Local Plan Consultation Statement

(Regulation 22)

March 2018

Contents 1. Introduction ...... 3 2 Who we consulted ...... 4 3 How we consulted ...... 5 4 How we responded ...... 9

Appendices ...... 10 Appendix A – Regulation 18 List of People and Organisations consulted ...... 11 Appendix B – Regulation 18 Draft Local Plan - respondents ...... 19 Appendix C – Amendments following the Regulation 18 Consultation ...... 22 Appendix D – Regulation 19 Pre-Submission Local Plan Respondents ...... 28 Appendix E – Copies of Publicity Materials...... 30 Appendix F – Regulation 19 Official Statements ...... 36 Appendix G – Summary of the issues raised (Regulation 19 stage) ...... 38

1. Introduction

1.1 This Consultation Statement describes the processes followed by Broxbourne Council in undertaking community participation and stakeholder involvement in the production of the Broxbourne Local Plan and sets out how the main issues raised through consultation have helped shape the Plan.

1.2 The Consultation Statement has been prepared to comply with the requirements of Regulations 18, 19 and 22 (1) part (c) of the Town and Country Planning (Local Planning) (England) Regulations 2012 (referred to throughout this Consultation Statement as ‘the Regulations’). The Consultation Statement will assist the Inspector at the Examination in Public to determine whether the processes that the Council followed leading to the Submission of the Local Plan comply with government guidance and requirements for public participation.

1.3 In detailing what the requirements for the ‘Submission of documents and information to the Secretary of State’ are, Regulation 22 (1) part (c) directs the Council to prepare a statement which sets out:

i. which bodies and persons were invited to make representations under Regulation 18 of the Local Planning Regulations; ii. how those bodies were invited to make representations; iii. a summary of the main issues raised in those representations; iv. how those main issues have been taken into account; v. if there are representations made under Regulation 20, the number made and a summary of the main issues raised in those representations; and vi. if there are no representations made under Regulation 20, that no such representations were made.

1.4 In carrying out its consultation processes, it should be noted that, in addition to complying with the Regulations, the Council has also complied with the provisions of its Statement of Community Involvement (SCI), May 2016. This document sets out the Council’s approach to public engagement in the planning system and how it seeks to involve the local community in Broxbourne. The SCI may viewed at: http://www.broxbourne.gov.uk/sci.

2 Who we consulted

(i) Bodies and Persons invited to make representations under Regulation 18

2.1 The Council has consulted extensively at each stage of the preparation of the Local Plan. This Consultation Statement is concerned with the approach taken at the Regulation 18 and 19 stages, i.e. Preferred Options and Pre- Submission consultations.

2.2 To aid the consultation process, the Council maintains a live consultee database, which is stored on the Objective system. The database is continuously updated at each consultation event and as and when notified of changes by consultees.

2.3 In addition to Specific and General Consultees (as identified under Part 1 of the ‘Regulations’), all consultees on the Objective database (i.e. those interested parties who had previously commented and/or expressed an interest in being notified) were contacted by means of email or letter, as appropriate. The Council’s Objective database currently consists of over 600 persons, bodies and groups. A list of named persons and bodies notified of the Regulation 18 draft Local Plan consultation is included at Appendix A. In addition to the list in Appendix A there are a number of consultees registered on the database who have provided a contact email but no name, and were notified of the consultation by email.

2.4 Additionally, an article and cover story about the consultation was featured in the summer edition of Broxbourne Life, the Council’s regular news magazine for residents (see Appendix E). The Council’s Communications Team arrange distribution of Broxbourne Life to households across the borough.

2.5 The Council has also carried out comprehensive ongoing formal and informal Duty to Co-operate discussions with various Councils, organisations and stakeholders, which has helped to inform the preparation of the plan. The separate Duty to Co-operate Statement shows how these requirements have been met in more detail.

3 How we consulted

(ii) How those bodies and persons were invited to make representations

Regulation 18 Consultation

3.1 The Draft Local Plan consultation (Regulation 18) was carried out between 18 July and 16 September 2016. All Specific, General and other consultees on the Objective database (i.e. those interested parties who had previously commented and/or expressed an interest in being notified) were contacted by means of email or letter, with relevant documents provided, as appropriate. Hard copies of the full suite of consultation documents were made available at the Council’s Offices, One-Stop Shops and libraries.

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

Action Timings Team Details/format responsible Press Friday 8 or Comms to Information to be embargoed briefing Monday 11 July organise until close of Cabinet Meeting on 12 July Staff briefing July Comms to To be compulsory for all staff organise to attend; Three separate Planning to sessions for staff to choose present from Press Details of Local Comms 1. To encourage public releases Plan Events and attendance at the consultation events process – 12 July 2. To encourage people to take part in the consultation Canopy/letter From 19 July Comms Message: ‘Have your say on footer/frankin the Borough’s Local Plan’ g machine Letter to Immediately after Planning 1. To promote awareness stakeholders 12 July Cabinet of the consultation Meeting 2. To fulfil statutory requirements FAQ To be finalised by Planning To be sent to all members document 12 July and published on the Council’s website Public Events The Spotlight, Comms to Same format at each event: (all at 7pm) Hoddesdon, organise Introduction by the Leader; (Thursday 28 About Broxbourne video to be July); Leader, Portfolio shown prior to start of the Wolsey Hall, Holder and session as people arrive; Waltham Cross Planning to Presentation by Planning on (Thursday 25 represent the the consultation process and

August); Council on the key elements of the plan; Goffs Oak Village day Panel Q&A session – Hall (Wednesday 7 Councillors and planning September) The Leader to officers Chair the events Broxbourne To be distributed Comms Special ‘Local Plan’ edition. Life (Council to residents week Planning To include dates for Local Magazine) commencing 18 Plan Public Events. July Posters Have your say - Comms To be put up across the July/August Borough, in the Borough Offices and in the One Stop Shops Local Plan July edition Planning Distribution to all Broxbourne update Councillors and to planning e-newsletter policy contacts database.

Mercury To be published on Comms Statutory notification of the advert 21 July Local Plan consultation period and availability of documents. Electronic Ongoing Comms Twitter campaign media E-communications to residents Homepage of the Council’s website

3.2 Hard copies of the full suite of consultation documents were made available at the Council’s Offices, the Laura Trott leisure centre and public libraries at Cheshunt, Goffs Oak, Hoddesdon, and Waltham Cross. Following press releases a number of articles were published in the local press discussing the consultation.

3.3 The Council’s Local Plan Update, which detailed the consultation as part of its contents, was distributed by email to all those parties who had registered an interest in receiving this communication through the consultation portal.

3.4 Copies of relevant forms and publicity material for the Preferred Options consultation (Regulation 18) are included at Appendix E.

Regulation 19 Pre-Submission Local Plan

3.5 The Pre-Submission n (Regulation 19) was carried out for a 6 week period between 9 November and 5pm 21st December 2017, together with a simultaneous consultation on the draft Transport Strategy and the draft Local Cycling and Walking Infrastructure Plan. All Specific, General and other consultees on the Objective database (i.e. those interested parties who had previously commented and/or expressed an interest in being notified) were contacted by means of email or letter, with relevant documents provided, as appropriate. Hard copies of the full suite of consultation documents were made available at the Council’s Offices, One-Stop Shops and libraries.

Regulation 19 Consultation

3.6 A total of 681 comments from 111 respondents were received to the Pre- Submission consultation. The Consultation Action Plan set out in the table below was considered by the Scrutiny Committee on 17 September and agreed by Cabinet on 31 October 2017.

Table 2: Pre-Submission Local Plan Consultation Action Plan agreed by Cabinet, 31 October 2017

Action Timings Team Details/format responsible Staff briefing November/December Comms to Sessions for all staff organise Planning to present Press releases Details of Local Plan Comms To encourage people to and consultation take part in the process and headlines. consultation. Canopy/letter From 13 November Comms Message: ‘Have your say footer/franking on the Borough’s Local machine Plan and Transport Strategy’ Letter to After 31 October Planning 1. To promote stakeholders Cabinet Meeting awareness of the consultation 2. To fulfil statutory requirements FAQ document To be finalised by 31 Planning To be sent to all members October and published on the Council’s website. Broxbourne First week of Comms Special ‘Transport Life (Council consultation Strategy’ edition, with Magazine) short section on the Local Plan. Posters November/December Comms To be put up across the Borough, in the Borough Offices and in the One Stop Shops Local Plan November edition Planning Distribution to all update Broxbourne Councillors e-newsletter and to planning policy contacts database.

Mercury advert First week of Planning Statutory notification of the consultation Local Plan consultation period and availability of

documents. Electronic Ongoing throughout the Comms Twitter campaign media consultation E-communications to residents Homepage of the Council’s website

3.7 All Specific, General and other consultees on the Objective database (i.e. those interested parties who had previously commented and/or expressed an interest in being notified) were contacted by means of email or letter, with relevant documents provided, as appropriate.

3.8 Copies of relevant forms, publicity material and press notices for the Pre- Submission consultation (Regulation 19) are included at Appendix E. A list of people and organisations who responded to the Pre-Submission consultation is provided at Appendix D. The full set of representations is available alongside this document, in both document order and alphabetical order by representor. A summary of the representations is provided below at Appendix G below.

3.9 The Consultation Portal can be accessed at http://consult.broxbourne.gov.uk and contains all the representations received, assigned to the appropriate part of the plan for both the Draft and Pre-Submission consultations, together with the relevant supporting documents at each stage.

3.10 In accordance with Regulation 19, the Council made a copy of each of the proposed submission documents and a statement of the representations procedure available in accordance with Regulation 35. It also published a statement of the fact that the proposed submission documents are available for inspection and of the places and times at which each could be inspected. This was sent to each of the general consultation bodies and each of the specific consultation bodies as set out in Appendix A. Copies of the Statement of Availability and the Statement of the Representations Procedure

are contained in Appendix F below.

4 How we responded

(iii) & (iv) Summary of the main issues raised by the representations and how these have been taken into account

Regulation 18 Consultation

4.1 A total of 2,225 comments from 328 respondents were received to the Draft Local Plan consultation. Proposed Council responses to all the issues raised in respect of individual chapters through the Draft Local Plan Consultation were considered at Scrutiny Committee on 17 October 2017 and at Cabinet on 31 October 2017.

Links to the Scrutiny Committee and Cabinet reports are provided below: http://www.broxbourne.gov.uk/your-council/meeting/cabinet-31-october-2017 http://www.broxbourne.gov.uk/your-council/meeting/scrutiny-committee-17- october-2017

4.2 Details of those people and organisations who responded to the Preferred Options consultation are provided at Appendix B. A summary of the main amendments arising from those comments is set out in the table in Appendix C below. These were discussed at Scrutiny Committee on 17 October and agreed at Cabinet on 31 October 2017. For a complete set of amendments, please refer to the document Local Plan Amendments – following the Regulation 18 Consultation – ‘Track Changes’ version (see www.broxbourne.gov.uk/localplan)

Appendices

Appendix A – Regulation 18 List of People and Organisations consulted

Bodies and persons invited to make representations under Regulation 18. The consultation took place between 18 July and 16 September 2016.

Specific Consultation Bodies

 East and North Herts Clinical Commissioning Group  Environment Agency  Highways England  Historic England  Homes and Communities Agency  National Grid  Natural England  Authorities: Conservators of Epping Forest, East Hertfordshire District Council, Enfield Council, Epping Forest District Council, Essex County Council, Greater London Authority, Harlow Council, Hertfordshire County Council, Hertsmere Council, Lee Valley Regional Park Authority, North Herts Council, St Albans District Council, Stevenage Borough Council, Uttlesford District Council, Welwyn Hatfield Borough Council  Network Rail  Thames Water  The Coal Authority

General Consultation Bodies and Other Organisations Andrews Lane Primary School Arlesdene Nursery B3 Living Bigbury Parish Council Bonneygrove County Primary School Boys Brigade – 1st Hoddesdon Company Bretheren Assembly British Aggregate Association British Horse Society British Naturalists Association – Herts Brooklands Infant and Nursery School Broxbourne Woods Area Conservation Society Campaign for Real Ale Campaign to Protect Rural England (Hertfordshire) (CPRE) Cheshunt Bowls Club Cheshunt RFC Canal & River Trust Conservators of Epping forest – City of London College Road, Hoddesdon Residents Dewhurst St Marys C of E Primary Association School Cranbourne Primary School Flamstead End Primary and Nursery School East of England Local Government Goffs – Churchgate Academy (Formerly Association Cheshunt School) Education and Skills Funding Agency Goffs Oak Junior Mixed Infants and Nursery School Fairfields Primary and Nursery School Greenfield Pre-School

General Consultation Bodies and Other Organisations Friends of Lowewood Museum Herts & Middlesex Wildlife Trust Goffs Oak Community Association Hertfordshire Constabulary Goffs Oak Residents Association Hertfordshire GATE Herts & Middlesex Bat Group Hoddesdon Business Focum Hertfordshire Local Enterprise Hoddesdon Society Partnership Hoddesdon Cricket Club Lee Anglers Consortium Kings Arms & Cheshunt Angling Society Lea Valley Growers Association Public Health Service – HCC Roselands Primary School Royal Mail Group Sheredes Primary & Nursery School Spitalbrook ‘Village Green’ Conservation St Cross Catholic Primary Group Sport England The National Federation of Gypsy Liaison Groups The Maxwell Trust The Wormley and Turnford Society The Waltham Cross and Cheshunt Transport for London Chamber of Commerce Theatres Trust V&E Club Windmill Residents Association Woodside Primary School The Woodland Trust

Land Owners, Developers and Others with Property Interest or Represented by Agents A & F Cannatella Ltd A & L Salads Ltd A J Maxwell Aaron Rio Planning Abbey Road Surgery Adam Roberts Consultancy Ltd Adventures River Cruises Aitch Group Ltd Amet Property Attfield & Jones Architects Barker Parry Town Planning Barton Willmore Bayfordbury Estates Ltd Bidwells Boyer C G Edwards (Goffs Oak) Ltd Capital and Country Holdings Limited Car Spares Cheshunt Ltd Carter Jonas LLP Catesby Property Group CBRE Co-op CODE Development Planners Ltd Curwens Solicitors Countrywide Planning D P P Cushman and Wakefield Datum Contracts Intl D2 Planning Limited Dean Lewis Estates De Merke Estates Derwent London Derrick Wade Waters Development Planning Partnership Development Land & Planning Edge Analytics Ltd Consultants Ltd DLA Town Planning Eurovia Infrastructure Limited Fishpools Ltd Fairview Estates (Housing) Ltd Freeths LLP Framptons Planning G R Planning Consultancy G F Planning Galliard Homes

Land Owners, Developers and Others with Property Interest or Represented by Agents Gallagher Planning George Wimpey

