Additional Public Consultation February/March 2016

Site Allocations and Development Management Policies Plan for Submission

Proposed amendments to Green Space policies: Additional public consultation February/March 2016

Report of Consultation

April 2016 [Intentionally blank page]

Preface

Hertsmere Borough Council’s Site Allocations and Development Management Policies (SADM) Plan was submitted to the Secretary of State in November 2015 and is currently being examined by independent Inspector Mr John Mattocks.

At the request of the Inspector, the council has put forward suggested changes to the policies SADM35 Major Green Space and SADM36 Local Green Space and the sites to which they apply. These changes have been subject to public consultation during the examination period.

This report of consultation sets out the way in which the consultation was undertaken, the number of representations received, a summary of the main issues raised in those representations and the council’s brief response to those issues. The report and the representations received were submitted to the Inspector in advance of the examination hearings scheduled for 12-14 April 2016.

Contents

1. Introduction ...... 1 2. Notification and Publicity ...... 3 3. Summary of Representations and Responses ...... 4 4. Conclusion ...... 8 Appendix 1: Inspector’s note on Local Green Space 29/12/2015 ...... 9 Appendix 2: Extract from Council’s Hearing Statement (Document HBC/1) ...... 11 Appendix 3: Note from Inspector 12/02/2016 ...... 26 Appendix 4: Text of notification email/letter ...... 29 Appendix 5: List of Bodies and Persons notified of consultation on proposed changes to SADM35 and SADM36 of the submitted Plan...... 31 Appendix 6: Press release issued 24/02/2016 ...... 37 Appendix 7: Press release as on Council website ...... 38 Appendix 8: e-alert...... 39 Appendix 9: Summary of representations ...... 40 Appendix 10: Local Green Space Revised Site Assessment Matrix ...... 50

iii

1. Introduction

1.1 At its full Council meeting on 8 July 2015, Hertsmere Borough Council resolved that the Submission Site Allocations and Development Management (SADM) Policies Plan “be approved for publication and submission to the Secretary of State for Communities and Local Government for public examination following a six week period in which representations may be made on the Plan.“ It was also approved for interim use in the determination of all planning applications from the date of its publication, in accordance with paragraph 216 of the National Planning Policy Framework.

1.2 The Submission Site Allocations and Development Management Policies Plan (‘the Plan’) was published on 31 July 2015. The period for representations ran from Monday 3 August to Monday 14 September 2015.

1.3 The Plan, together with representations received and all other documents required under the Town and Country Planning (Local Planning) (England) Regulations 2012 was submitted to the Secretary of State on 16 November 2015.

1.4 The Inspector wrote to the Council on 29 December 2015 raising a number of concerns in respect of policies SADM 35 Major Green Space and SADM36 Local Green Space in the submitted Plan. (Appendix 1). The note set out that the Inspector “considers it necessary for all of the potential Local Green Space (LGS) sites to be re-evaluated against the National Planning Policy Framework (NPPF) criteria and further evidence brought forward to show that the sites are, indeed, ‘demonstrably special’ and ‘of particular local significance’ for the local community.”

1.5 The Inspector also invited the Council to

• put forward a revised wording for Policy SADM35 Major Green Space in order to bring it more in line with paragraph 74 of the NPPF, and

• amend the wording of Policy SADM36 Local Green Space in order to refer to ‘very special’, rather than ‘exceptional’ circumstances as the test to be applied to proposals for development on sites to which the policy applies.

1.6 The Council has therefore

• undertaken a review of the sites identified as Local Green Spaces in the submitted Plan and identified nine sites for which it proposes to retain the Local Green Space designation.

• proposed a new Policy SADM35 Open Space, Sports and Leisure Facilities to replace the submitted Policy SADM35 Major Green Space. This new policy would apply to:

- sites that were originally proposed to be designated as Major Green Spaces in the submitted Plan (now to be called ‘Open Spaces’ rather than ‘Major Green Spaces’), and

- sites that were originally proposed to be designated as Local Green Spaces in the submitted Plan but following the review of sites are now proposed to be re-classified as Open Spaces.

• proposed an amendment to Policy SADM36 Local Green Space as requested by the Inspector. This policy would apply to the nine sites retaining the Local Green Space designation.

• proposed amendments to the supporting text to these policies as a result of the above changes .

1.7 Further explanation and evidence in support of these proposed changes is set out in the Council’s Hearing Statement (Document HBC/1) submitted to the Inspector (Appendix 2).

1.8 The Inspector’s response was set out in a further note in which he confirmed his request that the Council undertake public consultation on the proposed changes prior to the public hearings scheduled to start on 12 April 2016. (Appendix 3) The hearings had been scheduled to start in February 2016 but were postponed by the Inspector. This provided an opportunity to carry out a period of public consultation on potential changes to the SADM plan arising from the examination. It should be emphasised that there would still be a requirement to statutorily consult on any main modifications following the hearings.

1.9 The proposed changes were made available for public comment for a four week period, as agreed with the Inspector, between Monday 22 February 2016 and Monday 21 March 2016 (5pm). Minor amendments to some of the proposed wording and names of the sites which had been included in document HBC/1 submitted to the Inspector were incorporated into the consultation documentation. Four sites which had been inadvertently missed off the list of sites included in HBC/1 were also added to the consultation documentation.

