are proposed for residential development

Amend Policies Map to remove area designated as open space adjoining/to the east of the former St Marys School off Churchgate and Goffs Lane.

Policies Map

Appendix F: Glossary

Define ‘Waterside Green Chains’ as used in Policy ORC ….

Waterside Green Chains: A strip eight metres wide either side of any watercourse, whether main river or ordinary.

Policies Map Remove the open space designation from Land at the Read of Meadway.

This land should not be designated as open space as it is privately owned.



24.2 Delete sentence relating to education as unnecessary. Community facilities play a significant role in developing the social and physical health and wellbeing of residents by allowing activities and interests outside of home and work. They help bring people together and establish new communities. Access to education is another key contributor to a sense of community and wellbeing. Open spaces and recreational facilities also present great opportunities to protect and enhance biodiversity within the Borough.

Policy ORC1.I. Tighten up policy so that minimum standards have greater weight. I. The Council will require contributions to the provision of new open space, community and leisure facilities for all residential development proposals, having regard to national


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guidance, the Council’s Leisure Facilities Strategy, existing provision within the vicinity of a development and the potential for shared use of facilities, and in the Infrastructure Delivery Plan any supplementary planning guidance or any successor.

Policy ORC1.V Delete ‘The use of’ as unnecessary. V. Proposals should aim to provide for the dual or multiple use of facilities for wider community activities. The use of Community Use Agreements will be sought where appropriate.

Policy ORC2 “As shown on the policies map” is too restrictive and needs to be removed so that the policy applies to all such facilities.

Amend Policy ORC2 (I) I. Open spaces, sport, recreational and leisure facilities, including playing fields, allotments and children’s play areas, as shown on the Policies Map, will be protected from development.

Policy ORC2 Move (e) so that it follows the need criteria II. Exceptions to this will be considered if they meet the following criteria:

(a an assessment has been undertaken which clearly shows the open space, buildings, facility, or land to be surplus to identified need throughout the plan period;

(e)(b) the proposed use is of direct overall benefit to the wider local community or part of a wider regeneration scheme………

(e) the proposed use is of overall benefit to the local community or part of a wider regeneration scheme.

Policy ORC 2 new (b) Reword to strengthen benefits to the community so that less tangible community benefits such as an increase in the amount of housing provided is excluded.

(b) the proposed use is of direct overall benefit to the wider community or part of a wider regeneration scheme; or


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Policy ORC2 Delete (c) as largely duplicates (d) and replace with clause on alternative sports or recreational development

(c) in the case of non-open space recreational or leisure facilities or uses, enhanced alternative or better provision will be made elsewhere in the immediate area as part of the development proposal; the development is for alternative sports and/or recreational provision, in a suitable location, the need for which clearly outweighs the proposed loss; or

Policy ORC2 Clarify how the criteria will be applied. II. Exceptions to this will be considered if they meet the following criteria:

(a) an assessment has been undertaken, by a suitably qualified person, which clearly shows the open space, buildings, facility, or land to be surplus to identified need throughout the plan period and

(b) the proposed use is of overall benefit to the local community or part of a wider regeneration scheme or

(c) the development is for alternative sports and recreational provision, the need for which clearly outweighs the loss or

(d) the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location and accessible on the same basis as the original to local residents.

Policy ORC3 Update site specific references to reflect other changes Amend Policy ORC3: Local Green Space as follows: I. The St James’ Green Ring Link at Rosedale Park, Turnford

Brook at Brookfield, Theobalds Park Farm south of Park Plaza West, and Goffs Oak Village Green Open Space, are all designated as Local Green Space as


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shown on the Policies Map. Within these areas built development will not be permitted …

Policy ORC6 Delete ‘small scale’ and (up to 5 stables) as medium and large size operations may be just as acceptable and have just as limited impact on the environment. Five is also an arbitrary number, not based on any particular evidence, which may not be viable for a commercial enterprise.

Proposals for small-scale equestrian development (up to 5 stables), whether domestic or commercial, will be permitted when the following criteria are met:

Policy ORC6 Move to Green belt chapter as better included as part of rural diversification

Moved to GB chapter

Policies Map Remove the open space designation from land at St Marys School. This land should not be designated as open space as it is to be developed.

Policies Map Remove the open space designation from Land at the Read of Meadway.

This land should not be designated as open space as it is privately owned.

Changes to policies in the Local Plan 2005

Policy CLT3 Maintenance of Landscaping/Open Space – no longer relevant as the Council no longer takes commuted payments for sites to be taken on by the Council.

Policy CLT4 Lee Valley Regional Park – no longer required as the plan forms part of the ‘development plan’.

Policy CLT 5 Hotels and Overnight accommodation – no longer required as covered in Policy ED3: Visitor Infrastructure and Attractions and the DSC1: General Design

Principles

Policy CLT 6: Bed and Breakfast Accommodation - – no longer required as covered in Policy ED3: Visitor Infrastructure and Attractions and the DSC1: General Design

Principles


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Chapter 25: Water


Issue No.

Policy/ Para. no.

Commt. ID(s)


25.1 25 PO1906 Thames Water Utilities Limited In the event of an upgrade to sewerage network assets being required, up to three years lead in time is usual to enable for the planning and delivery of the upgrade and we may also request a drainage planning condition to ensure the infrastructure is in place ahead of occupation of the development

Noted. No amendment necessary

25.2 25 PO1907 Thames Water Utilities Limited Growth forecasts for wastewater treatment capacity are currently being reviewed and updated

Noted. We will work together with Thames Water to take into account any final forecasts or other new information.


25.4 25 PO1955 Environment Agency There should also be a policy which covers invasive non-native species and their management, including biosecurity measures

Noted. While Section 215 of the Town and Country Planning Act allows Local Authorities to act where amenity is an issue; there is a raft of more specific legislation on non-native invasive species which is more suitably deployed.


25.5 25.4 PO1794 Hertfordshire County Council – Spatial Planning Whilst the international significance of the Lee Valley is recognised, there is no mention of the required Habitat Regulations Assessment.

HRA is a process which underpins the plan. It does not need to form part of the plan text.


25.6 25.5 PO1797 Hertfordshire County Council – Spatial Consider that the point is already made


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Planning Paragraph 25.5 should be reworded as follows, ‘The Lee Valley SPA and Ramsar site benefits from the highest levels of nature conservation protection via the Habitats Regulations. These require all plans and projects that may harm the ecological interest of the site to be subjected to a ‘Habitats Regulations Assessment’ or ‘HRA’. Any proposals that are subsequently shown to result in an ‘adverse effect on the integrity of the site’ will not normally be permitted’

and is even stronger in the Natural Environment chapter. No amendment necessary.

25.7 25.6 PO1958 Environment Agency Paragraph 25:6: It is positive you have mentioned the WFD and Thames River Basin Management Plan (RBMP) but this should also be included within a policy

The Council considers that the content of these documents is reflected within the policies and does not consider it necessary include the name of the European Directive and title of the RBMP in the actual policy. Both will date quickly in the immediate future post-BREXIT and because of this we will amend the policy to remove all unnecessary detail.

Amend para 25.6 as follows: The Water Framework Directive requires

the Environment Agency to develop a management plan for each river basin. Local authorities must “have regard to the River Basin Management Plan and any supplementary plans in exercising their functions ”. This means they need to reflect these management plans in local planning policies; infrastructure delivery plans; and in determining planning applications. Within the Thames River Basin Management Plan 2015, the Lower Lee North Catchment Partnership has identified the following priority issues for our part of the catchment: poor water quality from waste water treatment, pollution incidents and misconnections, pollution and poor water quality from urban run-off and historic land use, and physical modifications for


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urbanisation and flood protection.

25.8 25.7 PO465 Kings Arms & Cheshunt Angling Society The wildlife habitats not to be affected must include both aquatic and waterside, as it’s no good providing a good habitat for a kingfisher to use if the adjoining water course is devoid of fish for it to eat; a good aquatic habitat will encourage proliferation of endangered species like the water vole and European eel both of which are currently in decline and need their environments protecting.


25.9 25.7 PO1189 Canal and River Trust Paragraph 25.7 states “The Council will resist any development which has the potential to contribute to flood risk, has adverse impacts on river channel stability or quality and which damages wildlife habitats” – we suggest this should be included within a policy

Noted. A more general approach could be included within the policy. Amend in accordance.

Amend Policy W1: New I. The Council will resist any development which has the potential to contribute to flood risk, have an adverse impact on river channel stability or quality and the potential to damage wildlife habitats. I. II. Development proposals will be required to preserve and enhance the water environment, ….

25.10 25.8 PO466 Kings Arms & Cheshunt Angling Society We believe the word “can” should be changed to “will” as this is a certainty rather than a possibility, as even if impact is not immediately local, cumulative effects will result downstream

Paragraph has been deleted – see under Section 3 below

25.11 25.8 PO1959 Environment Agency Changes to the shape of rivers and streams can also have an impact on flood risk

Paragraph has been deleted – see under Section 3 below


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25.12 25.9 PO467 Kings Arms & Cheshunt Angling Society We have concerns about the use of both culverts and watercourse straightening within surface water drainage systems – culverts should be of minimal length and large enough to cope with extreme flows, channel straightening should not be allowed as it damages the immediate aquatic environment

Agree. Amend paragraph 25.9 in accordance with issue 25.13 below.

25.13 25.9 PO1960 Environment Agency Physical modifications (such as culverts and weirs) should be removed wherever possible, rather than just installing fish passes

Agree. Amend in accordance. Amend paragraph 25.9 to read: Physical changes to watercourses such as the culverting or straightening of a restrict the natural processes that should occur functioning of the watercourse such as trapping pollutants through marginal vegetation, and stop the passage of fish and other animals. Culverts, and other structures being are vulnerable to blockages and can also increase flood risk by restricting the space available through which for water to can flow through an area and. In order to improve the quality of the water environment, the Council will seek the restoration of natural channels, wherever possible, and resist proposed physical modifications to watercourses. As a last resort, in order to address existing physical modifications, and where no opportunity for restoration exists, techniques such as fish and eel passes can may be installed to help with fish migration.


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25.14 25.10 PO1969 Environment Agency Buffer strips should be at least 8 metres and you should get this requirement included within a policy

Agree. Amend in accordance. Buffer strips, which set development back from the edge of a river or stream, are an essential element in ensuring there is sufficient space making space to allow natural processes to take place and provide for wildlife habitats. The Council will resist any development which has the potential to contribute to flood risk, hasve an adverse impacts on river channel stability or quality and which damages wildlife habitats. Amend Policy W1 by amending and adding new clauses as follows: I. The Council will resist any development

which has an adverse impact on river channel stability or quality and the potential to damage wildlife habitats, including by over-shadowing…

II. The Council will seek that all Ddevelopment proposals will be required to preserve and enhance the water environment, creating space for the natural functioning of watercourses…

IV. A landscaped buffer strip of an appropriate size should be maintained alongside all main rivers and ordinary watercourses.

Amend Information for Applicants as follows: The Council will expect details of any


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deculverting and river restoration works to be submitted with the planning application. Development proposals will need to include an appropriate management scheme for buffer strips. And subsequent numbering amendments.

25.15 Policy W1: I. Improving the Quality of the Environment

PO468 Kings Arms & Cheshunt Angling Society Can this also include water bodies i.e. lakes and/or ponds?

Disagree. Many of lakes and ponds are artificial creations, and therefore are not subject to the same regulatory regime as other aspects of the natural water environment.


25.16 Policy W1: I Improving the Quality of the Environment

PO1635 Home Builders Federation Ltd Development proposals are not required to ‘enhance’ the water environment and the levying of obligations to restore rivers in part III of the policy would not meet with the tests in the NPPF

Agree in part, although all conditions on a development approval are required to meet the 6 NPPF tests, and this plan would not in any way over-ride that requirement.

Amend Policy W1.I to read: The Council will seek that all new development proposals preserve and enhance the water environment, creating space for the natural functioning of watercourses. III. In some instances, financial contributions may be required towards the restoration of rivers, should adequate justification be provided for why this cannot occur on site.

25.17 Policy W1: Improving the Quality of the Environme

PO1188 Canal and River Trust Requests change to criteria ii) to ensure that the function of the waterway as for navigation is not compromised

Agree. Amend Policy W1 by adding: II. On sites ….as part of any development adjacent to a watercourse, provided that where the watercourse is a navigable waterway, that function is not


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nt compromised.

25.18 Policy W1: Improving the Quality of the Environment

PO1659 Crest Nicholson Criterion II should be revised to the following: “II. On sites adjoining or in close proximity to a water body, the Council will seek opportunities for removal of culverts, river restoration and naturalisation, improving in-channel habitat and reducing levels of shade where appropriate, as part of any development adjacent to a watercourse.”

Do not agree. Policy is aspirational as it includes the phrase ‘will seek’. It is not an absolute requirement.


25.19 Policy W1: Improving the Quality of the Environment

PO1970 Environment Agency Policy should mention the Thames River Basin Management Plan and specify a buffer width, also specify that buildings must not over shade watercourses

Partially agree. The Thames River Basin Management Plan is quite strategic. The Council expects that the Environment Agency will inform the Council of any development applications which have implications arising from this plan. Will amend policy to include a buffer strip as noted above under issue 25.14. Shading will be addressed by an amendment to Clause I (now clause II).

Amend Policy W1: New clause. The Council will resist any development which has the potential to contribute to flood risk; adversely impacts river channel quality or stability; and damages wildlife habitats, including by over-shadowing.

25.21 25.12 PO1190 Canal and River Trust Under paragraphs 25.12 – 25.13 “Other Consents and Permits” we would like to make reference to consents required from the Trust, including agreements for drainage, oversailing or encroachments over our land or waterspace

Agree. Amend policy in accordance. Amend Other Consents and Permits to read: Applicants proposing works oversailing, or encroaching on any land, waterspace or property adjoining a navigable waterway, will require consent from the Canals and Rivers Trust.

25.22 25.14 PO1971 Environment Agency Paragraph 25.14 is a bit vague

Agree. Amend policy in accordance. Amend paragraph to read: The discharge of water into the environment Land use activities can result in both direct and indirect discharges detrimentally affecting impact on the


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quality of local surface and ground waters. The discharge of water into the environment can have a detrimental impact on the quality of local waters.

25.23 25.16 PO1816 Hertfordshire County Council – Spatial Planning Concerned that the Local Plan could be encouraging waste planning applications to be submitted to the Local Planning Authority when the County Council is the determining authority for waste applications

Agree. Amend in accordance. Amend by adding in: … to the relevant consent authority.

25.24 25.16 PO1972 Environment Agency Can you also include petrol stations on the list as we will object to any petrol stations proposed within Source Protection Zone 1

Agree. Amend in accordance. Amend paragraph 25.16 by adding: In source protections zones, applications for the following certain uses must submit an assessment of the potential impact of the use on groundwater to the relevant consent authority. Examples of the types of uses where this will be necessary include:

Incinerators

….

Cemeteries

Petrol Stations

Discharge of foul sewer

to ground..

25.25 25.18 PO469 Kings Arms & Cheshunt Angling Society Can you require all drainage systems to not store surface water in enclosed pipes for long periods of time but release it into watercourses where natural climate processes will keep dissolved oxygen levels

Noted. While the exact detail of SuDs schemes is agreed at the time of an application for development, the use of underground or covered detention mechanisms such as tanks is strongly resisted in the SuDS

Amend paragraph Information for Applicants: Drainage Strategies and Plans as follows:

Drainage strategies and plans are required with any planning application


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within a survivable value i.e. at least 20%

policy for a number of reasons.

involving earthworks or construction. Drainage strategies should explain document how the most sustainable foul and surface water drainage solutions have been incorporated into the proposal development. To help prevent surface water contamination following heavy rainfall, the drainage strategy will need to detail how water will be contained on site during rainfall events; including during the construction phase.

The strategy or plan must be prepared in

accordance with accepted industry standards. As a minimum drainage strategies need to include:

A topographical survey;

Ground investigations;

Details of the existing drainage on the site, including flows on to the site;

Detail of how water will be contained on site during rainfall events; including during construction;

The SuDS system proposed and how that will be operated and managed in perpetuity;

The response to the development from the utility companies; and

The location of any sensitive receptors on, or in close proximity to, the site.


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25.26 Policy W2: Water Quality

PO1902 Thames Water Utilities Limited Proposes that planning permission is only granted for developments which increase the demand for off-site water and wastewater infrastructure where sufficient capacity already exists or extra capacity can be provided in time to serve the development

Add in specific policy on water supply and wastewater infrastructure: Proposed Policy Planning permission will only be granted for developments which increase the demand for off-site water and wastewater infrastructure where:· 1) Sufficient capacity already exists; or 2) Extra capacity can be provided in time to serve the development that will ensure that the environment and the amenities of other users are not adversely affected.

In accordance with the Planning Policy Guidance, when there is a capacity constraint and improvements in off-site infrastructure are not programmed, planning permission will only be granted where the appropriate infrastructure improvements will be completed prior to occupation of the development.

Supporting text should be also included:

Companies are subject to a statutory duty to ‘effectually drain’ their area. This requires them to invest in infrastructure suitable to meet the demands of projected population growth. To fulfil their statutory duty, water and sewerage companies must work with local planning authorities, so that proposed growth and environmental objectives are reflected in company business plans. This will help ensure that the necessary infrastructure is funded through the water industry’s price review mechanism.

-


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“The Council will seek to ensure that there is adequate water supply, surface water, foul drainage and waste water treatment capacity to serve all new developments. Developers will be required to demonstrate that there is adequate waste water capacity and surface water drainage both on and off the site to serve the development and that it would not lead to problems for existing or new users. In some circumstances it may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing wastewater/sewerage infrastructure. Drainage on the site must maintain separation of foul and surface flows. Where there is an infrastructure capacity constraint the Council will require the developer to set out what appropriate improvements are required and how they will be delivered.

The development or expansion of water supply or waste water treatment facilities will normally be supported, either where needed to serve existing or proposed new development, or in the interests of long term water supply and waste water management, provided that the need for such facilities outweighs any adverse land use or environmental impact that any such adverse impact is minimised.”


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25.27 Policy W2: Water Quality

PO1973 Environment Agency There is little mention on how Highways Drainage will be managed from the developments. You should also make the following changes to the Policy: Proposals should avoid damage to not result in pollution or decline of quality of groundwater below the site particularly in Groundwater Source Protection Zones, having regard to the Environment Agency's 'Groundwater Protection: Policy and Practice' guidance or successor documents.

It is assumed that drainage from highways will comply with the drainage standards in the Design Manual for Roads and Bridges. In all others ways, it will be addressed in the same way as any other drainage, and incorporated into SuDs systems where appropriate. Amend policy in partial accordance.

Amend Policy W2 as follows: Proposals should avoid damage to not result in the pollution or decline of surface or groundwater quality Groundwater Source Protection Zones, having regard to the Environment Agency’s ‘Groundwater Protection: Policy and Practice’ guidance or successor documents. I. A drainage strategy or plan must be

submitted with all applications requiring discharge to the sewerage system showing how:

a) rain water runoff will be managed on site, including during and following periods of heavy rainfall; and b) how foul and surface water will be managed and disposed of.

25.28 Policy W3: Water Efficiency

PO1905 Thames Water Utilities Limited Future pressures on water resources will continue to increase and key factors are population growth and climate change

The Council will continue to work closely with Thames Water in maximising water efficiency within the Borough and minimising water demand.