Geoffrey Lane Town Planning GIB Property Investment LTD Griffiths Environmental Planning Gerald Eve LLP Hertfordshire Constabulary - Strategic GL Hearn Limited Harrow Estates plc Higgins Homes PLC Hertfordshire County Council Property Hoddesdon Police Station (Development Services) Holmes & Hills LLP Home Builders Federation Ltd Howes Percival LLP Howard Sharp and Partners LLP Iceni Projects Hunter and Stone Developments Indigo Planning Improve It Design Ltd JB Planning Associates JAB Hire Services Ltd John Lewis Partnership JEA Manning & Sons Ltd KG Creative Consultancy Jones Day Lambert Smith Hampton L W Developments Lanes New Homes Landhold Developments MM Enterprises Ltd Montagu Evans LLP Nathaniel Lichfield & Partners Paul Wallace Land Plainview Planning Ltd Plan A (North West) Ltd Planning Potential Planware Ltd Portland PPML Consulting PRP Quod Planning Richborough Estates Ltd Roger Sargent Planning Ltd RPS RPS CgMs Sanders Laing Savills (UK) Limited Simply Planning Sinclair Will Trust SSA Planning Limited Strutt & Parker LLP Stuart Smith Reynolds Swanfield Tetlow King Ltd TfL Property TJB Planning Consultancy Town Planning Services Tribal MJP Turley Via Properties Vibrant Partnerships Vincent Gorbing Waller Planning Weston Homes PLC Woodhall Properties Ltd WS Planning and Architecture WYG Zog Brownfield Ventures (Zog BV) - Halstead

Individuals Ackling S Adam Denny Aiton Stephen Anderson Alex Anderson Andrew Anderson J P Andrew F Angeli Mario Ansell G L Antscherl Thomas Archer john Austen L & C Avery Jill Azzopardi Joseph Azzopardi Joe Baker Andrew Baldrey J & G Ball Patricia Barton Gary Bates V Bavetta Mr & Mrs Bell John Bellini Angelo Billington Heather Bilton David Bird Paul Blake Bev Bolton David Bottoms Beryl Bowler D Bowman Carol Boyle Neil Bradford C Bray Nick Brereton K Briggs Malcolm Brignall Becky Brockwell V Brogan Anthony Brosnan Humphrey Brunton Robert Bryant Heidi Burgess Jonathan Burke Cassie Butler Simon Butler Janet Buzzard Peter & Nicola Byrne Chris Byne Daniel Byne John Byne Richard Cannatella A & F Cargill Ian Carlton R Carroll Tom Caruso Paolo Casey Terry Caslake Alan Casselle Richard Chaplin Mark Chastell Mr & Mrs Cheetham Mrs Christen Victoria Christou Ivor Cifaldi Clarke RA & PE Clayton Mr & Mrs Cleak Katherine Cobden Gary Coffield Christine Cole D Cole Francesca Collier Stephen Conheeney Michelle Conte Sandra Cook Andrew Cooper Bill Cornell Bernice Cosgrove Andrew Coster Steven & Linda Cotter C & E Couch Richard Crane Michael Croke W Crouch Greg Crowder Gary Cummines Scott Cutler Lee Daffarn Toby Dagley Jeremy D’Agati Nick Daniel Ronald

Individuals Daniels P C Dark Alison Dattani-Demirci Leena Day Rogers Deacon Andrew Dean Gavin De’ath Ian Dellicolli Linda Dellow Marilyn Demetriou Michael Detheridge James Devoil Melanie Dileto Giuseppe Dodd Annette Donnovan Paul Drage Jane Draper Joshua Duffy Christeen Duffy Peter Dunsford Tony Eatson W Edward Sally Eggleton Penny Embleton Simon Emmett Michele Etheridge Tombae Evans Jane Evans Lesley Everett D Everett Stephen Fagan Gerry Fieldhouse M Firth James Flook Alan Flowerday Roger Folliard Jason Fordham John Forrester Bob Fury Billy Gallagher Killian Gardiner Paula Gardner Jane Garner Alison Gately Denice Giardina Nick Gibbs Ronald Gilmore Andrea Goldie Paul Gollop Stephen Greenwood Evelyn Grew B Grimmett Gill Haidergill Mr Hale Russell Hall Barry Hall Bill Hambleton Louise Hammond Jennifer Hanna Peter Hannah Theodora Harding Kim Hardwick A Harris Nigel Harvey Family Harris Stephen Hastler Gary Hatch Jim Hayden Geoff Hayden William Hayes Lorraine Haynes Peter Head Jean Henbest Robert Henderson Mark Hendley Kenneth Hennell Jane Hill M Hill Jenna Hill Elizabeth Hillebron Richard Hodgson M Holloway Michael Hounslow Stephen Howard Lynda Howden Derek Huggett Jean Hughes A E Hughes Lisa Hunt Andrew Hussey Ryan Hutchinson Clare

Individuals Ifeanyi Mbamali Irwin Hella Jacewicz Heather Jackman Janet Jackson Alison James Chris James Malcolm Jarrold Anna Jarrold Stuart Jennings Lorraine Jericho Matthew Johnson Bola Kajese Tsitsi Kearney Mr & Mrs Kennett Bryan & Josephine Kernot Caroline Khan Shiraz Knapp Carol Knipes Heather Lambe Stephen Lavelle Lynda Leage G M Le Gresley Marion Leaver Zoe Lewis Cassandra Ley Deborah Liddard Stephen Llewellyn Mr & Mrs Lodge Janet Love Chris Lovelock Jane Lowe Mr & Mrs Lucas John Ludlam Gillian Lyons Christine Lyons Christine Malekkou Constantine Mann Angela Manning Joseph Manning D Martin Len Maxen C Maxwell Paul Maxwell M McCann Paul McGovern Mark McLuckie Ailsa McNamara Martin Mead Peter Meadhurst D F Mellis Patricia Mellon Paula Metcalf Jim Mewes Kelly Michael Hargreaves Mills Peter Milsom Isabel Mitchell Wilma Monk Mr & Mrs Monck Russell Monk F Monk-Striebig Mrs Montanaro Zoe Montgomery Mark Moore John Morgan Gareth Morris Brian Morris Laura Morris Wendy Morrison Andrew Moss Anthony Mukherji Penelope Murphy Lynn Musicka Rosemary Needle John Needs Denise Needs John Neville W T Newton Robert Nixon J Norris Carole Nuttall Graham Oakley Gwennie O’Connor M Oldman Ben Omechi Annabel P Alan Paine Sid Palmer John Palmer Sarah Papas N Parker Lyndsey Parr Robert Parsons Katie

Individuals Pattison B Payne Andy Pearce Rob Pearson Terry Perez Bridget Perfect Susan Perry Karen Perry Philip Pett Emily Petts Joyce Petty Adrian Phelps Sandra & Gary Pike Tom Price Gwennie Priestley Richard Priestley Sara Proctor Andrew Prosser Kevin Regis Jemma Rensten Mary Richards John & Eileen Richings Alan Ricotta Joe Riddle J M Ridley Matthew Rivers Julia Robinson Charlotte Robinson Tricia Rockall Elaine Roe Matthew Rogers Susan Rogers David Rogers Sharon Rowley Brett Ruane John Ryder Emma Saini Mahavir Sargent Roger Sarno Andrew Sarno Mario Saunders R A Scrutton Mark Secondis Christian Seeby Paul Sheehan Michael Shepperd Anne Sime Claire Sinclair Anne Sinnett Danielle Smith Zhanine Smith B Smith Nigel Smith Sharon Smith Sherrie Solly Roy Songaila Stephen Spagnuolo Mark Spagnuolo J M Spencer Jeanette Sprunt David St John Howe Louise Stacey David Staines Derek Stapley John Starling Valarie Stewart Fixter Storey Carole & David Storey Sue Streater Richard Striebig Lisa Sturman D G and J B Styles Lee Swain Sue Tate Mark Taylor Duncan Taylor M Thompson Karen Thomas David Thompson Anthony Thompson Clive Thompson Ian Thorn Amanda Thrussell David Tiley Sue Tipson Jo Toolan Adrian Travers Ken Trouse Ian Tsilika Saranto Tucker Ian Turnbull R

Individuals Turnball Hazel Turnball Nick Tyrell Barbara Verralls Keith Wacey Linda Wade Mr & Mrs Wade Lee Wallace Paul Waller Stephen Walshaw Karen Warren Roy Watson Nicola Watson Katherine Wellbeach Susan Welton Des Whitehead Jane Whitmore Les Whitmore Leslie Wickham Robert Williams J Williams Christine Williams Tony Willis Robert Willis Sarah Wilkinson Stephen Williamson Lee Wilson Diane Wilson Frazer Wiltshire Carol Ann Wood Adam Wootton Paul Wright P

Appendix B – Regulation 18 Draft Local Plan - respondents

328 individuals and organisations responded to this consultation as set out below. The consultation took place between 18 July and 16 September 2016.

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 Francesca Cole, 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. Griffith, 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 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 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

Appendix C – Amendments following the Regulation 18 Consultation A summary of the main amendments to the draft Local Plan are set out in the table below. These were discussed at Scrutiny Committee on 17 October and agreed at Cabinet on 31 October 2017. For a complete set of amendments, please refer to the document Local Plan Amendments – following the Regulation 18 Consultation – ‘Track Changes’ version (see www.broxbourne.gov.uk/localplan).

Section Changes Comments 1) Introduction Minor amendments Updating Part 2: Development Strategy 2) Vision and New objective on Health and This was raised by a Objectives Wellbeing, and a new section in the number of consultees and Development Strategy linked to represented a significant this. gap in the Regulation 18 Plan.

3) Development Update housing numbers to reflect To reflect updated evidence Strategy new plan period 2016-2033 and on Objectively Assessed reflect increase in Objectively Needs. Assessed Needs from 7,123 to 7,718.

Delete policies DS2 (housing To enable small sites to be provision) and DS3 (urban capacity updated over time through sites) and incorporate into DS1. the Authority Monitoring Report. Delete ‘rejected options’ section To streamline document, and the ‘cross boundary strategic and focus policies on planning’ section, and replace by implementation, as advised cross-references to the appropriate by the Planning documents. Inspectorate.

Health and Wellbeing Strategy To reflect new objective. added.

Part 3: Places 4) Sustainable Retitle as ‘introduction’ and add To provide an introduction. Place-Making brief introduction to Part 3. 5) Brookfield Minor amendments to text and Additional detail following concept diagram. from the Transport Strategy. 6) Broxbourne Broxbourne school policy updated. To reflect permission granted.

Section Changes Comments 7) Cheshunt Cheshunt Lakeside: a) increase Cheshunt Lakeside: Based dwellings from 1,000 to c. 1,750 on critical appraisal of the with heights capped at 8 storeys b) latest evidence submitted clarification of the need to mitigate by the site promoters and impacts on the nearby Special work undertaken with Protection Area. Natural England on the Habitats Regulations Assessment. Rosedale Park: a) insert 50 Rosedale Park: a) to dwellings South of Andrews Lane facilitate the Green Link b) b) South housing increased from based on appraisal of latest 340 to 360, north from 375 to 380. promoter submissions. New policies on Cheshunt Park To provide guidance on the and Cedars Park. future of the parks. Bury Green and Churchgate: a) Bury Green and new policy for the Former East Churchgate: a) To reflect Playing Field b) new policy for the suitable, availability and Council offices. achievability of development on the site b) to clarify existing position on the Council offices SLAA site Deletion of policy on Maxwells To provide flexibility in Farm West and Rush Meadow relation to the future use of this site. Increase of housing proposed at To reflect scrutiny of the Cheshunt Sports Village from 120 latest proposals and to 165. estimated capacity of the site. 8) Goffs Oak and South of Goffs Lane reduced from To reflect reduced site area St James’ 45 dwellings to 30 dwellings; to keep avoid the open valley landscape. Clarification that the designated To reflect availability of land Village Green on Jones Road will to expand the school to the remain, that Woodside School will east. extend on land to the east. Deletion of Oakfield policy. To reflect conclusion of the Green Belt Topic Paper that the exceptional circumstances necessary to release Oakfield from Green Belt do not exist. 9) Hoddesdon Deletion of Rye Park residential To reflect conclusions of site allocation policy (Lee Valley the SLAA assessment that Industrial Estate). the existing employment area is in active use and therefore not available for housing.

Section Changes Comments Deletion of proposals to re-open Reflecting advice from Ryelands. Insertion of plans to Hertfordshire County expand Cranborne and St. Council. Catherine’s primary schools. 10) Park Plaza Minor additions and clarifications to Planning permission has policies PP1 and PPS, including now lapsed but the issues clarification of transport remain current. infrastructure. Expand Policy on Plot D and rename as Park Plaza South 11) Waltham Clarification added that Fishpools is To reflect request by Cross seeking to relocate to Park Plaza Fishpools. North. 12) Wormley and New River Secondary School: New River School: to reflect Turnford primary access from the A10 to technical studies looking at Turnford link Road. access options. Proposed location of Turnford To reflect further work on station has moved to a location station access options. between Hertford Regional College and Groom Road.

Possibility of major redevelopment To reflect early proposals of the Macers Estate. from B3 Living. 13) Lee Valley Spitalbrook: long-term development Consideration of Crossrail Regional Park potential of parts of Spitalbrook 2. beyond the Local Plan period. New policy on the Britannia Britannia Nurseries policy Nurseries site at location of extant included for consistency planning permission for 90 homes. with the approach elsewhere e.g. High Leigh Garden Village. 14) Countryside No major changes - 15) The New No changes - River 16) Gypsies, Reduce additional pitch provision Conclusions of the Gypsy Travellers, and from 31 to 21. and Traveller Travelling Accommodation Needs Showpeople Assessment. Delete previously proposed Landowner confirmed that extension to Travelling Showpeople needs can be met within site at Goffs Lane. existing site area. Reduce size of the St James’ Assessment of need for Traveller site as shown on the that site. policies map. Part 4: Infrastructure and Delivery

Section Changes Comments 17) Infrastructure New policy on the Broxbourne To reflect the availability of Transport Strategy, and details the strategy. updated on specific transport proposals. Bus transport policy updated. To reflect the transport strategy.

Walking and Cycling Strategy To reflect the availability of updated and North to South paths the Local Walking and policy deleted. Cycling Infrastructure Plan. New policy on utilities statements. To ensure early resolution of utilities provision. New policy on hotels. To reflect availability of suitable sites and Council aspirations. 18) Planning New sections on Infrastructure To reflect the availability of Obligations and Delivery Plan and priorities for the Infrastructure Delivery CIL planning obligations. Plan. 19) New policy on delivery of To assist with delivery. Implementation development (compulsory purchase). Part 5: Development Management Policies 20) Design and Split policy DSC1 into new policies To create shorter and more Sustainable DSC2, 3 and 4. user-friendly policies. Construction 21) Housing Deletion of starter homes To address concerns about requirement. the Council’s waiting list – starter homes no longer a government requirement. Deletion of 20% affordable housing No evidence base to justify. for sites between 5 and 10 units; New policy resisting loss of Reinstated from existing specialist residential (2005) Local Plan; accommodation. Policy tightened to resist Concerns about impacts on permanent residential moorings. river environment. 22) Economic New policy to protect designated Omission from first draft. Development employment areas. Deletion of policy on visitor Policy duplicates other infrastructure and attractions. infrastructure policies. 23) Retail and Brookfield changed from Borough Consistency with standard Town Centres Centre to Town Centre in the retail definition of town centres. hierarchy. Deletion of policy criterion Lack of local evidence. restraining new hot food takeaway uses in proximity to schools.