2. Notification and Publicity

2.1. Details of the proposed changes were made available in accordance with Regulation 35 i.e. on the Council’s website and in hard copy form at 10 other locations across Hertsmere. These other locations were:

• Main Council offices in Borehamwood and district offices in Potters Bar and Bushey • Parish Council offices at Shenley and Radlett (Aldenham Parish Council) • Elstree and Borehamwood Town Council offices • Borehamwood, Potters Bar, Radlett and Bushey libraries

2.2. Letters/emails containing notification that the Council had proposed changes to the submitted SADM policies SADM35 and SADM36, that details of the changes and how to make representations were available for inspection, and the places and times at which this information could be inspected were sent out on 19 and 22 February 2016. A copy of the notification is attached at Appendix 4.

2.3. Those notified included: a) statutory consultees as set out in Regulation 2(1) of the Regulations; b) general consultees including interest groups, residents’ and other organisations; c) Hertsmere Borough Council departments d) all those who had made representations on the published version of the Plan during the August/September 2015 period for representations, unless they had specifically requested no further correspondence concerning the Plan.

See Appendix 5 for further details of those notified.

2.4. A Press release was also issued at the end of February (copy at Appendix 6). This was also displayed on the Council’s website (Appendix 7). A copy of the e-alert sent to 802 people registered to receive Planning news via email is at Appendix 8.

3. Summary of Representations and Responses

Representations received

3.1. Representations were received from the following:

Aldenham Parish Council Bushey Museum Property Trust Bushey Heath Residents Association CALA Management Ltd Mr R Dunkley (resident of Bushey) Mrs Whitaker (resident of Bushey) Mr Whitaker (resident of Bushey) Mrs J McNulty (resident of Bushey) Mr P McNulty (resident of Bushey) Mrs J Steer (resident of Bushey) Sir A Steer (resident of Bushey) Mr W Whitaker (resident of Bushey)

3.2. One representation, from Aldenham Parish Council, was a general comment in respect of the proposed removal of Local Green Space designation from sites in Radlett.

3.3. The remaining 11 submissions covered several issues, focussed mainly on the revised scoring matrix and The Paddock site in Bushey Heath.

Overview of Issues raised

3.4. The table at Appendix 9 summarises the representations and the Council’s comments on these.

3.5. All the representations received have been in relation to Policy SADM36 Local Green Space, and all but one have related either directly or indirectly to The Paddock site.

3.6. The main support in respect of the proposed revised SADM36 can be summarised as follows:

Scoring Matrix - General

• Support raising of threshold for LGS designation to 30

The Paddock

• Fully support retention of LGS designation for the Paddock; it meets NPPF para 74 criteria and is demonstrably special to local community. • Development on the site cannot be compliant with planning policies; development has been twice refused and local residents have petitioned against these applications.

3.7. The main objections raised in respect of the proposed revised SADM36 can be summarised as follows:

Scoring Matrix - General

• ‘Amenity benefits and sense of place’ and ‘cultural and heritage benefits’ should not have increased weighting to the exclusion of others – ecological benefits weighting is not increased and this has equal standing in NPPF. • ‘structural and landscape benefits’ which is not listed in the NPPF should not have more weight than ecological benefits which is. • Inconsistent arithmetic – page 2 and following, 2 x 5 = 8, and 1 x 5 = 4

Scoring Matrix – The Paddock

• Re-scoring of The Paddock does not meet NPPF criteria so is unsound:

o ‘Structural and landscape benefit’ is not an NPPF criterion, and site only makes a contribution to street scene, is not a fundamental element in the landscape. Should score be lower. o ‘Amenity benefits and sense of place’ – Paddock only makes partial contribution, local parks and gardens deficit is irrelevant (and the Paddock is inaccessible to public and there are other parks and open spaces locally), protecting site from development is contrary to NPPF. Should score lower. o ‘Cultural and heritage benefits’ – Paddock doesn’t score on any of NPPF factors for this criterion. Factors listed by Council are not relevant. Incorrect claim concerning history of site in relation to Bushey Heath and enclosure (see below). Should score lower.

• As score for Cultural and Heritage benefits should be reduced the site would no longer meet Council’s own requirement to score 2 in both 'amenity benefit and sense of place' and 'cultural and heritage benefits' so is deemed not to be demonstrably special and is thus disqualified from LGS designation.

• Reducing scores in any category would also bring the Paddock below the threshold of 30 for LGS designation.

• Council admit cut off point of 30 is arbitrary and that LGS status is justified ‘on balance’ – this is unsound

• The Paddock was not a new enclosure in 1806 – it must have been enclosed since 1500s. Neither was it common land, nor heathland. It was farmland in private ownership. Cannot therefore use this to justify high score for ‘cultural and heritage benefits.’

• It is Reveley Lodge, not the Paddock, that is important locally. Council has failed to demonstrate that it is of special local significance.

3.8. Other comments made in respect of the proposed revised SADM36 can be summarised as follows:

• Supporting designation of the Paddock as LGS (response to submission from Bushey Museum Property Trust): o Alternative funding to support Reveley Lodge should be investigated – selling the Paddock is not the only option. o Site was intended to be for the benefit of local people, is part of the original Bushey Heath, and bench in Caldecote Gardens does provide a tranquil view for people to enjoy (all contrary to arguments by objector to proposed designation).

• Objecting to designation of the Paddock as LGS (response to submission from Bushey Heath Residents Association): o No provenance for any paintings referenced in representations being linked to the Paddock o Local memories acknowledged, but no real interest in the field locally until development was mooted o No condition attached to the bequest of the estate that the Paddock was not to be disposed of.