PO1636 Home Builders Federation Ltd The Council will need to justify why it wishes to adopt the optional technical standard for water efficiency and consider the viability implications

The Thames region has been designated as seriously water stressed by the Environment Agency. The standard is ‘optional’ to a degree but has been proposed within the NPPG where there is evidence of local need. It is obviously the intention of Government to support the use of this standard in areas that are



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water stressed.


PO1974 Environment Agency You should extend the wording of Policy I (d) to include successors of the BREEAM standard, ensuring that any potential changes of BREEAM during the 15 year plan are included within the policy. Should also strengthen position on retro-fitting existing developments.

Agree. Amend in accordance with the wording proposed.

Amend Policy W3 as follows: II. Where extensions are proposed to existing development, the Council will seek to secure no increase in the average daily amount of water used, or capable of being used if the property is empty, beyond the average daily consumption or consumption capability for the property as existing. If the property is already an exemplar of sustainable development, an increase in consumption may be permitted. III. (d) Commercial and retail buildings will need to demonstrate the BREEAM excellent standard linked to efficient use of water or the equivalent rating within its successors. IV. Proposals to retro-fit existing development with water efficiency measures will be supported.


PO2182 Will the Council stipulate that all new buildings must have rain water harvesting systems installed?

These types of processes are inherent in the proposed water target that the Council is proposing under Policy W3. Requiring developers to meet a water efficiency target allows for a degree of flexibility in how developers choose to meet this standard.


25.32 Policy W4: PO1904 Thames Water Utilities Limited Requests that Misconnections are discussed in the No amendment necessary.


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SuDS the following be included in Policy W4: “It is the responsibility of a developer to make proper provision for surface water drainage to ground, water courses or surface water sewer. It must not be allowed to drain to the foul sewer, as this is the major contributor to sewer flooding”

introductory text to Policy W2. This amendment is considered unnecessary as a number of regulatory processes, including the SuDs approval, building control and development management processes, ensure that surface water is kept separate from foul water under all circumstances.

25.33 Policy W4: SuDS

PO471 Kings Arms & Cheshunt Angling Society It is in everyone’s interest especially anglers that this policy is enforced to avoid negative impacts as a result of non-compliance



PO1637 Home Builders Federation Ltd The Council will need to justify greenfield run-off rates as well as assess the considerable cost implications associated with achieving this very high standard

The Council is required to have regard to the Lead Local Flood Management Strategy. The Lead Local Flood Authority’s SuDS Policy Statement Addendum to the Local Flood Risk Management Strategy states in Policy 14: Proposals for SuDS must demonstrate how the frequency, rate and volume of runoff from the development will be managed to achieve a greenfield rate. On previously developed land, a greenfield runoff rate should aim to be achieved, except in exceptional cases. Where Greenfield runoff rates cannot be achieved, a betterment rate may be deemed acceptable. Flow rate and storage volume calculations should be presented in a



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manner that is acceptable to the LLFA. Local Plan Policy W4 also says ‘should aim to achieve’ so is not an absolute requirement.


PO1674 Constable Homes Ltd Where practicable, SuDS should be designed to ensure the sustainable drainage networks have the additional capacity required to cope with infrequent adverse weather conditions and therefore reduce flood risk



PO1975 Environment Agency You should include a further point to state that SuDS should also aim to deliver improved/new habitat to provide a net gain in biodiversity

Point is covered in clause I. No amendment necessary.

25.37 Policy W5: Flood Risk

PO2013 Woodland Trust The Trust would like to see trees and woodland, which have been proven to have a significant effect on flood amelioration, more explicitly acknowledged in section 25 “Water”, particularly in the subsection “Sustainable drainage”

Agree that the role of catchment management and trees in reducing flood risk is important.

Additional paragraph under Flood Risk before paragraph 25.31 to read: Catchment management has an important role to play in reducing flood risk. Tree planting has a number of benefits and forms an essential component of effective catchment management. Trees slow the rate at which rainfall reaches the ground and enters watercourses and drains. The Council will seek a catchment management approach to managing flood risk, as well as the implications of climate change. Additional sentence under Sustainable Drainage to read:


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Sustainable Drainage Systems (SuDS) mimic natural drainage form a site and manage rainwater runoff from a site. SuDs are a form of catchment management where drainage techniques are used to manage the flow and quality of resulting surface water runoff through a site.

25.38 Policy W5: III. Flood Risk

PO472 Kings Arms & Cheshunt Angling Society Impeding flow by design in a sacrificial area may reduce peak flow slightly but extend duration of peak which could reduce possible over-topping of defences downstream, i.e. stop a flood event lower down

Agree Add into Policy W5: Flood Risk III.b) impede flood water flows, unless by design, and

25.39 Policy W5: Flood Risk III.

PO1675 Constable Homes Ltd Supports this approach to flood risk but believes that the exceptions test, as defined in the NPPF, should be included in this policy to ensure consistency with national policy

Agree. Amend Policy W5: Flood risk III. Development proposals, including the raising of land, in areas at risk from flooding will only be considered if the pass the flood risk sequential test, and if necessary the exceptions test, and they do not…..

25.40 Policy W5:III Flood Risk

PO1976 Environment Agency Even water compatible development should not be allowed in flow routes or storage areas; development proposals in areas at risk of flooding should only be considered if they pass the Exception test, if necessary, and if they do not increase the risk of flooding from all sources of flooding, not just surface water; and if they do not reduce the capacity of the floodplain II. Overland flow routes and flood storage

Agree. Amend Policy W5 to read:

II. Overland flow routes and flood storage areas will be protected from all development other than that which is "water compatible".

III. Amended as 25.38 above

a) Increase the risk if of flooding elsewhere as a result of faster surface


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areas will be protected from all development other than that which is "water compatible". Even water compatible development should not be allowed in flow routes or storage areas.

III. Development proposals, including the raising of land, in areas at risk from flooding will only be considered if they pass the flood risk sequential and if necessary, the Exception test and they do not:

a) Increase the risk if flooding elsewhere as a result of faster surface water run off This should cover all sources of flooding not just surface water.

b) Impede flood water flows, and/or

c) Endanger river channel stability, and/or

d) Reduce the capacity of the floodplain flood water storage areas.

water run off

…

d) Reduce the capacity of the floodplain flood water storage areas.


Policy/ Para. No. Commt. ID(s)


25 Sus Design and Construction

PO2182 Will the Council stipulate that all new buildings must have solar panels and rain water harvesting systems installed?

These types of processes are inherent in the proposed water stand that the Council is proposing under policy W3. While most buildings can support rainwater harvesting, solar panels are not always appropriate. There is some flexibility in how developers choose to meet this standard. No amendment necessary,


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Infrastructure PO1902 A key sustainability objective for the preparation of the new Local Plan should be for new development to be co-ordinated with the infrastructure it demands and to take into account the capacity of existing infrastructure. The National Planning Policy Framework (NPPF) includes specific guidance on water and sewerage infrastructure. Paragraph 156 of the NPPF states:

“Local planning authorities should set out strategic policies for the area in the Local Plan. This should include strategic policies to deliver:……the provision of infrastructure for water supply and wastewater….”

Supporting text

The development or expansion of water supply or waste water treatment facilities will normally be supported, either where needed to serve existing or proposed new development, or in the interests of long term water supply and waste water management, provided that the need for such facilities outweighs any adverse land use or environmental impact that any such adverse impact is minimised.”

17 Infrastructure

Policy W2: Water Quality

PO1902 Thames Water Utilities Limited

Add in specific policy on water supply and wastewater infrastructure

Companies are subject to a statutory duty to ‘effectually drain’ their area. This requires them to invest in infrastructure suitable to meet the demands of projected population growth. To fulfil their statutory duty, water and sewerage companies must work with local planning authorities, so that proposed growth and environmental objectives are reflected in company business plans.

Possible new policy to be added to the Utilities section of the infrastructure chapter.

New Policy in 17…..


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This will help ensure that the necessary infrastructure is funded through the water industry’s price review mechanism. Amend policy in general accordance with that suggested. Policy W ?: Water Infrastructure Planning permission will only be granted for developments which increase demand for off-site water and wastewater infrastructure where: 1) Sufficient capacity already exists; or 2) Additional capacity can be provided in time to serve the development. Where a capacity constraint has been identified, and the necessary improvements in off-site infrastructure are not programmed, planning permission will only be granted subject to the improvements being completed prior to occupation of the development. Supporting text to be inserted: The Council will seek to ensure that there is adequate water supply, surface water, foul drainage and waste water treatment capacity to serve all development proposed in this Local Plan. In addition, developers will be required to demonstrate that there is adequate waste water capacity and surface water drainage, both on and off site, to serve the development. It may be necessary for developers to fund studies to ascertain whether the proposed development will lead to overloading of existing wastewater/sewerage infrastructure. Where there is an infrastructure capacity constraint, the Council will require the developer to set out the improvements required and detail how they will be delivered.


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25.1 Delete first sentence as unnecessary. Amend para 25.1 as follows: Water is both an essential resource, necessary for life itself and a potential hazard. Broxbourne’s…..

25.2 Minor amendments to second paragraph to increase comprehension.

Amend para 25.2 as follows: Over time the past 150 years people have made many changes to rivers and streams. They

have changed the size and shape of river channels for flood defences and weirs, and straightened them for land drainage and navigation. These changes alter natural flow levels, cause excessive build-up of sediment, increase flood risk or divert it to elsewhere within the catchment, lead to loss of habitats loss and restrict the range of recreational opportunities available.

25.4 Replace breeding with over-wintering for accuracy

Amend para 25.4 as follows: Broxbourne residents are fortunate to be living alongside a river and wetland system of

international importance. The Lee Valley Special Protection Area (SPA) has been designated for internationally important numbers of breeding andover-wintering wildfowl, especially Gadwall, Northern Shoveler and wintering Bittern. The Lee Valley system is also a Ramsar site, designated under the Convention on Wetlands of International Importance.

25.5 Minor amendments to increase accuracy.

Amend para 25.5 as follows: This level of significance means that the Lee Valley complex has an additional layer of legal protection known as through the habitats regulations. The Rregulations require that when making plans, such as this plan, or when determining planning applications, the Council must consider the effects of new development on protected sites and prevent any significant harm to the significance of occurring to these sites.

25.8 Delete paragraph as unnecessary detail. Delete paragraph 25.8 as follows: Changes to the shape of rivers and streams, water abstraction, and the discharge of dirty water into

rivers and streams can have a detrimental impact on water quality, wildlife habitats and biodiversity .


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25.12 Remove reference to flood defence consent dated terminology.

Delete as follows: ‘This was formerly called a Flood Defence Consent’.

Groundwater Quality Amend introductory para to remove unnecessary detail.

Amend para 25.15 as follows: Groundwater maintains the flow in many of our rivers and provides a third of our drinking water in England and Wales, and it also. In some areas of Southern England, groundwater supplies up to 80% of drinking water. It is crucial that the relevant authorities we looks after these sources to and ensure that our water is safe to drink. Much of the Borough overlies Groundwater Source Protection Zones 1 and 2.

Surface Water Quality

Add in introductory paragraph after para 25.17 to clarify importance of good surface water quality.

Add in introductory paragraph after para 25.17 as follows: Surface waters make an important contribution to the quality of the local environment. Because of the complexity of the urban environment, achieving a high standard of surface water quality can be challenging. Land uses must be carefully controlled to ensure that unplanned discharges to surface watercourses are minimised.

Misconnections Amend paragraph to clarify issue. Amend para 25.19 and 25.20 as follows: Site level drainage infrastructure must be connected to the correct outfall. If When foul drainage is wrongly connected to surface water sewers, raw sewage discharginges directly into rivers and streams it will have serious detrimental effect on water quality as a result of. If When rain surface water runoff is wrongly connected to foul drains or sewers, the sewerage infrastructure and treatment plants do not have the capacity to cope with the significant amount of additional, unplanned, water. This can result in sewerage bypassing the overloaded treatment plants and discharging straight to rivers and streams.

Misconnections (also called cross-connections) can occur if when building work is undertaken without adequate planning and supervision, e.g. if non-residential spaces or buildings are occupied illegally, or building work occurs without building regulations approval. They are a significant and often largely unknown issue until they are bought to light. This Council aims to ensure that any misconnections are identified and remedied wherever possible. from the Council’s Building Control Service. Development adjacent to, or likely to affect, groundwater or surface water bodies covered by the Thames River Basin Management Plan should contribute towards those water bodies maintaining or achieving Good Ecological Status. This may take the form of on-site measures or a financial contribution to off-site measures.

Policy W2 Add into policy to reduce the likelihood of misconnections

Add to Policy W2: Water Quality II. Drainage on the site must clearly delineate and provide a separation distance between foul and


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surface flows.

25.21 Amendments for clarification on roles of respective organisations.

Amend paragraph 25.21 by amending as follows: Hertfordshire has one of the highest water consumption rates in the country. While water companies have a duty to supply new development, sources of supply are becoming increasingly stressed. Water efficiency measures are essential to ensure there is have enough water for our needs and the needs of the environment in the future.

25.21 Add into first sentence ‘Information for applicants’: ‘strategy or’

Amend ‘Information for Applicants’ un-numbered paragraph after 25.20 to read: Relevant aApplications, as above will not be validated without a drainage strategy or plan prepared in accordance with ….

Policy W3: Information for Applicants

Delete requirement to include options for recycling grey water as unnecessary onerous requirement which should be addressed through other channels.

Delete as follows: Development proposals will need to include details of how the target of 110 l/p/day can be met. Options for recycling grey water should be included.

New para Policy W3 Information for Applicants….

Add in para which advises applicants to approach water and sewerage utility companies at the earliest opportunity when planning a development.

Add in new paragraph to Policy W3: Water Quantity - Information for Applicants as follows: Statutory responsibility to provide water supply and waste water services rests with the water and sewerage utility companies. Applicants are strongly advised to approach the relevant utility company as soon as the details of a site specific development proposal are known. The provision of new infrastructure can take up to 10 years and development needs to factor timeframes for the provision of infrastructure into assumptions about phasing and delivery.

25.23 Amend to offer additional detail on how SuDs can help cope with climate change.

The term SuDS includes a broad range of measures covering methods which trap pollutants at the side of the carriageway through a swales (shallow grassy ditch) to large balancing ponds that regulate flow quantity as well as allowing pollutants to settle out. SuDS are moderately offer a greater degree of resilientce to the effects of climate change over piped solutions as they use natural processes and designed to cope well with fluctuations.

25.25 Amend to clarify benefits of SuDs A significant benefit of applying SuDS principles to a site can be are the multi-functionality of the resulting open space. The benefits of SuDS include:

Increased open space for amenity and recreational uses

Increased recharge of groundwater and aquifers

Reduced turnrunoff into the sewer system (resulting in reduced energy and chemical costs of treatment costs)

Improved groundwater quality via natural infiltration

Improved surface water quality

Increased open space for amenity and recreational uses


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Improved ecological habitat for wildife

Improved amenity values of the location for the site

Helping achieve the objectives of the Thames River Basin Management Plan

Policy W4: SuDs Add ‘underground’ before holding tanks as there are no maintenance issues with tanks above ground.

Policy W4:III Amend to read: Development must utilise the most sustainable forms of drainage systems in accordance with the SuDS hierarchy. The Council will strongly resist the use of underground holding tanks because of the uncertainties and difficulties in maintaining these over the long term.

Policy W4: Amend to provide greater clarity on what is required

Amend Policy W4 as follows: I. Sustainable Drainage systems should be designed and implemented in ways that deliver other policy objectives of this Plan multiple benefits, including water use efficiency and improvements in water quality, biodiversity, amenity and recreation. Where practicable, SuDS should be designed to ensure the sustainable drainage networks have the additional capacity required to cope with infrequent adverse weather conditions and therefore reduce flood risk. … IV. The provision of balancing ponds as part of an area of public open space for recreation or wildlife should be designed to ensure the safety of other users of the space. V. Where SuDs are provided as part of a development, applicants should detail how it will be managed and maintained in the long term. VI. The Council will require retrofitting of sustainable drainage systems (SuDS) and other water management measures where-ever possible, to improve water quality and reduce the responsivity of catchments in the Borough to high intensity rainfall events.

25.29 Amend to provide greater clarity

Where possible, for the benefit of biodiversity, flood storage basins should be over-deepened to permanently retain water, at the bottom of the feature, on a permanent basis, whilest still functioning as flood storage above in times when additional capacity is required.

Policy W3 Change section and policy title from Water Efficiency to Water Quantity to make it a bit more general and fit better with the rest of the chapter

WATER EFFICIENCY QUANTITY Hertfordshire has one of the highest water consumption rates in the country….

Policy W34: Water Efficiency Quantity


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Policy W5: Flood Risk Remove ‘or’s in sub-clause III of policy as all will apply.

Amend Policy W5: III as follows: III. Development proposals, including the raising of land, in areas at risk from flooding will only be considered if they pass the flood risk sequential test and they do not: a) increase the risk of flooding elsewhere as a result of faster surface water run-off, and/or b) impede flood water flows, and /or c) endanger river channel stability, and/or d) reduce the capacity of flood water storage areas.

Policy W5 Flood Risk Amend to remove requirement for flood storage and flood resilient features in Flood Zone 2 as unreasonable.

Amend Policy W5 as follows: Redevelopment on Floodplains IV. Any proposal for intensification or redevelopment of a site within Flood Zone 2 or 3, as currently defined, must include on site flood storage and flood resilient features

Paragraph W5: Information for Applicants (former para 25.32)

Amend to clarify Amend paragraph 25.33 as follows The Council has carried out a Strategic Flood Risk Assessment (SFRA) for the Borough. The SFRA which

contains maps showing flood risks from various sources, including river and surface water flood risk areas. These represent a snapshot of flood risk at a given moment. The Environment Agency publishes regular updates to its flood maps, and the latest evidence should be a material consideration in determination of planning applications.


Clarify flood risk assessment requirements.

Amend paragraph 25.33 as follows: Site Specific Flood Risk Assessments For development proposals of 1 hectare or greater, or for certain types of development on any site within Flood Zones 2, 3a or 3b, a Flood Risk Assessment (FRA) should be submitted with the planning application. The Environment Agency’s Standing Advice for applicants provides further information. The SFRA also contains guidance for developers on preparing site specific flood risk assessments in the Borough.


Delete para as unnecessary. Delete para 25.34 as follows: Where floodplain is to be returned to greenfield status, habitat creation and management in these areas must be appropriate for the site and reflect habitat creation priorities for the area.

All policies from 2005 included in some form. Some out of date clauses omitted.


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Chapter 26: Green Belt


Issue No.

Policy/ Para. no.

Commt. ID(s)


26.1 26 PO1023 B3Living Ltd Applications for discreet developments of 100% affordable housing should be encouraged in rural areas.

Disagree. This would lead to development in unsustainable locations with no proximity to public transport and services. No amendment necessary.

26.2 26 PO1475 Lea Valley Growers Association The Council can support the sector by introducing a scheme to help its residents start their own horticultural businesses.

Noted. This is not a role for the Council. We suggest the Association contact the Hertfordshire Local Enterprise Partnership who aims to support businesses in Hertfordshire and may be interested in supporting such a scheme. No amendment necessary.

26.3 26.2 PO2165 Lindhill It is therefore clear the Government is supportive of the consideration of brownfield sites in the Green Belt to provide new homes.


26.3 26.2 PO1404 Hertfordshire County Council Property (Development Services) Welcomes the removal of all school sites from the Green Belt as indicated on the Proposals Map

Noted. The Council has decided to keep school sites currently designated as Green Belt, within the Green Belt. This will allow the Council control over the open spaces of the sites and restrict inappropriate developments unrelated to educational need on land which should otherwise be


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kept open. The Council will overlay the Green Belt designation with an additional policy designation, facilitating educational use so that Very Special Circumstances (VSC) are not required to be demonstrated for every application related to a school use. No amendment necessary.