Section Changes Comments 24) Open Space, Strengthened protection for To protect undesignated Recreation, and undesignated amenity spaces; land used as a community Community amenity space. Facilities 25) Water No significant changes - 26) Green Belt Simplification and clarification of To assist in implementation policy on residential development of the policy. on derelict glass house sites. Deletion of policy on new glass Unnecessary policy – house and nursery developments. covered by other policies. 27) Natural New policy providing general To distinguish clearly Environment and strategy for biodiversity. between overall strategy Biodiversity and specific protections. Additional protection for ancient woodland and veteran trees. 28) New general policy on To protect the amenity of Environmental environmental quality. existing residential Quality properties; Minerals and waste policies Cross-refer to County deleted. Minerals and Waste Local Plans. 29) Heritage Section title and references To broaden scope to Assets amended to ‘historic environment’; include setting. New policy on general strategy for To set out the Council’s the historic environment added. proactive approach to managing the historic environment. Protection for the setting of listed To strengthen protections buildings extended to include all and streamline the existing heritage assets, and combine with policies. separate policy on the setting of nationally designated assets. Policy wording on enabling To improve navigability of development moved to a dedicated the document. policy. 30) Transport Policy wording on electric vehicle To improve navigability of and Movement charging points moved to a the document. dedicated policy. Parking standards policy amended To provide a wider range of to include consideration of information to inform the accessibility to shops, services, application of parking and sustainable transport standards. infrastructure. Appendix A: Deleted To include a Housing comprehensive, updatable Trajectory trajectory as a separate spreadsheet.

Section Changes Comments Appendix B: Deleted To enable updating of the Urban Capacity urban capacity sites over SLAA sites time through updates to the SLAA. Appendix C: No changes - Schedule of Urban Spaces Appendix D: Car No changes - and Cycle Parking Standards Appendix E: List Updated to reflect changes to To reflect the proposed of policies policies as set out above. changes. Appendix F: Definition of derelict glass house To aid interpretation of Glossary sites added policy in Green Belt section. Appendix G: Amendments to reflect changes set To update the diagrams. Concept out in Part 3: Places above. Diagrams

Appendix D – Regulation 19 Pre-Submission Local Plan Respondents

111 individuals and organisations responded at this stage, as listed below. The consultation took place between 9 November and 21 December 2017. An index setting out which clients each agent represents is submitted separately alongside the full set of representations received.

Individuals:

Daryk Armfield, Mr & Mrs J & G Baldrey, Mr Malcolm Briggs, Mr Ian Cargill, Mr Tom Carroll, Mark Chaplin, Mrs Evelyn Cotter, Dr Carol Cragoe, Nick D'Agati, Mrs Leena Demirci, Mr James Detheridge, Mrs Joanne Fortune, Ms Annie Freeman, Mr Neal Freeman, Mr S Garib, Ms Denice Gately, Mr Ron Gibbs, Mr Robert Henbest, Mr Mark Henderson, Mr Tim Maloy, Ms Mead, Mrs Kelly Mewes, Mr Geoffrey Nixon, Neil Pearson, Mrs Pierce, Mr M Robinson, Dr David Storey, Mr Richard Scott Streater, , Lisa Smith, Dr Ian Tucker, Keith Veralls, Mr Scott Ward, Mrs L West.

Clients & Site Promoters:

Mr R Brunton, Messrs Lambe and Rafferty, Steven Liddard, Mr G Spitaliotis, Mr Harold Pritchard, Harvey Family, Michael O'Connor, Mr Tony Sawyer, CG Edward, Adam Hunt and the Petts Family, Peter Elliot, Abbey View Produce, Aldwyck Housing Group, Aquila Developments and Pears Property Group, Bayfordbury Estates Ltd, Brookfield Property Unit Trust, CEG, Cheshunt Lakeside Developments Ltd , Countryside Properties Ltd. , Crest Nicholson, Cushman and Wakefield1 (Agent), Derwent London, Fusion Residential2, HCL (Hertford Road) Ltd, Hertingfordbury Road Ltd, HHGL Ltd, Inspire Village Group, Kechto Holdings Ltd, Kentucky Fried Chicken (Great Britain) Limited, Kier Property Developments Ltd, Lands Improvement, London & Cambridge Properties Limited, LW Developments, Rentplus UK Ltd., Sainsbury's Supermarkets, Sapphire (Harlow) Nominee, Standard Life, Stoford Developments Ltd, StX (A10) Ltd, Tesco Stores Limited, The Co- Operative Group, The Hertfordshire University NHS Foundation Trust, Trent Developments, Wharf Road Residents, Woodhall Properties (London) Ltd.

Organisations:

B3 Living Ltd, Campaign to Protect Rural England Hertfordshire (CPRE), Canal and River Trust, Car Spares Cheshunt Ltd, East and North Herts Clinical Commissioning Group, Education and Skills Funding Agency, Enfield Council, Environment Agency, Eurovia Infrastructure Limited, GATE Herts (Gypsy & Traveller Empowerment), Goffs Oak Community Association3, Greater London Authority, Harlow Council, , Herts & Middx Badger Group, Herts and Middlesex Wildlife Trust, Public Health Service -

1 Cushman and Wakefield submitted a response on behalf of a potential purchaser of Park Plaza North. For the time being, until the purchase concludes, the client wishes to remain anonymous. 2 Fusion Residential have been represented twice by two different agents for different sites. 3 Represented twice by 1) Murray Scott, and 2) Mr Barry Cressey.

Hertfordshire County Council, Hertfordshire County Council Development Services, Hertfordshire County Council - Environment Department, Hertfordshire County Council - Property and Estates, Hertfordshire Local Enterprise Partnership, Highways England, Historic England, Lee Valley Regional Park Authority, Natural England, Sport England, Thames Water Utilities Limited, Transport for London, Transport for London - Commercial Property, Welwyn Hatfield Borough Council.

Appendix E – Copies of Publicity Materials

Broxbourne Life magazine, distributed to households across the borough and containing 5 pages on both draft Local Plan consultation and details of the 3 public meetings.

Poster put up at the Borough Offices, One-Stop Shops and noticeboards across the borough.

Council website homepage screenshot during Reg 18 Consultation period (18 July – 16 September 2016)

Pre-Submission Local Plan consultation, November-December 2017

Broxbourne Life magazine, distributed to households across the borough and containing 5 pages on both the transport strategy and Pre-Submission Local Plan consultations.

Advertisements in Hertfordshire Mercury

Above: 9 July 2016 edition

Right: 9 November 2017 edition

Local Plan Update

The Local Plan Update e-newsletter was used to publicise the Draft Local Plan Consultation in July 2016 and the Pre-Submission Local Plan in November 2017. The newsletter is distributed to everybody who has indicated a wish to be on the list.. Updates have been issued regularly throughout the process of plan preparation as follows: February 2016; April 2016; July 2016; October 2016; April 2017; July 2017, November 2017. Current and previous issues are online at www.broxbourne.gov.uk/lpupdate.

Appendix F – Regulation 19 Official Statements

The following statement was published for the duration of the Pre-Submission Local Plan consultation in print and online:

Statement of Representations Procedure (Regulation 19)

The following statement was published for the duration of the Pre-Submission Local Plan consultation in print and online:

Appendix G – Summary of the issues raised (Regulation 19 stage)

Section/Para Summary of responses Policy

Whole Plan Objection:  Development set out will result in a definite loss of biodiversity and the woodland inhabited by numerous species would be seriously impacted upon [Herts & Middlesex Badger Group, ID 334].  Needs to carry out a full ecological survey and incorporate adequate mitigation, including wildlife corridors and tunnels [Herts & Middlesex Badger Group, ID 334].  Need to reconsider Brookfield development because of importance of area to biodiversity [Herts & Middlesex Badger Group, ID 334].  Consultation inadequate [Denice Gately ID196 & 197]

Modification Requested:  Possible solution/modification would be to seriously reduce the size of these developments so that they do not result in a loss in the biodiversity [Herts & Middlesex Badger Group, ID 334].  Plan to advise developers to consult Canal & River Trust’s Code of Practice for practical advice [Canal & River Trust ID 560]

1. Introduction 1.6/Figure 1 Requested Modifications Sustainable  Fig 1 amended so environment circle reads "natural, built, and Development historic environments". [Historic England ID 146]  emphasise the environmental role of sustainable development involves protecting and enhancing the natural, built and historic environment. [Historic England ID 146]. 1.9 Support  Support for removal of Faints Close site from the Green Belt [Woodhall Properties Ltd, ID 436] 1.13 Requested Modifications  Spatial Portrait to include reference to historic environment of the borough [Historic England ID 147]  Borough is in the middle Lea Valley, not Upper Valley and not in ‘core area’ of the London Stansted Cambridge Corridor (LSCC) [CPRE, ID 335]. 1.17 Requested Modifications  The words ‘protected by the Green Belt’ should be added after ‘attractive countryside’ in the first sentence [CPRE, ID 336]. 1.19 Objection  Councillors should be knocking on people’s doors to engage better [Denice Gately ID 61] 2.Vision and Objectives 2.1 Objection  Fails to address NPPF para. 156 [Historic England ID 148]

Modification Requested:  Release 305 Ware Road, Hailey (a sustainable, urban, previously developed site) from the Green Belt [Hertfordshire University NHS

Foundation Trust, ID 322].  References to focussing development on Green Belt land, expansion of Brookfield and building commercial offices in the Green Belt at Park Plaza West should be removed from the Section 2.1 Vision [CPRE, ID 338]. Vision Support:  Vision to maximise job creation, diversify economic base and reduce out-commuting [CEG, ID 298].  Expect references to the historic environment in the vision, the inclusion of a policy/ies and other references to the historic environment throughout the plan [Historic England, ID 223]. 2.2 Objection  Merging of distinct settlements [Denice Gately, ID 62]  Policies for housing, retail, and transport and site allocations need to conserve and enhance the historic environment, and avoid harming heritage assets and their settings [Historic England, ID 223]. Support  Support objective to enhance and protect historic environment [Historic England ID 148]  Provides consistency with the Local Plan’s vision for creating healthy places [Sport England ID 2].  Support employment objective [CEG, ID 298].

Modification Required:  Insert new objective to protect the Green Belt as the first of nine objectives [CPRE, 338] 3.Development Strategy Whole Chapter Modification Required:  Strategy should be redrafted in the context of NPPF paragraph 14 and in accordance with the Barwood court judgement [CPRE, ID 340]. 3.1 Object:  Chapter should set out strategy for implementing a specific objective to protect the Green Belt [CPRE, ID 339]. Growth levels Comment and locations  historic environment should have been considered earlier in selecting growth locations [Historic England ID 149]. Modifications Requested  Insert reference to the cumulative impact of smaller development [Hertfordshire County Council, Environment Department, ID483] 3.2 Objection  Plan does not take Brexit into account when calculating OAN [Denice Gately, ID 63]. Allocating Land Objection to  The presentation of the site allocations should be clear and Accommodate accessible. Precise boundaries to be shown [Historic England ID Growth 149]  Expect to see references to setting and how this could be enhanced in policies throughout the Plan [Historic England ID 149].

3.5 & 3.6 Modifications Requested  303 Ware Road (on its own) should be released from the Green Belt as iit does not serve GB purposes (Stephen Liddard, ID 316).  Release 305 Ware Road, Hailey (a sustainable, urban, previously developed site) from the Green Belt [Hertfordshire University NHS Foundation Trust, ID 321]. 3.7 Support  The overall provision of 6,500 net additional jobs, and the strategic release of land at Park Plaza West to provide new employment opportunities are supported. [CEG, ID 299].  Additional evidence provided to support the Council’s case for exceptional circumstances at Tudor Nurseries [CEG, ID419] 3.9 Objection  No clarity/consultation on Green Belt [Daryk Armfield ID 43]. 3.12 Modifications Requested  Amend to include Land at Hertford Road as a reserve site, suitable for 130 houses [HCL (Hertford Road) Ltd].  Amend incorrect reference to Maxwells Farm West as having reserve site status under Policy CH8 [StX (A10) Ltd, ID 435] 3.14 Modifications Requested  Provision for older and vulnerable peoples to be addressed [Denice Gately ID 140] 3.15 Objection  Avoid building on glasshouse sites - of value to shops and households [Daryk Armfield, ID 50] 3.16 Objection.  OAN incorrectly calculated [Denice Gately ID 65 & 141].  Does not address the interim period between the end of the last plan and 2016 so five year gap which has not been accounted for in terms of housing need. [Mrs Pierce, ID 314].  20% buffer not explained [Mrs Pierce, ID 314].  Support development strategy to focus on urban/brownfield land first - but oppose Rosedale Park coming forward until very end of plan period as a last resort [David Storey, ID542] Support

 Support housing trajectory and Tudor nurseries contribution, although the pace indicated is too conservative [CEG, ID421] 3.19 Support  Lichfields analysis supports the economic development strategy [CEG, ID 300].

Objection  BELS statistics incorrect [Denice Gately ID 141]  Plan does not take into account Brexit [Denice Gately ID 141] 3.21 Objection  No provision for business relocations [Mrs Pierce, ID 99] 3.24 Objection  No assessment of jobs provision/need/relocations [Mrs Pierce, ID 100] Support

 There is scope to deliver in the order of 100,000sq.m of high quality office space and the Council’s approach set out at paragraph 3.24 is supported [CEG, ID 300]. 3.28 Object  Object to Brookfield as a Town centre in the retail hierarchy as it could have a significant impact on Harlow [Harlow Council, ID546] 3.29 Objection  Prioritise brownfield first [Denice Gately, ID 68] 3.31 Support  Support design approach that reinforces character and distinctiveness [Historic England ID 149] 3.33 Modifications requested  Address inconsistent use of ‘local strategic gap’ [Crest Nicholson, ID422] 3.34 Objection.  Council has permitted development in the countryside [Denice Gately ID 69] 3.36 Objection  Concern about historic assets such as Darkes Moat [Denice Gately 70]  No heritage assessment of the impact of Park Plaza West on Theobalds Manor [Mrs Pierce 101] Support

 listed buildings Theobalds Park Farm as part of Park Plaza West will secure their long term retention as a feature [CEG, ID 301]. 3.39 Objection  Impact of traffic on AQMAs [Mrs Pierce ID 102] 3.40 Objection  Transport Strategy ignores other key routes besides A10 [Mrs Pierce ID 103] 3.56 Objection  Poor air quality on school run as a result of [Mrs Pierce ID 105] Table 1 Objection  Why refer to the Brownfield Register when it has not yet been published? [Denice Gately ID 67] Figure 2 Objection  Figure misleadingly suggests that Goffs Oak Ward/Rosedale Park area is built up whereas actually large parts are Green Belt/countryside [GOCA]. Modifications Requested  Amend Figure 2 to reflect masterplan and delete Local Green Space designation [CEG, ID 304]. Policy DS1: The Support Development  Support the development strategy [Crest Nicholson, ID415] Strategy  Support references to new secondary school and five new primary schools [Hertfordshire County Council Development Services, ID 461]  Support use of the GLA housing projections and commitment to meet needs in full [Greater London Authority, ID577]

Objection  Number of planned homes is too high [GOCA, Tom Carroll]  Object to greenfield/Green Belt development and destruction of countryside [Daryk Armfield ID 44]  The Council should be planning to deliver 8,500 dwellings as against 7,700 dwellings. [Harvey Family ID 227, Michael O’Connor ID 271].  The Council should conduct an early review of the Plan to meet the higher housing target. [Michael O’Connor 271].  Question appropriateness of the Brookfield allocation (see under BR1)[HCL (Hertford Road) Ltd, ID 552]  Why is borough assumed to be a Housing Market Area (HMA)? [HCL (Hertford Road) Ltd, ID 552].  Support increase in OAHN in the partial review of the SMHA, although underestimates housing need for the Borough [HCL (Hertford Road) Ltd, ID 552].  454 homes pa below real housing need – smaller sites such as Hertford Road, Hoddesdon, would help [HCL (Hertford Road) Ltd, ID 552].  Housing trajectory not based on a 5-year supply at all points of the trajectory [Countryside Properties Ltd, ID458]  Housing target to be raised to raised to 8,500 units, with Cheshunt Country Club / Theobolds Sports Ground considered as a site to meet this increase [Tesco Stores/GL Hearn (agent) ID555]

Modifications Requested:  Clarify why Maxwells Farm West cannot be used to address some of the unmet need in the Welwyn Hatfield HMA [Welwyn Hatfield BC, ID 452] Housing Support strategy  Support the housing strategy, but crucial to bring forward the SLAA site owned by TfL property at Theobald’s Grove station car park [TfL Commercial Property ID40]  Support the housing mix [CEG, ID420] 3.52 Support  Consistent with Government/Sport England strategy for sport and Health and physical activity [Sport England, ID 3] Wellbeing  Will enable achievement of improved physical and mental health Strategy [Public Health Service, Hertfordshire County Council ID 80] Modifications Requested  Include a policy requiring development to be subject to health impact assessment [Public Health Service, Hertfordshire County Council, ID 80] 3.55 Object:  Wait for the Old Pond development strategy to be created before building alternative retail centres to the Old Pond [James Detheridge, ID 385].