3.9. In response, the Council considers that Paragraph 7.8 –to 7.14 of the Council’s Hearing Statement (Document HBC/1) provides detailed justifications as to why and how the Paddock site has been re-scored. As far the Council is concerned the re- scoring of the Paddock site is valid and justified.

3.10. Aldenham Parish council commented that sites in Radlett, which had previously been listed, should continue to be given appropriate local recognition, as local green spaces, in the proposed Neighbourhood Plan.

3.11. The Council acknowledge the arithmetical error it has inadvertently made in the previous assessment matrix. After correcting the arithmetic error, which was due to the way sites were totalled in the excel spreadsheet, three more sites (BW021, EV010 and RT025) have been identified as meeting the relevant criteria for LGS allocation as stated in section 7 of the Council’s Hearing Statement (Doc ref: HBC/1) and in the NPPF. It is proposed that these three sites, which each have a score of 30, should also be allocated as Local Green Space in addition to the 9 sites identified in the Council’s Hearing Statement and the LGS consultation document. A revised matrix is included in Appendix 10.

3.12. Appendix 9 provides a fuller summary of the representation from each representor and the Council’s response to each representation.

4. Conclusion

4.1. The Council has considered the comments made in response to the consultation. Apart from the correction of an arithmetical error and the resulting new proposed LGS allocations it does not wish to propose any further changes to Policies SADM35 and SADM36 as set out in the consultation documents, nor to other sites proposed to be covered by each policy.

Appendix 1: Inspector’s note on Local Green Space 29/12/2015

Appendix 2: Extract from Council’s Hearing Statement (Document HBC/1)

Appendix 3: Note from Inspector 12/02/2016

Appendix 4: Text of notification email/letter

Dear «Name»

Hertsmere Site Allocations and Development Management (SADM) Policies Plan

The Site Allocations and Development Management (SADM) Policies Plan sets out criteria which the Council will use to judge development proposals and planning applications in Hertsmere; it also defines sites and areas where specific planning criteria or constraints will apply. It was submitted to the Secretary of State in November 2015 for examination by an independent Planning Inspector and the Hearings were planned to begin on Tuesday 16 February 2016. I am writing to advise you of two matters concerning the Plan. Change of date for Hearings 1 (You do not need to do anything unless you are appearing at the Hearings or have a question about the change). As those participating in the Hearings will already be aware, the Inspector has unfortunately had to postpone the Hearings and the arrangements are now as follows:

Independent Inspector: Mr John Mattocks BSc DipTP MRTPI FRGS Hearings: commence at 9.30am on Tuesday 12 April 2016 at the Civic Offices, Borehamwood. Independent Programme Officer: Ms Helen Wilson

The revised programme for the Hearings will be available on the Programme Officer’s website http://www.hwa.uk.com/projects/hertsmere-site-allocations-and-development-management-policies- plan/ some time between 21 March 2016 and 1 April 2016. If you have any queries about the Examination or the Hearings please contact the Inspector via the Programme Officer Ms Helen Wilson. Her contact details are • email [email protected] • telephone 01527 65741 or 07879 443035.

SADM Policies for Green Spaces: proposed changes (You do not need to do anything unless you wish to make comments on revisions to the Green Spaces policies which were included in the submitted SADM Plan now being proposed). As a result of his consideration of the SADM Plan to date, the Inspector has requested the Council to re-consider policies SADM35 Major Green Space and SADM36 Local Green Space; this includes reviewing the sites to which the policies apply. The Council has now undertaken this review and submitted proposed changes to the Inspector. Postponement of the Hearings provides an opportunity for interested people and groups to submit comments on the proposed changes prior to the Hearings so that the Inspector can consider them. Details of the revised policies, sites to which they are proposed to apply, changes to the supporting text, how to submit comments and the response form to use, and answers to some Frequently Asked Questions (FAQs) are available on the Council’s website https://www.hertsmere.gov.uk/openspaceconsultation and at the Deposit points listed below.

If you wish to make any comments on the revised policies, text or sites to which they apply you should submit them, preferably on the response form available on the website and at the Deposit points, to [email protected]. Submissions sent by post should be addressed to:

Policy and Transport Team, Planning and Building Control, Hertsmere Borough Council, Civic Offices, Elstree Way, Borehamwood, WD6 1WA.

There is no need to repeat representations you made at Pre-Submission stage (August/September 2015). Representations must be received by 5pm on Monday 21 March 2016 ; late responses will not

29 be accepted. If you do not agree with any aspect of the proposed changes it is important that you say why you object, what you think should be changed and how that would make the policy sound. People requesting a relevant change to the Plan have a right, if they wish, to appear at the Hearings. If you wish to do so please indicate this in your response or contact the Programme Officer direct by the above deadline. NB written representations carry the same weight as those made orally at a Hearing. The Inspector has issued a detailed note explaining his position on the above two issues which is available on the Programme Officer’s Examination website http://www.hwa.uk.com/site/wp- content/uploads/2015/11/Hearings-postponement.pdf . Hard copies are available on request by contacting the Programme Officer direct.