26.5 Policy GB1: Green Belt

PO1451 Hubert C Leach There is no mention within this Policy or its supporting text relating to the development proposals to remove land from the Green Belt to accommodate development and no reference back to the Proposals Map.

Noted. More details of the Council’s approach to Green belt releases could be provided. Amend supporting text and Policy in partial accordance.

Amend Policy GB1 and supporting paragraphs as follows: The fundamental aim of Green Belt

policy is to prevent urban sprawl by keeping land permanently open. The permanence of Green Belts is fundamental to its effectiveness. Land designated as The Green Belt in Broxbourne forms part of the London Metropolitan Green Belt, which limits the growth of London into the surrounding countryside. Broxbourne’s total land area is 51 km2. Of this, 28km2 (55%) is currently countryside, and designated as Green Belt. Housing demand has increased steadily, and will continue to increase. Broxbourne has a highly constrained urban area, with few opportunities for development. This increases pressure on the Council to release Green Belt land for residential development.

The construction of new building

within the Green Belt is generally


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inappropriate. Exceptions to this are set out in the National Planning Policy Framework (NPPF) paragraphs 89 and 90. The Council has released approximately 14% of the land currently designated as Green Belt, mainly for housing development.

Policy GB1: Green Belt Within the Green Belt, as defined on the Policies Map, permission will not be given for development identified within the NPPF as inappropriate development, unless very special circumstances are demonstrated.

26.6 Policy GB1: Green Belt

PO1580 Campaign to Protect Rural England Hertfordshire (CPRE) Agrees with these statements and points out that the Plan currently proposes the very urban sprawl that the NPPF seeks to prevent, and the removal of permanence, that the NPPF seeks to protect, and therefore asks Broxbourne Council to reconsider both the Plan’s Strategy, and the specific proposals in it

Noted. Given the highly constrained nature of the borough, and the scarcity of Previously Developed Land, the Council has no alternative but to release some Green Belt land in order to meet its housing need. We have undertaken a thorough assessment of the land in the borough’s Green Belt, including its purpose and the effectiveness of each parcel in limiting sprawl. We have decided to release approximately 14% of land designated as Green Belt for development. The Council has safeguards in place to ensure that the open-ness of the Green Belt is maintained. We consider this to be balanced approach between meeting housing demand and

Amend Policy GB1 as follows: Within the Green Belt, as defined on the Policies Map, permission will not be given for development identified within the NPPF as inappropriate development, unless very special circumstances are demonstrated which clearly outweigh the harm.

Amend Information for Applicants as follows: Maintaining Openness 26.3 To be acceptable any

development within the Green Belt will need to preserve the openness of the Green Belt and minimise the area of built development. New buildings


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restricting further urban sprawl. No amendment necessary.

should normally form part of a group, rather than stand in isolation. Floodlighting, large areas of hard standing, car parking, and ancillary buildings, together with associated structures, should be kept to a minimum. The spacing of development and the placement of ancillary development can cause harm to the Green Belt.

26.7 26.3 PO219 I think this plan will harm the nature and openness of the Green Belt

The Council has gone to some lengths to make sure that the land that is released under this Plan will not significantly harm the openness of the Green Belt. Nature issues are addressed under a different section of the plan (Natural Environment and Biodiversity). The Council aims to ensure that wildlife and habitats are protected as far as possible. No amendment necessary.

26.3 PO1566 Broxbourne has a duty to protect agricultural land for the good of the whole country.

Noted. Broxbourne takes this responsibility seriously, as shown in our most recent policy position which prevents development in the Green Belt. No amendment necessary.

26.5 PO2150 Weston Homes: The Broxbourne Borough Glasshouse Industry (Planning for the Future) 2013 document is a key document in terms of the site’s current lawful use.

Noted. The key factors for each site put forward for development has been individually assessed through the Call for Sites process.


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This is regarded by Weston Homes as being out-of-date with the NPPF noting that key evidence should be kept up to date. If the Council is to be reliant on data that is a few years old then regard should be had to the most up-to-date information available. Whilst some of the findings are not disputed, particularly that the industry within Broxbourne had declined to cottage industry scale, available information on individual sites, should be re-evaluated.


26.8 Policy GB2: Development to address Derelict Glass Houses

PO2248 Support for the industry is set out in Policy GB4 of the Local Plan, but this is seemingly contradicted by Policy GB2, which supports residential development on derelict glass house sites. The future of the remaining glass houses and the derelict sites should form part of a comprehensive area review.

The Council seeks to ensure that these sites remain in a horticultural use or other use compatible with the Green belt designation, wherever possible. However some sites have become derelict and have an adverse effect on the amenity of the borough. The aim of Policy GB2 is to regenerate sites containing derelict greenhouses subject to certain, stringent, criteria being met. The Council considers that the criteria for redevelopment are sufficiently strict to avoid creating further hope value for greenhouse sites. However, it is accepted that the requirement to improve openness could be strengthened and further emphasised. A comprehensive review of the glasshouse industry in Broxbourne was carried out in 2013. It was noted at that time that the

Amend Policy GB2 as follows: Policy GB2: Residential Development on Derelict Glass House Sites I. Operating glass house sites will be safeguarded for horticultural production. Where horticultural production has ceased, their redevelopment for self-build housing will be considered in accordance with the following criteria: i) The glass houses were erected prior to 20th October 2015; and ii) Evidence is provided that the site has been marketed for a period of at least one year at a realistic market value for use as a horticultural business; and/or iii) Evidence is provided that the site is incapable of accommodating a viable horticultural business; and iv) Tthe continued horticultural use of the site is not necessary to support a larger horticultural/agricultural holding; and


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state of the industry in Broxbourne was not similar to the state of the industry in neighbouring Epping Forest District.

II. On the glass house sites, changes of use to residential development will only be permitted where the following criteria are met: iv) The residential dDevelopment would comprise of serviced plots suitable for the delivery of self-build housing development; and iii v) Where there are buildings on the site, the clearance and redevelopment of which would benefit the overall openness of the Green Belt. and iii) The redevelopment assimilates the site into the open countryside through the quality of the design and the overall landscaping of the site; and iv) Design III. Development will only be permitted if the following criteria are met: a) The developments proposed should reflect the approach set out in the Council’s Supplementary Planning Guidance; b) The development enhances openness and the rural character of the countryside within which it is set; b) The development will result in building site coverage of no more than 15% of the original glasshouse site and 20% of individual building plots. c) The proposal includes an draft acceptable design code, that sets out the layout, servicing and landscaping of the


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development and coding for the dimensions, design and materials for all aspects of the development. including the location of building plots, setbacks from frontages and maximum heights; and landscaping for the site including SuDs features. d) The proposal includes a delivery and management plan for the development. III. Where the site has been contaminated, decontamination of the entire site will be required as a precursor to the residential development. IV. Development will not be permitted if any of the following apply: i) New buildings or uses would promote coalescence between existing urban developments; ii) The development would adversely affect the open character of the countryside; iii) The proposed development would, or would have the potential to, adversely affect horticultural or agricultural uses of the countryside; iv) The proposed development is incompatible with surrounding rural activities and enterprises; v) The proposed development would result in the loss of any landscape or historic features V. Infill development of plots within


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these glass house sites will not be permitted.

26.9 Policy GB2: Residential Development on Derelict Glass House Sites

PO361 Woodhall Properties Ltd Considers that the restriction to allow only self-build housing on these sites would not result in viable development schemes because of high remediation costs.

Viable development is not the objective of this policy. This policy has the primary objective of restoring derelict sites, with a secondary objective of providing plots suitable for self-build development. Because of the Green Belt designation and lack of proximity to local services, any development needs to be on a low density basis. If evidence suggests the market cannot provide for self-build on these sites, they will remain in horticultural use. Horticultural uses are excluded from the definition of Previously Developed Land. No amendment necessary.

26.10 Policy GB2: PO361 Woodhall Properties Ltd Many derelict glass house sites within the Borough have been derelict for a significant period of time, and may have been sold to new owners since the horticultural use ceased, so it may be difficult to provide the required evidence that a viable, commercial horticultural operation existed on the site for 10 years

If site owners are unable to provide the necessary information, they will not be able to apply for development under this policy. No amendment necessary.

26.11 Policy GB2 PO361 Woodhall Properties Ltd Many derelict glass house sites within the Borough have been derelict for a significant period of time and their previous horticultural use may have predated the Lea Valley Growers

This is not a policy requirement within the Policy. The Information for Applicants section offers additional information and guidance on how the Council will interpret the policy at the time of taking a decision


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Association, making the requirement to have sought assistance from them difficult to meet

on the site. If site owners are unable to provide the information necessary to show that they conform with the criteria, they are unlikely to be successful in an application made under this policy.

26.12 Policy GB2: I. PO1469 Lea Valley Growers Association The Association welcome the Council’s statement that operating glass house sites will be safeguarded for horticultural production, however, as above this does appear to contradict Appendix A Housing Trajectory and the BROXBOURNE BOROUGH GLASSHOUSE INDUSTRY, Planning for the Future report 2013.

Noted. The Council has reviewed land within the Green Belt as part of the background work for the Local Plan and has decided that some former greenhouse sites, located within the Green Belt are suitable for redevelopment. No amendment necessary.

26.12 Policy GB2 PO395, PO1469

Lea Valley Growers Association The Council should indicate what they consider to be a derelict site

Noted. Will amend plan in accordance.

Add to Appendix F: Glossary: Derelict Glass House Sites – a site where the majority of the glass house buildings have been disused for at least ten years. On these sites, most of the buildings must be decayed to the extent that they are incapable of reasonable reuse for a viable horticultural business.

26.12 Policy GB2: Residential Development on Derelict Glass House Sites I.

PO395, PO1469

Lea Valley Growers Association The Association would prefer an "Unviable criteria" based on location and size to avoid a situation such as Wharf Road where the Council & Lee Valley Regional Park Authority through their actions created an area non-compliant uses.

Noted. Market conditions change constantly, and will change further under Brexit including the possibility of more targeted replacement ‘subsidies’ for horticultural producers where currently there are minimal or none. The Council has reduced its criteria to viability related to location and size, as the


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aim of this policy is to redress issues relating to dereliction. See proposed amendments to policy under Issue 26.8 above.

26.13 Policy GB2 PO542 East Hertfordshire District Council This approach is likely to lead to the development of isolated dwellings in the countryside which is contrary to the NPPF and would not represent a sustainable pattern of development.

Agree that this could happen as it did following the 1994 Plan. To address this issue, the Council has tightened the test for derelict glass house sites and will only allow them for low density self or custom-build housing. No amendment necessary.

26.13 Policy GB2 PO542 East Hertfordshire District Council Individual self-build houses would not form the exceptional circumstances or very special circumstances required to warrant development in the Green Belt and would conflict with the purposes of including land within the Green Belt.

The very special circumstances for this type of development are the remediation of the derelict glasshouse sites and the significant increase in openness of the site. The self-build is a secondary objective, being identified as development suitable for low density development. No amendment necessary.

26.13 Policy GB2 PO542 East Hertfordshire District Council Policies GB1, GB2, GB3, GB4 and GB5 are incompatible with each other and in some cases are contradictory. Paragraph 25.20 refers to ensuring that the openness of the Green Belt is not eroded on a piecemeal basis over time, yet these Green Belt policies will facilitate this very event.

These policies have been written to work together. Policy GB2 will result in a significant increase in openness on each site, particularly by way of the site coverage restriction proposed. Please see amended policy under Issues 26.8 above.

26.14 Policy GB2 PO658 Historic England We suggest that the word ‘features’ is changed to ‘assets or have a significant impact upon their settings’

Noted. This section has been deleted as it is covered by other, more specific, policies in the plan.

.


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Please see amended policy under Issue 26.8 above.

26.15 Policy GB2 PO473 Kings Arms & Cheshunt Angling Society II/iv support this policy of total removal as capping with inert material on top would not prevent contaminates leaching into watercourses or groundwater


26.16 Policy GB2 PO988 Welwyn Hatfield Borough Council Whilst responding to dereliction is clearly an issue of local importance within Broxbourne, allowing self-build development only at a low density means that the increased sprawl of Cheshunt towards Cuffley can be managed


26.17 Policy GB2 PO936 CODE Development Planners Ltd Suggest the policy should make clear that it does not apply to those derelict or used glass house sites which are allocated in the plan for development.

We suggest the wording of the first sentence of Policy GB2 to read:

“Operating glass house sites will be safe guarded for horticultural production unless they are allocated in this plan for alternative uses.”

This amendment is not necessary as the Policies Map makes it clear what the proposed use of the site will be. No amendment necessary.


PO1020 B3Living Ltd The redevelopment of former glass houses could be restricted to affordable housing in lieu of, or as well as, self-build housing

The key tenet of this policy is that the development is at a low density. It is unlikely that affordable housing delivery models will conform to this specification as it is normally important for the housing provider to maximise the development potential of the site.


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Occupiers also tend to have lower incomes. Access to a private car will be essential because of the location of these sites in the countryside.

26.19 Policy GB2: (Title)

PO1078 G&C Produce Limited The policy should be in relation to “financially unviable” glasshouse sites rather than “derelict” glasshouse sites

Disagree. The purpose of the policy is to address issues of dereliction in the interests of the amenity of the borough. No amendment necessary.

26.20 Policy GB2: (I) PO1079 PO1660

G & C Produce Limited delete reference to ‘self-build’. It is considered that this policy will deliver minimal housing and self-build unlikely to be deliverable on former glasshouse sites.

Disagree. The purpose of this policy is not to meet housing need; it is to address unsightly, long-term, dereliction on these sites. As the respondent notes, the Sustainability Assessment states “…The self-build approach will continue to explore opportunities for promoting local scale food production ... The total level of housing coming forward under this approach is expected to be relatively minor. The policy provides a number of design requirements that would act to ensure that the development of the site would not adversely affect the Green Belt.” No amendment necessary.

26.21 Policy GB2 I.(ii) and (iii)

PO1080 G & C Produce Limited The reference to “and” between Part I (ii) and (iii) should be deleted

Agree. Have removed the marketing requirement as the viability test is more robust. See proposed amendments to policy under Issue 26.8 above.


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26.22 Policy GB2: (II) PO1081 G & C Produce Limited It is considered that Part II ii) and iii) are design related statements which are dealt with within the third part of the policy and are effective duplications of Part III b) and Part IV ii). Part ii) and iii) are superfluous and should be deleted.

Agree in part. See proposed amendments to policy under Issue 26.8 above.

26.22 Policy GB2: Residential Development on Derelict Glass House Sites II.(i)

PO1081 G & C Produce Limited Self-builders typically require serviced plots which are unlikely to be able to be provided on a former nursery site. There would be no control in the cohesive and comprehensive delivery of the overall site.

The respondent has not provided any evidence to suggest that this is not achievable. The requirement for a design code will allow for the cohesive and comprehensive delivery of the site. Subdividing a site and selling it off plan to other developers to build out is accepted planning practice. Co-ordination of the provision of infrastructure normally falls to the initial site developer. No amendment necessary.

26.22 Policy GB2: Residential Development on Derelict Glass House Sites II.(iv)

PO1081 G & C Produce Limited This part of the policy is contradictory to the provisions of paragraph i) self-build; the “decontamination of the whole site” has potential to be very expensive and also would require the co-ordination of all of the self-builders, should the developer restriction contained in i) Self Build be maintained. The culmination of this Policy would render the former nursery sites unviable for

It is currently envisioned that the nursery site is decontaminated before the self-build plots are sold off to prospective builders. See proposed amendments to policy under Issue 26.8 above.


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development

26.23 Policy GB2: Residential Development on Derelict Glass House Sites III.

PO1082 G & C Produce Limited It is considered that the paragraphs contained within the third part are excessive, notwithstanding this they would provide a huge amount of control over the types of development which could be delivered on former glasshouse sites.

The Council considers that this level of control is necessary to address the issues raised by the respondent in issue (26.22 – co-ordinated inf. development) above. These criteria provide the Council with the level of control necessary for a site which would not normally be considered suitable for residential development because of its Green Belt location. No amendment necessary.

26.24 Policy GB2 PO1566 With the current instability in the world, the UK should be protecting agricultural land to increase its food security rather than adding to imports

Noted. It is agreed that the policy context for food production and market conditions change constantly and Brexit will change these further. To address this, the Council requires evidence that the site is not viable for food production.

26.25 Policy GB2 PO1579 Campaign to Protect Rural England (CPRE) Considers that the current definition of previously-developed land, combined with the ongoing emphasis on maximising the potential of such land, may limit the ability of the Council to prevent such permissions leading to higher density development, resulting in the total loss of Green Belt openness in such locations

Former nursery sites are not PDL. The NPPF defines PDL as excluding agricultural land (which is defined under the 1990 TCP Act as including horticulture). No amendment necessary.

26.25 Policy GB2 PO1579 Campaign to Protect Rural England (CPRE) Paragraph 26.1 of the Plan, states that ‘The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open', and 'The permanence of Green Belts is fundamental to its

Noted. The Council considers that this Policy addresses this by requiring an increase in open-ness and removing permitted development rights from the redeveloped sites.


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effectiveness', paraphrasing NPPF paragraph 79.



PO1608 The Council should consider amending Emerging Policy GB2 to allow for low density market housing on appropriate sites well related to existing built-up areas

Disagree. Taken as a whole, these sites tend to be located within the Green Belt and tend to be remote from local services. Under normal circumstances, they would not meet the test for exceptional circumstances and therefore would not be considered suitable for residential development. In 1994, as part of a strategy to address dereliction on Green Belt nursery sites, the Council released derelict nursery sites for redevelopment. This led to unsustainable patterns of development in the West Cheshunt area. It also gave residential hope value to remaining glasshouse sites, possibly hastening their decline and dereliction. A number of glasshouse sites were identified in the Scott Wilson Green Belt Review 2008 as potential options for safeguarded land for long-term development. However, the limitations of the previous strategy have become clear. A change in strategy for these sites is therefore considered necessary. No amendment necessary.

26.27 Policy GB2: Residential Development

PO1660 Crest Nicholson The significant cost of carrying out necessary remediation to address the contamination present on

Noted. This cost would be shared amongst the


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on Derelict Glass House Sites

former glass house sites would be prohibitive to a self-build developer, rendering these sites unviable and blighting them for development.

number of plots on the site. If the remediation was unachievable with the low density residential development, redevelopment may or may not be brought forward for other development which does not require this remediation. No amendment necessary.


PO1661 Crest Nicholson The requirement to prove that a viable, commercial, horticultural operation existed on the site for 10 years is too onerous and would blight many sites for development.

Noted. The Council would prefer that the site remain in a horticultural use, or other use suitable for the Green Belt. The purpose of this policy s to offer an alternative source of funding to redress dereliction. These tests are necessarily strict to avoid creating hope value for all glasshouses in the borough. No amendment necessary.

26.28 Para 26.10 PO1661 Crest Nicholson Many derelict glass house sites within the Borough have been derelict for a significant period of time and their previous horticultural use may have predated the Lee Valley Growers Society. This policy requirement should be limited to sites which have been in operation within the last 10 years.

Noted. This does not form part of the policy and is therefore not a requirement. Should a glasshouse not have been in operation during the time of the Lee Valley Growers Association, their help will not be expected to have been sought. No amendment necessary.