4.Introduction to Part 3: Sustainable Place-Making PM1:Sustainabl Object: e Place Making  Policy PM1 not explained/not effective [Mrs Pierce, ID 106] 5. Brookfield Whole Chapter Objection  Unclear how the allocation of this site has been justified – requires further justification and impact assessments [Historic England ID150].  The entire chapter should be removed from the plan as the development is contrary to national policy, is not justified by exceptional circumstances, and unjustified [CPRE, ID 341] Modifications Requested:  Insert reference to important heritage assets and how effect of Brookfield on these assets will be mitigated [Historic England ID150]. 5.2 Objection  Unfair to relocate the allotments and the gypsies and travellers [Malcolm Briggs ID 19]  Unacceptable impacts on Hells Wood and the ancient monuments [Malcolm Briggs, ID 19]  Brookfield proposals will destroy existing local shops and bring traffic chaos [Malcolm Briggs, ID 19] Figure 3: Modification Requested: Brookfield  Both my land and my neighbors Nick D'Agati is still shaded Riverside and incorrectly as community woodland to the north west corner of the Garden Village plan [Mrs Kelly Mewes, ID 329]. Indicative Concept Plan 5.6 Objection  Impact on elderly residents not considered [Mrs Pierce, ID 107] 5.10 Objection  Brookfield will increase traffic and congestion, drawing trips from outside the borough [Mrs Pierce, ID 108] 5.19 Objection  Soft edges to the Brookfield development are indefensible [Mrs Pierce, ID 109]  Land is marked incorrectly as community woodland and inaccurately described. It is flat level grazing land for horses. Once housing borders the land this will make the usage for horses unsuitable [ Mrs Kelly Mewes, ID 330]. 5.21 Objection  Segregation of the garden village into areas of ‘family and executive homes’ will result in ghettoisation [Mrs Pierce, ID 110] 5.24 Objection  Inadequate provision for relocation of existing businesses [Mrs Pierce, ID 112]  Need to resolve issue of relocation of the household waste recycling centre [Hertfordshire County Council, Environment Department, ID523]

BR1: Brookfield Objection  Retail development in an out of town location unjustified [Aquila Developments and Pears Property Group, ID 318].  Relocated uses should be relocated to flagship development sites [Aquila Developments and Pears Property Group, ID 318].  The adverse impact of Brookfield Riverside on Harlow Town Centre generated by “excessive” development is underestimated and not adequately addressed by the Retail Impact Study [Harlow Council, ID545, Sapphire Harlow ID608]  level of retail and leisure floorspace will have negative impacts on existing nearby town centres [Enfield Council, ID602]  Scale of retail floor space proposed is equivalent to the scale of retail floor space rejected in 2011, thus reasons for rejection in 2011 still apply [Sainsbury’s Supermarkets ID450, Standard Life ID592]  relocate Household Waste Recycling (HWRC) and Council Depot [Harvey Family, ID 228].  Land at Hertford Road, Hoddesdon is free from constraints and more logical than Brookfield [HCL (Hertford Road) Ltd, ID 261].  Inconsistencies between the plan and the Brookfield Retail and Leisure Impact Assessment regarding retail floorspace [Tesco Stores Ltd, ID559]  Impact on existing retail centre as a result of Brookfield Riverside allocation and changes to highway network cannot be fully assessed without further information [Tesco Stores, ID559]  Development would have negative impact on existing use of adjacent land [Nick D’Agati ID597]  Include protection of Ancient and Semi-Natural Woodland and the maintenance of connectivity with the wider landscape [Natural England 672].  Brookfield Riverside: Development should be planned to ensure no building in the floodplain and enhance the river and its riparian zone [Environment Agency, ID 677].  A buffer strip of at least 8 metres (m) must be left alongside the river channel [Environment Agency, ID 677].  The Local Wildlife Site and Ancient Woodland must be protected and left undeveloped [Environment Agency, ID 677].  no mention of the needs of secondary school age children [Mrs Pierce, ID 111]

Support

 A much-needed cohesive retail, leisure, and civic centre for the borough - detailed reps attached [Bayfordbury Estates Ltd, ID460]  County Council as landowner supports the allocation and is working with Broxbourne Council in relation to masterplanning [Hertfordshire County Council - Property and Estates, ID614]

 Support (Herts County Council, Development Services, ID 622]

Modifications Requested

 Both Maxwell’s West and Park Plaza North are better suited locations for a HWRC and Council Depot [Harvey Family, ID 228].  The Business Park at Park Plaza West combined with land at Maxwell’s Farm West would collectively provide the critical mass to establish a Business area of Regional significance [Harvey Family, ID 228].  Land adjoining the site to the north should be included as part of the Brookfield development. This would open an alternative access route to the development via Holy Cross Hill [Mrs Kelly Mewes, ID 331].  Delete reference to Brookfield Town Centre status and insert requirement for applications over 1000sqm retail to be accompanied by a retail impact assessment on centres within catchment area [Welwyn Hatfield BC, ID453]  Address public transport accessibility in the policy [Hertfordshire County Council, Environment Department, ID469]  Scale of retail floor space at Brookfield Riverside must be reduced [Tescos Stores Ltd ID559, Standard Life ID592]  Add reference to opportunistic sand and gravel extraction [Hertfordshire County Council, Environment Department, ID519]  A site for a 3 forms of entry of primary schooling school (Herts County Council, Development Services, ID 622]. 6.Broxbourne 6.1 Objection  Statement that population of Broxbourne (village) will remain stable to 2033 contradicts statement at 3.3 that population of Broxbourne (borough) will rise [Daryk Armfield, ID 42] BX1: Objection Broxbourne  Site not shown on interactive map or in plan [Historic England Village ID151] Improvement  Mention should be made to the Conservation Area and the need to Plan protect and enhance this [Historic England ID151] BX2: Objection Broxbourne  The policy lacks clear policy aims and so the impacts on European Station and Sites have not been adequately assessed through the Habitats Environs Regulations Assessment [Mrs Pierce ID113].  There must be no negative impact on the New River or Spitalbrook [Environment Agency ID 678].  Options to enhance the rivers should be explored as part of the redevelopment to give a net gain for biodiversity [Environment Agency ID 678].  Site not shown on interactive map or in plan [Historic England ID152]  Station is grade II listed - this and any measures regarding this should be included in wording [Historic England ID152].

Modifications requested:

 Add reference to high-quality transport interchanges and non-car modes [Hertfordshire County Council, Environment Department, ID470]  Strengthen policy to better reflect long-term opportunities offered by Crossrail 2 [Greater London Authority, ID578, Transport for London, ID582]  Add reference to south and east side of the railway line to paragraph 6.3 [Transport for London, ID 581] BX3: Objection Broxbourne  Unclear what the policy seeks to achieve [Mrs Pierce] School  Insufficient protection for heritage assets/setting [Historic England ID153]. 7.Cheshunt 7.1 Object:  Brookfield should not be developed until the plans for the old pond are finalised [Mrs Evelyn Cotter, ID 332].  Object to CPO proposals [James Detheridge, ID 373, Mrs Evelyn Cotter ID333]. 7.2 Modifications requested:  Insert reference to current lack of bus service [Hertfordshire County Council, Environment Department, ID481] 7.4 Object:  Building a piazza on such a useful potential roadway shows a lack of imagination [James Detheridge, ID 388].  density of flats too high [James Detheridge, ID 389].  sustainability appraisal has not assessed full number of planned homes [James Detheridge, ID 389, Dr Ian Tucker, ID445]. 7.5 Objection  Unclear what interventions will be made to ensure the viable relocation of existing business [Mrs Pierce, ID 115]  Should exclude the pedestrian plaza to be built over the private right of way [James Detheridge, ID 382].  Council failure to consult local community [Mrs Leena Demerci, ID 417]  Complaint about behaviour of site promoters contractors [Mrs Leena Demerci, ID 426] Policy CH1: Objection Cheshunt  No proposal from the Council or developers to relocate our Lakeside business [Car Spares Ltd ID 39, Eurovia ltd, ID 229]  Land should not be purchased by the developers if it does not yet have planning permission ([Ian Cargill, ID 76]  Unrealistic/unreasonable offers for our property [Ian Cargill, ID 76]  Negative impact on Old Pond shops [Ian Cargill, ID 76]  Congestion on the local road network [Ian Cargill, ID 76]  Habitats Regulations Assessment does not address the full impact of 2,000 homes proposed by the developers and the full

range of impacts including different species and impacts [Mrs Pierce, ID 116]  No mention of the effects of the extended period of construction on existing businesses [Eurovia ltd, ID 229].  Policy should include a requirement to bring the development forward in conjunction with an approved masterplan [Eurovia ltd, ID 229].  No mention of how the requirement to pursue compulsory purchase would affect the deliverability and viability of the development [Eurovia ltd, ID 229].  No evidence to support the assertion that the proposed allocation is deliverable.  No certainty that compulsory purchase powers shall be successful or viable for all parts of the proposed development [Eurovia ltd, ID 229].  No highways schemes proposed in Plan or IDP to mitigate the effects of this development of 1750 homes on congestion on local roads such as Windmill Lane, other than some minor walking and cycling to Cheshunt Station [Eurovia ltd, ID 229]  Policy CH1 cannot simply require the ‘priorities of the IDP’ to be dealt with as is unlawful. Case law has made clear that contributions in a planning obligation towards a pooled fund on infrastructure which had no more than a trivial connection to the development in question are unlawful [Eurovia ltd, ID 229].  Development is based on the premise of Crossrail 2 although there is no certainty about if or when this will proceed [Eurovia ltd, ID 229].  The relocation of the Network Rail depot should be removed as understand it is no longer part of the development [James Detheridge, ID 383].  Produce evidence to show that there is demand for shops at Windmill Lane Neighbourhood centre including footfall, type of shop needed [James Detheridge, ID 380].  Policy should make clear that any proposal must take account of any agreed mitigation strategy and implementation of this strategy [Natural England ID 669].  Enhancements must be made to the Windmill Lane Ditch and Small River Lee to provide a net gain in biodiversity and an 8m buffer strip provided [Environment Agency ID 679].  Conflict of interest in Council relying on developer feasibility testing of capacity [Dr Ian Tucker, ID 429]  Development promotes “excessively high population density” causing pressure on the transport network [Mark Chaplin ID604]  Existing businesses not considered in the proposals [Mark Chaplin ID604]

Support

 Comments on behalf of Cheshunt Lakeside Developments Ltd [ID 668]. a. Support inclusion of the need to have a master plan framework. b. Support the Council’s commitment to use compulsory purchase powers c. Site to be optimised for residential-led development. d. Sie able to accommodate more than the stated 1750 dwellings e. Accommodation of affordable homes is supported but policy must show consideration of viability f. Fixed limit on building height is considered arbitrary g. inclusion and quantum of elderly or specialist housing types should be determined on a needs basis and the need to optimise the site for housing. h. Policy should show clarity regarding the type of compatible business uses that will be sought. i. Relocation of the Network Rail depot is subject to Network Rail operational requirements j. Development of the site should be subject to the parking ratios agreed at pre-application stage.

 Amendments to the policy welcomed [Lee Valley Regional Park Authority, ID 78]  Support inclusion of primary school and master planning process [Herts County Council, Development Services, ID 623].

Modifications Requested:  Amend point 8 as follows: “landscaped open space, including dedicated areas for dog walking” [Lee Valley Regional Park Authority, ID 78]  Needs references to further evaluation at the project level and an outline of potential mitigation measures in the Appropriate Assessment [Natural England ID 669].  Add the following text to the end of the paragraph which begins “the Council will work in partnership…” “This mitigation plan should include a robust monitoring schedule which will allow for re-evaluation and amendments to the scheme to ensure that it meets the required objectives.” [Lee Valley Regional Park Authority, ID 78]  Amend policy to include provision for a strategy to accommodate existing business on the site and support the relocation of existing businesses [Eurovia ltd, ID 229].  Policy needs to include specific provision for emergency vehicle access to properties the other side of the Windmill Lane crossing [Eurovia ltd, ID 229].  Policy CH1 needs to include alternative arrangements to deal

with the possibility of Crossrail 2 not coming forwards as planned [Eurovia ltd, ID 229].  Supporting text should consider the closure of the level crossing with Crossrail 2 and how the new road crossing will be accommodated [ Transport for London, ID583]  Housing density reduced on Delamere Road [Mark Chaplin ID604].  Development of new housing on part of the proposed business park on the A10 [Mark Chaplin ID604]  A site for a 2 form of entry of primary schooling school [Herts County Council Development Services, ID 623].  Detailed wording to be amended to better reflect the development opportunities of the site. 7.7 Modifications requested  Regulations dated 2017, not 2010 [Hertfordshire County Council, Environment Department, ID503] 7.8 Objection  Plan needs to identify the specific mitigation measures on the SPA [Mrs Pierce, ID 117] Rosedale Park Modification requested:  Paragraphs 7.9-7.11 should be removed from the plan as the development is contrary to national policy, is not justified by exceptional circumstances, and unjustified [CPRE, ID 342] 7.10 Modification requested  Clarify that precise numbers will be established at the detailed planning application stage [Crest Nicholson, ID 439] Policy CH2: Objection Rosedale Park: Goffs Oak Community Association [GOCA] objects to the proposed site allocation as follows [IDs 24, 28, 30,33,34,35,37,38]:  Rosedale Park is located in Goffs Oak not Cheshunt  Rosedale Park housing proposals are too big to be accommodated by existing health facilities and too small to pay for new health facilities  Insufficient secondary school capacity  Harm to the Green Belt, especially coalescence with Cheshunt  Government favours sustainable locations such as next to railway stations rather than unsustainable car-dependent rural locations such as Rosedale Park  Majority of Tudor Nursery site is not derelict and is open land  Tudor nurseries site is viable for glasshouse/horticultural use  Flood risk at the Tudor Nurseries site  Biodiversity loss resulting from Tudor Nursery proposals  Rosedale Park North is a greenfield site with high landscape and biodiversity value  Misleading to claim that the housing will expand/extend/improve Rosedale Sports Club  Too much housing on Rosedale Park North

 Destruction of beautiful countryside  No need for additional open spaces/paths as Goffs Oak already well served  Unsustainable proposal as no access to services  No exceptional circumstances for release from Green Belt  Insufficient provision for elderly people [GOC, Mr Barry Cressey, ID449]

Other objections to Rosedale Park:  No development in floodplain [Environment Agency ID 680].  River buffer strip of at least 8m [Environment Agency ID 680].  Road network cannot cope [Keith Veralls ID 591, Dr David Storey, ID 58]  Cap on apartments will worsen affordability [Mrs Pierce]  No evidence of how secondary education need will be met [Mrs Pierce, ID 118]  Transport strategy will mean that residents will have to travel to Lieutenant Ellis Way or Brookfield [Mrs Pierce, ID 118]  Should mention the heritage assets close to the proposed development and any protections [Historic England ID 155]  Green Belt - ref Barwood court case 2017 [CPRE, ID 342].  5% apartments inappropriate [Crest Nicholson, ID 423]  Tree requirement excessive [Crest Nicholson, ID 424]  Unnecessary reference to CPO [Crest Nicholson, ID 427]  Site off Rags Lane should be allocated [Abbey View Produce, ID 573 ]  Tudor Nurseries should be retained.[Keith Veralls ID 591]  The council should not have assisted the landowners with their application prior to the matter going to public consultation [Keith Veralls ID 591]  merging of Goffs Oak and Cheshunt [Keith Veralls ID 591] Support  Proposals would provide much needed housing [M Robinson, ID 77]  Strategic site supported and additional evidence supplied [Crest Nicholson, ID 418, CEG, ID410]  Positive that it is stated that the Rags Brook valley will be protected and enhanced [Environment Agency ID 680].  Revisions to the greenbelt boundary supported [Peter Elliot, ID 607]  Support inclusion of primary school and master planning requirement [Herts County Council, Development Services, ID 624].