Yours faithfully

Mark Silverman Policy and Transport Manager

DEPOSIT POINTS (please check opening times before visiting)

Civic Offices, Elstree Way, Borehamwood, Aldenham Parish Council, Radlett Centre, WD6 1WA 1 Aldenham Avenue, Radlett, WD7 8HL Monday – Thursday: 9:00 – 17:15 Monday - Friday: 10.00 - 14.30 Friday: 9.00: – 17:00 Elstree and Borehamwood Town Council Offices, Council Offices, Wyllyotts Centre, Wyllyotts Fairway Hall, Brook Close, Borehamwood, WD6 5BT Place, Darkes Lane, Potters Bar, EN6 2HN Monday – Thursday: 9.00 – 16.00 Thursday: 9.30 – 14.00 Friday: 9.00 – 16.00

Council Offices, The Bushey Centre, High Shenley Parish Council Offices, The Hub, London Street, Bushey, WD23 1TT Road, Shenley, Radlett, WD7 9BS Tuesday: 9.30 – 14.00 Monday – Thursday 8.30am - noon

Bushey Library, Sparrows Herne, Bushey, Borehamwood Library, 96 Shenley Road, WD23 1FA Borehamwood, WD6 1EB Monday & Wednesday: 13.00 - 18.00 Monday & Wednesday: 09.00 - 18.00 Tuesday & Friday: 10.00 - 18.00 Tuesday: 12.00 - 18.00 Thursday & Sunday: Closed Thursday: 12.00 - 19.00 Saturday: 10.00 - 17.00 Saturday: 09.00 - 16.00 Friday and Sunday: Closed Oakmere Library, High Street, Potters Bar, EN6 5BZ Radlett Library, 1 Aldenham Avenue, Radlett, Monday & Friday: 13.00 - 18.00 WD7 8HL Tuesday & Thursday: 10.00 - 18.00 Monday: 12.30 - 18.00 Wednesday & Sunday: Closed Tuesday, Thursday & Friday: 10.00 - 18.00 Saturday: 10.00 - 17.00 Saturday: 10.00 - 14.00 Wednesday & Sunday: Closed

Appendix 5: List of Bodies and Persons notified of consultation on proposed changes to SADM35 and SADM36 of the submitted Plan

a) Statutory consultees as set out in Regulation 2(1) of the Regulations

Affinity Water Air Traffic Control - Airport Safeguarding Airports Operators Association Aldenham Aviation LLP BAA Aerodrome Safeguarding British Gas BT Openreach Canals and Rivers Trust Civil Aviation Authority County Architectural Liaison, Hertfordshire Constabulary Defence Estates Defence Infrastructure Organisation (DIO) DEFRA DEFRA (National Wildlife Management Team) Department for Transport EDF Energy Networks (Gas & Elec) EE Elstree Airfield Energy UK Environment Agency EON Energy Forestry Commission Friends Families and Travellers Govia Thameslink Railway Greater London Authority Gypsy Association Homes and Communities Agency (HCA) Hertfordshire Building Preservation Trust Hertfordshire Constabulary Hertfordshire Community NHS Trust Herts Valleys CCG Highways England Historic England London Luton Airport Operations Ltd Mobile Operators Association National Grid National Trust Natural England Network Rail (Town Planning) NHS nPower Office of Rail Regulation Police and Crime Commissioner for Hertfordshire Royal Town Planning Institute Scottish Power (NOT REQUIRED - DON'T COVER HERTFORDSHIRE) Showmen's Guild of Great Britain Sport England

SSE Energy Thames Water The Coal Authority Three Transport for London Traveller Movement UK Competitive Telecommunications Association (UKCTA) UKPN Vodafone and O2

Neighbouring and other local authorities Broxbourne Borough Council Central Bedfordshire District Council Dacorum Borough Council East Hertfordshire District Council Hertfordshire County Council (various departments) London Borough of Barnet London Borough of Enfield London Borough of Harrow Luton Borough Council North Hertfordshire District Council St Albans City and District Council Stevenage Borough Council Three Rivers District Council Watford Borough Council Welwyn Hatfield Borough Council

Hertsmere Parish and Town Councils Aldenham Parish Council Elstree & Borehamwood Town Council Ridge Parish Council Shenley Parish Council South Mimms Parish Council

Neighbouring Parish and Town Councils Colney Heath Parish Council London Colney Parish Council North Mymms Parish Council St Stephens Parish Council Watford Rural Parish Council b) General Consultees – interest groups, residents’ groups and other organisations (163 organisations and groups notified)

National/Local organisations and groups Age UK Hertfordshire Agency for the Legal Deposit Libraries Allotments Association (Watford) Ancient Monuments Society Arts Council England, East BBC - Transmitter Department Borehamwood Four Parks Friends Association

Borehamwood Library Borehamwood Youth Football club BREEAM British Horse Society Bushey & District Footpaths Association Bushey Conservative Club Bushey Green Belt Association; Little Bushey Residents Association Bushey Hall Park Residents Association Bushey Hall School Bushey Heath Residents Association Bushey History Research & Conservation Group Bushey Meads School Bushey Museum Bushey Residents Action Group Caldecote Neighbourhood Association Campaign for Real Ale Cherry Tree Lane Green Belt Protection Group Church Commissioners Church of Christ Evangelical Borehamwood Community Development Agency for Hertfordshire Community Learning Disabilities Service (ACS) Community Programmes Manager CPRE Hertfordshire CPRE Hertfordshire Cranborne Road Residents Association Crown Estate Office Dame Alice Owen's School Darnhills Ltd Elstree and Borehamwood Green Belt Society Elstree and Borehamwood Residents Association English Nature - Essex Herts & London Team Footpaths Friends of Fishers Field Golf Development / Course Secretary Golfwatch Residents' Association Hadley Wood Assoc. Council Hartsbourne Manor Residents Association Haydon Hill House (Garden Association) Ltd Haydon Hill House Flat Association Head of Herts Libraries, Arts & Information Head of Operations Health & Safety Executive Heathways Residents Association Hertfordshire Archaeological Trust Hertfordshire Association for The Disabled Hertfordshire Gardens Trust- Garden History Society Hertfordshire Local Access Forum Herts & Middlesex Badger Group