26.28 Policy GB2: Residential Development on Derelict Glass House

PO1661 Crest Nicholson Restricting the sites to self-build is inappropriate as significant enabling infrastructure (e.g. bringing necessary services on to the site, creating access to

Agree. If the market value of the plots for self-build does not facilitate the essential infrastructure required to build on the site or basic planning application requirements


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Sites the site and spine roads within it etc.) is required to serve residential development on former glasshouse sites and requirements attached to the planning permission all have costs that self-builders operating individually will have to meet.

for this type of residential development, then the site will not be redeveloped.

26.29 Policy GB2 PO1661 Crest Nicholson It is unclear how S106 contributions could be sought across multiple self-build plots, with each self-builder acting independently from the others

Noted. The Section 106 would be applied to the initial subdivision of the plots. T is expected that the initial developer would recoup of the cost of the planning obligations when the self-build plots are sold.


PO1661 Crest Nicholson There are concerns over how the construction process could operate if there are multiple self-build plots on a site and more than a single main contractor working at once

Noted. All contractors would have to comply with the initial planning applications conditions as the planning application runs with the land. The effect would not be dissimilar to one develop having multiple contractors on site at one time. It may also have the benefit of reducing the duration of the works and providing housing over a shorter period. No amendment necessary.


PO1696 Countryside Properties (UK) Ltd In order to utilise an untapped source of housing supply, a full spectrum of housing types should be provided on derelict glass house sites, not restricted to self-build. Low density housing, which could also contribute towards Starter Homes and affordable rent, would achieve the same objective in terms of protecting the

Noted. These sites would not ordinarily be released for residential development because of their location in the Green Belt, however the Council considers that limited, low-density, self-build development which increases the open-ness of the site is a sustainable remedy for the issue of derelict glasshouses which have an adverse effect on amenity in the borough.


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countryside as self-build housing. The Council is required to provide sites for self-build, which tend to be at lower densities than the offer provided by the volume house-builders. No amendment necessary.


PO2150 Weston Homes PLC Because of increasing costs only modern, large glasshouses are now viable. These factors, along with increasing regulation and site specific issues such as isolation from other nurseries, making deliveries uneconomic, have rendered many nurseries unviable. Submitted documents to demonstrate the non-viability of continued business operations by A & L Salads ..\..\..\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO2150

Noted. The Limes Nursery site was considered for development as part of the Call for Sites Process. That process found that the site was not suitable for residential development as the area performs strongly against Green Belt purposes and no change to the boundary in this location were proposed. No amendment necessary.

26.33 Policy GB2 PO2151 Weston Homes PLC Submitted documents advising the Council of business closure at The Limes and Rosary Nurseries..\..\..\Consultations\Reg 18 LP Consultation Responses Summer 2016\Documents uploaded to Objective\PO2151

Noted. It should be noted that the site does not meet the definition of PDL which excludes agricultural buildings (which include buildings in a horticultural use). As for above under issue …. No amendment necessary.

26.34 Policy GB2 PO2152 Weston Homes PLC An alternative, which should also be acknowledged in the policy objective, is for those derelict sites that are located close to existing development and sustainable criteria to be redeveloped for housing, provided that an opportunity is taken to provide a broad mix of housing

Noted. Each site is considered on its own merits. The particular details and location of each particular site was considered through the Call for Sites process. The fact that the site is located ‘close to existing development’ emphasises its


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types and tenures importance in containing urbanism. No amendment necessary.

26.35 Policy GB2 PO2153 Weston Homes PLC Sites at The Limes and Rosary Nurseries represents a significant opportunity of turning a derelict brownfield site into a high quality housing development, providing much needed housing and helping to meet the Council’s need for housing as part of its 5-year supply. Self-build is unlikely to be viable isolation.

Noted. Each site is considered on its own merits. The merit of each particular site was considered through the Call for Sites Process. No amendment necessary.

26.36 Policy GB3 PO474 Kings Arms & Cheshunt Angling Society Would this prevent a landowner if so inclined from converting a boggy bit of his ground into a commercial fishery enterprise, as may cause a slight increase in traffic during working week and a bit more at weekends? Same query applies if we were able to purchase a suitable plot of land, could we create a fishery of our own on it?

Noted. Will amend (e) to allow more flexibility.

I. Rural/farm diversification schemes will be permitted where:

(a) the proposal retains existing or provides additional employment; and ….

(e) the proposal will not result in an significant increase in adverse effects associated with site related traffic or have an unacceptable greater adverse impact on the local environment, residential amenity, ecological interests or green belt openness than the existing use.

26.37 Policy GB3: Rural Diversification

PO1021 B3Living Ltd Rural diversification housing schemes should be limited to provide 100% of affordable rented and shared ownership housing to limit the impact

It is not envisaged that rural diversification schemes will include any notable housing component. No amendment necessary.

26.38 New Glass PO396 Lea Valley Growers Association An Noted.


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House and Nursery Developments

opportunity has been missed by the Council to require developers to seek a sustainable solution to waste heat issues for horticultural businesses

It is not considered reasonable or feasible to require horticultural users to use waste heat from these sources, although the Council will always support this sort of joined up approach. No amendment necessary.

26.39 Policy GB4: New Glass House and Nursery Developments

PO398 Lea Valley Growers Association Settlements could be set up in rural areas where each successful applicant would be given a small-holding of approximately 5 acres with provision for modest rural housing

Noted. The Council understands that the smaller horticultural sites are less likely to be viable in the long term. We also understand that landowners would inevitably be subject to pressure to sell the houses and land for a premium on the open market. Should the Lee Valley Growers Association be able to provide evidence of how such a scheme would work, and examples of where it has worked elsewhere within the London Metropolitan Green Belt, in the last 10 years, the Council will consider the issue further. No amendment necessary.

26.40 Policy GB4 PO1467 Lea Valley Growers Association Welcome the Council’s support for new glass houses, extensions to glass houses and replacement glass houses on existing sites or on new sites

Noted. Policy is being deleted as the amount of new applications does not justify its retention.

26.41 Rural Housing PO397, PO1471

Lea Valley Growers Association Agrees that there is a clear and established need for reasonably priced rural housing for agricultural, horticultural or forestry workers



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26.42 Policy GB5: Occupancy Conditions

PO1022 B3Living Ltd Consideration could be given to redefining agricultural workers, to a wider definition of low paid workers/key workers to potentially occupy surplus dwellings`

Noted. The purpose of these dwellings is that agricultural works can live in reasonably close proximity to their place of employment. No amendment necessary.


Policy/ Para. no.

Issue Considered as: New Issue No.

26.3 26.3 Hertfordshire County Council Property (Development Services) Welcomes the removal of all school sites from the Green Belt as indicated on the Proposals Map

Policies Map

Policy GB1: Green Belt

Define ‘limited infilling in villages’.

Include in general Design Policy




Whole chapter Remove all references to Supplementary Planning Guidance unless they have particular relevance.

New policy Add in supporting text and equestrian policy from Open Space and Recreation Chapter

Equestrian Development 24.25 Equestrian or horse related activities are popular forms of leisure and

recreation in the Borough. Riding schools and stables can fit in well with agricultural activities and help to diversify the rural economy. Changes of use of riding schools and stables can result in the loss of strategically or locally important equestrian facilities, contrary to Government policies which aim to support and retain such facilities.


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24.26 The Council will support equestrian development that maintains environmental quality and the character of the countryside.

24.27 While equestrian development can be appropriate in the open countryside, the cumulative impact of horse related activities and associated buildings can have an adverse impact on the character and appearance of rural areas. Existing buildings should, wherever possible, be re-used. New buildings for horse related activities, including stables, field shelters and tack rooms should be no larger than is essential, and careful attention paid to siting and landscaping. Particular care will be needed where floodlighting is proposed in order to avoid an unacceptable impact on residential amenity.

24.28 In assessing any application, regard will be had to the British Horse Society standards for welfare, and particularly grazing, access to clean water, and space, taking account of access to the wider countryside.

Policy ORC6: Equestrian Development I. Proposals for small-scale equestrian development (up to 5 stables), whether domestic or commercial, will be permitted when the following criteria are met: (a) The proposal is not sited in a prominent location; (b) Where new buildings are proposed, applicants must demonstrate that existing structures cannot be re-used; (c) The siting, scale and design of the proposal is in keeping with the character of the area, with adequate pasture to support the anticipated number of horses in accordance with the DEFRA (2009) Code of Practice for the Welfare of Horses, Ponies, Donkeys and their Hybrids; (d) Suitable provision is made for the storage of hay, feed and tack; (e) The amenity of nearby residential properties is not adversely affected, for example, in relation to floodlighting, smell, noise and disturbance; (f) The proposal would not (by itself or cumulatively) have a significant adverse impact in terms of traffic generation; (g) Suitable provision is made for drainage; (h) There will be no detrimental impact on a recognised wildlife site. II. Development proposals involving the loss of equestrian facilities or their


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conversion to other uses will not be permitted unless an assessment has been undertaken which clearly shows that the facilities are surplus to requirements.

Information for applicants 24.29 Any application which results in the loss of an equestrian facility should be

accompanied by an assessment of community equestrian need and the role of that facility in meeting that need.

24.30 In considering any proposal for equestrian development, the Council will expect freestanding stables to be well screened from the surrounding countryside and that new buildings for indoor use should be located closely to existing buildings.

24.31 The Code of Welfare (above) recommends minimum land requirements and stable sizes for horses. Applicants should demonstrate how they have adhered to these standards in any application.

26.6 Clarify the consequences of the previous strategy, under the 1994 Local Plan, to address dereliction on Green Belt nursery sites.

Amend paragraph as follows; A recent assessment of land around Goffs Oak concluded that development of glass house sites under the previous 1994 Local Plan had led to unsustainable patterns of development isolated from services and transport links. The assessment concluded that the development of further glass house sites would result in unsustainable urban sprawl, and that assessment of the majority of derelict sites have found them “... not to be preferable for development at conventional densities”.

Policy GB1: Information for Applicants

Delete extension as should not have special status Amend paragraph Information for Applicants as follows: Extensions 26.4 Residential extensions should be proportionate to the size of the original

dwelling. Generally, the Council requires that any extension does not result in a dwelling having a greater impact upon its surroundings than before the extension was constructed. Volumetric calculations will need to be submitted.

Policy GB2: Residential development on Derelict Glasshouse

Definition of the glass house site may alter to maximise development on a derelict glasshouse site.

Amend Information for Applicants as follows: The boundaries of the glass house will be as defined and outlined in red in the 2013 Glass House Study.


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Sites

Policy GB4: New glass House and Nursery developments

Delete as there have not been any applications for new glass houses in recent memory so policy is no longer justified

Delete policy in its entirety. New Glass House and Nursery Developments Policy GB4: New Glass House and Nursery Developments I. The Council will support new glass houses, extensions to glass houses and replacement glass houses on existing sites or on new sites, subject to consideration of how the development meets the other policies within this plan, with particular regard to the height of new glass houses. II. The Council will support the consolidation or amalgamation of sites where it makes sites more economically viable. III. When granting planning permission for new, replacement, or extensions to, glasshouses or other buildings including packhouses, and any ancillary activities or uses, the Council will require that these sites are fully returned to a condition appropriate for their previous use when or if the land is no longer used for glass house horticulture.

Policy GB5: Occupancy Conditions

Need to ensure that price marketed at is affordable for rural workers

Amend Policy GB5: Occupancy Conditions as follows: Where a restrictive occupancy condition has been imposed, the Council will strongly resist the removal of the condition. Any applications for removal will need to demonstrate that: a) there is no demand in the Borough for rural workers dwellings; and b) the dwelling has been comprehensively marketed for at least two years to rural workers at an affordable price.

Policy GB1: Green Belt

Define ‘limited infilling in villages’. Include in general Design Policy

Policy GB3 Add in qualifier as not every conversion for such uses will be acceptable in planning terms.

III. Where appropriate, Tthe Council welcomes proposals that would involve the conversion of suitable premises for visitor or tourism activities, subject to compliance with the policies in this Plan.


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Chapter 27: Natural Environment and Biodiversity


Issue No.

Policy/ Para. no.

Commt. ID(s) Issue Officer Response Proposed Amendment

27.1 NEB1 Wildlife, Wildlife sites and biodiversity III.

PO362 PO1662

This policy should not apply to all development on locally designated sites of wildlife value, only to development which causes negative effects. If there is a detrimental impact, then both criteria a) and b) should apply. If there are no detrimental effects, it should not be necessary to meet criterion a). Suggest re-wording to read: III. Development which negatively affects a Local Wildlife Site or Local Nature Reserve, as shown on the Policies Map, will not be permitted unless:

a) The development provides appropriate avoidance/mitigation/compensation measures to offset any detriment to the nature conservation interest on the site, or

b) The local development needs significantly outweigh the nature conservation value of the site.

Local Wildlife Sites feature a balanced combination of factors which together create valuable habitat for local species. Development will, in almost all cases, disturb the particular set of conditions pertaining to a wildlife site. Because biodiversity in the borough is still in decline and under threat, and the levels of success in the mitigation hierarchy can be highly variable, development on a Local Wildlife Site must be in the public interest for


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the site to be considered. Wildlife sites were required to be of substantive local nature conservation importance before they were designated, and therefore justify this level of protection. No amendment necessary.

27.2 NEB1.I. PO476 Expect only strong reasons to be deemed to justify contravention of this policy.

Should be applied to protected plant and fish species, as well as animals.

Noted. Protected Species are protected under other legislation as well as local planning policy. It is considered that the Protected Species clause overlaps with other aspects of the policy and the NPPF so the clause has been removed. No amendment


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necessary.

27.3 NEB1 PO2005 Despite references earlier about the value of ancient woodland and veteran/aged trees, there is no reference to them in this policy. Recommend the policy is amended as follows: The Borough will not permit any development proposal which would result in the loss or deterioration of ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefit of, the development in that location is wholly exceptional.

Agree. Veteran and aged trees have an important role to play as stepping stones for wildlife.

New NEB Policy…Ancient Woodland, Trees and Hedgerows Development proposals which would result in the loss or deterioration of ancient woodland; or aged or veteran trees found outside ancient woodland; will not be permitted unless the need for, and benefit of, the development in that location is wholly exceptional. Plus text of current NEB4 Add new supporting text : Mature trees and hedgerows can make a significant contribution to biodiversity and appearance of the local area. Trees and hedgerows play a crucial role in softening the hard materials and lines of built up areas. Ancient woodland, and aged and veteran trees outside woodland areas have an important role to play in providing habitat for a range of species. Aged trees, as a consequence of their rarity and physical condition, can harbour large numbers of rare and threatened species.

27.4 NEB1 PO1018 PO2086

The environmental data on which the draft Plan is based is not up-to-date and therefore not compliant with clauses 158 and 165 of the NPPF. There are several discrepancies in the ecological information about Local Wildlife Sites (LWS), their boundaries presented in the Draft Plan and the information held by the Hertfordshire Environmental Records Centre (HERC),

The Council is currently in the process of updating the data working together with the Herts Middlesex Wildlife Trust. Discrepancies between sites will


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e.g. 71/028/03 and 80/007. The maps in the Draft Plan also contain extra sites not included in the HERC LWS records

be remedied once surveying of the sites has occurred later in this year.

27.5 NEB1.II PO1795 PO1796

Differences in the level of legal protection and policy tests provided for different types of site should be reflected in the policy and supporting text, specifically:.

Local Wildlife Sites are non-statutory

but Local Nature Reserves are statutory; this is a formal designation with legal implications.

Could be a soundness issue.

Agree that Local Nature Reserves are statutory sites. Although they are designated using a legal mechanism, their protection from unsympathetic development is provided through the Local Plan. LNRs with SSSI status are protected by the SSSI legislation. The Plan aims to resist development which would adversely affect Local Nature Reserves and Wildlife Sites. Amend to include a new site specific policy (NEB2) from former NEB1

Add in following introductory text: The Habitats Regulations require the highest levels of protection for internationally designated wildlife sites. The Borough of Broxbourne includes the internationally designated Broxbourne-Hoddesdon Woods complex, a Special Area for Conservation (SAC) and the Lee Valley Special Protection Area (SPA) and Ramsar sites along the River Lee. The nature conservation and geological interest of internationally designated sites are not permitted to be harmed by development unless they meet the criteria listed below.

Local Wildlife Sites are identified by the Hertfordshire Local Wildlife Sites Partnership, coordinated by the Herts and Middlesex Wildlife Trust. Local Wildlife Sites (LWS) are considered to be of significance for wildlife in at least a district context. There are currently 35 Local Wildlife Sites in Broxbourne.

Distinction will be made between the hierarchy of international, national, locally designated and non-designated sites so that the level of protection afforded is consistent with their status.

Add in new policy: Policy NEB 2: Wildlife Sites.


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which addresses the different levels of protection.

Internationally and Nationally Designated Wildlife sites I. Development which would harm the nature conservation or geological interest of an internationally or nationally important wildlife site, as shown on the Policies Map, will not be permitted unless: (a) it is required in connection with the management or conservation of the site; or (b) there are imperative reasons of overriding public interest for the development; and (c) there is no alternative to the development. Compensation for the harm will be required. Locally designated sites of wildlife value II. Development on, or which negatively affects, a Local Wildlife Site or Local Nature Reserve, as shown on the Policies Map, will not be permitted unless: (a) local development needs significantly outweigh the nature conservation value of the site; and (b) the development provides appropriate avoidance or mitigation, and as a last resort compensation measures, to offset any detriment to the nature conservation interest on the site. Conservation and enhancement of biodiversity IV. When determining relevant development proposals the Council will ensure that decisions will minimise impacts and result in net gains to biodiversity. V. In granting permission the Council will impose conditions or seek planning obligations that secure appropriate management regimes to deliver biodiversity gain in perpetuity.


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27.6 NEB1.III(b) ------------------------------------

Rather than just avoiding a negative impact, opportunities should be sought to improve habitat for protected species to ensure their continued survival.

Agree. Biodiversity levels are critically low in Hertfordshire. In recent years a series of reports have demonstrated that biodiversity anand ecosystem functions are continuing to decline. This Local Plan needs to provide an overall strategy and approach, as 27.2 required by the NPPF.

Reword Policy NEB1.III as follows: The Council will seek the creation of new networks of biodiversity, as well as the extension, enhancement and active management of existing sites. IV. Opportunities to connect habitat fragments through the use of stepping stones and other green areas will be assessed as part of all applications. Add in following text to supporting paragraph ….: Because of the poor state of biodiversity, and particularly habitat connectivity in Hertfordshire, opportunities to enhance biodiversity will be actively sought wherever possible. Undesignated sites make a significant and important contribution to the successful establishment of functional ecological networks.

27.7 27.5 PO194 Statement could be improved by adding the word negative after affected, so that it reads: …Where there is a reasonable likelihood that protected species, or the habitats upon which they depend, may be negatively affected by a development proposal…etc.

Amend 27.5 as follows: Where there is a reasonable likelihood that protected species, or the habitats upon which they depend, may be negatively affected by a development proposal, planning applications will not be validated until survey information has been submitted that shows the presence (or otherwise) and extent of the species or habitat, over the course of a calendar year.

NEB 1.IV & V

Should require the use of native species only.

Agree Add new text under Information for Applicants Native Species The use of locally appropriate native species will be encouraged for all applications.


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27.5 PO2083 Requirement for survey information, prepared to industry standards, be submitted with applications supported.

Noted. No amendment required.

27.8 27.6 PO195 Clarify reference to BS42020, as not a survey methodology, but a standard describing how ecological information, including appropriate surveys should be supplied in support of planning applications. It is a mechanism intended to ensure consistency, transparency, high quality and functionality to facilitate better planning decisions. Re-word paragraph to read: The submission of ecological information must be in accordance with British Standard 42020: Biodiversity – Code of Practice for Planning and Development. Unauthorised deviation from this standard will not be accepted.