Modifications requested  Delete Policy CH2: Rosedale Park from the plan [GOCA]  Amend the capacity to "Approximately 65 homes" in respect of

land south of Andrews Lane [R Brunton, ID 364, G Spitaliotis, ID 367].  Indicate need to secure developer contributions for enhanced public transport [Hertfordshire County Council, Environment Department, ID 473]  Add caveats about viability on 40% affordable housing and local shop [CEG, ID536]  Land at Burton Grange to be included as a designated site for housing [Peter Elliot, ID 607]  A site for a 2 form of entry of primary schooling school [Herts County Council Development Services,ID 624]. Figure 5 Objections: Rosedale Park  Map not clear [Denise Gately ID 145] Indicative Concept Map CH3: Cheshunt Objections: Old Pond  No point in this policy [Mrs Pierce, ID 119].

Modifications Requested

 Any options to deculvert the College Brook river channel should be explored [Environment Agency, ID 681].

Support

 Support strategy which will seek to improve the appearance and experience of public realm. Consideration must be given to Heritage Assets, especially listed buildings [Historic England ID 156] CH4: Old Objections: Cambridge Road  No point in this policy [Mrs Pierce, ID 120] Corridor  Transport Strategy does not assess the impacts arising from right turn bans [Mrs Jenny Pierce, ID 120].  Options for an 8m buffer strip to the main river and habitat enhancements should be explored [Environment Agency ID 683].  Not clear whether housing proposed as part of the improvement plan for area. Any additional housing may have implications on school place planning in this area [Herts County Council ID 625]. Modifications Requested:

 Any options to deculvert the College Brook river channel should be explored [Environment Agency 682]. Support

 Support strategy which will seek to improve the appearance and experience of public realm. Consideration must be given to Heritage Assets [Historic England ID 157] CH5: Cheshunt Comment Park  not shown on interactive map [Historic England ID 158]

CH6: Cedars Support Park  Inclusion of Heritage Asset is supported [Historic England ID 160] 7.18 Objection  No clarity regarding quantity of development at Cheshunt Club [ID 129 Mrs Pierce].  Access to the site unclear [ID 129 Mrs Pierce]. CH7: Cheshunt Objection Football Club  The proximity of this site to Cedar's Park in retaining setting [ID 129 Mrs Pierce]  Proposed development unsuitable in area as inadequate access and out of keeping with surrounding victorian development [Mr Mark Henderson, ID 324].  Adverse impact on Cedars Park [Historic England ID 161]  Object to the enabling of public subsidy to the private development from the policy as currently worded [Hertfordshire County Council, ID616]  Policy refers only to Cheshunt Football Club. Reference is made in paragraph 7.18 to Policy INF11 allocating a primary school at Albury Farm but there is no policy within this section of the plan referring to the school allocation [Herts County Council Development Services, ID 623].  Figure 6 shows the proposed school being located to the east of the Cheshunt Club on land which is not in the ownership of the County Council [Herts County Council Development Services, ID 623].

Support

 Benefits to the continued viability of the football club and local community [LW Developments, ID464]

Modifications Requested

 Replace words ‘ to enable’ with the word ‘and’ [Hertfordshire County Council, Property and Estates, ID616] Policy CH8: Objection: Albury Farm  Lack of clarity regarding Landscape Protection Zone policy Landscape status, not NPPF compliant [ID 130 Mrs Pierce]. Protection Zone

Policy CH9: Objection Theobald’s Brook  Policy lacking in detail and depth [ID 131 Mrs Pierce]. Field Support

 Landowner support for policy [Hertfordshire County Council, ID617]

Modifications requested:  Reference to bus service routing [Hertfordshire County Council, Environment Department, ID482]  Policy CH9 refers to 96 homes being built at Theobald’s Brook Field; however, Figure 8 refers to the provision of 100 homes at the site [Herts County Council Development Services, ID 627].

CH10: East of Objection Dark Lane  Policy lacking in detail and depth [ID 132 Mrs. Pierce].  Heritage/archaeology not addressed [Historic England ID163].

Support  Policy is supported by HCC [HHC (M. Wells) ID 618]

Modifications requested  Wording to highlight need for archaeological evaluation[Historic England ID164] CH11: Former Objection Eastern Playing  Loss of residential amenity [Neil Pearson, ID 128] Field  No policy criterion to ensure that setting of heritage assets are protected or enhanced [Historic England ID 165]  Landowner objects to allocation for a care home, proposing 60 residential units instead [Hertfordshire County Council, Property and Estates, ID619] Policy CH12: Objection Land North of  Policy lacking in detail and depth [ID 133 Mrs Pierce]. Bonney Grove  Number of units not disclosed [Hertfordshire County Council Development Services, ID 629] Policy CH13: Objection Council Offices,  Policy lacking in detail and depth [ID 134 Mrs. Pierce]. Churchgate  Site unclear on proposals map [Historic England ID 167].  Setting of heritage assets (listed buildings) not protected or enhanced in policy [Historic England ID 167)  Impact on Conservation Area at Risk and setting of listed buildings [Historic England ID 167]  Number of units not disclosed [Hertfordshire County Council Development Services, ID 630] 7.23 Objection:  Paragraph removes this site from Green Belt but as there is no Maxwells Farm policy the proposed uses are unclear. If any proposals could West and Rush contain residential development, need an indication of the scale Meadow to be able to assess the impact on HCC services, particularly school places [Herts County Council Development Services, ID 631].

Support:  Highly accessible and suitable location for strategic employment [StX (A10) Ltd, ID 434]

Modifications requested:  more clarity on how site will be appraised and developed [ID 135 Mrs Pierce].

 Retain in Green Belt [CPRE, ID 343].  Clarify why Maxwells Farm West cannot be used to address some of the unmet need in the Welwyn Hatfield HMA [Welwyn Hatfield BC, ID 452] CH14: South of Objection: Hammondstreet  Impact on Grade II listed Woodmans Stores [Historic England Road ID168] 7.25 Modifications requested:  Reword to clarify that a new school is proposed in Wormley [ID 135 Mrs Pierce]. 8.Goffs Oak and St James Objection  Consented scheme at Oak View/Small Acre Crouch Lane is a dangerous precedent and should be mentioned in the Goffs Oak section [Goffs Oak Community Associated, IDs 31 & 32]  Cumulative impact of traffic on the B156 through Goffs Oak will be unacceptable [G and J Baldrey, ID 79]  Infrastructure, including GPs, cannot cope with proposed developments [Mr S Garib, Mr Richard Scott Streater ID 224, Mr Ron Gibbs ID 283, Mrs L West ID 398]]  Impact of proposed developments on the B156 [Mr Richard Scott Streater, ID 224].  Parking outside schools is currently dangerous which will get worse with more children [Mr Ron Gibbs ID 283].  The Plan is unsound because it does not make adequate provision for housing provision in the final five years of the plan period [Mr Harold Pritchard, ID 253].  Site CG-GB-31 should be considered for development [Mr Harold Pritchard, ID 253].  Northward extension to the village of Goff’s Oak preferable to development along the busy east-west road through the village [Mr Harold Pritchard, ID 253].  Goffs Oak cannot cope with any more traffic which is already re- routing [Mrs Joanne Fortune, ID 396].  Proposed 62 dwellings at Goffs Oak not clearly acknowledged as a possibility [Denice Gately ID 605]  Proposed volume of development will have negative effects that have not been considered. Key concerns include: a. Traffic b. Healthcare provision c. Public parking [Annie Freeman ID 609 & Neal Freeman ID 610]

 Plans do not correctly reference Tudor Nurseries and Rosedale Park as part of Goffs Oak. [Annie Freeman ID 609 & Neal Freeman ID 610] Support

 Support proposals for growth in Goffs Oak and expansion of

Woodside primary school [Welwyn Hatfield Borough Council, ID 454] Modifications Requested:  The only large scale developments, should have free access to the A10 / M25, along Lt. Ellis Way. Consider the acquisition of large plot alongside Lt. Ellis Way, owned by the Manning fairground family [Mr Richard Scott Streater, ID 224].  Rosedale allocation also gives access to the M25, through Lt. Ellis Way [Mr Richard Scott Streater, ID 224].  Allocate Oak Field for a development of up to 20 affordable homes [Tim Waller (agent) ID551] 8.1 Objection  Growth figures incorrect - do not to take account of the significant growth planned at Rosedale Park in Goffs Oak Ward, which cannot be supported by the infrastructure [GOCA ID 26, Robert Henbest ID 71] 8.2 Objection  Green Belt not protected [Denice Gately ID 159] GO1: Goffs Oak Objection Village  Policy not effective or positively prepared [Mrs Pierce ID 137]. Improvement  Policy not shown on interactive map or in plan [Historic England Plan ID 169] GO2:North of Object: Goffs Lane  Contrary to Green Belt policy [CPRE, ID 344].  Impact on Grade II Listed Burton Farm [Historic England ID170] GO3: South of Object: Goffs Lane  Delete as contrary to national policy and unjustified [[CPRE, ID 345].  Impact on Grade II listed Goffs Oak House [Historic England ID171]

Support:  Support principle of the allocation [Countryside Properties, ID459]

Modifications requested:  Enlarge site allocation to include Lafiya House and the south- western field - landscape rebuttal statement attached [Countryside Properties, ID459]  Enlarge site allocation to south-west to rear of Myles Court and Goffs Oak House[Michael O’Connor, ID272] GO4:Newgatestr Objection eet Road  Consented scheme at Oak View/Small Acre Crouch Lane is a dangerous precedent and should be mentioned in the Goffs Oak section (Goffs Oak Community Association, ID 31]  Unacceptable cumulative impact of traffic on the B156 through Goffs Oak [G and J Baldrey, ID 78] Support  Site is suitable, available and deliverable [Messrs Lambe and Rafferty, ID 121]

Requested Modifications  Increase the number of dwellings proposed from c. 25 to 32 [Messrs Lambe and Rafferty, ID 121] GO5: North of Support: Cuffley Hill  Site owners strongly support the allocation of the site for residential development in the Local Plan [CG Edwards, ID553]  Developer supports the allocation and submits additional evidence [Countryside Properties, ID611-3]

Modifications requested:  Developer seeks increase in number of dwellings proposed from 50 to ‘up to 59’. [Countryside Properties, ID611] 8.8 Objection:  Land off Poppy Walk should not be designated greenbelt [Mr Adam Hunt and the Petts Family ID554] 8.9 Objection:  No healthcare /schooling provision [Denice Gately ID 173]

Requested Modifications  The first sentence of Paragraph 8.9 should be reworded “There is currently sufficient spare secondary school capacity at Goffs School and the Goffs Churchgate multi-academy trust. in local schools.” [Hertfordshire County Council Development Services ID 632] 8.10 Objection:  Objection to lack of medical facilities [Denice Gately ID 180] 9.Hoddesdon Whole Chapter Modifications Requested:  Land at Hertford Road, Hoddesdon should be allocated for development of 130 homes on its 5 ha developable (sustainable and constraint free) land [HCL(Hertford Road) Ltd, ID 265].  Inconsistency between Policies Map and Interactive Map on employment area/wildlife site boundary at Essex Road employment area [Trent Developments, ID538]  The need arising for primary school places from the sites HOD2 and HOD4 can be met through the expansion of existing primary schools [Herts County Council Development Services, ID 633]. 9.1 Object:  Release 305 Ware Road, Hailey (a sustainable, urban, previously developed site) from the Green Belt [Hertfordshire University NHS Foundation Trust, ID 326]. 9.3 Modifications Requested:  Re-instate the dropped site allocation for Rawmec site, Plumpton Road [B3 Living Ltd, ID443] HOD1: Support: Hoddesdon  Support this policy [Historic England ID 175] Town Centre Modifications Requested:  B3 Living will promote a high quality high density scheme at 17+19 Amwell Street [B3 Living Ltd, ID446]

HOD2: Turnford Support Surfacing Site  Welcome intention to update the development brief [Lee Valley Regional Park Authority, ID 86] Objections:

 Impact upon setting of listed structures at Rye House [Historic England ID176].  Difficult site as completely within the floodplain. Careful consideration will be needed to match the land use to the level of flood risk including climate change allowance [Environment Agency, ID 684].  An 8m buffer strip and habitat enhancements should be proposed [Environment Agency, ID 684].  Site is adjacent to Rye Meads SSSI so there should be no disturbance/impact to this as result of any development [Environment Agency, ID 684].

9.8 Object:  Should restore reference to the Energy Recovery Facility at Ratty’s Lane which was determined at the County Council’s Development Control Committee on 20 December 2017 [Herts County Council Development Services, ID 635].

HOD4: High Objection Leigh Garden  process lacking in transparency [Daryk Armfield, ID 54 & 57] Village  Planning process is lacking in opportunities for public engagement [Daryk Armfield ID 45 & 57]  Don’t understand where the S106 contributions from High Leigh went [Daryk Armfield, ID 45]  Where is the viability appraisal for High Leigh? [Daryk Armfield, ID 46]  Object to greenfield development at High Leigh [Daryk Armfield ID 57]  No consideration of the traffic impact [Daryk Armfield ID 47 & 57]  No clear basis for determination of the level of educational provision [Daryk Armfield ID 48, 55 & 57]  40% affordable housing is unattainable because it is squeezed by developer profit [Daryk Armfield ID 57]  policy requires more detail to be sound [Mrs Pierce ID 138].  Should be extended to include Land at Hertford Road, Hoddesdon [HCL(Hertford Road) Ltd, ID 263].  If Land North of Hertford Road is not required to meet need in this Plan period, the land should be released from the Green Belt and included as a Reserve Site [HCL(Hertford Road) Ltd ID 263].  In including planning reference policy does not allow for flexibility or new submissions brought about by changing circumstances [Lands Improvement, ID 268].  Any development must enhance the Woollens Brook and its riparian zone for biodiversity, as well as for public access.