Herts & Middlesex Bat Group Herts Education Service Hertsmere Chamber of Trade Hertsmere Leisure Trust Hertswood School / Hertfordshire Scouts / Hertsmere Flyers Swimming Club Hertswood Secondary School Highwood JMI School Holy Cross Church Borehamwood HSE Health & Safety Executive Immanuel College Imperial Cancer Research Fund Jewish Care Kinetic Business Centre Land Access & Recreation Association Legal Deposit Office Letchmore Heath Village Trust Local Agenda 21 Transport & Pollution Group Local Studies Library London Essex and Hertfordshire Amphibian & Reptile Trust London Travel Watch London Travel Watch Longwood School and Nursery Manor Court Residents Association Maxwell Park Community Centre Merryhill Residents Association Mill Hill Neighbourhood Forum Ministry of Defence Mount Grace School National Farmers Union National Federation of Gypsy Liaison Groups National Trust Network Watford Newberries JMI School Newlands Avenue Road Committee North Bushey Residents Group North Mymms District Green Belt Society Oakmere Library Oakridge Avenue Road Association Open Spaces Society Origin Group Oxhey Village Environmental Group Paddock Road Allotments Parish of Bushey Parish Secretary Patchetts Green Bridleways Trust Patchetts Green, Roundbush & Aldenham Conservation Society Phillimore Trust Potters Bar and District Society for Mencap

Potters Bar Chamber Of Commerce Potters Bar Congregation of Jehovah's Witnesses Potters Bar in Focus Potters Bar Society Potters Bar Society (Rural Access Co-ordinator) Potters Bar Society (Town Group) Queens' School Radlett Library Radlett Society and Green Belt Association RAID Residents Against Inappropriate Development Railtrack plc Ridge Residents Association Royal Commission on the Monuments Of England Royal Society for the Protection of Birds (RSPB) Royal Town Planning Institute Royds Conservation Residents Association Save the Green Belt Association School of Construction & Engineering, Oaklands College Shenley Park Trust Shenley Village Society Society for Protection of Ancient Buildings South Mimms & Ridge Protection Committee Sport England St Hilda's School St Margaret's School St Michaels C of E Church Swanland Road Residents' Group Tabard Rugby Football Club Thameslink The Barnet Society The Bushey Forum The College Of Osteopaths The Gardens Trust The Georgian Group The Green Belt Council For Greater London The London Green Belt Council The National Federation of Gypsy Liaison Groups The Potters Bar Society & PBIF The Ramblers Association The Ridgeway Road Association The Royal Veterinary College The Showmans Guild of Great Britain The Society For The Protection Of Ancient Buildings The Theatres Trust The Woodcock Hill Village Green Members The Woodland Trust Twentieth Century Society Victorian Society

Visit East Anglia Limited Wall Hall Management Company Warren Estate Residents Association Watford and District Talking Newspaper for the Blind Watford and West Herts Chamber of Commerce and Hertsmere Connect Watford Chamber of Commerce and Industry Watford Mail Centre Well End Residents Association West Herts College WHOSE! Woodland Trust Wroxham Residents Action Group

Hertsmere Borough Council Departments Building Control Corporate Communications Democratic Services Planning – Development Management Engineering Services Environmental Health Estates Finance Housing Legal Services Parks and Open Spaces Partnerships and Community Engagement Waste and Street Scene c) Representors – 920 representors consulted All individuals and organisations who made representations on the published SADM (July 2015) have been consulted. 920 emails and letters were sent out to all of those people who made representations, including all those who signed a slip in relation to the Paddock proposed Local Green Space. The Council has not consulted those people who had signed slips relating to the Paddock, but have subsequently requested that the Council does not contact them again on this matter

d) Further notifications – 10 private owners consulted

Owners of 10 sites which may otherwise not have been aware that a level of protection for their site is proposed were identified. Notification of the consultation was sent to them on 3 March 2016, for response by 29 March.

Appendix 6: Press release issued 24/02/2016

Have your say on our amended plan

With public hearings starting soon to review the council's proposed plan for site allocations and planning policies, there's an opportunity for people to comment on some suggested changes that have now been proposed.

These amendments relate specifically to proposals to protect green spaces in the borough.

The council's Site Allocations and Development Management Policies Plan (SADM) was submitted to the Secretary of State in November 2015 and is now being examined by an independent Planning Inspector to check that it is sound and that correct procedures have been followed. A public hearing will take place in April as part of that examination process.

Whilst the Inspector is examining SADM there is now an additional opportunity for people to have their say on the council's approach to protecting green spaces prior to the hearings. Details of the revised policies and the sites to which they are proposed to apply are available on our website: www.hertsmere.gov.uk/openspaceconsultation

The information is also available at our council offices (including district offices in Potters Bar and Bushey), local libraries, Shenley and Aldenham Parish Council offices, and Elstree and Borehamwood Town Council offices. Information on how to submit comments is also available on the website and at these locations. Anyone wanting to submit comments on the proposed changes must do so by 5pm on Monday 21 March.

The public hearings into various aspects of the submitted plan will be held at the council offices in Borehamwood. They will start on 12 April at 9.30am and are expected to last for three days.

Appendix 7: Press release as on Council website

Appendix 8: e-alert

Chance to have your say on amended green spaces plans

With public hearings starting soon to review the council's proposed plan for site allocations and planning policies, there's an opportunity for people to comment on some changes that have now been proposed.