Agreed.

Amend paragraph 27.6 (2nd Bullet Point) to read: Survey methodology and reporting must be conducted in accordance with British Standard 42020: Biodiversity – Code of Practice for Planning and Development. The submission of ecological information must be in accordance with British Standard 42020: Biodiversity – Code of Practice for Planning and Development. Unauthorised deviation from this standard will not be accepted.

27.9 27.6 PO477 Surveys would need to include the aquatic environment if watercourses and/or waterbodies are nearby, in light of Policy W1 etc.

Noted. No amendment to Plan in response to this issue.

27.10 27.7 PO196 Suggest using the Biodiversity Impact Calculator (Environment Bank 2014), which is virtually identical and intended for use throughout England. Suggest re-wording to read: The DEFRA and NE endorsed Biodiversity Impact Calculator (BIC, Environment

Agreed. The DEFRA and NE endorsed Biodiversity Impact Assessment Calculator (BIAC, Warwickshire County Council BIAC 2014 v18 BIC, Environment Bank 2014 v2 or as amended) has been designed to quantify the value of biodiversity (in terms of habitats) in a consistent, transparent and objective way. . This mechanism is considered to be the most an appropriate method to determine ecological value and


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Bank 2014 v2 or as amended) has been designed to quantify the value of biodiversity (in terms of habitats) in a consistent and objective way….

deliver net ecological gain. When required, development proposals must demonstrate a positive ecological unit score as determined by the calculator. If biodiversity losses (as determined by the BIC) resulting from a development cannot be avoided (by locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission will be refused.

27.11 27.7 PO745 The use of the biodiversity calculator should not be limited to the development site but also applied to nature conservation areas on the periphery of the garden suburb proposal.

Agree. It can be used to calculate the effect of development on nature conservation areas. No amendment to plan necessary.

27.12 27.7 PO1798 The term biodiversity offsetting should also be referred to in the context of applying the biodiversity impact calculator.

It is implicit in the use of the BIC that it may result in biodiversity offsetting – but not always. The mitigation hierarchy must always be applied. Specific mention of biodiversity offsetting is considered unnecessary, It is


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also a frequently misunderstood and controversial term. No amendment to plan proposed.

27.13 NEB2 Green infra-structure

PO2014 Should acknowledge trees as helping combat climate change in this policy.

The supportive text in paragraph 27.12 refers to the role of trees in cooling and cleaning the air. No amendment necessary.

27.14 NEB2 PO2084 Incorporate reference to The Lea Catchment Nature Improvement Area (NIA) into this section, as this will strengthen green infrastructure planning in the Borough and support policy NEB2. The NIA is endorsed by the Herts Local Nature Partnership and seeks to establish a joined up, resilient ecological network at a landscape scale throughout the Lea Valley, by improving biodiversity, ecological management of designated sites, restoring characteristic ecological, hydrological and landscape features etc.

Noted. This is more of a process issue and such a reference would add unnecessary detail without informing decision-taking by Officers. No amendment necessary.


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27.15 NEB2 PO1737 It is not clear how the statement in this Policy, The Local Plan will create a diverse, linked network of multi-functional green infrastructure is to be achieved. The Plan should set out a strategic approach for green infrastructure and biodiversity as required by the NPPF paragraph 114. Evidence of such a strategic approach could be underpinned by a Green Infrastructure Strategy.

Agree. Policy NEB1 will be reworked into a new strategic policy. It is hoped that this general policy will help achieve the creation of multi-functional green infrastructure. The Council will look to prepare a borough-specific Green Infrastructure Strategy within the local plan period.

Amend Policy NEB1 as follows: NEB 1: General Strategy for Biodiversity I. Development proposals will be expected to apply the mitigation hierarchy of avoidance, mitigation and compensation. II. When determining Ddevelopment proposals must, the Council will ensure that decisions will minimise impacts on and result in net gains to biodiversity wherever possible. III. The Council will seek the creation of new networks of biodiversity, as well as the extension, enhancement and active management of existing sites. IIV. Opportunities to connect habitat fragments through the creation of stepping stones, using built form, vegetation or green areas will be assessed as part of all relevant applications. V.. If In granting permission, the Council will impose conditions or seek planning obligations that secure appropriate management regimes to deliver biodiversity gain in perpetuity. Protected species When there is a reasonable likelihood of the presence of protected species or their habitats, development will not be permitted until it has been demonstrated that the proposed development will not result in a negative impact on these populations. Internationally and nationally designated wildlife sites II. Development which would harm the nature conservation or geological interest of an internationally or nationally important wildlife site, as shown on the Policies Map, will not be permitted unless:


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(a) it is required in connection with the management or conservation of the site; or (b) there are Imperative Reasons of Overriding Public Interest for the development; and (c) there is no alternative to the development. Compensation for the harm will be required. Locally designated sites of wildlife value III. Development on, or which negatively affects, a Local Wildlife Site or Local Nature Reserve, as shown on the Policies Map, will not be permitted unless: (a) the local development needs significantly outweigh the nature conservation value of the site; and (b) the development provides appropriate avoidance/mitigation/compensation measures to offset any detriment to the nature conservation interest on the site. Conservation and enhancement of biodiversity I When determining relevant development proposals the Council will ensure that decisions will minimise impacts and result in net gains to biodiversity. V. In granting permission the Council will impose conditions or seek planning obligations that secure appropriate management regimes to deliver biodiversity gain in perpetuity.

27.16 Biodiversity and land-scaping

PO1806 While it is important to create wildlife rich places, sometimes people are the priority end user and nature conservation approaches may not be appropriate, particularly for sites near urban areas where pressure for recreational and leisure resources are high. In these circumstances,

Noted. This issue requires a balanced approach, particularly in the light of the increased recreational


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stakeholders need to identify a clear vision and objectives for the development from the outset.

pressures on the internationally designated sites in Broxbourne. No amendment necessary.

27.17 27.16 PO1978 PO476

Add native when referring to species here, so that it reads, Ecologically appropriate native species will be expected in such schemes…

Agree. It is important that the species is appropriate to the underlying geology and character area.

Proposed amendment to Plan Ecologically appropriate native species will be expected in such schemes

27.18 NEB3 PO1979 Addition to text in part IV, as follows: New developments must make connections to biodiversity features and habitat networks outside the site, particularly through the use of a strong landscape framework and green infrastructure to strengthen and widen wildlife corridors.

Agree. A recent study by the Herts and Middlesex Wildlife Trust found that ‘existing habitat networks are highly fragmented and failing’.

Proposed amendment to Plan. New developments must make connections to biodiversity features and habitat networks outside the site, particularly through the use of a strong landscape framework and green infrastructure to strengthen and widen wildlife corridors.

27.19 NEB3 PO2085 Support this policy. Suggest minor amendment to text of VI, to acknowledge that features such as bird boxes will offer wildlife benefits even if not immediately bordering open space.

Agree, especially in the light of recent evidence suggesting that habitats are becoming increasingly fragmented.

Amendment to Policy NEB 3.VI. Integrated features for wildlife e.g. Swift, House Martin and bat boxes should be incorporated into all suitable buildings bordering open space.

27.20 27.19 NEB4

PO2006 Make reference to aged and veteran trees

New broader tree policy as proposed

New amended NEB 4 as above


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Protected trees and hedgerows

under …above

27.21 27.19 NEB4

PO1799 Make reference to the application of the Hedgerow Regulations within the Policy or 27.19.

Agree. Proposed amendment to Plan Information for applicants The Council will seek to ensure that the requirements of the hedgerow regulations are followed at all times. Developers should familiarise themselves with these requirements, and address any issues in their planning applications.


Policy/ Para. no.


NEB2 PO2014 Acknowledge trees as helping combat climate change in chapter 20, including policy DSC1

Chapter 20 – Design and sustainable construction, Policy DSC1

20.8

Policies Map

BoB Omission of National Nature Reserve Designation for Hoddesdonpark woods

Policies Map



Confusing policies with too much in them and the wrong emphasis

Amend and divide policies up as follows:

General Strategy for Biodiversity

Wildlife Sites

Ancient Woodland, Trees and Hedgerows (former NEB 4 with ancient woodland, aged and veteran trees added in)

Green Infrastructure

Landscaping and Biodiversity in New Developments


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Numbers no longer correlate Consequential renumbering of subsequent paragraphs.

Policies Map (chapter 27?) The site to the north of Faints Close, Rosedale is no longer a designated Local Wildlife Site

Check with HMWT. Amend the Policies Map accordingly.

NEB1.I Remove clause on protected species as overlap with other parts of the biodiversity policy, and therefore unnecessary.

Delete protected species clause.

27.8 Delete “…as determined by the BIAC…” as in some instances other methods to calculate total impact could be just as suitable.

Amend para. 27.8 as follows: If biodiversity losses (as determined by the BIAC) resulting from a development cannot be avoided (by locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission will likely be refused.

NEB1 – Information for Applicants

Need to stress that avoidance/mitigation and compensation is a hierarchy with avoidance the preferred option, then mitigation of the effects if avoidance is not possible, or of residual effects remain and compensation only as a last resort.

Add in the following paragraph after 27.6 (so new paragraph 27.7). Mitigation Hierarchy Avoidance, mitigation and compensation activities to manage adverse impacts from development on biodiversity form a hierarchy. Avoidance is the preferred option, and must be considered first. If avoidance is not possible, or if residual adverse effects remain, mitigation of the effects can be scoped. If avoidance and mitigation do not address all the adverse effects, compensation or offsetting measures may be appropriate. The success of compensation measures can be very variable and carry a high degree of uncertainty over a long timeframe. For this reason, compensation will only be acceptable as a last resort. Compensation for a lost habitat will not make an unacceptable development acceptable. Biodiversity offsetting is not designed to be applied to priority habitats.

New area non-statutory designation: Lea Catchment Nature Improvement Area

Amend Policies map in accordance Lee Catchment Nature Improvement Area

Identify Top Field and Cozens Grove and Cheshunt Park as Local Nature Reserves on Policies Map as are statutorily designated (although protection is still afforded by way of Local Plan policies) .

New Site Designation ‘Local Nature Reserve’ on Policies Map and two sites Cheshunt Park (see MaGIC for site outline) and Top Field and Cozens Grove.


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27.5 Add in where to find list of protected species. Add to Information for applicants Protected species An up to date list of Species and Habitats of Principle Importance, designated as such under the Natural Environment and Rural Communities Act 2006, can be viewed on the Government website.

27.5 Insert negatively to clarify the sorts of effects the policy is trying to address

Amend Information for applicants: Protected species as follows: Where there is a reasonable likelihood that protected species, or the habitats upon which they depend, may be negatively affected by a development proposal….

Policy NEB4

Remove reference to open space so applies to all buildings

VI. Integrated features for wildlife e.g. Swift, House Martin and bat boxes should be incorporated into all suitable buildings bordering open space.

27.15 Expand monitoring provisions to provide more certainty about what will be required

Amend Monitoring and Review paragraph 27.15 as follows: Monitoring and Review 27.15 The Council will monitor new GI green infrastructure and habitat

creation to ensure that it develops as expected. Any green infrastructure and habitat created carries with it a degree of uncertainty as to success of the final outcome. To mitigate against this eventuality, additional measures may be required if the space has not developed as anticipated at the time of granting the permission expected. Permissions will contain a review clause to this effect.

All policies from 2005 carried over.


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Chapter 28: Environmental Quality


Issue No.

Policy/ Para. no.

Commt. ID(s)


28.1 Air Quality PO2128 Public Health Service, Hertfordshire County Council The County Council has an approved Air Quality Strategic Plan for Hertfordshire - it would be helpful to cross-reference to this policy with various proposed developments across the Borough, particularly where vulnerable communities may be located adjacent to traffic hotspots

It is unclear what value would be added by referencing this non-statutory plan primarily aimed at increasing joint working. The majority of poor air quality is attributable to transport emissions; however the Air Quality Strategic Plan does not include this as a recommended action.


28.2 Policy EQ1: Air Quality

PO2129 Public Health Service, Hertfordshire County Council Strengthen policy to require mitigation to be built into development design,

Agree, will amend policy to include references to development design.

Amend paragraph 28.4 to include the following: New development should consider design solutions to reduce poor air quality and mitigate the effect of transport related pollutants. The role of vegetation in the management of air quality is complex and needs to be carefully considered. Amend policy to read: II. Developments proposing housing and other uses vulnerable to the effects of poor air quality will be required to provide tree planting or other mitigateion for this these effects through development design.

28.2.i Policy EQ1: Air Quality

PO2129 Public Health Service, Hertfordshire County Council

Monitoring the effectiveness of mitigation measures is a key element in reducing the

Amend policy to read: III. Major developments Proposals which will


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Require proposals resulting in a reduction in air quality to monitor as well as mitigate.

uncertainty associated with implementing these measures. However, requiring air quality monitoring for all developments is not practical as the cost would disproportionately fall on smaller developers and smaller developments are unlikely to manage any effective mitigation.

result in a reduction in air quality will need to offer measures to mitigate this effect.


PO2129 Public Health Service, Hertfordshire County Council Specify sources of air pollution to include PM2.5

There are currently no statutory obligations on Local Authorities in respect of PM 2.5 and because of its many and varied sources this is better addressed at the national level. No amendment necessary.


PO1664 Crest Nicholson Part I should not reference EU Limit Values – the reference should be to National Air Quality Strategy Objectives

Agree. While Councils can be held responsible for infractions of EU law, BREXIT means that these references will be redundant in the short term. The Air Quality (England) Regulations 2000 (as amended) set the statutory basis for the targets known as air quality objectives (AQOs).

Amend policy to read: I. Applicants should consider the impact of their proposals on air quality. Where necessary it is likely that a decline in air quality will result from a proposal they applicants they should provide details of how adverse effects on air quality have been mitigated in order to comply with EU limit values national air quality objectives.


PO1664 Crest Nicholson Part II should instead of tree planting require mitigation to ensure new residential receptors would not be subject to air quality worse than National Air Quality Strategy Objectives

Agreed. Policy has been amended above under 28.2


PO1664 Crest Nicholson Part III should be deleted as it effectively allows no worsening of air quality

Partially agree. Clause has been amended as for issue 28.2 above.


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anywhere, regardless of the level of worsening or whether air quality is poor in the area under consideration


PO1664 Crest Nicholson Part IV should be deleted as it could effectively sterilise development and prevent any additional traffic being added to a road where National Air Quality Strategy Objectives are exceeded

Disagree. The Council does not expect that proposals that result in a decline in air quality will be submitted without proposing appropriate mitigation. The policy could benefit from further clarification in accordance with that suggested. Amend policy to provide greater clarity about how the policy will be applied.

Amend policy as follows: IV. If the following mitigation, a development proposal results in a residual, net decline in air quality which exceeds, or further exceeds, EU Limit Values or national policy objectives for pollutants, especially in Air Quality Management Areas as shown on the Policies Map, and any subsequently designated, in any part of the borough, it will be refused.

28.8 Policy EQ2: Lighting

PO1980 Environment Agency For any development in close proximity to a watercourse the developer must be aware that the buffer strip should be left intrinsically dark (0-2 lux)

Noted. Will include in forthcoming guidance documents as more guidance than policy. No amendment necessary.

28.9 28.9 PO90 Sport England In relation to sports lighting, this paragraph should signpost applicants to Sport England’s Artificial Sports Lighting Guide which provides detailed advice to applicants and local authorities on the lighting issues associated with sports facilities

Noted. Will amend paragraph in accordance.

Amend paragraph 28.9 Information for Applicants as follows: Applicants should refer to Sport England’s Artificial Sports Lighting Guide for advice on lighting for sports facilities.

28.10 Policy EQ3: Noise

PO89 Sport England At present, criteria (a) and (b) of the policy do not refer to the acceptability of measures incorporated into proposals to minimise the impact of noise which would need to be considered in addition

Agreed. Will amend policy in accordance. Amend policy EQ3 II. as follows: (d) the acceptability of measures incorporated into development proposals to mitigate the impact of noise on noise sensitive land uses.


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to the these criteria. It is therefore requested that an additional criterion be added to the policy along the following lines: “ (c) the acceptability of measures incorporated into development proposals to mitigate the impact of noise on noise sensitive land uses”

28.11 Policy EQ3: Noise: Information for Applicants

PO89 Sport England The supporting text to the policy should, in relation to artificial grass pitches which is the most common sports facility that generates noise, signpost applicants to considering Sport England’s guidance on acoustics for artificial grass pitches https://www.sportengland.org/facilities-planning/tools-guidance/design-and-cost-guidance/artificial-sports-surfaces/

Agreed. Will amend policy in accordance. Amend paragraph 28.13 Information for Applicants as follows: Applicants proposing artificial pitches should consult the Sport England website for guidance on acoustics for artificial grass pitches.

28.12 Policy EQ5: Waste and Recycling

PO1810 Hertfordshire County Council – Spatial Planning Policy 2: Waste Prevention and Reduction in the adopted Waste Core Strategy and Development Management Policies document should be acknowledged, as this policy aims to encourage the reduction and prevention of waste within the county

This plan forms part of the development plan, which is explicitly stated in paragraph 28.18. It is therefore considered that the particular policies in that plan do not require an explicit reference. No amendment necessary.

28.13 Waste and Recycling

PO1811 Hertfordshire County Council – Spatial Planning Whilst the Waste Disposal Authority and Waste Collection Authority are referred

Noted. Will amend paragraph 28.16 to include a reference to HCC as waste planning authority.

Amend paragraph 28.18 as follows: The Hertfordshire Waste Local Plan is prepared by Hertfordshire County Council. It

https://www.sportengland.org/facilities-planning/tools-guidance/design-and-cost-guidance/artificial-sports-surfaces/




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to it is considered that there needs to be a reference to the Waste Planning Authority within paragraph 28.18 to ensure the clarity of roles

details policies involving the depositing of refuse or waste materials other than mineral waste, this and encourages ….

28.14 28.18 PO1812 Hertfordshire County Council – Spatial Planning Paragraph 28.18 could be misleading in that its only refers to the Waste Local Plan containing policies which relate to landfill. The Waste Local Plan includes policies relevant to applications for all types of waste management facilities, covering the management of all waste streams

Disagree. The sentence in paragraph 28.18 says that the Waste Local Plan regards disposal by landfill as a last resort. No amendment necessary.


PO1813 Hertfordshire County Council – Spatial Planning Additional supporting text should be included to ensure that the policy relates to the separation and storage of waste as an ancillary part of other developments.

Noted. Add new paragraph after Policy EQ1 ‘Information for Applicants’ .

Add new paragraph after Policy EQ1: Information for Applicants as follows: Applicants should ensure that the separation and storage of waste, and access to them suitable for waste management vehicles, is an intrinsic part of the design of all new developments


PO1813 Hertfordshire County Council – Spatial Planning It could be understood that this policy encourages applications for waste management facilities to be submitted to the borough council for determination and not the Waste Planning Authority.

The chances of waste operators making applications to Broxbourne for waste management facilities are low. No amendment necessary.


PO1403 Hertfordshire County Council Property (Development Services) Would expect Broxbourne Council to

A site for a suitable replacement has been found. No amendment necessary.