Restoration options must be considered as part of the development [Environment Agency ID 685].  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 [Environment Agency ID 685].  Habitat corridors to the river channel must be maintained [Environment Agency ID 685].

Requested Modifications  Policy lacking in detail [Mrs Pierce ID 138].  Add reference to opportunistic sand and gravel extraction [Hertfordshire County Council, Environment Department, ID519]  Add reference to new primary school site as stated in paragraph 9.10 [Herts County Council Development Services, ID 636] . HOD 5: Barclay Objection Park and  Policy is not adequately prepared [Mrs Pierce ID 139]. Spitalbrook Support:  Support conservation or enhancement the historic landscape of Barclay Park, however the policy could be more positively worded [Historic England ID179]

Requested Modifications  Policy to be more detailed, particularly regarding how land is to be protected [Mrs Pierce ID 139].  B3 Living will promote a residential development at Beech Wall overlooking the park [B3 Living Ltd, ID444]  As part of the improvements, the river channel should be re- naturalised as appropriate. There is also potential for wetland creation and flood storage [Environment Agency ID 686].

9.9 Modification Requested:  "Additional secondary capacity to serve the Borough will be met through the provision of a new school at Wormley [Herts County Council Development Services, ID 637].

10. Park Plaza 10.1 Object:  No evidence that Park Plaza North site is deliverable as has not been developed despite being allocated for over the long term [Mrs Pierce, ID 230].

Support:  CEG supports paragraphs 10.1 to 10.3 of the Plan. The Green Belt Analysis report submitted alongside these representations supports the Council’s position that Park Plaza West will contribute to delivering the vision and employment objectives [CEG, ID 302]. 10.2 Support:  Park Plaza West has a unique locational advantage and the potential to attract companies that will deliver employment objectives [CEG, ID 302].  Masterplanning demonstrates that a high quality business park can accommodate up to 100,000sqm floor space with 12.5 Ha of open space that provides a visual gap between the M25 and the employment area. [CEG, ID 302].

PP1: Park Object: Plaza West  Requirement for the Pond should “be restored” is overly prescriptive and subject to wide interpretation. Neither does it comply with para 17 NPPF [CEG, ID 303]  Lack of clarity in relationship between PP1 and policy ORC3.  CEG considers that the Council’s approach in separately designating the employment site and a separate area of Local Green Space is unsound as it does not therefore comply with national policy (NPPF para 76).  The extent of the Local Green Space shown is not justified. [CEG, ID 303].  Delete as not justified and contrary to national policy [CPRE, ID 346].  Employment allocations within close proximity to a number of heritage assets not addressed in policy wording [Historic England ID 181]  Policy supported however Local Plan is unsound as PP1 does not include the site at the Cheshunt Country Club / Theobalds Sports Ground for residential development [GL Hearn (Agent) ID557]

Support:  CEG supports allocation of Park Plaza West, the provision of a gap between the M25 and the employment area, and the introduction of a new bus service, pedestrian and cycle routes [CEG, ID 303].  The Green Belt Analysis report (GBA) submitted confirms that exceptional circumstances exist to justify the release of the Park Plaza West as a strategic site [CEG, ID 299].  The future economic growth needs for Broxbourne and the wider sub-region are set out in the Economic Growth and Needs Assessment and Addendum (EGNA), GBA. This confirms that there is a substantial requirement for commercial office accommodation [CEG, ID 299].  The Alternative Sites Assessment and Addendum (ASA), GBA found that there are no alternative sites for a high quality business park [CEG, ID 299].  There is no single location within the Borough that could provide sufficient scale and critical mass to accommodate a strategic business park [CEG, ID 299].  The removal of the Park Plaza West site from the Green Belt would not affect the ability of the retained Green Belt to contribute to its purpose. Harm would be limited by the character of the land and existing features [CEG, ID 299].

Requested Modification:  Individual changes to policy wording [GL Hearn (Agent) ID557] 10.2 Object:  Delete as not justified and contrary to national policy [CPRE, ID 346]. 10.3 Object:  Delete as not justified and contrary to national policy [CPRE, ID 346].

Figure 12: Park Object: Plaza Concept  Does not meet definition of Local Green Space in NPPF [Mrs Plan Pierce ID 275, CEG ID 353].  The proposed Local Green Space designation shown on Figure 12 of the Plan is larger than envisaged. The boundary shown is arbitrary and does not reflect the masterplanning [CEG, ID 304].  The provision of an open area adjacent to M25 junction 25 should be a requirement of Policy PP1 and is not appropriate as a separate designation [CEG, ID 304].  The use of the Local Green Space Designation and its extent is unsound [CEG, ID 304].

Modification Requested:  Public Open Space may be a more appropriate designation [Mrs Pierce ID 275].  Amend by extending the Employment Area to cover the entire area to be delivered as part of the business park development. This should include the 12.5Ha landscaped open space to the south and the Local Green Space designation should be deleted [CEG, ID 304].  Policy should mention upgrading of M25/A10 junction [Hertfordshire County Council, Environment Department, ID479]

PP2: Park Objection Plaza North  Lack of policy reference to Homebase relocating to Park Plaza North [London & Cambridge Properties].  Site serves important strategic Green Belt purpose in one of the last gaps separating London from Hertfordshire [Mrs Pierce].  Development at this site will exacerbate congestion, adversely affecting safety on roads in the area, including tailbacks on to the M25 [Mrs Pierce].  Additional jobs will add to the existing congestion, and force residents wishing to access Cheshunt from the A10 on to the already severely congested Winston Churchill way [Mrs Pierce].  Other points in road network need to be upgraded to cope with increase in jobs, but these options were not modelled for the Transport Strategy [Mrs Pierce].  Highly doubtful whether all the employment land proposed in the Plan will be delivered on a speculative basis [Mrs Pierce].  The mitigation strategy is not evidenced or realistic. The new rail station is unlikely to be delivered until after driving to the site is embedded [Mrs Pierce].  The market has shown there is no reasonable prospect of the Site being used for B1 purposes [Kier Property Developments Ltd, ID 285].  The Council has not taken its own Employment Land Study into account as there is considerable demand for B8 uses in the area [Kier Property Developments Ltd, ID 285].  There is limited interest from businesses wishing to relocate from Waltham Cross Town Centre, who are retail occupiers happy with the town centre location. [Kier Property Developments Ltd, ID

285].  The NPPF considers offices a town centre use. Park Plaza is an out of centre location not suitable for office development [Kier Property Developments Ltd, ID 285].  Employment allocations within close proximity to a number of heritage assets not addressed in policy wording [Historic England ID 181]  Support Park Plaza North for comprehensive development, however object that: a. That occupation should be limited to small and medium sized enterprises, b. That PPS2(1) should also include reference in employment uses to B8, c. That there should be an insertion PPS2(3) which should include reference to the relocation of existing A1 uses, d. That there should be an insertion PPS2(4) which should include reference to supporting infrastructure/ancillary uses. [Cushman and Wakefield (agent) ID 574]  Evidence base does not support the policy being explicitly directed to SME's [Aquila Developments and Pears Property Group ID 599]  The exclusion of B8 is not justified [Aquila Developments and Pears Property Group ID 599, Stoford Developments Ltd, ID550]  Policy provides insufficient certainty that allowance will be made for complementary retail uses that consolidate the Park Plaza location from a commercial perspective. [Aquila Developments and Pears Property Group ID 599]

Modifications Requested:  Make specific reference to relocation of Homebase store to Park Plaza North [London & Cambridge Properties, ID 22].  Include B8 within the list of acceptable use classes [Kier Property Developments Ltd ID 285]  Does not provide certainty and the approach to allocating land uses lacks clarity for landowners/developers. Reference to small and medium sized enterprises needs to be removed or clearly defined. Policy needs to be updated to state: a. 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 [The Co-operative Group (James Litherland) ID 293]  Policy should increase flexibility of uses to encourage business to the borough and needs to be updated to state: a. Ancillary uses that compliment and will best promote the site for business [The Co-operative Group (James Litherland) ID 293]  a. Clarification within Policy PP2 in respect of A1 uses. b. A cap on the percentage of A1 (retail) floorspace within Park Plaza North to ensure that the overall diversity of business is achieved. c. A reference to B8 uses being acceptable within the site. d. The reference to the allocation being for small and medium sized enterprises to be less restrictive. e. A reference to ancillary uses being appropriate to enable

the site to fairly compete with other strategic employment sites. [Turley (agent) ID 550]

 Changes to individual wording of policy [Cushman and Wakefield (agent) ID 574]  Specific policy wording sought regarding B1, B2, and B8 uses, Bulky goods retailers, and complementary employment uses. [Aquila Developments and Pears Property Group ID 599]

10.4 Object:  Comments as for PP1 [Mrs Pierce ID 231].  The Coop supports the proposal but has concern on the inclusion "for a variety of small and medium sized enterprises" which needs defining [The Co-operative Group (James Litherland) ID 293].  Objections as for PP2 [Cushman and Wakefield ID 575] Requested Modifications  Redrafting of the paragraph to include relocation of businesses [Cushman and Wakefield ID 575]

PP3: Park Object: Plaza South  Comments as for PP1 [Mrs Pierce, 232].

10.6 Object:  The proximity of and direct access onto, the strategic road network will reduce the impact of any proposed development on the site on the surrounding local highway network [CEG, ID 306].

Modifications requested:  Mention signalised junctions at Church Lane/College Road [Hertfordshire County Council, Environment Department, ID480]

10.7 Object:  The proposed new pedestrian and cycle bridge is not essential to the sustainability of Park Plaza West [CEG, ID 307].  New rail station at Park Plaza is not integral to the feasibility of the site with regards to sustainable transport accessibility [CEG, ID 307]. 10.8 Object:  New bus service that would be provided as a shuttle bus service that would connect Park Plaza with other local public services and the rail station. [CEG, ID 308]. 10.9 Object:  The existing connections, in combination with the proposed new pedestrian and cycle bridge across the railway line, if brought forward by the local authority will ensure that safe pedestrian and cyclist connections are established [CEG, ID 309]. 11. Waltham Cross Policies WC1 & Object: WC2 &  Bunnings/Homebase wish to retain retail representation within Paragraph 11.4 Waltham Cross. [HHGL - Owners of Homebase/Bunnings].  The loss of two key anchor stores will detrimentally affect the vitality of the town centre [Mrs Pierce ID 233].

Modifications Requested:  Policy WC2 should confirm that the redevelopment of the Northern High Street Site can only proceed once a suitable relocation site has been identified [HHGL].  Mention potential for bus station expansion [Hertfordshire County Council, Environment Department, ID474] WC1: Waltham Support Cross Town  Support in principle the redevelopment of northern High Street Centre provided that there is flexibility in its delivery. [London & Cambridge Properties, ID 20] Objections:

 Significance and setting of Heritage assets is not mentioned. Proposals need to protect and enhance heritage assets and their settings [Historic England ID 182] WC2: Waltham Objection Cross Northern  Development on the Homebase site could come forward as a first High Street phase of an overall comprehensive development. No flexibility as currently drafted [London & Cambridge Properties, ID 21]  No acknowledgement within the Park Plaza policies that retail development is acceptable [London & Cambridge Properties, ID 21]  The evidence base does not support the requirement to provide affordable housing together with other financial contributions – may not be viable [London & Cambridge Properties, ID 21]  Significance and setting of Heritage assets is not mentioned. Proposals need to protect and enhance heritage assets and their settings. Should also be addressed in para 11.5 [Historic England ID 184 & 198]  It is noted that there are around 300+ new homes planned which can be accommodated through expansion of existing schools. HCC would need to understand demand for places if numbers increase significantly [Herts County Council Development Services, ID 638]. 11.5 Object:  In order to plan for HCC services, particularly school places, it would be useful to have information regarding the number of proposed housing units [Herts County Council Development Services, ID 639]. 11.6 Object:  Any large scale residential development would impact on HCC services. Welcome early engagement in the preparation of the Area Action Plan [Herts County Council Development Services, ID 640].

11.8 Support:  Would meet currently anticipated demand [Herts County Council Development Services, ID 641] WC3: Waltham Object:

Cross  If this site could come forward within the Plan period then it needs Renaissance to be allocated within the Plan with a policy which specifies what Area Action the Council will expect from this allocation [Mrs Pierce, ID 234]. Plan  Any redevelopment proposals in this area will need to protect and enhance grade II listed Christ Church and other heritage assets. Presence of these heritage assets or conservation or enhancement measures are not mentioned [Historic England ID 185]

Support:  Support the policy to work with Network Rail and Transport for London to prepare an AAP [Transport for London, ID584] 12. Wormley and Turnford 12.2 Object:  The cost of the access off is likely to render the school undeliverable [Mrs Pierce, 235].  The proposed access to the school is likely to be dangerous given speeds along that road and an alternative pedestrian access will be necessary [Mrs Pierce, 235]. Support:  Reference to new secondary school site at Church Lane welcomed. Likely that will not be required until towards the end of the plan period [Herts County Council Development Services, ID 642]. 12.4 Modifications Requested:  Should reference that the Council will work with Network Rail to examine feasibility of the new station [Transport for London, ID585] WT1: Wormley Support: conservation  Proposals are supported [Historic England ID 196] Area Improvement Plan WT2: Macers Object: Estate  This policy mentions possible new homes, but this is neither quantified or appraised in terms of the SA or transport modelling [Mrs Pierce, ID 236].

Support:  Support the proposals - B3 Living has masterplans [B3 Living Ltd, ID442]  Additional housing may impact upon the demand for school places in the area [Herts County Council Development Services, ID 643].

Modifications Requested:  Either provide certainty with regards to the amount of new development, so that the cumulative impacts can be assessed appropriately, or the policy should remove reference to new homes [Mrs Pierce, ID 236].  Measure to protect and enhance the character and appearance of the adjacent Conservation Area to be mentioned in paragraphs 12.5- 12.6 and in policy WT2 [Historic England ID187] 12.8 Support:  Care home referred to will provide 75 beds [Herts County Council

Development Services, ID 644].

13. Lee Valley Regional Park LV2: Lee Valley Support White Water  Would complement and improve the sustainability of the existing Centre facilities [Sport England, ID 6] Modifications Requested:  The caveats in paragraph 13.6 should be included in the policy [Mrs Pierce, ID 237]. 13.9 Object  Unclear whether housing is proposed at Spitalbrook as well as recreation [Daryk Armfield, ID 53] 13.3 Modifications Requested:  Amend footnote 2 to refer to Park Development Framework [Lee Valley Regional Park Authority, ID 82] 13.8 Modifications Requested:  Add relationship and timing of the long term development plan for Broxbourne Station and its environs to work on updating the development brief for the Leisure Pool site [Lee Valley Regional Park Authority] LV3: Object: Broxbourne  Housing is unquantified and unassessed (e.g. Flood Risk Leisure Pool Assessment) which sets a dangerous precedent for the park [Mrs Site Pierce ID 238].  Site provides access and parking for a very popular gateway to the Park and provides access to the boating lake and plays an important role in the setting of the Park [Mrs Pierce, ID 238].  Proposal will be a visually harmful intrusion into this valued Parkland area and conflicts with the objective of preserving the parkland and the natural areas [Mrs Pierce, ID 238].  Difficult site to develop as completely within the floodplain. Careful consideration needed to match the land use to the level of flood risk including allowance for climate change [Environment Agency ID 687].  Enhancements must be made to the watercourse to provide a net gain in biodiversity. Potential for ponds and wetland to be created on site [Environment Agency ID 687].  Would be useful to have an indication of the scale of housing to be able to assess the impact upon HCC services, particularly schools [Herts County Council Development Services, ID 645].