These changes relate specifically to proposals to protect green spaces in the borough.

Whilst the Inspector is examining the SADM there is now an additional opportunity for people to have their say on the council's approach to protecting green spaces prior to the hearings. Details of the revised policies and the sites to which they are proposed to apply are available on our website: www.hertsmere.gov.uk/openspaceconsultation

Information on how to submit comments is also available on the website and at these locations. Anyone wanting to submit comments on the proposed changes must do so by 5pm on Monday 21 March.

The public hearings into various aspects of the submitted plan will be held at the council offices in Borehamwood. They will start on 12 April at 9.30am and are expected to last for three days.

Working with you, for you, improving our communities, our places.

www.hertsmere.gov.uk

[email protected]

020 8207 2277 Civic Offices, Elstree Way, Borehamwood, WD6 1WA

Appendix 9: Summary of representations SADM Representor Summary of Representation HBC response to the representation ref no

OS/001a Aldenham Comment Noted Parish Council Sites in Radlett, which had previously been listed, should continue to be given appropriate local recognition, as local green spaces, in the proposed Neighbourhood Plan. It was agreed that this matter should be referred to the Neighbourhood Plan Steering Group

OS/002a Bushey Heath Support Noted Residents Fully support retention of LGS designation for The Paddock and that it meets Association criteria in NPPF para 74

OS/002b Bushey Heath Comment Noted Residents Contrary to BMPT representation, Paddock is demonstrably special by virtue Association of historical importance, views over Hertfordshire, and contribution to well- being of local residents

OS/002c Bushey Heath Comment Noted Residents Designation as LGS does not mean BMPT unable to fund maintenance and Association development of Reveley Lodge. Alternative financing should be investigated.

OS/002d Bushey Heath Comment Noted Residents Refute BMPT's criticisms of BHRA submission supporting LGS designation of Association The Paddock: land WAS intended to be for benefit of people of Bushey Heath, it IS part of original Bushey Heath, not all the benches face the A411 - one in Caldecote Gardens overlooks the site - rural/tranquil view.

SADM Representor Summary of Representation HBC response to the representation ref no

OS/002e Bushey Heath Comment Noted Residents Refute BMPT claim that a modest development proposal on The Paddock Association could be fully compliant with council policies. Would not be consistent with LGS designation. Local residents have petitioned twice against planning applications. Query how local many of the objectors to the LGS designation are local.

OS/003a CALA Support Noted Management Support raising of threshold for LGS designation to 30.

OS/003b CALA Object on the grounds of soundness As indicated in paragraph 7.5 of the Council’s Management Object to increased weighting to 'amenity benefits and sense of place' and Hearing Statement (Document HBC/1), the 'cultural and heritage benefits' to the exclusion of others - especially as Council believes that these two criteria are the ecological benefits weighting is not increased and this is an equal criterion in most relevant when assessing whether a site is NPPF. ‘demonstrably special’ and hold ‘particular local significance’ to a local community, in accordance with paragraph 77 of the NPPF. OS/003c CALA Object on the grounds of soundness The NPPF is very clear that the considerations Management Object to 'structural and landscape benefits' which is not listed in NPPF listed in paragraph 77 are examples only. It is having more weight than ecological benefits which is. therefore clear that local planning authorities needs to decide how best to assess whether a green area is ‘demonstrably special and holds a ‘particular local significance’. In this case the Council believes that ‘structure and landscape benefit’ is an important element in making such assessment and should be afforded significant weight, especially in light of the particular pressure for development on the main settlements, within an authority which has 80% Green Belt.

SADM Representor Summary of Representation HBC response to the representation ref no

OS/003d CALA Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Management Object to re-scoring of Paddock site. Does not meet NPPF criteria for LGS Statement (Document HBC/1) provides detailed designation. Firstly structural and landscape benefit - previous appeal justifications as to why and how the Paddock site decisions identify Paddock as only making contribution to street scene, not has been re-scored. As far the Council is being a fundamental element in landscape. Also structural and landscape concerned the re-scoring of the Paddock site is benefit is not listed in NPPF. Should retain original score of 1. Secondly valid and justified. amenity benefits and sense of place - Paddock only makes partial contribution, local deficit in parks and gardens is irrelevant, protecting site from development is against spirit of NPPF. Should retain original score of 1. Thirdly cultural and heritage benefits - score should be zero as Paddock doesn't meet any of the factors for scoring this criterion (historic buildings, gardens, symbol of the area, conservation area, monuments/memorials). Factors the council lists in its statement are not scoring factors. 2012 Appeal statement says it adds little to the character of Reveley Lodge. Factors Council has based increased score on are not factors that are relevant to the scoring factors for this criterion.

OS/003e CALA Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Management Increased score for Paddock not supported in evidence. Meets lower scoring Statement (Document HBC/1) provides detailed threshold of 30 points - any reduction due to objections to scoring justifications as to why and how the Paddock site methodology being upheld would reduce site score below threshold. has been re-scored. As far the Council is Paddock does not qualify for LGS status either under NPPF criteria or concerned the re-scoring of the Paddock site is Council's scoring framework. valid and justified.

OS/004a Mr Robert Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Dunkley The Paddock: assessment as having “cultural and heritage significance”. The Statement (Document HBC/1) provides detailed Resident unenclosed common land of the Heath lay to the south-east of Belle Vue justifications as to why and how the Paddock site Lane, whereas the Paddock is to the north-east (and therefore was not part has been re-scored. As far the Council is of Bushey Heath). The scoring in the Matrix, which is heavily weighted in concerned the re-scoring of the Paddock site is favour of “cultural and heritage benefits” is therefore unsound. valid and justified.

