ensure you respond, in your own words, adding your own personal experience and thoughts
include as many different reasons as you can
use the list below, and on the ALFA website, for guidance
Reasons to object Please note additional objections added 14/5/24 1. Green Belt land is protected for good reason. It captures carbon to slow down climate change, ensures clean air, absorbs significant amounts of rainfall to prevent local flooding, avoids coalescence of settlements, retains an environment for wildlife and provides green spaces for our mental and physical health. (See 25, 26 and 27 below)
2. Green Belt land is further protected by the National Planning Policy Framework (NPPF) guidelines published in December 2023. This Care Community is an inappropriate development on Green Belt and there are no Very Special Circumstances for building non affordable homes, particularly the building housing a swimming pool, studio, gym, 3 treatment rooms, dining room, activity room, salon etc.
3. This development is sited adjacent to two other Green Belt sites (field to be for expansion of cemetery and Elle Dani Farm to be used for 8 luxury homes). This would cause a coalescence of settlements between Elstree and Elstree Village.“The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.” NPPF
4. There is much wildlife throughout the year on the fields. Muntjac deer are often seen and roam into adjacent gardens. The Site Assessment document states “Based on the habitat types present, it is considered that the site has potential to support breeding birds, badgers and bats.” Not only is there an abundance of wildlife but there is potential for more – but not if the land is heavily developed, regardless of the dubious biodiversity percentages.
5. This development could set a precedent for further developments on these fields.
6. There are existing issues with flooding with houses in Lodge Avenue, Bishops Avenue and The Rise all having experienced flooding due to underground streams and the high-water table. If you have experienced flooding, please include it in your response. The fields themselves may not suffer from flooding but building on the land. Concreting over this piece of Green Belt land would compromise the ‘natural soak away sponge’ effect, which could be detrimental to surrounding roads when heavy rain is experienced. Given climate change, rainfall in the UK is likely to increase. The last paragraph of the Flood Report document states “The EA confirm the site is located in an area at High risk of surface water flooding.“
7. On the site are public Rights of Way that enjoyed by walkers throughout the year. The view of the countryside from Allum Lane and surrounding roads will change the character of the entrance to Borehamwood if the development goes ahead. (see 16 below for further reasons to object re footpaths).
8. Landscape and visual impact. The loss of this important Green Belt will have a negative impact on the general landscape
9. The proposed site for the relocation of Schopwick Surgery is not in Elstree village. Moving the surgery away from the village will make it difficult for many to access their doctors without the use of a vehicle. Allum Lane is a very steep hill and not easy to walk or cycle. Schopwick has a partner surgery in Bushey, so a location on the Bushey side of Elstree Village is advised to avoid additional traffic. Site HEL1011 Edgwarebury House would be a more suitable location for these reasons. (see 21, 22 and 23 below)
10. The developers own consultation showed that 40% of people did not support this location for a new care community whereas only 36% did support it.
11. No more elderly residential facilities are needed in Elstree. Elstree has two care homes, Hill House Care Home on Elstree Hill South and Elstree View Care Home, Edgwarebury Lane, off Barnet Lane. The BUPA care home on Barnet Lane has closed in recent years due to lack of occupancy. The Cecil’s Horse Sanctuary site in Elstree Village is in the Hertsmere Local Plan as a site for 141 Elderly Residence flats.
12. Increased traffic density in Allum Lane. Traffic is already gridlocked at peak times on Allum Lane. More traffic visiting a Doctors Surgery and staff, service providers, residents, and visitors to the Care Community, will bring more traffic to this narrow, overburdened road. This could add a significant amount of time to commuters on their daily work or school run. Cycling is not a safe option as the roads are very narrow and in poor order. Buses are infrequent.
13. Access to the planned development will require a proposed moving of the traffic island slightly westwards. There is no mention of the need to lower the pavement/road at the crossing as both sides are on a steep ridge. Even to cross in two halves south to north you would need to check for traffic appearing over the top of Allum Lane hill and also back behind you to the west, which is not safe especially for the elderly / infirm.
14. Access via The Rise will potentially lead to this road being used for a few years by construction traffic and, on a permanent basis for emergency vehicles. If such vehicles require access, the road will be accessible to other traffic causing it to become a major cut through, affecting traffic on The Rise and surrounding roads.