Figure 14: Modification Requested: Former Leisure  A key would be very useful for such maps so that the reader can Pool site and understand these images without the need to refer to the separate Spitalbrook. policy map [Mrs Pierce, ID 239]. LV4: Support: Spitalbrook  Welcomes additional aim of delivering environmental improvements [Natural England ID 673].  Supportive of new wildlife habitat creation here [Environment Agency ID 688].

LV5: Lee Valley Modification Requested:

Park Gateways  Could be improved with reference to the protection and enhancement of ecological features, a commitment to consulting Natural England where appropriate, and the potential requirement of a HRA assessment [Natural England, ID 674].

LV6: Former Modification Requested: Britannia  Policy needs more detail including the parameters of what the Nurseries Site, Council expects to be achieved from this site [Mrs Pierce, ID 240]. Waltham Cross

14.Countryside 14.3 Object:  Statement is hypocritical given that a 100,000sq.m business park is proposed immediately adjacent to this site. If the rural setting is that vital for the country club site, then the same assertion should also apply to the Park Plaza West site [Mrs Pierce ID 241].

Policy CS1: Support Cheshunt  Provides recognition of the facilities that exist on this site which will Country Club need to be considered in any development proposals for the future of the site [Sport England, ID 4] Objections:  Site should be considered for (residential) development [GL Hearn (Agent) ID556]  Local Plan is unsound due to incorrect analysis in Green Belt Topic Paper [GL Hearn (Agent) ID558] Requested Modifications:  Individual changes to policy wording [GL Hearn (Agent) ID556]  Changes to analysis [GL Hearn (Agent) ID558] 14.6 Object:  Enabling development is not compatible with maintaining the openness of the Green Belt [Mrs Pierce, ID 242]. 15.The New River

NR1: New River Object: Conservation  Designation of the land adjoining Park Plaza west is not justified Area as there is no historic interest [CEG, ID 356]. Support:  Proposals at paragraphs 15.4, 15.5 and policy NR1 are welcomed [Historic England ID188] NR2: New River Object: Path  Support but note that Park Plaza West is not dependent upon its delivery [CEG, ID 357]. 16.Gypsies, Travellers, and Travelling Showpeople Policy GT1  Reserved position on the Wharf Road travellers site pending a further meeting [Lee Valley Regional Park Authority, ID 88]  Not based on sound evidence [Hertfordshire GATE, ID 407] Object:

 Does not provide 5 year trajectory of delivery of new sites [Mrs Pierce, ID 315, Ms Mead ID 319].  It fails to include a trajectory of where pitches will be delivered or

at least provide broad locations for growth for years 6 to 10. [Ms Mead ID 319];  Fails to include a criteria-based policy to guide land supply allocations or to provide a basis for decisions in case applications come forward [Mrs Pierce, ID 315; Ms Mead ID 319]  Is too restrictive in restricting provision purely to those families already resident in the Borough without allowing any other form of in-migration [Mrs Pierce, ID 315; Ms Mead ID 319; Welwyn Hatfield BC, ID457]  Does not allow for any flexibility should additional accommodation needs be identified through the Borough's refresh of its Accommodation Needs Assessment [Mrs Pierce, ID 315; Ms Mead ID 319]  No provision for meeting accommodation needs of Non-Nomadic Gypsies and Travellers [Mrs Pierce, ID 315; Ms Mead ID 319]  Does not consider the role of the Hertfordshire Transit Site at South Mimms [Welwyn Hatfield BC, ID 457] Support:

 Support proposals on behalf of Wharf Road plots 2,14,15,16, ‘Bens’, 65 Wharfside Nursery , 51 & 52 [WS Planning and Architecture, ID447]  Increase in number of pitches welcomed [Herts County Council Development Services, ID 646].  16 additional plots appropriate; five will be supplied on the relocated Halfhide Lane site [Herts County Council Development Services, ID 646].  Proposal to relocate Halfhide Lane site to accommodate approximately 20 pitches in total welcomed. Details of the relocation of this site are currently being developed [Herts County Council Development Services, ID 647]. GT2: Extended Object: Travelling  Does not comply with Planning Policy for Traveller Sites 2015 [Ms Showpeople Mead ID 320]; Site  Is too restrictive as restricts provision to families already resident in the Borough [Ms Mead ID 320];  Does not allow for any flexibility should needs be identified through the Borough's refresh of its Accommodation Needs Assessment [Ms Mead ID 320];  Does not make provision for meeting accommodation needs of Non-Nomadic Travelling Showpeople [Ms Mead ID 320].

16.1 Object:  Approach inadequate to meet needs [Hertfordshire GATE, ID 402] 16.2 Object :  Council engagement inadequate and non-compliant [Hertfordshire GATE, ID 403] 16.6 Object:  Exclusion of those without a long-term connection to the borough

is non-compliant with PPfTS [Hertfordshire GATE, ID 404] 16.8 Object:  GB2 will render the option of purchase of the sites for gypsy and traveller provision undeliverable given the opportunity to sell the land for market housing [Mrs Pierce, ID 243].  Should not be alternative to allocating sufficient sites [Hertfordshire GATE, ID 406] 17.Infrastructure Entire Chapter Objection  The policies refer to the Transport Strategy and the Walking and Cycling Infrastructure Plan where the relevant detail should be included within the plan itself [Historic England ID 200].  The Plan does adequately consider the historic environment within the context of infrastructure delivery [Historic England, ID 200].  Neither the Transport Strategy and Walking and Cycling Infrastructure Plan refer to the historic environment or to the impact that infrastructure can have on it [Historic England, ID 200].  Consideration should be given to the impact of the proposals on the setting of designated and non-designated assets and the potential for unknown archaeology [Historic England, ID 200].  Should include a list of the services that HCC provides. There should also be an emphasis on the need to provide for community facilities to support sustainable development [Herts County Council Development Services, ID 648].

Support

 Support infrastructure measures, including expansion of Woodside primary school [Welwyn Hatfield BC, ID456]  As a provider of a number of services HCC welcomes the opportunity to be involved in the preparation of this plan [Herts County Council Development Services, ID 648].  HCC would like there to be a reference to the provision of water supplies for firefighting (e.g. suitable and sufficient water mains and hydrants) and would welcome the possibility of re-locating stations should an opportunity arise in the future that is both economically and operationally viable [Herts County Council Development Services, ID 663].

17.3 Object:  This statement only applies when it can be proven that the proposed mitigation as set out in the Plan can be delivered [Mrs Pierce, ID 244].  The Transport Strategy identifies that the majority of proposals are unfunded. The majority of the schemes cannot be funded by residential developments as this will not meet Circular 5/05 [Mrs Pierce, ID 244]. INF 2: Object: Transport  Transport Strategy uses an out of date evidence base and fails to Strategy model or consider the impacts of its proposals on the two main north-south routes that traverse the borough [Mrs Pierce, ID 245].  Singular aim to speed up flow of through-traffic on the A10 at the expense of other vehicle movements. This will unlock the latent demand to use this route as an alternative to the M11 and the A1

[Mrs Pierce, ID 245].  Strategy will prevent access to the A10 for residents, diverting large volumes of traffic to minor roads and roads like Blindmans Lane, increasing circular traffic movements as drivers are forced to circumnavigate the borough in order to reach the A10 [Mrs Pierce, ID 245].  Strategy will worsen congestion and therefore exacerbate air pollution in designated AQMAs [Mrs Pierce, ID 245].  The Strategy states bus priority junctions will be installed, but does not identify how this will be achieved as there is insufficient carriageway width [Mrs Pierce, ID 245].  The creation of new stations will assist in some modal shift [Mrs Pierce, ID 245].  Not notified of proposals by Council [Mr Scott Ward, ID462]  Too focused on north-south movement on A10, not enough on local wellbeing [Mr Scott Ward, ID462]  Concerns about air quality [Mr Scott Ward, ID 462]  Concerns modelling is not robust [Mr Scott Ward, ID462]  Insufficient consideration of the southern side of the junction 25 M25 in Enfield [David Storey, ID543]  B156 Cuffley Hill/Goffs Lane congestion is caused by congestion in Cuffley itself, which is not addressed by the proposed signalisation in Goffs Oak [David Storey, ID543]

Support:  Overall aims and objectives of the Broxbourne Transport Strategy are supported and welcomed [CEG, ID 358].  Evidence presented demonstrates that the package of interventions suggested would provide the correct balance of transport infrastructure to support the growth set out in the Local Plan [Hertfordshire County Council, Environment Department, ID465]

Modifications requested:  Enshrine core principles of the Transport Strategy in the policy itself [Hertfordshire County Council, Environment Department, ID466] 17.5 Object:  Council’s own modelling shows that the transport infrastructure cant cope with 1200 homes at Cheshunt Lakeside [James Detheridge, ID 372]. 17.9 Modifications:  Should refer to contributions from other site allocations west of A10 towards the specific improvements [Crest Nicholson, ID 428] INF3: Road Support: Infrastructure  Please that issues previously addressed. No further comments at this stage [Highways England, ID448] 17.10 Object:  The 'improvements' are uncertain - no understanding of how these schemes can be achieved [Mrs Pierce, ID 246]. INF4: Crossrail Modifications Requested: 2/four tracking  Add reference to growth potential of Broxbourne as a result of the

new stations. [Transport for London, ID 586]  Enfield wishes to see a stronger emphasis on the benefits of Crossrail 2 in the plan [Enfield Council, ID601] 17.14 Modifications Requested:

 Should reference the increased potential for development as a result of Crossrail 2. [Transport for London, ID 587] INF5: Rail Support: Stations  The new rail station at Park Plaza supported, but is not integral to the site in terms of sustainable transport accessibility [CEG, ID 359].

Object:  This policy illustrates that there is no certainty or even reasonable prospect that the mitigation proposed for the Plan can be achieved [Mrs Pierce, ID 247].  Location of proposed station not clear [Lisa Smith ID 606]

Modifications Requested:  Supporting text should be amended to highlight the Special Protection Area adjacent to proposed Turnford Rail station site and the need to minimise disturbance to its ecology [Lee Valley Regional Park Authority]  Should reference need for a business case and that the stations are currently unfunded [Transport for London, ID 588] INF7: Bus Support Transport  Support provided that the operational needs of the bus station are recognised [TfL Commercial Property, ID 41].  The expansion of the bus station is supported, although its delivery is not related to the delivery of development on the Park Plaza site [CEG, ID 360]. Modifications Requested:

 Address pump priming, bus stop infrastructure, and bus priority measures [Hertfordshire County Council, Environment Department, ID468, 484] INF8: Local Support Cycling and  Welcome the approach set out in the Local Cycling and Walking Walking Infrastructure Plan [Lee Valley Regional Park Authority, ID 92] Infrastructure Object Plan  Over-reliance on 20mph zones not consistent with County Council’s Speed Management Strategy [Hertfordshire County Council, Environment Department, ID475]  St James’ road unsafe for cycle route due to volume of traffic [David Storey, ID544] Modifications Requested:

 Should reference Windmill Lane also as part of the level crossing closure programme . [Transport for London, ID 586] 17.18 Object:

 More frequent bus services would not lead to modal shift if these buses are stuck behind traffic which is forced down the Old Cambridge Road/High Street because vehicles cannot access the A10 because of banned right turns [Mrs Pierce, ID 248].

Modifications requested:  Change ‘will provide for bus services...’ to ‘will provide the opportunity for bus services…’ [Crest Nicholson, ID 432-3] 17.19 Modifications Requested:  Delete reference to the royal mail depot as the Group is not intending to dispose of the site in the short term [Royal Mail Group] 17.20 Object:  The likelihood of success in increasing walking and cycling is limited because of the increased traffic on local roads created by the prevention of right turns on to and off the A10, increasing congestion and worsening air quality along walking and cycling routes [Mrs Pierce, ID 249]. 17.22 Object:  While Thames Water do not have generally have concerns regarding the supply of water for new development, there may be requirements for network upgrades [Thames Water, ID 281].  The scale of growth in the Plan, especially Brookfield, could result in requirements for water treatment works upgrades to ensure water supply to the development [Thames Water, ID 281].  Thames Water would encourage ongoing dialogue to ensure that infrastructure requirements are aligned [Thames Water], ID 281.

Modification Requested:  Broxbourne’s water supplies are provided by Thames Water. The company has indicated that all new development can be supplied although upgrades may be required to serve development sites. As such applicants should enter early discussions with Thames Water to discuss both water and wastewater infrastructure requirements for development proposals. [ID 281]

17.23 Object:  What about the period beyond 2026? [Mrs Pierce, ID 250] INF9: Utilities Object: Statements  Needs a policy commitment to phasing development in line with the capacity of the Sewage Treatment Works at Rye Meads to be compliant with the Habitats Regulations [Natural England, ID 670].  Concerns whether there is sufficient capacity in the sewer network serving the WWTW. Expect it demonstrated that there is sufficient capacity in both the sewer network and the WWTWs to accommodate development [Environment Agency, ID 689].

Modification Requested:  The Authority will co-operate with utilities and service providers to ensure that appropriate capacity is available to serve new development and ensure new development does not have an adverse effect on the Lee Valley Special Protection Area. New development post 2026 will only be permitted if the required capacity is available at Rye Meads Sewage Treatment Works,

including any associated sewer connections.’ [Natural England, ID 670].

Support:  The policy will help ensure that development is delivered alongside any necessary infrastructure required to support it.

17.26 Support:  Is difficult to determine exactly when new primary schools would be needed. [Education and Skills funding Agency, ID 125]  Schools at Brookfield Garden Village, Cheshunt Lakeside and Rosedale Park will be required as close to the occupation of the first dwellings as possible. HCC would welcome dialogue with the developers and the local planning authority at to ensure the appropriate plans are in place to meet the demand pupil yield arising from these developments [HCC Services (Martin Wells), ID 655] 17.29 Object:  Reference to ‘additional primary capacity’ in Hoddesdon is too vague [Daryk Armfield] Modification Requested:

 Amend fifth bullet point to state: "Waltham Cross has identified additional primary school capacity" [Herts County Council Development Services, ID 650].  Amend seventh bullet point to state: "In Goffs Oak, land has been made available to enable the expansion of Woodside Primary School” [Herts County Council Development Services, ID 650]. 17.30 Modification Requested:  Paragraph appears to repeat some of the text in 17.29. Object:  Access to the site from the Turnford Link Road to this site is problematic. It will need to deal with a significant change in land levels; as well as to ensure a safe access point for a high speed route [Mrs Pierce].  There will be considerably greater volumes of traffic using this route as a result of the Plan and the Transport Strategy which will affect affect the creation of a safe access [Mrs Pierce].  Inappropriate for the Derwent Turnford Land to remain in the Green Belt [Derwent London, ID 313].  Development for educational purposes would be inappropriate in the green belt as underlined by the similar situation in Warwick [Derwent London, ID 313].  The site boundary should be more clearly defined on the Policies Map [Herts County Council Development Services, ID 649].