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consult with the County Council to secure either a suitable replacement for the Household Waste Recycling Centre, or an appropriate financial contribution to a facility, which is capable of serving residents from the Borough

28.18 Minerals PO1807 Hertfordshire County Council – Spatial Planning The Minerals Planning Authority aims to protect mineral resources from sterilisation, and regard should be given to the issue of minerals sterilisation and the need to recover mineral prior to any development

While regard can be given to sterilisation, to the best of the council’s knowledge, no proposals for mineral development have been put forward by landowners or mineral operators. Site specific survey work would be required to determine whether the mineral at risk of sterilisation was ‘significant’. Viability of extracting the mineral is key to any mineral development. The high price of land within Broxbourne, immediate development pressures, small size of the deposits and lack of mineral development infrastructure suggests that most extraction for off-site use or processing may be of marginal viability. No interest has been expressed in extracting any mineral within the borough to date. No amendment necessary.

28.19 Policy EQ6: Minerals

PO1809 Hertfordshire County Council – Spatial Planning The sand and gravel belt should be referred to on the Policies Map or within the text.

Including the sand and gravel belt on the Policies Map would obscure or obliterate the detail of the Policies Map on much of the eastern side of the borough. The section will be amended to include a reference to sand and gravel belt within the

Add in a paragraph as follows: Before submitting an application for development, applicants must check whether their development sites fall within the sand and gravel belt as shown on the Map n Appendix ….


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text and include the map as an appendix showing the sand and gravel belt. The council considers that the threshold for consulting the council as ‘excluded development’ is too low and fails to adequately consider the viability and practicality of working small minerals sites in high density residential areas.

28.20 28.21 PO1808 Hertfordshire County Council – Spatial Planning Minerals Local Plan covers the period from 2002-2016.

Noted. Will amend in accordance. Amend paragraph 28.21 as follows: …..The County Council has adopted the Hertfordshire Minerals Local Plan 1991-2006 2002-2016, which ….


Policy/ Para. no.

Commt. ID(s)


Waste and Recycling

PO1810 Hertfordshire County Council – Spatial Planning The amount of waste arising from the new developments, including the construction and demolition associated with them, as proposed in the plan should be considered under sustainable design and construction.

Sustainable Design and Construction 20.15 & 20.19


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Whole Chapter Remove all unnecessary references to Supplementary Planning Guidance.

Amend chapter as follows: The policy below should be read in conjunction with the Council’s Supplementary Planning Guidance on Waste.

Air Quality Section Remove all reference to EU standards and replace with national ones

Replace all instances of EU and EU limit values with references to national air quality objectives.

Air Quality Section Air Quality Management Areas (AQMAs) can change over time. If shown on the Policies Map this may result in a Policies Map which dates quickly. Remove all references to policies map and replace with a reference to where they can be found.

IV. If the following mitigation, a development proposal results in a residual, net decline in air quality which exceeds, or further exceeds, EU Limit Values or national air quality objectives for pollutants, especially in Air Quality Management Areas as shown on the Policies Map, and any subsequently designated, in any part of the borough, it will be refused.

Policy EQ1: Air Quality

Add in a specific reference to schools so that they can be considered at the earliest stages

Developments proposing housing, schools and other uses vulnerable to the effects of poor air quality will be require …


Add in AQMAs to restrict mitigation requirements to those areas of poor air quality.

Developments proposing housing, schools and other uses vulnerable to the effects of poor air quality within AQMAs will be required …

Policy EQ1: Air Quality I.

Define ‘necessary’ and ‘they’ for greater certainty.

Amend policy to read: I. Applicants should consider the impact of their proposals on air quality. Where necessary it is likely that a decline in air quality will result from a proposal, they applicants they should provide details of how adverse effects on air quality have been mitigated in order to comply with EU limit values national air quality objectives

Policy EQ1: Air Quality III.

Clarify major developments will only be required to mitigate its effect on air quality.

III. Major developments1 Proposals which will result in a reduction in air quality will need to offer measures to mitigate this effect.


Proposals that exceed national air quality standards should be refused in all areas, not just in areas designated as AQMAs.

IV. If the following mitigation, a proposal results in residual, net decline air quality which exceeds, or further exceeds, EU Limit Values or national air quality objectives for pollutants, especially in Air Quality Management Areas as shown on the Policies Map, and any subsequently designated, in any part of the borough, it will be refused.

1 as defined within the Town and Country Planning (Development Management Procedure) Order (England) 2010 [(Wales) 2012


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Policy EQ1: Air Quality: Information for applicants.

Add in additional detail on locations of AQMAs Amend Information for Applicants to read: Information on the location of declared AQMAs in Broxbourne, including maps of AQMA boundaries can be found at broxbourne.gov.uk .Images of the AQMA boundaries in conjunction with the wider vicinity can also be viewed on our online interactive map.

Policy EQ1: Air Quality: Information for applicants.

The Council is currently developing an AQAP for

Air Quality Management Areas 1, 4, 5, 6 & 7.

Add a clause to Information for Applicants

which refers to the Action Plan.

Amend Information for Applicants to read: For developments located within, or directly adjoining, an AQMA, applicants should refer to the Council’s Air Quality Action Plan.

Policy EQ1: Air Quality Information for applicants.

Consequential amendment to 28.2 – comments from HCC. Add in additional supportive text on design considerations under Information for Applicants.

Information for Applicants Travel Plans Where a new major development generates additional traffic, applicants are required to submit, at the time of application, a detailed travel plan which sets out measures to encourage sustainable movement including increased use of sustainable transport via improved public transport infrastructure, site layouts to improve accessibility to public transport and the safe movement of pedestrians, cyclists and horse riders (where applicable). The travel plan will need to include provisions to measure its implementation and effectiveness in achieving the sustainable movement of new occupants and users.

Policy EQ1: Air Quality Information for applicants.

Defra’s Policy Guidance LAQM. PG16 states that

Local Authorities are expected to work towards

reducing emissions and/or concentrations of

PM2.5 (particulate matter with an aerodynamic

diameter of 2.5µm or less). A risk assessment

and Dust Management Plan is required before

commencement of a development.

Dust

Prior to the commencement of the development, applicants for major development will need to

submit a risk assessment and Dust Management Plan, prepared in accordance with the Institute

of Air Quality Management’s Guidance on the Assessment of Dust from Demolition and

Construction 2014, or its successors.

Policy EQ3: Noise I. Add in timeframe for more certainty Amend clause I. as follows: New development, and extensions or alterations to existing developments, emitting noise levels noticeably above background levels on a consistent or consistently periodic basis, …..


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Policy EQ3: Noise I. Remove ‘noticeably’ for clarification and certainty purposes

Amend clause I. as follows: New development, and extensions or alterations to existing developments, emitting noise levels noticeably above background levels …..

Policy EQ3: Noise I. Add in timeframe for more certainty Amend clause I. as follows: New development, and extensions or alterations to existing developments, emitting noise levels above background levels, on a consistent or consistency periodic basis, should be sited away from noise sensitive land uses

Policy EQ3: Noise II.

Amend for more certainty Amend clause II. as follows: II. If this is unavoidable the Council will consider the following criteria when determining an application: (a) the time-span of noise generated and (b) the nature of the noise; and (b) (c) the cumulative impact of noisy development, and (d) the character and context of the area in which the activities will be sited.

Policy EQ3: Noise III.

Amend for more certainty III. Noise sensitive development should be located away from existing noise generating sources to avoid prejudicing the continued operation of the existing, lawful, noise generating use. The use of design, materials, layout, landscaping tools and construction methods including noise insulation should be employed, where needed, to reduce the impact of surrounding noise sources.

Paragraph 28.14

Add in ‘industrial’ and ‘horticultural’ after ‘commercial’ to provide more information about the type of uses which may result in ground contamination.

Land may be contaminated and/or unstable for a number of reasons, such as a previous commercial, industrial or horticultural use or use as a landfill site. Such land can be re-used for new purposes but special remedial measures may be needed to reduce hazards arising from the previous use of buildings and land. SuDS features may need to be specially designed.

Paragraph 28.14

Add more information on why SuDs may need to be specially designed.

Land may be contaminated and/or unstable for a number of reasons, such as a previous commercial, industrial or horticultural use or use as a landfill site. Such land can be re-used for new purposes but special remedial measures may be needed to reduce hazards arising from the previous use of buildings and land. SuDS features may need to be specially designed to ensure that contaminants do not enter groundwater or surface watercourses.

Paragraph 28.15

Paragraph requires more explanation. Developers are responsible for ensuring that there are no risks to public health or the environment from contamination and land instability are not present on a development site during and after site remediation. Any unacceptable risk will be successfully addressed through the remediation of contaminated land, without undue environmental impact during and following


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the development.

Policy EQ4: Contaminated Land

Paragraph requires more explanation of cause and effect.

II. The Council will require evidence, in the form of a land contamination and geotechnical report, as part of any application, to show that all unacceptable public health or environmental risks from site related contamination and land instability will be successfully addressed through remediation. without undue Development proposals will need to address, manage and mitigate, any environmental impacts likely to arise during the remediation process and following the completion of development.



III. Should residential use be proposed, and the site concerned is unable to be satisfactorily remediated to a standard suitable for that use, the development will be refused.



IV. Monitoring procedures to be undertaken prior, during and post remediation, and periodically for 5 years, and then 10 years following the completion of the development, will be agreed with the applicant. These should be set out in a verification monitoring report.

Paragraph 28.16 Paragraph requires clarification to ensure it applies to land at risk of contamination as not all sites will be verified as contaminated before a planning application is submitted.

Proposals on land at risk of contamination or instability ed land will not be validated until all necessary contamination and/or instability surveys have been undertaken carried out. Geotechnical and contamination reports must be submitted at the time of an application.

28.29 On making an application for development on a contaminated or site subject to instability, a draft remediation management plan will be required to be submitted detailing: the process to be used to address the issue; timeframes; and mitigation measures, including transportation of any contaminated material off the site; dealing with unexpected weather events, and ongoing monitoring arrangements.

Paragraph 28.17 The LQM/CIEH 'Suitable 4 Use Levels' (S4ULs) follow on from the previous LQM/CIEH Generic Assessment Criteria. The S4ULs are based on Health Criteria that represent minimal or tolerable levels of risks to health as described in the Environment Agency's SR2 guidance, ensuring that the resulting assessment criteria are 'suitable for use' under planning.

Reword paragraph as follows:

Where historical use, proximity to landfill, or an Environmental Consultants report indicates a risk of contamination, any planning permission will be subject to planning conditions or obligations to ensure the final development is fit for its proposed end use; having regard to the latest government guidance and the Chartered Institute for Environmental Health's General Assessment Criteria for Human Health Risk Assessment 'Suitable 4 Use Levels' (S4ULs). The S4ULs are based on health criteria that represent minimal or tolerable levels of risks to health.

New Policy – Need a policy which covers all aspects of Add in new policy and introductory text as follows:


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Environmental Quality

residential amenity Environmental Quality Residential amenity is a measure of the pleasantness of an area. It is influenced by a range of factors such as the amount of vegetation and outdoor space; privacy; outlook and natural light. The relationship of buildings to each other and their individual design can have a significant impact on these factors, and on residents’ comfort. The Council is keen to ensure that the level of amenity in residential areas should not be diluted over time by development within urban areas. Policy EQ1: Environmental Quality I. All proposals for development within the urban area must avoid detrimental impacts on the amenities enjoyed by the occupiers of neighbouring properties in terms of daylight, sunlight, outlook and overlooking. II. Proposals which generate dust, noise and odour must not result in a persistant and measurable deterioration in the level of amenity levels currently enjoyed in an area. III. All development proposals must include provision for the storage of bins refuse and recycling facilities in compliance with the Council’s Waste Supplementary Planning Guidance and ancillary household equipment.

Rename Land Contamination and Instability ‘Land Remediation’

Replaces references to ‘Land Contamination and Instability to ‘Land Remediation’ throughout.

New policy on Unstable Land

Separate policy is required on unstable land as different issues to Contaminated Land

(New) Policy EQ6: Unstable Land I. The Council will encourage the remediation of unstable land to ensure that land is

brought back into effective use. II. The Council will require evidence, in the form of a geotechnical report, as part of any

application, to show that all unacceptable public health or environmental risks from land instability will be successfully addressed through remediation.

III. Development proposals will need to address, manage and mitigate, any adverse environmental impacts likely to arise during the remediation process and following the completion of development.


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IV. Should residential use be proposed, and the site concerned is unable to be satisfactorily remediated to a standard suitable for that use, the development will be refused.

V. Monitoring procedures to be undertaken prior, during and post remediation, and periodically for 5 years, and then again 10 years following the completion of the development, will be agreed with the applicant.

New para on monitoring.

Need details on how monitoring proposals will be incorporated into the planning application.

A draft monitoring report, detailing how the site will be monitored for changes over the medium term, should be set out in a draft monitoring report to be submitted with the application.

Policy EQ5 Delete Policy EQ5 as unnecessary duplication of Waste Local Plan. Text will ensure people are pointed in the right direction.

Amend section as follows: The policy below should be read in conjunction with the Councils Supplementary Planning Guidance on Waste.

Policy EQ5: Waste and Recycling Facilities sufficient to permit the separation and storage of different types of waste prior

to collection will be encouraged.

Policy EQ6 Delete Policy EQ6 as unnecessary duplication of Minerals Local Plan. Text will ensure people are pointed in the right direction.

Amend section as follows: There is a need to safeguard known mineral supplies from inappropriate development. Accordingly, proposals which would sterilise or prejudice the extraction of known, workable supplies will be resisted.

Policy EQ6: Minerals Development which would be likely to sterilise or prejudice the extraction of known,

workable, minerals resources would not be permitted.

2005 Plan – Policies omitted

Policy SUS5 Pollution – superseded by policies on air and water quality

Policy SUS7 – Air Quality Management Areas – not necessary for a planning purpose.


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Chapter 29: Heritage Assets


Issue No.


Com-ment IDs



PO659 We very much welcome the inclusion of a separate chapter relating to the Historic Environment.

No amendment in response to this issue


PO1775 The County Council supports reference to the significance of Scheduled Monuments, historic settlements and parks and gardens to the Borough and reference to the New River.



PO659 PO1773

We would advise that the term ‘Historic Environment’ is used instead of ‘heritage assets’ as it is a broad term which includes both tangible heritage assets such as Listed Buildings and less tangible elements such as cultural heritage and setting.

Amend chapter by replacing the word Heritage Assets with Historic Environment, where appropriate e.g. rename chapter from Heritage Assets to Historic Environment and insert ‘Historic Environment’ in to the policies and text where the more general term is appropriate. See under Policy HA1 for the amended wording of the policy.

29.03 General Comments (not

PO1773 The chapter contains some inaccurate or confusing statements.

Chapter and policies have been reviewed as a whole, in line with the NPPF.


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attributable to a particular policy)

These policies and the accompanying text should be clarified and re-written to ensure full compliance with the NPPF and national guidance.

This will include a strategy for the protection of the historic environment in accordance with paragraph 157 of the NPPF.


PO1776 There is a wide range of other evidence of the Borough’s heritage which could be incorporated including:

nationally significant (possibly Bronze Age) landscapes of Broxbourne and Wormley Woods.

archaeological sites along the river Lea.

Bronze Age settlement, a late Iron Age and Roman cemetery and Rare Tudor wall paintings in Hoddesdon.

A roman roadside settlement in Cheshunt Park,

the Outer London Stop Line constructed to protect London in World War II.

Amend the introductory text to include reference to the heritage assets mentioned.

29.2 The Borough is fortunate to have a varied historic environment which This varied environment ranges from nationally significant Bronze Age landscapes in Broxbourne and Wormley Woods, to archaeological sites dating from the Mesolithic (middle Stone Age) period along the river Lea and a Bronze Age settlement at John Warner school. It also includes a Late Iron Age and Roman cemetery in Hoddesdon; Rare Tudor Wall Paintings at the Star Public House in Hoddesdon; a Roman roadside settlement in Cheshunt Park and part of the Outer London Stop Line constructed to protect London in World War II.

Broxbourne has We have the following types of nationally designated heritage assets within the Borough:

260 258 listed buildings and structures;

34 Areas of Archaeological Significance;

eight Scheduled Monuments;

six conservation areas and a

Grade II Registered Park and Garden at Wormleybury currently


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designated at the national level in the Borough.

The borough also has a number of heritage assets on the Heritage At Risk Register including two of our conservation areas – at Churchgate and Wormley.


PO1774 The potential for as yet unknown heritage assets is not recognised and needs to be addressed. These may be very significant.

Amend Policy HA1:Historic Environment

Amend ‘Information for Applicants’ section following Policy HA1 as follows: A Heritage Statement, prepared in

accordance with paragraph 128 of the NPPF should accompany all applications that affect heritage assets. The statement should describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and should be sufficient to understand the potential impact of the proposal on its significance. Appropriately qualified persons should be used.

Where a development has the potential to affect heritage assets with an archaeological interest, i.e. is in reasonable proximity to other known finds, or a landscape or geological feature generally associated with sites of archaeological interest, applicants should submit a desk based assessment and, where necessary, the results of a field evaluation, at the time of the


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submission of an application.

Applicants will need to consult with the Hertfordshire County Council’s Historic Environment Unit directly in preparing the required assessments.

29.06 PO1987 There is a lack of recognition of the national policy requirement for balance in a number of the other Heritage policies including those mentioned below.

It is not the role of the Local Plan to restate the NPPF; its role is to apply criteria which implement national requirement at the local level.

The supporting text on paragraph 29.6 refers to the criteria on page 31 of the NPPF. This will be amended to read: Planning consent will be refused where proposed development leads to significant substantial harm to or total loss of significance of, a heritage asset unless there are substantial public benefits that outweigh the loss harm. The criteria exceptions to be used in making this judgement be determined are set on page 31 are listed in Paragraph 133 of the NPPF.

29.07 Whole Plan PO671 Other policies (housing etc.) may need to be tailored to achieve the positive improvements that paragraph 8 of the NPPF demands.

Need to avoid unnecessary duplication between other topic policies and Historic Environment policies. The Council is confident that the policies in this section should achieve the protection required. No amendment required.

29.08 Whole Plan PO671 Site allocations may need to refer to the historic environment.

Many of our development sites are in close proximity to, or contain, historic assets.


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The policies of this plan will ensure that aspects of the historic environment contained within each site will be protected, conserved and enhanced where possible without reference to each element within the site allocation. Given the amount and distribution of sites within the Borough, the Council will include in its Strategic Policy, a clause on the need to take a precautionary approach (see under Issue 29.13) to the development of sites.

29.09 Whole plan PO671 The plan may need to include areas identified as being inappropriate for certain types of development due to the impact they would have on the historic environment.

No amendment made. While this is a requirement of the NPPF (P 157) the constrained nature of the Borough means that a blanket ban on certain types of development is inappropriate. The Council is satisfied that the effects of development on the Borough’s historic environment and heritage assets can be sufficiently assessed using the detailed policies in the Historic Environment Chapter.

29.10 29.2 PO660 According to our records there Amend paragraph in accordance


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are 258 listed buildings. (see above under 29.04)

29.11 29.2 PO660 Paragraph should also refer to the 1 Historic Park and Garden in the Borough, as well as the number of assets on the Heritage at Risk Register (of which there are two Conservation Areas).

Amend paragraph in accordance (see above under 29.04)

29.12 29.3 PO661 Paragraph should state number of locally listed buildings in Borough.

Amend paragraph in accordance to state 113.

29.13 Policy HA1 PO662 Does Policy HA1 refer to all heritage assets or just designated heritage assets? If it just relates to designated heritage assets, this should be reflected through the policy.

Policy is the general strategy policy

Policy HA1: Heritage Assets Historic Environment:

I. When assessing applications for

development, there will be a

presumption in favour of the

retention and enhancement of

heritage assets the historic

environment, and to putting

heritage assets to viable and

appropriate uses to secure their

future protection.