SADM Representor Summary of Representation HBC response to the representation ref no

OS/004b Mr Robert Object on the grounds of soundness This arithmetic error is noted. After applying the Dunkley The Matrix: arithmetic. On page 1, score 2 x weighting 5 = 10; but on page 2 correct formula to the matrix only three more Resident and following, 2 x 5 = 8, and 1 x 5 = 4. This does not affect the score for The sites (Site BW021, EV010 and RT025) are deemed Paddock, but it reduces the scores for other sites, making The Paddock’s eligible for Local Green Space allocation given the score look higher by comparison. selection criteria detailed in Paragraph 7.6 of the Council’s Hearing Statement (Document HBC/1) and paragraph 77 of the NPPF.

A revised matrix is attached in Appendix 10 of this document. The three sites mentioned above are highlighted.

OS/005a Bushey Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Museum Remove LGS designation from Paddock. Paddock fails to meet NPPF criteria; Statement (Document HBC/1) provides detailed Property Designation as LGS is therefore unsound. Evidence to justify designation is justifications as to why and how the Paddock site Trust incorrect so Paddock fails to meet threshold for designation. has been re-scored. As far the Council is concerned the re-scoring of the Paddock site is valid and justified.

OS/005b Bushey Object on the grounds of soundness Paragraph 7. 5 –to 7.14 of the Council’s Hearing Museum Hertsmere is not using NPPF methodology, despite previous objections. Statement (Document HBC/1) provides detailed Property Revised markings and weightings have moved the Paddock from 53rd place justifications as to why and how the Paddock site Trust in LGS ranking to 9th. HBC admit the methodology involves a somewhat has been re-scored. As far the Council is ‘arbitrary’ cut-off point, and that ‘on balance’ LGS status for The Paddock is concerned the re-scoring of the Paddock site is justified. Such variable results based on arbitrary weightings and scorings valid and justified. must be unsound by definition.

OS/005c Bushey Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Museum Remove LGS designation from Paddock. Responses to HBC's explanation of Statement (Document HBC/1) provides detailed Property changes in scoring. a. Planning Inspector rulings: Appeal decisions state site justifications as to why and how the Paddock site

SADM Representor Summary of Representation HBC response to the representation ref no

Trust ‘contributes’ &‘adds’ to street scene. Council’s criteria says should ‘define’ has been re -scored. As far the Council is or ‘separate it from other areas nearby,’ to be afforded full marks. b. concerned the re-scoring of the Paddock site is Shortage of parks: not a valid explanation as Paddock inaccessible to public valid and justified. & Hertsmere has no target for parks. Bushey has above Local Plan target for 'general use space' of 0.4ha/1000 people. Stanmore Common is only 0.6 miles away. c. Historical evidence: HBC misinterprets enclosure map - Paddock was not a new enclosure under the Bushey Enclosure Act. OS/005d Bushey Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Museum Remove LGS designation from Paddock. Comment on reps by BHRA. a. Statement (Document HBC/1) provides detailed Property Historical significance: see response to HBC case. b. Artistic heritage: none of justifications as to why and how the Paddock site Trust paintings referenced by BHRA have any provenance that they relate to the has been re-scored. As far the Council is Paddock. More likely to have been of Stanmore Common. b. Memories of concerned the re-scoring of the Paddock site is local residents: memories are ok but there was no community interest in the valid and justified. field until development was mooted. d. Appeal decision: see response to HBC case. e. Mrs Chewett's wishes: In bequeathing estate Mrs Chewett did not attach condition that Paddock not to be disposed of.

OS/005e Bushey Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Museum Remove LGS designation from Paddock.. Council said in Hearing Statement Statement (Document HBC/1) provides detailed Property para 7.6 that any site scoring less than 2 in both 'amenity benefit and sense justifications as to why and how the Paddock site Trust of place' and 'cultural and heritage benefits' is deemed not to be has been re-scored. As far the Council is demonstrably special and thus disqualified from LGS designation. Score for concerned the re-scoring of the Paddock site is Cultural and Heritage benefits should be reduced from 2 to 1, lowering the valid and justified. overall score for the Paddock to 25 so not eligible for LGS designation. Also having a score of less than 2 means it is not demonstrably special and must be disqualified from LGS designation.

SADM Representor Summary of Representation HBC response to the representation ref no

OS/006 a Mrs Katherine Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Whittaker Remove LGS designation from Paddock. Bushey Heath is a place name Statement (Document HBC/1) provides detailed Resident originating in 12th Century. It has come to mean a bigger area as currently justifications as to why and how the Paddock site known. The term 'heath' has been in this context incorrectly used, making has been re-scored. As far the Council is the HBC assertion that the Paddock represents a last remaining part of the concerned the re-scoring of the Paddock site is heath unsound. valid and justified.

OS/007 a Mr Jim Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Whittaker Remove LGS designation from Paddock. Incorrect assertion made about site Statement (Document HBC/1) provides detailed Resident being part of 'common land'. The site has never been common land and it justifications as to why and how the Paddock site has been in private ownership for at least 400 years. Therefore to state that has been re-scored. As far the Council is the Paddock is the last remaining site of common land in Bushey Heath is concerned the re-scoring of the Paddock site is unsound. valid and justified.