15. The proposal is to site the development next to the Recycling Centre. This is an important and well used resource> it is not good practice to have a housing development and surgery next to a Recycling Centre due to noise, smells etc. A housing development could result in the closing of the Recycling Centre.
Additional reasons to object added 14/05/24 16. Footpaths (in addition to 7 above) The Rights of Way department at Herts County Council have OBJECTED to these plans. The proposed development does not mention that Elstree and Borehamwood Public Footpath 7 crosses the site. It also seeks to permanently obstruct this public right of way in a number of locations.
17. Impact of proposed development on Heritage Sites Within a 1km search area around the site there are twenty-four listed buildings, the Elstree Conservation Area, Aldenham House Registered Park and Garden and twenty-four non-designated built heritage assets, identified as locally listed buildings. After considering the assets and their settings, the Heritage Assessment determined that the proposed development has the potential to affect, through changes in their settings:
the Elstree Conservation Area,
Nicoll Farmhouse (Grade II listed),
the Barn and Byre at Nicoll Farm (Grade II),
the Church of St Nicholas (Grade II)
18. Consultation Period The planning application was published less than a month after the Hertsmere Local Plan (HLP) was first made public. This means it is easily lost to many, as they are concentrating on the HLP and don’t expect such a large proposal to be made at the same time.
The consultation period is under 30 days. There are 160+ documents attached to this proposal, many of which were 40+ pages long, making it very difficult for members of the community to analyse and understand in such a short period of time.
19. Prematurity The Hertsmere Local Plan is at Regulation 18 stage. This site is not included, although others in Elstree are. To allow plans including such a sizable amount of Green Belt to be considered, in advance of the Plan going through its remaining formal stages, means the strategic planning for Elstree regarding Green Belt will not be possible or satisfactorily carried out.
20. Location of Schopwick Surgery (see 9 above) The Surgery should be located within walking distance from Elstree village, the majority of whose residents live on the composers Estate, and the same distance or closer to Bushey, as the two Surgeries have a shared service.
We have not been provided with alternative sites for the Surgery in the planning documentation, only the alternative sites considered for the Care Community. As yet the NHS, though their Freedom of Information Service, have not replied to our request for the alternative sites considered
21. Schopwick Surgery Parking Requirements (see 9 above) The requirement for 50 parking spaces indicates a huge expansion of the surgery as at present they only have 10 spaces. It is understood that at present parking can be difficult, but increasing to 50 spaces is a huge jump. This indicates a much greater need to travel to the surgery, if relocated, so more vehicles, more congestion, more pollution, and less walking and public transport. This will be in part due to increased services, but if so many spaces are required it indicates the location is not central to those requiring its services.
22. Location of new Medical Health Facilities (see 9 above) If Schopwick Surgery are planning to provide medical facilities such as x-ray equipment, to facilitate patients in Elstree and Borehamwood, a relocation to the centre of Borehamwood town where the majority of people live in walking distance, and where bus routes start / finish, would be preferable and in line with NPPF policy. A narrow, hilly, already heavily congested, road between Elstree and Elstree Village, is a not a suitable location for new Heath Services. A Health Centre Hub in Borehamwood town centre would allow Schopwick to stay in its current location at Elstree Village, with additional services being offered in the centre of Borehamwood.
If a site is required then the local authority be working to find a location in keeping with the NPPF. Borehamwood should be critically reviewed to find a vacant site or building or group of unused and underused property, which could then be reused or redeveloped.
As there is no case presented to justify the use of this Green Belt land, it seems that it is just convenient for the surgery to pursue a Green Belt site as they know it will be cheaper and easier for them to develop. This reason of lower cost and greater convenience to them is no reason to override Green Belt policy.
23. Alternative Sites for the Care Community The developers search for alternative sites has rejected many sites for commercial reasons. The Hertsmere Local Plan (HLP), on the other hand, includes a proposed allocation at Elstree (HEL 212) for 140 elderly persons’ units. The Council, through its Sustainability Appraisal work has identified this to be the best option for such development. The HLP was drafted to be in the public interest, and as this site was rejected by HBC, respect should be given to that, rather than follow than a commercially driven non - compliant planning application.