II. Development proposals that

would harm the significance of a

heritage asset will not generally be

permitted.

IV. The cumulative effect of small

scale, incremental and piecemeal

changes on the significance of the


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heritage asset will be considered at

the time of any application.

Information for Applicants A Heritage Statement, prepared in

accordance with paragraph 128 of the NPPF should accompany all applications that affect heritage assets. The statement should describe the significance of any heritage assets affected, including any contribution made by their setting. The level of detail should be proportionate to the assets’ importance and should be sufficient to understand the potential impact of the proposal on its significance. Appropriately qualified persons should be used.

Where a development has the

potential to affect heritage assets

with an archaeological interest, i.e.

is in reasonable proximity to other

known finds, or a landscape or

geological feature generally

associated with sites of

archaeological interest, applicants

should submit a desk based

assessment and, where necessary,

the results of a field evaluation, at

the time of the submission of an


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application.

Applicants will need to consult with the Hertfordshire County Council’s Historic Environment Unit directly in preparing the required assessments.

Planning consent will be refused where proposed development leads to significant substantial harm to or total loss of significance of, a heritage asset unless there are substantial public benefits that outweigh the loss harm. The criteria exceptions to be used in making this judgement be determined are set on page 31 are listed in Paragraph 133 of the NPPF.

Where there is evidence to suggest that a heritage asset has been deliberately neglected or damaged, the state of that asset will not be considered in taking a decision on the effect of the proposal on the heritage asset.

Heritage England has published a number of documents and publications which provide further guidance on developments and heritage assets. These should be taken into consideration alongside the policies set out within this document.

29.14 Policy HA1 PO662 We would also suggest the The Policy has been amended


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insertion of the words, ‘and their settings’. The rewording after the first mention of heritage assets in clause I.

(under Issues 29.13 above) to include the term historic environment which would also cover less tangible aspects such as settings.

29.15 Policy HA1 PO783 Under II) It is suggested that 'substantially' is added before ‘harm’ to comply with the NPPF.

It is not the role of the Local Plan to duplicate the NPPF. The policy is intended to be more strategic than the NPPF paragraph quoted.

29.16 Policy HA1 PO1987 Policy not positively prepared and does not reflect national policy to "conserve assets in a manner appropriate to their significance".

The Council understand that the term ‘positively prepared’ relates to the provision of housing and infrastructure delivery than the safeguarding policies. It is not the role of the Local Plan to restate the NPPF. The policy demonstrates the intention of the Council to plan positively for the protection and enhancement of the Borough’s significant historic environment in accordance with paragraphs 126 and 157.

29.17 Policy HA1.II PO1987 II does not accord with the requirements of NPPF (paras 132-134) as does not contain a balancing mechanism to weigh harm to significance against the benefits of development.

This is a very general policy which sets out an overall approach. The more specific asset–based policies contain details on how the significance of the asset will be considered, and the balance will be struck between the harm


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to the heritage assets and the significance of the heritage assets. It is not the role of the Local Plan to restate the NPPF.

29.18 Policy HA1 PO1987 The allowance of exceptions is reflected by the use of the word 'desirability" in the drafting of the Planning (Listed Buildings and Conservation Area) Act 1990.

Policy should be redrafted to be consistent with national policy and guidance.

Exceptions are established in law and national level policy. It is not the role of the Local Plan to replicate legislation and duplicate the NPPF. The Plan is required to be consistent with the higher level policies. This is a very general policy which sets out a positive strategy for the conservation and enjoyment of the historic environment. The more specific policies later in the chapter contain details on how the significance of the asset will be considered, and the balance assessed between the harm to the heritage asset and the significance of the heritage asset. The supporting text refers to the criteria on page 31 of the NPPF.

29.19 29.6 PO663 For consistency with the NPPF, p.133, first sentence should be re-worded to read, ‘Planning consent will be refused where a proposed development will lead to substantial harm to or total

Amend text in accordance. Paragraph will be amended as follows: Planning consent will be refused where proposed development leads to significant substantial harm to or total loss of significance of, a heritage asset unless there


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loss of significance of a designated heritage asset unless…’

are substantial public benefits that outweigh the loss harm. The criteria exceptions to be used in making this judgement be determined are set on page 31 are listed in Paragraph 133 of the NPPF. Have not included the word designated as the policy does not just apply to designated assets.

29.20 29.8 PO664 Change reference to Historic England.

Paragraph to be amended in accordance.

29.21 Policy HA.3 PO1988 Criteria III not positively prepared or consistent with national policy as does not allow for the balance between the benefits of a proposal and harm to the significance of the conservation area. Should be redrafted to remedy.

It is not the role of the Local Plan to duplicate the NPPF. The Council understand that the term ‘positively prepared’ relates to the provision of housing and infrastructure delivery rather than the safeguarding policies. Clause is not so onerous that it requires a balancing mechanism. No amendment to Plan in response to this issue

29.22 PO1988 Criteria IV not positively prepared or consistent with national policy as does not allow for the balance between the benefits of a proposal and harm to significance. Should be redrafted to remedy.

The Council understand that the term ‘positively prepared’ relates to the provision of housing and infrastructure delivery than the conservationist type policies. It is not the role of the Local Plan to duplicate the NPPF. Clause is no so onerous that requires a balancing mechanism.


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No amendment to Plan in response to this issue

29.23 29.19 PO666 Delete the word ‘or’ after ‘assets’. This paragraph could helpfully use the term, ‘Heritage at Risk’.

Paragraph to be amended in accordance.

29.24 Policy HA.5 PO667 Delete ‘will preserve the Borough’s listed buildings and’ since it is not the Borough who will be preserving the Buildings. Sufficient for the policy to state, ‘The Council will only support applications…’.

Amend policy to state:

The Council will preserve the Borough’s Listed Buildings and will only support applications for development affecting a listed building where

29.25 29.24 PO668 Welcome inclusion of policy and supporting text relating to Locally Listed Buildings. Welcome a specific policy on local listing including a general presumption in favour of retention of heritage assets.


29.26 Policy HA.6 PO668 List should be expanded to cover all types of heritage assets.

Not necessary as all heritage assets are covered in chapter.

29.27 Policy HA.6 PO668 Important to ensure locally listed building policies do not upstage policies for listed buildings and that the appropriate position in the hierarchy is reflected.


The wording of this policy is less onerous and looser than the wording of the Listed Building Policy. The text in paragraph 29.24 also states this.

29.28 Policy HA.6 PO1988 Policy does not allow for It is not the role of the Local Plan


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balance of the benefits in considering harm arising from proposals for alteration or extension.

to duplicate the NPPF, which stresses the need in paragraph 135 for a balanced judgement. No amendment necessary

29.29 Policy HA7 PO1991 Policy HA7 I and/or supporting text should make it clear that setting is not a heritage asset in itself, it is only important to the extent that it contributes to an appreciation of an asset’s significance.

The setting of a listed building is of great importance and should not be harmed by unsympathetic development on adjoining sites or in close proximity. The NPPF accords great importance to the setting of a heritage asset. Among the many references in the NPPF are the following: ‘Significance can be harmed or lost through …development within its setting’ (para.132); and ‘Settings can make a contribution to the significance of a heritage asset’ (para. 128). Council officers have requested that a separate policy on setting be included within the plan to assist with the consideration of the role of setting in assessing any the effect on the significance of a heritage asset. Nevertheless the setting is sub-ordinate to the significance of the heritage asset

Policy HA7 to be amended as follows: I. Proposals within the setting of a nationally designated building, structure, landscape, or other historic feature or a locally listed asset building, should demonstrate that they have safeguarded the relevant features of the building, structure or feature heritage asset and its setting in order to ensure that the appearance, character and setting are significance of the heritage asset is sustained and enhanced.


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29.30 Policy HA7 PO1991 HA7II should be included in HA5 not HA7 as it relates to changes to listed building themselves rather than changes to settings.

Clause II will be moved to Policy HA5 which will be amended as follows. Amend Policy HA5 in accordance.

Policy HA5: Listed Buildings The Council will only support applications for development affecting a listed building where: i) The extension/alteration would not adversely affect its character as a building of special architectural or historic interest both internally or externally or it’s wider setting; and ii) The design is high quality, with particular attention paid to details such as fenestration; materials including type of bricks and bonds used; and means of enclosure; and ii) Any change of use would preserve its character as a building of special architectural or historic interest; and iii) the application will ensure the continued use and viability of the building or structure. II. Any application should have regard to the following matters: (a) whether any original features or aspects that led to the building being included on the list will be lost, altered, or negatively impacted on, as a result; and (b) whether the proposal, due to cumulative alterations and additions, will lead to an unsympathetic and/or effect on the


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significance of the heritage asset. (c) whether the style and proportions of additional or altered doors, windows and roof(s)complement or preserve the characteristics of the original doors, windows, or roof(s); (d) whether the proposal is in keeping with the overall design/appearance of the existing building/s and its surroundings; (e) whether the proposal, due to cumulative alterations and additions, will lead to an unsympathetic and or adverse development.

29.31 29.27 PO669 Replacement of ‘Whilst inclusion on the register does not confer any form of legal protection, the Council will nevertheless’ with ‘Registration is a ‘material consideration’ in the planning process, meaning that planning authorities must consider the impact of any proposed development on the landscapes’ special character. The Council will…’.

Amend text in accordance by replacing text with that suggested.

Amend paragraph 29.27 as follows: …. Wormleybury comprises a 57ha landscaped park surrounding a country house which developed from an earlier formal scheme in the 1770s and the remnants of an early nineteenth century garden famed for its international plant collection. Whilst inclusion on the register does not confer any form of legal protection, The Council will nevertheless seek to ensure that the special interest of this parkland (and of any others which may from time to time be added to the register) is maintained and, if necessary, restored.

29.32 Policy HA9 PO670 Welcome the inclusion of policy HA9.


29.33 Policy HA12 PO784 Under a) add ‘significantly’ before ‘adversely’

Policy deleted as no longer needed because of consequential


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change arising from issue 29.29 above.

29.34 29.43 PO671 A good strategy will also be spatially specific, unique to the area, describing the local characteristics of the borough and respond accordingly with policies that address the local situation.

Will expand supporting text as for Issue 29.13.

29.35 29.43 PO671 We suggest that the words, ‘and enhancement’ be added after ‘enjoyment’ to reflect paragraph 157 of the NPPF.

Amend text in accordance. Amend text to state: The NPPF requires Councils to “set out in their Local Plan a positive strategy for the conservation, and enjoyment and enhancement of the historic environment”.

29.36 29.43 PO671 Positioned at the end of the chapter, these two paragraphs appear to be an afterthought. Suggest that the strategy be amplified and re-positioned at the start of the chapter.

Delete paragraph. Text has been reworded and moved to introductory section before Policy HA1 and expanded in accordance with comments.

29.37 29.4 PO671 The strategy should offer a strategic overview including overarching heritage policies to deliver the conservations and enhancement of the environment.

Strategy will include HA1 an overarching heritage policy. Supporting text will be moved to paragraph 29.4 which will be amended in accordance.

Paragraph 29.4 which will be amended as follows: The Council will seek to ensure that development not only avoids harm, but also improves the setting of Broxbourne’s historic environment, and better reveals the significance of heritage assets.

29.38 29.44 PO671 A good strategy will offer a positive holistic approach where

The amended introductory section under ‘Overall Strategy’

Amend Overall Strategy section as follows; As well as the implementing the policies in


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the historic environment is considered as an integral part of every aspect of the plan, interwoven into the entire document.

details how the Council will care for the historic estate.

this plan, including taking enforcement action when required, the Council will develop a plan for the protection and management of the whole historic estate may including: the preparation of conservation area statements; reviewing the local list of locally important buildings using the Local List Selection Panel; seeking designation of non-designated heritage assets; and the investigating most appropriate measures to manage heritage assets, including the serving of Building Preservation Notices and applying Article 4 directions to restrict permitted development rights, limit the amount of small scale, incremental changes that can adversely affect the historic environment

Part 2: Other proposed amendments (not from consultation responses)


Paragraph 29.4 Add in intent to carry out work on the historic heritage in the borough

To help achieve this, the Council will carry out a borough-wide characterisation study; investigate the use of Article 4 Directions in conservation areas; improve signage relating to heritage assets and seek to increase public access to heritage assets where possible.

Policy HA1: Information for Applicants Duplication of NPPF Amend paragraph 29.5 as follows: A Heritage Statement, prepared in accordance with paragraph

128 of the NPPF should accompany all applications that affect heritage assets. The statement should describe the significance of any heritage assets affected, including any contribution made by their setting. The level of


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detail should be proportionate to the assets’ importance and should be sufficient to understand the potential impact of the proposal on its significance. Appropriately qualified persons should be used.

HA2: Non-designated assets Relocate within chapter Move Policy HA2 to after Archaeology.

Policy HA3: I. Conservation Areas Include changes of use as well for greater certainty

Amend text to state: I. Proposals for new development, changes of use, and alterations and extensions to existing buildings, within the conservation areas, as shown on the Policies Map, will be permitted providing that the development preserves or enhances the established character and appearance of the conservation area.

Policy HA3:IV. Conservation Areas Extend to include development ‘visually related to…’

Amend text to state: IV. Development outside but adjoining, or visually related to, a conservation area must not have a detrimental effect on the character, appearance, or land uses within that area; or views in to or out of, the conservation area.

Policy HA3:VI. Conservation Areas Add in the word sightline VI. The Council will not support applications for additional signs that would result in a proliferation of advertisement material on any individual building, group of buildings or sightline.

New paragraph After Policy HA3

The demolition in conservation areas policy needs some introduction and context.

There is a presumption against the demolition of buildings within Conservation Areas. Exceptions may be considered where the character and appearance of the area would benefit by removal of a particular eyesore. The importance of any building, in terms of the qualities, character and appearance of the conservation area will be assessed with particular regard to the following factors, based upon advice provided by Historic England:

• the age, style, architecture, and materials of the building;


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• its relationship with any nearby listed buildings; • whether it contributes as part of a group; • whether it has significant historical associations with established townscape features; and • whether it has significant historical associations with local people or past events.

New paragraph before 29.25 Information for Applicants

Add in information on the effects of complying with other legislation on the historic asset.

Add in new paragraph as follows: Information for Applicants Changes of Use In determining applications affecting listed buildings, the Council will be mindful of government advice that the best use for any historic building is usually the use for which the building was originally designed and constructed. A change in the use of a listed building brings with it the same inherent risks of damage as physical alterations promoted for their own sake. It is important to assess all additional legislative requirements such as those arising from compliance with the building control and fire regulations, which may necessitate internal alterations to features such as doors, fireplaces and stair cases. Applicants will need to provide this information at the outset in the consideration of any development proposals because of the potentially damaging effects of these requirements on the character of a building. The Council will give serious consideration to such issues before any decision is taken about whether or not consent should be granted.

Para 29.25 Not enough description of how setting contributes to the importance of a heritage asset.

Add to supporting text: While the setting of a listed building may be limited to its immediate surroundings, it often can extend some distance from it. The value of a listed building can be greatly diminished if unsympathetic development elsewhere harms its appearance or


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its harmonious relationship with its surroundings.

HA 7: Works within the setting of a Listed or Locally Listed Building

Consequential change to wording following issue

Amend ‘locally listed building’ to read ‘locally listed heritage asset’.

HA 7 II: Works within the setting of a Listed or Locally Listed Building

Duplication with some of existing Policy HA5 where II has been moved to,

Delete duplicating clauses.

HA7: Works within the setting of a Listed or Locally Listed Building

Note enough guidance in paragraph – needs entire policy.

Delete paragraph on enabling development and replace with more comprehensive policy below.

HA7: Works within the setting of a Listed or Locally Listed Building

Enabling development policy wrongly located at end of in historic settings policy

New Policy HA 12 to be named ‘Enabling Development’.

Policy HA8:Demolition of Listed Buildings Add in the need for an expert view.

I. Proposals for developments that involve the demolition of a listed building or structure will not be approved unless there are proven overriding issues that would favour demolition over protection. Applicants will be required to submit detailed, expert, evidence justifying demolition, and havinge regard to the following criteria:

29.31 Minor amendment 29.31 Archaeological areas include those that contain features of historical interest or locations where there is evidence to suggest that archaeological remains may be present. It may also be necessary for archaeological investigations to be carried out on land not designated due to the Borough’s long history of occupation.

Policy HA10: Archaeology Clarify wording I. Proposals Development which would adversely affect the site or setting of nationally important archaeological remains will not normally be permitted. Any harm or loss will require clear and convincing justification.

II. An archaeological field evaluation must be submitted where proposals are on, or adjacent to sites of known archaeological interest or sites believed to with a reasonable likelihood to possess potential archaeological significance.


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III. Where development proposals are considered to have an impact on archaeological remains the Council will seek to firstly preserve them in situ. Where this is not possible, there must be appropriate management of archaeological sites, including preservation of any material, as part of the planning consent.

HA12: Setting of Nationally Designated Features Very similar to HA7. Parts No longer required because of change arising from Issue 29. …. Above.

Amalgamate into HA7 as sub-clause II. so it reads: Policy HA7: Works within, and affecting the setting of, Listed and Locally Listed Buildings Heritage Assets I. Proposals within the setting of a nationally designated building, structure, landscape, or other historic feature or a locally listed asset building, should demonstrate that they have safeguarded the relevant features of the building, structure or feature heritage asset and its setting in order to ensure that the appearance, character and setting are significance of the heritage asset is sustained and enhanced. Policy HA12: Works affecting the setting of a Nationally Designated Building, Structure, Landscape, Park or Garden or Other Feature II. Proposals outside the curtilage, which affect the setting of a nationally designated building, structure, landscape, historic park or garden or other feature, should demonstrate that: a) the proposal does not adversely impact on the relevant features of the building, structure or feature and its setting,

New extended policy: Enabling Development Officers consider that more detailed guidance on how to deal with enabling development is necessary.

The maintenance and upkeep of listed buildings, due to their age and structure, can be costly. It is the responsibility of the landowner to maintain the features and qualities which resulted in the listing of the asset. Proposals are occasionally submitted for new development within the grounds of a listed building to help fund essential improvements to that building. This is commonly referred to as “enabling development”. The Council is mindful that the effect of any enabling development can be negative and destroy more than is saved.


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The Council supports Historic England in wishing to see a presumption against such development unless the applicant demonstrates that the benefits of the proposed enabling development clearly outweigh any disbenefits to both the historic asset and its setting. HA…. ENABLING DEVELOPMENT

Policy HA…. Enabling development

New development, which is required in the grounds of a nationally listed building to help fund essential improvements to that building, will only be permitted where it is demonstrated that:

i) its benefits significantly outweigh any detriment to the historic, archaeological or architectural qualities of the asset; and

ii) its benefits significantly outweigh any detriment to the local character and setting; and

iii) it is the only financially viable solution; and

iv) the enabling development will secure the long term future of the heritage asset and, where applicable, its continued use for a purpose sympathetic to the building; and

v) the extent of enabling development is the minimum necessary to secure the future of the heritage asset.

Listed Building Policy Add additional information into Information for Applicants

Information for Applicants Changes of Use In determining applications affecting listed buildings, the

Council will be mindful of government advice that the


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best use for any historic building is usually the use for which the building was originally designed and constructed.

A change in the use of a listed building brings with it the same inherent risks of damage as physical alterations promoted for their own sake. It is important to assess all additional legislative requirements such as those arising from compliance with the building control and fire regulations, which may necessitate internal alterations to features such as doors, fireplaces and stair cases. Applicants will need to provide this information at the outset in the consideration of any development proposals because of the potentially damaging effects of these requirements on the character of a building. The Council will give serious consideration to such issues before any decision is taken about whether or not consent should be granted.