OS/008a Mrs J Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing McNulty Remove LGS designation from Paddock. Not true that there is a deficit of Statement (Document HBC/1) provides detailed parks and gardens in Bushey. Reveley Lodge, Warren Lake, Mary Forsdyke justifications as to why and how the Paddock site Gardens. Close to Stanmore Common. Hillmead Nature Park. Scoring for has been re-scored. As far the Council is 'amenity benefits and sense of place' therefore unsound. concerned the re-scoring of the Paddock site is valid and justified.

OS/008b Mrs J Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing McNulty Remove LGS designation from Paddock. Bushey Heath is a place name Statement (Document HBC/1) provides detailed originating in 12th Century. It has come to mean a bigger area as currently justifications as to why and how the Paddock site known. The term 'heath' has been in this context incorrectly used, making has been re-scored. As far the Council is the HBC assertion that the Paddock represents a last remaining part of the concerned the re-scoring of the Paddock site is heath unsound. valid and justified.

SADM Representor Summary of Representation HBC response to the representation ref no

OS/008c Mrs J Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing McNulty Remove LGS designation from Paddock. Incorrect assertion made about site Statement (Document HBC/1) provides detailed being part of 'common land'. The site has never been common land and it justifications as to why and how the Paddock site has been in private ownership for at least 400 years. Therefore to state tha has been re-scored. As far the Council is the Paddock is the last remaining site of common land in Bushey Heath is concerned the re-scoring of the Paddock site is unsound. valid and justified.

OS/009a Mr P McNulty Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Remove LGS designation from Paddock. Not true that there is a deficit of Statement (Document HBC/1) provides detailed parks and gardens in Bushey. Reveley Lodge, Warren Lake, Mary Forsdyke justifications as to why and how the Paddock site Gardens. Close to Stanmore Common. Hillmead Nature Park. Scoring for has been re-scored. As far the Council is 'amenity benefits and sense of place' therefore unsound. concerned the re-scoring of the Paddock site is valid and justified.

OS/009b Mr P McNulty Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Remove LGS designation from Paddock. Bushey Heath is a place name Statement (Document HBC/1) provides detailed originating in 12th Century. It has come to mean a bigger area as currently justifications as to why and how the Paddock site known. The term 'heath' has been in this context incorrectly used, making has been re-scored. As far the Council is the HBC assertion that the Paddock represents a last remaining part of the concerned the re-scoring of the Paddock site is heath unsound. valid and justified.

SADM Representor Summary of Representation HBC response to the representation ref no

OS/009c Mr P McNulty Object on the grounds of soundness Paragraph 7.8 –to 7.14 of t he Council’s Hearing Remove LGS designation from Paddock. Incorrect assertion made about site Statement (Document HBC/1) provides detailed being part of 'common land'. The site has never been common land and it justifications as to why and how the Paddock site has been in private ownership for at least 400 years. Therefore to state tha has been re-scored. As far the Council is the Paddock is the last remaining site of common land in Bushey Heath is concerned the re-scoring of the Paddock site is unsound. valid and justified.

OS/010a Mrs J Steer Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing This part of Bushey Heath is not short of open spaces. Reveley Lodge Statement (Document HBC/1) provides detailed gardens are opposite. - open to public, lots of visitors, educational use, art justifications as to why and how the Paddock site and gardening groups. has been re-scored. As far the Council is concerned the re-scoring of the Paddock site is valid and justified.

OS/010b Mrs J Steer Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing It's Reveley Lodge, not the Paddock that provides historical context and local Statement (Document HBC/1) provides detailed landmark. justifications as to why and how the Paddock site has been re-scored. As far the Council is concerned the re-scoring of the Paddock site is valid and justified.

OS/011a Sir A Steer Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Paddock is not the only local green area, not recreational and not part of Statement (Document HBC/1) provides detailed ancient heath. justifications as to why and how the Paddock site has been re-scored. As far the Council is concerned the re-scoring of the Paddock site is valid and justified.

SADM Representor Summary of Representation HBC response to the representation ref no

OS/011b Sir A Steer Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing Council failed to demonstrate that Paddock is of special local significance to Statement (Document HBC/1) provides detailed the community justifications as to why and how the Paddock site has been re-scored. As far the Council is concerned the re-scoring of the Paddock site is valid and justified. OS/011c Sir A Steer Object on the grounds of soundness Paragraph 7.8 –to 7.14 of the Council’s Hearing HCC has been erratic in their scoring of this case [The Paddock]. Statement (Document HBC/1) provides detailed justifications as to why and how the Paddock site has been re-scored. As far the Council is concerned the re-scoring of the Paddock site is valid and justified.

OS/011d Sir A Steer Object on the grounds of soundness The Council has an up -to -date Core Strategy and Area needs more houses is able to demonstrate 5 years of deliverable housing land. The SADM have allocated sufficient additional housing in the Borough therefore additional housing allocation in this locality is not required.

SADM Representor Summary of Representation HBC response to the representation ref no

OS/012a Mr W Object on the grounds of soun dness Paragraph 7.8 –to 7.14 of the Council’s Hearing Whitaker Not true that there is a deficit of parks and gardens in Bushey. Reveley Statement (Document HBC/1) provides detailed Lodge, Warren Lake, Mary Forsdyke Gardens. Close to Stanmore Common. justifications as to why and how the Paddock site Hillmead Nature Park. Scoring for 'amenity benefits and sense of place' has been re-scored. As far the Council is therefore unsound. concerned the re-scoring of the Paddock site is valid and justified.

Appendix 10: Local Green Space Revised Site Assessment Matrix (April 2016)