24. No Affordable Housing The HLP proposes to address the general housing needs of Hertsmere, with policy requirements for affordable housing. There is a total absence of affordable housing in this proposal, demonstrating the flawed nature of the entire proposition. It is not acceptable, then, for this non-compliant housing and employment development to be used to as a way of subsidising an NHS provision, piggybacking it as a means to gaining Very Special Circumstances.
Hertsmere Strategic Policy 1 Point viii states that ‘All development across the Borough should seek the maximum level of Affordable Housing on site."
25. Green Belt (in addition to 1 above) The site lies within designated Green Belt. As such, the National Planning Policy Framework (NPPF) bestows on it a very high level of protection from inappropriate development. The proposal is a major planning application and constitutes major inappropriate development.
The NPPF goes further to explain how Green Belt land can and cannot be used. This planning proposal contravenes all of these policies. These can be seen as follows:
“ The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence.” NPPF paragraph 142
“ Green Belt serves five purposes: a) to check the unrestricted sprawl of large built-up areas; b) to prevent neighbouring towns merging into one another; c) to assist in safeguarding the countryside from encroachment; d) to preserve the setting and special character of historic towns; and e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.” NPPF paragraph 143
Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. NPPF paragraph 152
When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm resulting from the proposal, is clearly outweighed by other considerations.” NPPF paragraph 153
Lastly, Hertsmere Strategic Policy 1 Point vii states that ‘All development across the Borough should avoid inappropriate development in the Green Belt."
26. Reduction in Green Belt promised, but increase in Elstree (in addition to 1 above) Hertsmere Borough Council have reduced the amount of Green Belt included in the latest local plan, due to the previous plan having to be shelved following public objections to the use of Green Belt to build. A particular concern was urban sprawl and coalescence of settlements. In Elstree, however, the Plan proposes to increase the overall housing provision compared to the last Draft Local Plan. This development, on top of those in the new HLP and others already in for development could cause such coalescnce that Elstree Village would loose it's Village status. The Village is protected and should remain so.
Within the HLP, of the 290 additional homes proposed for Elstree, 140 are specialist elderly units on site HEL 121, land south of Watford Road. The Council, which has been through internal processes, including sustainability appraisal, and external consultation, has decided that HEL121 is the appropriate site for providing housing for the elderly population, not Allum Lane.
27. Coalescence / merging of Settlements (in addition to 1 above) The plans state that the National Planning Policy Framework (NPPF) purpose of preventing neighbouring towns from merging does not apply because Elstree Village is a village, not a town. This part of Elstree is described in the adopted Core Strategy as ‘a distinctive village in its own right’. Siting a large development in the Green Belt around Elstree goes against the strategic element of the statutory development plan. Whilst Borehamwood itself sits at the top of the Core Strategy hierarchy, that does not include land within the Green Belt, where the development plan follows national policy. As stated previously, we do not want a development that risks Elstree Village loosing its Village status.
28. Proposal is against Hertsmere Strategic Policy 1 Strategic Policy 1 states that ‘All development across the Borough should: iv) be of high quality design and appropriate in scale, appearance and function to the local context and settlement hierarchy, taking advantage of opportunity to improve the character and quality of an area. v) avoid prejudicing, either individually or cumulatively, characteristics and features of the natural and built environment. vi) minimise and mitigate the impact on local infrastructure and services. This development does not fulfill these requirements for achieving sustainable development in Hertsmere. Don’t forget the deadline for responding is 23rd May 2024
If we all respond we can stop this development!
How to object?
Allum Lane Fields is Green Belt land. It must be preserved!
We do not want or need a high end Care Community in Elstree . It is not a valid use of Green Belt land.