29.48 Although still providing an essential element of distinctiveness, buildings on the local list are not subject to the high level of protection afforded to nationally designated buildings. The inclusion of a building on the local list is a material consideration in the determination of planning applications.

Delete unnecessary paragraphs Remove paragraph justifying enabling development

The Council encourages proposals which facilitate the rehabilitation, maintenance, repair and enhancement of listed buildings. The maintenance and upkeep of listed buildings, due to their age and structure, can be costly. It is the responsibility of the landowner to maintain the features and qualities which resulted in the listing of the asset. Occasionally, it may be appropriate to allow development to be built in the curtilage of the heritage asset to fund essential improvements to that asset. This is called enabling development.


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Locally Listed Buildings Delete policy as unnecessary as have policy on non-designated assets

Delete Policy HA6: Locally Listed Buildings as follows: The Council encourages the retention of Locally Listed Buildings.

Where planning permission is required for the alteration, extension or change of use of a Locally Listed Building, permission will be granted where historic or architectural features are retained or enhanced.

Paragraph and Policy renumbering Renumbering required as a consequence of amendments to chapter.

Renumber policies and paragraphs.


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Chapter 30: Transport and Movement


Issue No.

Policy/ Para. no.

Commt. ID(s)

Issue Officer Response

Proposed amendments to the Plan

30.1 Para 30.2 PO1065 Highways England The plan should make reference to both Highways England and the local highway authority as either or both may need to be consulted at pre-application or application stages where development may impact on the safety of operation of the relevant road network.

Agreed. Add in references in new paragraph.

Add in new paragraph after 30.2 as follows: Highways England are responsible for the Strategic Road Network (SRN), i.e. the M25 including Junction 25.

30.2 Policy TM1: Sustainable Transport

PO1535

Hertfordshire Local Enterprise Partnership The LEP supports this policy.


30.3 Policy TM1: Sustainable Transport II.

PO2080 Lee Valley Regional Park Authority Notes the support for pedestrian routes to and within the Park.


30.4 Policy TM1: Sustainable Transport II.

PO1665 Crest Nicholson The requirement for access to community facilities by wheelchair users is unclear.

Noted. Delete this clause in its entirety.

IV. …… This policy will also apply to the needs of wheelchair users for new community facilities.

30.5 Para 30.4 PO1065 Highways England The plan should make reference to both Highways England and the local highway authority as either or both may need to be consulted at pre-application or application stages where development may impact on the safety of operation of the relevant road network. The plan should mention that in various circumstances the DMRB (for example on, or on the approaches to, the Strategic Road Network- SRN) will be the appropriate standard to adopt rather than Manual for Streets 2

Partially agree. Applicants can ask Council officers about pre-application or application stage discussions with either

Amend Information for Applicants by inserting new paragraph before para 30.4 and amending paragraph 30.4 as follows: Applicants should consult the latest guidance and documentation produced by the Department for Transport including the Design Manual for Roads and Bridges and the Manual for Streets 2 guidance tool.


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authority as the situation may change over the lifetime of the plan. Agree regarding the Design Manual for Roads and Bridges (DMRB) and will amend paragraph in partial accordance.

30.6 Policy TM2: Transport and New Developments

PO94 What are your proposals for road widths, particularly in view of the number of cars that are double parked, as in Canada Fields, as an example of where it is difficult to drive along the roads?

Road widths are standard and are reviewed periodically by the Department for Transport in its Design Manual for Roads and Bridges, or on receipt of a planning application by Hertfordshire County Council as the highways authority.


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The issue at Canada Water was the amount of parking and transport alternatives provided. Car ownership has increased markedly since the recession, as has the number of people moving back in with extended family. As car ownership and the number of people per house increases, so does the need for parking. As parking demand is not limited in any way, the council must strike a balance between


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meeting parking needs and other considerations. Frequent, reliable alternatives to the private car are necessary to reduce car ownership. No amendment necessary.

30.7 Policy TM2: Transport and New Developments

PO1536 Hertfordshire Local Enterprise Partnership The LEP supports this policy. In addition to traffic impact, economic regeneration and sustainable place making are equally significant criteria.

Noted. Economic regeneration and sustainable place making are inherent within any planning application. Given the over-riding presumption in favour of sustainable development (NPPF para 14), it is not considered


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necessary to add these in specifically as separate criteria. No amendment necessary.

30.8 Para 30.6 PO1065 Highways England The plan should make reference to both Highways England and the local highway authority as either or both may need to be consulted at pre-application or application stages where development may impact on the relevant road network.

Agreed. Amend paragraph in accordance.

Amend Information for Applicants by inserting new paragraph and amending the existing paragraph as follows: Applicants should consult the latest guidance and documentation produced by the Department for Transport including the Design Manual for Roads and Bridges and the Manual for Streets 2 guidance tool.

30.9 Paragraph 30.7

PO1066 Highways England We recommend that reference is made to showing how infrastructure may be funded and delivered.

Partially Agree. Amend paragraph to include reference to funding.

Amend paragraph 30.7 as follows: A TA should include a non-technical summary, an explanation of the existing conditions and proposed development, the trip generation arising from the development, and environmental impact and funding sources for any new infrastructure required as a result of the development. It should also highlight the more sustainable choices to be implemented through the travel plan, including mitigation measures, and proposals for monitoring transport impacts.

30.10 Para 30.10 PO1065 Highways England The Council should ensure that it is relying on extant government guidance on Transport Assessments see: http://planningguidance.communities.gov.uk/blog/guidance/travel-plans-transport-assessments-and-statements-in-decision-taking/

Noted. Amend paragraph to make a more general

Amend paragraph 3.10 as follows: Further guidance on Transport Assessments

can be found on the Department for Transports website. Guidance on Transport

http://planningguidance.communities.gov.uk/blog/guidance/travel-plans-transport-assessments-and-statements-in-decision-taking/

http://planningguidance.communities.gov.uk/blog/guidance/travel-plans-transport-assessments-and-statements-in-decision-taking/


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and https://www.gov.uk/government/publications/guidance-on-transport-assessment

reference to the Department for Transports webpage so that the latest guidance is accessed.

Assessments (Appendix B Indicative Thresholds for Transport Assessments). Guidance on travel plans can be found on the Herts Direct website.

30.11 Para 30.14 & Policy TM4: Parking Standards

PO1896 Transport for London

TfL supports a restraint based approach to car parking as set out in the London Plan. Broxbourne has a boundary with Enfield and parking policies within Broxbourne should take account of the potential for cross boundary journeys.

They should be designed to encourage sustainable travel options and to minimise additional car trips for travel across the London boundary. This will be particularly relevant for growth areas or large development sites on cross boundary routes.

Noted. Amend car parking by adding in new paragraphs to include references to parking restraint and the relationship with rail. No amendment necessary to Policy TM4 although minor clarifications will be made to increase the certainty of the policies application.

Add in new paragraphs after para 30.14 as follows:

As car ownership and housing occupancy rates increase, so does the demand for parking. As demand for parking increases, the land take required to service this demand can reduce quality of life. Providing more car parking spaces per house increases the cost of each house because of the additional land required. Car parking uses land that could be put to better use. More cars create additional congestion, as roads have limited capacity and new road building and improvements are now largely unaffordable. Parking restraint is one of the few tools available to local authorities to manage the effect of the car on our environment. To be successful, parking restraint must be delivered alongside effective alternative means of movement, so that car ownership is an option and not a necessity.

https://www.gov.uk/government/publications/guidance-on-transport-assessment

https://www.gov.uk/government/publications/guidance-on-transport-assessment


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30.12 Para 30.14 & Policy TM4: Parking Standards

PO1896 Transport for London

Add in additional positive references to rail and Crossrail 2 in the following areas to strengthen and clarify Council support for this project:

car parking

paragraph 30.14

TM4 – Parking Standards

Noted. Addressed above under 30.11 See amendment to Policy TM4 above (30.11).

30.13 Policy TM4: Parking Standards

PO1408 Hertfordshire County Council Property (Development Services) Car parking standards for educational establishments should be applied flexibly to enable local conditions to be taken into consideration

Noted. The standards are intended to be applied as guidelines only, having regard to the local context. No amendment necessary.


Policy/ Para. no.


Policy TM4: Parking Standards

PO1896 Transport for London Add in additional positive references to rail and Crossrail 2 in the following areas to strengthen and clarify Council

Appendix D


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support for this project: - Appendix D

Policy TM1 & Glossary

N/A For clarification include a definition of rights of way to include all footpaths, bridleways and byways.

Right of Way – for the interpretation of the policies within this plan Right of Way includes all rights of way, footpaths, bridleways, byways and unformed roads.

Appendix D

Amend to include reference to PTAL levels C3 Residential The Council will consider up to 60% of the maximum 1.5 per dwelling parking guidance in town centres and 75% within the accessibility corridor for sites with PTAL levels of 3 or above.




Para 30.1 Sentence too long and meaning is lost. Needs more detail to paint picture as to why alternative forms of movement are so important to Broxbourne.

Amend para 30.1 as follows: ….. Using trains, buses, cycling and walking to access employment, education, services and facilities reduces the number of vehicles on the road. It also easesing congestion levels and improvesing air quality, while also minimising greenhouse gas emissions such as carbon dioxide. To help us move towards more sustainable ways of moving around, the Council has prepared a Transport Strategy which sets out plans for improvements to public transport and road infrastructure. Walking and cycling also provides are physical activityies which are enjoyable, improveing health and wellbeing and quality of life. In Broxbourne 22% of children in year 6 are officially classified as obese, the highest in Hertfordshire. The Council is keen to address rising levels of obesity and promote healthy lifestyles.

Para 30.2 Add in more detail on rights of way into paragraph. Spilt paragraph in two.

Add new text to 30.2 and new paragraph after 30.2. Split and reorder sentences in original paragraph 30.2 as follows: Hertfordshire County Council (HCC) is the local authority responsible for highway infrastructure, both

vehicular and active i.e. cycling and walking. The county council also administers Public Rights of Way. Public Rights of Way (PRoW) are protected by law in exactly the same manner as any other


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highway such as a High Street or dual carriageway. They are recorded in a document called the Definitive Map, available online.

The County Council has preparesd several documents to help guide transport and new development proposals. The overarching policy document is the Local Transport Plan which sets out transport objectives, and guides funding priorities, for the County. The Local Transport Plan (LTP) is supported by a number of daughter documents including the Rail Strategy, Road Safety Strategy, Bus Strategy, the Active Travel Strategy and Rights of Way Improvement Plan, which aim to help implement the LTP objectives. Highways England are responsible for the Strategic Road Network (SRN), i.e. the M25 including Junction 25.

Policy TM1 Sustainable Transport I.

Reword to exclude minor extensions and minor changes of use. Tighten up wording.

Amend clause I. as follows: The Council will expect all new major development proposals to show how have explored ways to reduce the use of the car use and promote provide alternative ways to travel have been considered. Detailed evidence of this process will be included in the Transport Assessment and supporting Travel Plan accompanying a planning application.

Policy TM1 Sustainable Transport II.

Reorder sentences in the clause so as not to confuse with Policy TM2

Amend clause II. as follows: New development proposals must clearly demonstrate how pedestrian movement and connections have been prioritised and provided for. Development must not impact upon existing footpaths and public rights of way and proposals should, wherever possible, extend, enhance or provide for new pathways, rights of ways and equestrian routes. New development proposals must clearly demonstrate how pedestrian movement and connections have been prioritised and provided for.

Policy TM1 V. Cycling provision

Tighten up wording to clarify requirements and reduce uncertainty.

Amend V. as follows: New development proposals.

New Development proposals must provide for cycle facilities through the use of accessible and safe routes to and around the site, the provision of cycle storage and cycle parking areas. Appropriate provision should be made for showering facilities. The number of cycle spaces required in new developments can be found in Appendix D.

Policy TM1 VI. Transport and New Developments

Add in more detail on exactly what sort of transport infrastructure is preferred for greater certainty. Remove revenue contributions

Amend clause VI as follows: All new major development should, wherever possible, contribute to improved public transport opportunities accessibility and interchange facilities, including the direct provision of bus infrastructure and allocation of space for infrastructure within a development, and revenue contributions for enhanced


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clause as that is always the default option and so does not need stating specifically.

services.

Para 30.3 Amend for clarification Amend para as follows: To enable people to choose more sustainable modes of transport they easy access must be provided to a be safe, secure, direct, frequent, reliable and affordable alternative to car travel. The Council will ensure that the options for sustainable modes of transport continue to increase. To facilitate this, the Council will bring forward major infrastructure improvements, working in partnership with rail and bus operators and Hertfordshire the County Council.

Policy TM2.III Transport and New Developments

Improve certainty by providing greater clarity about which applications would be caught by the policy.

IIIV. Travel Plans must be submitted where the development involves large scale major residential development; employment and other commercial and leisure developments; and non-residential institutions such as including schools and colleges. The Travel Plan will need to demonstrate that mitigation of the transport impacts of the proposal is achievable, and include provisions for monitoring to address the effects of any unforeseen consequences.

Policy TM2 I. Transport and New Developments

Even though the list is not meant to be comprehensive, cyclists, skateboarders and scooters should also be included to foster greater awareness of the range of other users. Amend policy to remove examples and add list of users into the Information for Applicants section.

Amend Policy TM2 I. as follows: I. Development will not be permitted where there would be a severe residual detrimental impact on the transport network. II. Development proposals must ensure that the safety of all movement corridor users including pedestrians, equestrians and powered two-wheelers is of paramount importance is not compromised.

And consequential amendments to the numbering of the rest of the policy.

Policy TM2 Transport and New Developments III.

Monitoring of the effectiveness of travels plans is an essential component of addressing any unforeseen or unintended consequences.

Amend Policy TM2:III. As follows: Travel Plans must be submitted where the development involves large scale major residential development; employment and other commercial and leisure developments; and non-residential institutions such as including schools and colleges. The Travel Plan will need to demonstrate that mitigation of the transport impacts of the proposal is achievable, and include provisions for monitoring to address the effects of any unforeseen consequences.

Policy TM2 Transport and New

Delete reference to Home Zones as outdated concept, superseded by

Amend Policy TM2:IV. as follows: The Council will encourage the use of Home Zones for new residential developments where appropriate


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Developments IV. Manual for Streets. design and traffic calming measures are implemented to meet the needs of various movement corridors users speed limits.

Policy TM2 Transport and New Developments V.

Delete as unneccessary. V. Development that would result in significant traffic increase on rural roads will be resisted unless access roads are adequate in width, alignment and construction.

Para 30.6 Consistency in wording Amend paragraph 36 as follows: Transport Assessment (TA) is a process that analyses the transport effects arising from a proposed development. It should identify measures to deal with anticipated transport impacts of a scheme, and how the scheme will improve accessibility and safety for all modes of travel movement, particularly alternatives to the car such as walking, cycling and public transport.

Policy TM3 Add in ALL to make clear that policy applies to all new development ….

I. All New proposals for development proposals must provide for adequate, safe and convenient servicing arrangements, access points and drop-off areas.

Policy TM3 Add in ‘goods’ to vehicles listed IV. Adequate provision must be made for the movement and turning of goods, emergency vehicles and refuse vehicles.

Policy TM3 Increase the requirement for electric vehicle charging points in line with the significant increase in sales of such vehicles and demand for charging facilities.

30.12 The NPPF states that there is an overall need to reduce the use of high-emission vehicles. Therefore Sales of Electric Vehicles (EV), including plug-in hybrids, have risen substantially in the last 4 years. The Council will ensure that aims to facilitate a substantial increase in the amount of consideration is given to making provision for electric vehicle charging infrastructure in the borough. It is recognised that making Increasing provision for electric vehicle charging points will potentially reduce vehicle emissions, and improving air quality and reducing dependency on fossil fuels. Policy TM3: Access and Servicing

I. All New proposals for development proposals must provide for adequate, safe and convenient servicing arrangements, access points and drop-off areas. II. The Council will expect that 20% of all on-site parking spaces within all new housing plots have EV charging points. For communal, off-site parking areas, the Council will require the provision of at least one electric charging point for every 5 spaces. within every new communal car park serving a residential development of over 8 homes, and for. III. 20% of all parking spaces for new retail and commercial development over 1000m2 must be fitted with EV charging points. III. IV. Extensions and alterations to existing retail and commercial developments over 1000m2 involving any increase in floor space, parking or servicing areas, will be required to fit an electric


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charging points to 20% of the additional spaces required. communal car park where none currently exists. V. All cabling and charging points for commercial parking spaces must be capable of supplying a rapid charging service. VI. Adequate provision must be made for the movement and turning of goods, emergency vehicles and refuse vehicles.

Information for Applicants 30. 30.13 In developments of below 8 new homes, electric charging points are encouraged and may be

required as mitigation for development in certain locations. All Nnew non-residential/commercial developments less than 1000 square metres will also be encouraged to make provision for electrical charging points.

A management, maintenance and repair plan will be required to be submitted as part of any

application requiring EV charging points.

Paragraph 30.4 & Appendix D

Move from using accessibility corridors to measurable accessibility levels including the Public Transport Accessibility Levels (PTAL). PTALs are widely used, including throughout London, although will be applied in Broxbourne with greater emphasis on proximity of a site to walking and cycling routes.

Amend Policy TM1.VI as follows: VI. All new major development should, wherever possible, contribute to improved public transport

opportunities accessibility and interchange facilities, including the direct provision of bus infrastructure and allocation of space for infrastructure within a development, and revenue contributions for enhanced services.

Add in the following paragraph after 30.4 Information for Applicants Accessibility Levels

The Council will use a site’s public transport accessibility levels as a starting point, but will also consider the proximity of cycle and walking routes and future improvements when evaluating development proposals. Broxbourne Council is moving towards using Public Transport Accessibility Levels (PTAL) as our measure of the accessibility of a site to public transport. Applicants should note that areas with medium to high PTAL ratings have reduced parking requirements (see also Policy TM4 Parking Standards and Appendix D Car and Cycle Parking Standards).


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Amend Policy TM4: Parking Standards as follows:

Policy TM4: Parking Standards Guidelines Planning applications will be determined with regard to the Car Parking Standards in Appendix D. In interpreting these standards as guidelines only, tThe Council will seek a sensible balance of car and cycle parking spaces based on: - the nature of the proposal, - site context and wider surrounding area, and - the provision, and accessibility of shops, services and sustainable movement infrastructure, with the overall aim of reducing private car use.

Car parking Standards, paragraph 30.14 and Policy TM4:Parking Standards

Move to after Policy TM2: Transport and New Developments and supporting information so follows on directly from information on PTALS

Policy TM4 TM3:Parking Standards

Para 30.14 Amend paragraph be deleting sentence on maximum parking standards as these are no longer used.

Amend para 30.14 as follows: Hertfordshire has the sixth highest rate of car ownership in the UK and at the last census 87% of households in Broxbourne had access to at least one car or / van. Maximum parking standards do not meet current patterns of car ownership, and can affect the economic viability of commercial activities. A lack of sufficient parking can create significant on-street parking problems in and around key destinations such as strategic employment sites, town centres, railway stations and shopping centres.

Local Plan 2005 policies

Policies not taken forward: T1: Local Transport Plan – dated, and doesn’t refer to Broxbourne! T4: Green Travel Plans – concept dated, intent covered in other policies T6: Rural Roads T7: Home Zones – dated concept – intent included in Manual for Streets and design policies