Join the fight to save our local green spaces: 1. Find out more about the plans and reasons to object on this website 2. Put in your own personal comments / objections, including as many reasons as possible (as each reason has to be considered individually) 3. Ensure everyone over 18 in your household responds separately 4. Do it within the deadline of 23rdMay 2024 5. Spread the word
How to comment / object: 1. Logging onto the website using this link
2. Emailing [email protected] quoting the application number 24/0442/FUL stating you OBJECT
3. Posting your comments to The Planning and Economic Development Department, Hertsmere Borough Council, Civic Offices, Elstree Way, Borehamwood, Herts WD6 1WA quoting the application number 24/0442/FUL stating you OBJECT
What objections are valid and invalid? Hertsmere Borough Council have provided the following valid and invalid objections to planning:
Valid objections to planning: •Loss of light or overshadowing •Overlooking/loss of privacy •Visual amenity (but not loss of private view) •Adequacy of parking/loading/turning •Highway safety •Traffic generation •Noise and disturbance resulting from use •Hazardous materials •Smells •Loss of trees •Effect on listed building and conservation area •Layout and density of building •Design, appearance and materials •Landscaping •Road access •Local, strategic, regional and national planning policies •Government circulars, orders and statutory instruments •Disabled persons' access •Compensation and awards of costs against the Council at public enquiries •Proposals in the Development Plan •Previous planning decisions (including appeal decisions) •Nature conservation •Archaeology Air pollution - Case : Gladman v SCLG
Invalid objections to planning •The perceived loss of property value •Private disputes between neighbours •The loss of a view •The impact of construction work or competition between firms •Restrictive covenants •Ownerships disputes over rights of way •Fence lines etc •Personal morals or views about the applicant.
Below this point is information regarding the old development plans and Draft Local Plan first published in 2018 This is for information only
Action Plan
The Local Plan will be published in early September 2021.
If site BE1 is included for development we need a very strong response.
If you are not already a member JOIN ALFA NOW (no charge or commitment).
Ask all your friends, neighbours and family to join.
It is important we increase our membership so we can advise on representation against this development should it be included in the plan.
Please read up about these sites and talk to your neighbours about them and about ALFA.
If you are not happy about these plans, join ALFA by emailing [email protected] and share your opinions and information with like minded local residents and we, in turn, will share the information we gather. This has to be a combined effort. STRENGTH IN NUMBERS!
We don't recommend contacting the Planning Department and Councillors until the new Local Plan is published so that - if needed - our voice is officially heard, loud and clear, at that time. However, should additional information come to light, such as the Schopwick Surgery consultation, we will recommend the response by members.
We believe that Elstree and Borehamwood has experienced more new housing developments in the last 5 years than any other area of Hertsmere and that our local area is now saturated with housing causing heavy congestion on local roads, lack of infrastructure to support the increased population, a risk of coalescence of settlements and a drop in air quality.
Do you want to see our local Green Belt lost forever? Do you want to see this precious land used to build a further 1500+ houses? Do you want to see: ⁃ A potential 6000+ additional residents and cars? ⁃ A loss of our valuable green spaces? ⁃ A loss of local wildlife and ecosystems? ⁃ A negative effect on local air quality? ⁃ A high risk of flooding? ⁃ A further increase to already congested roads and rail travel? ⁃ A further stretch on health facilities? ⁃ A general reduction in the wellbeing of all those living in the local area?
No? Then join us so we can work together to protect the irretrievable green spaces within our community so we and other local residents can enjoy their benefits for many years to come and avoid the over-development of our town.
What objections are valid and invalid? Hertsmere Borough Council have provided the following valid and invalid objections to planning:
Valid objections to planning: •Loss of light or overshadowing •Overlooking/loss of privacy •Visual amenity (but not loss of private view) •Adequacy of parking/loading/turning •Highway safety •Traffic generation •Noise and disturbance resulting from use •Hazardous materials •Smells •Loss of trees •Effect on listed building and conservation area •Layout and density of building •Design, appearance and materials •Landscaping •Road access •Local, strategic, regional and national planning policies •Government circulars, orders and statutory instruments •Disabled persons' access •Compensation and awards of costs against the Council at public enquiries •Proposals in the Development Plan •Previous planning decisions (including appeal decisions) •Nature conservation •Archaeology Air pollution - Case : Gladman v SCLG
Invalid objections to planning •The perceived loss of property value •Private disputes between neighbours •The loss of a view •The impact of construction work or competition between firms •Restrictive covenants •Ownerships disputes over rights of way •Fence lines etc •Personal morals or views about the applicant.