Support:  inclusion of a reserve secondary school site at Church Lane in Policy INF10 is supported [Herts County Council Development Services, ID 649]. INF 11: New Modification Requested: and Expanded  Vehicular access to primary school at Albury Ride should be via

Primary the Cheshunt Sports village site, keeping cars separate from the Schools cycle and pedestrian routes [Mr Mark Henderson, ID 328].  Add reference to opportunistic sand and gravel extraction [Hertfordshire County Council, Environment Department, ID519]  Make clear that any new accommodation will be provided within the existing site of Woodside primary school [Hertfordshire County Council, Property and Estates, ID651] INF12: Support: Educational  Supplied information detailing the current position and the Facilities requirements arising from the proposed development for Early Years facilities in the Borough [Herts County Council Development Services, ID 664].

Modification Required:  Clarify designated centre in Part III [Mrs Pierce, ID 252]? INF14: Hotels Object  Lack of clarity and public engagement on hotel plans [Daryk Armfield ID 56] 18.Planning Whole chapter Object:  It is noted that there is no reference within this section regarding the calculation of planning obligations.In ensuring planning obligations meet the three tests, there is a need to look at existing capacity. Supporting infrastructure should be provided in advance of, or alongside the development, unless there is existing capacity [Herts County Council Development Services, ID 656].  Expect planning obligations to be spent in alignment with the IDP [Herts County Council Development Services, ID 656]. 18.7 Object:  Don't compulsory purchase where the market should be allowed to operate [James Detheridge, ID 397]. 18.8 Object:  Disagree with the intention that CIL would not apply to strategic developments, as instead these will be negotiated through section 106 agreements [Herts County Council Development Services, ID 657]. 19.Implementation IMP1: Delivery Support: of Development  Change of emphasis on CPO from ‘we will’ to ‘as a last resort’ [James Detheridge, ID 384]. 20.Design and Sustainable Construction 20.2 Support  Good design can encourage healthy lifestyles [Sport England ID 7] 20.9 Support  refer to Sport England Active Design Guidance [Sport England, ID 8] 20.2; 20.4 and Object: DCS1: General  As the SPD is not subject to the examination, the Plan cannot Design require applications to 'comply' with the SPD, only 'to take account Principles of' [Mrs Pierce, ID 254]. Support  Especially references to links between good design and local distinctiveness [Historic England, ID 201]

Modifications requested:  Could be improved with reference to National Character Areas, East of England Landscape Framework, local townscape, landscape work, and arboricultural guidance [Hertfordshire County Council, Environment Department, ID492] DSC4: Support Management  Welcome emphasis on the management and maintenance of open and and public spaces [Historic England, ID 203]. Maintenance DSC5: Objection Sustainable  Is not appropriate to apply this policy to the historic environment Construction and heritage assets [Historic England, ID 202]. DSC6: Object: Designing Out  The wording of I(b) should be re-worded as it currently reads like it Crime advocating the use of flat roofs as a means to access upper floor windows [Mrs Pierce, ID 255]. 20.19 Modification Required:  The final sentence needs to explain landlocked land means [Mrs Pierce ID 257]. DSC7: Object: Comprehensive  Support policy [Herts County Council Development Services, ID Urban 658]. Regeneration 20.21 Support  Welcome reference to shopfronts needing to complement and enhance frontages which have historical character [Historic England, ID 204]. DSC8: Shop Support fronts and  Welcome standalone policy and point (i) which requires historic Fascias shopfronts to be retained or restored [Historic England, ID 204]. 21.Housing Object  Does not consider ‘housing with care’ model [Inspire Villages, ID 409]  Plan does not consider section 124 of the Housing and Planning Act 2016 (residential moorings) [Canal & River Trust ID 566] 21.1 Object:  Build less flats either - reduce the land footprint or reduce the density of the flats on the site [Mr James Detheridge, ID 379].

Support  Welcome reference to the need for new housing to have regard to local historic character and the relationship of this with local identity [Historic England, ID 205]. H1:Affordable Object: Housing  Needs to include reference to affordable rent to buy housing [Rentplus UK Ltd ID 284].

Modifcation Requested  I. Affordable housing includes social/affordable rented and affordable rent to buy housing, intermediate and shared ownership housing. The provision of affordable housing will be required on all

new residential developments of more than 10 units, or which have a maximum combined gross floorspace of more than 1,000 square metres (gross internal area) [Rentplus UK Ltd ID 284].  IV. The affordable housing split will be 65% social/affordable rented and affordable rent to buy and 35% intermediate and shared ownership housing unless identified requirements or market conditions indicate otherwise [Rentplus UK Ltd ID 284].

Object:  Policy should allow for flexibility to allow for flexibility in meeting other policy objectives. [Lands Improvement, ID 269].

Modification Required:  "VII. Proposals to provide affordable housing (or financial contributions towards off-site provision) which fall short of the above requirements on the grounds of viability shall be acceptable where they are accompanied by a full economic appraisal of the development costs and anticipated values and the Council has considered the provision of affordable housing against the other planning objectives which also need to be given priority" [Lands Improvement, ID 269]. Objection 1. Plumpton Road site should be retained in plan as a housing site [Kechto Ltd, ID75] H2: Conversion Modification Required: of non-  Mention that the General Permitted Development Order allows residential conversion to residential properties [Mrs Pierce, ID 260]. buildings to residential use

H3: Housing Object: Mix  Would be more effective by including reference to encouraging a mix of housing that enables access to home ownership [Rentplus UK Ltd ID 284].

Modification Required:  Remove threshold and increase proportion of homes for accessible and adaptable buildings? [Mrs Pierce, ID 262] H4:Houses in Modification Required: Multiple  Amend iv(c) to remove ‘adjoining’ as means same as adjacent are Occupation the same. Add in ‘nearby residential occupiers’ after adjacent [Mrs Pierce, ID 264]. 21.15 Objection:  Plan fails to accommodate adequately for vulnerable people - in particular those with dementia [Denice Gately ID 199] Policy H5: Support: Housing for  Policy supported [Herts County Council Development Services, ID Specific Needs 657].

Modification Required:  Should all be wheelchair accessible in order for users who need this type of accommodation [Mrs Pierce, ID 266]. 21.16 Modification Required:

 Include detail of what action is being taken [Mrs Pierce ID 267]. H8: Permanent Objections: Residential  Trust objects to a restrictive policy on residential moorings [Canal Moorings & River Trust ID567] Support  Welcome the change made to indicate resistance to permanent residential moorings [Lee Valley Regional Park Authority, ID 89] Residential Objections: moorings  Plan has failed to assess other policy options and is therefore unsound [Canal & River Trust ID571] 21.23 Objections:  Policy is not consistent [Canal & River Trust ID568] 21.24 Objections:  Policy lacks evidence and/or justification [Canal & River Trust ID569] 21.25 Objections:  Policy is unclear and incompatible with H8 [Canal & River Trust ID570] 22.Economic Development 22.1 Support:  Support strategy of diversifying the employment base and to reduce out commuting [CEG, ID 312 & ID 352].

ED1:New Support: Employment  Will help deliver economic strategy and is justified and positively Uses prepared. The validity of the strategy and the allocation of Park Plaza West is set out in the attached Green Belt Analysis report [CEG, ID 311]. ED2:Employme Support: nt Areas 1. [Herts County Council Development Services, ID 660] Policy ED3: Object: Loss of  18 month marketing period is too long and unjustified [Lands Employment Improvement, ID 270]. Uses - Rest of  Amend to allow the change of use of employment areas not the Borough designated as employment areas in the Plan to other uses [CPRE, ID 347].

Modification Required:  (a) An active marketing exercise has been undertaken for a period of 12 months which demonstrates no viable interest in the site for the existing or an alternative employment use, defined as B1, B2 and B8 use classes [Lands Improvement, ID 270].

Para 22.12 Object:  Medium term of 10 years is too long [Lands Improvement ID 270].

Modification Required:  For an application to be considered against criteria (a), evidence of active marketing for a period of 12 months will be required prior to planning permission being granted for a non-employment use. This evidence should clearly demonstrate active marketing of the site with two or more agents, using a range of media at the

average market rate [Lands Improvement, ID 270]. 22.13 Modification Requested:  This should say 'also apply'. [Mrs Pierce, ID 273].

23. Retail and Town Centres RTC1: Retail Object and Town  Object to promotion of Brookfield Riverside as a Town centre Centres location [Sainsbury’s Supermarkets, ID451, Welwyn Hatfield BC, ID455]  Object to the promotion of Brookfield Riverside as a town centre in the Retail Hierarchy [Plan A Ltd/Chris Smith (Agent) ID 593] Requested Modifications:  Brookfield Riverside to be removed from the Retail Hierarchy [Plan A Ltd/Chris Smith (Agent) ID 593] RTC2: Requested Modifications: Development  Reference to Brookfield Riverside as a designated town centre within removed [Plan A Ltd/Chris Smith (Agent) ID 594] Designated Centres 23.6 Object:  The relocation of two large retailers from a town centre (Waltham Cross) location to an out of centre location is contrary to Government policy [Mrs Pierce, ID 279]. 23.8 Modification Requested:  Refer to the General Permitted Development Order as this significantly impacts on the ability to manage changes of use in retail centres [Mrs Pierce, ID 282].

23.15 Object:  No link between location of fast food outlets and childhood obesity [Kentucky Fried Chicken Ltd, ID 400] RTC4: Hot Object: Food Take-  The local plan does not need to include 197 to 211 Windmill Lane Away Uses for shops which will be mostly food shops. These will be in competition to the Old Pond and the need for shops here has not been proved [James Detheridge ID 378].

24. Open Space, Recreation, and Community Facilities Whole Chapter Object:  There is no mention of facilities specifically for young people. Facilities for young people are essential where they can engage in informal educational opportunities [Herts County Council Development Services, ID 665]

Support:  HCC services are responsible for providing a number of community facilities [Herts County Council Development Services, ID 661] 24.3 Support  Recognition that most sports facilities are not located on-site [Sport England, ID 9]

24.5 Support

 Reference to Leisure Strategy provides context for policies ORC1 and ORC2 [Sport England ID 10]

24.6 Support  Sets out practical application of the approach [Sport England, ID 11]

ORC1: New Support Open Space,  Appropriate policy framework consistent with national policy [Sport Leisure, Sport England, ID 12] and Recreation ORC2: Loss of Support Open Space,  Will help safeguard sports facilities from development [Sport Leisure, Sport England, ID 13] and Recreation  Modifications Requested: One minor amendment is requested to criterion (a) of the policy - the reference to "and" at the end of the sentence should be replaced with "or". In its current form, the policy would require development to meet criterion (a) and one of the other criteria to be acceptable which would not be consistent with paragraph 74 of the NPPF which only requires one of the criteria to be met. [Sport England, ID 13]

24.11 Support  Leisure Strategy should be the first consideration for an applicant when assessing the need for a sports facility [Sport England, ID 14] 24.13 Object:  This section is not in conformity with Paragraphs 76 and 77 of the NPPF [Mrs Pierce, ID 286].

ORC3: Local Object: Green Space  Amend to make consistent with national policy [CEG, ID 355].

Modifications requested:  Proposal to designate Local Green Space at land south of Andrews Lane and east of Burton Lane should be deleted [R Brunton, ID 365, G Spitaliotis, ID 366].

24.15 Modifications requested:  Amend to reflect communal ownership only, as previously stated in paragraph 24.13 of Reg 18 Local Plan [Woodhall Properties (London) Ltd), ID 438]. ORC4: Amenity Object: Space  This policy is confusing and requires re-wording to make its intentions clear, particularly in regards to a visual break [Mrs Pierce, ID 287].

ORC5: Object: Community  There is a need for facilities similar to Wolsey Hall [Mrs Pierce, ID Uses 288].

Support  Provides an appropriate policy framework [Sport England]  Please note that HCC would like to relocate Cheshunt library should the opportunity arise [Herts County Council Development Services, ID 656] 24.20 Support:  Recognition of contribution that riding schools/stables make to range of outdoor sports/fitness activities on offer [Sport England, ID 16]

24.21 Object:  Floodlighting in rural areas can also have a detrimental impact on the nocturnal behaviour of protected species and the tranquillity of the rural environment. [Mrs Pierce, ID 289] ORC 6: Object: Equestrian  Amend to require applicants to show that their proposals are in Development accordance with section 9 of the NPPF, or if inappropriate, that very special circumstances apply [CPRE, ID 348].  Policy needs to be strengthened to resist loss of equestrian facilities to comply with Government policy (which includes equestrian facilities- para 74 NPPF) [Sport England, ID 16].

Modification Requested:  Amend to require a needs assessment at application stage to demonstrate that existing equestrian facilities are surplus to requirements before principle of redevelopment is considered [Sport England, ID 16].

25.Water W1: Improving Object: the Quality of  No watercourses within the borough are currently meeting good the Water ecological status. To help comply with the WFD 8 m buffer strips Environment are required as a minimum and financial contributions towards the restoration of watercourses may also be required [Environment Agency ID 690].

Modification:  Add words ‘where appropriate’. [Crest Nicholson, ID 430]  Add in requirement for 8m buffer strips as a minimum [Environment Agency ID 690].  In some cases, financial contributions to the restoration of watercourses may be required [Environment Agency ID 690].

W2: Water Modifications Required: Quality  I. Proposals should not result in pollution of or a deterioration of surface or groundwater quality particularly in Groundwater Source Protection Zones, having regard to the Environment Agency’s ‘Groundwater Protection: Policy and Practice’ guidance or successor documents [Environment Agency, ID 691].

Support:  Support the requirement for drainage strategies. [Thames Water, ID 274].

W3: Water Support: Efficiency  Support the efficiency requirements [Thames Water, ID 276].  Support the efficiency requirements [Environment Agency ID 692] 25.25 Support:  To avoid delays to the delivery of development it is essential that developers discuss their infrastructure requirements with Thames Water at an early stage [Thames Water, ID 277]. W4: SuDS Support:  Surface water should be addressed through SuDS measures and should not be attached to the foul sewer network which can result in sewer flooding [Thames Water, ID 278].  Support the SuDS policy [Environment Agency ID 693]

25.29 Modification Requested:  Provide more detail on the guidance to be consulted [Mrs Pierce, ID 290].

W5: Flood Risk Modification Requested:  Amend as follows: V. Developments in Flood Zones 2 and 3 need to be constructed using flood resilient design and construction practices. They will also need to demonstrate that key services can continue to be provided and the building safely evacuated during a flood event. [Environment Agency ID 693]

26.Green Belt Whole Chapter Modifications Requested:  Land North of Hertford Road should be released from the Green Belt and considered for development [HCL Ltd, ID 258]. 26.1 Object:  Release 305 Ware Road, Hailey (a sustainable, urban, previously developed site) from the Green Belt.[Hertfordshire University NHS Foundation Trust, ID 327]

GB1: Green Modifications Requested: Belt  Policy should reflect the proposed releases of land to be allocated for development and also to the removal of land from the Green Belt to be safeguarded for future development [HCL Ltd, ID 258].  Proposals Map should demonstrate clearly where a new Green Belt boundary will be drawn to provide clarity [HCL Ltd, ID 258].  Amend to reflect Section 9 NPPF [CPRE, ID 349]

Support

 Support for removal of Faints Close site from the Green Belt [Woodhall Properties Ltd, ID 436] 26.3 Requested Modification  Light pollution to be addressed [Denice Gately ID 183] 26.4 Object:  Exceptional circumstances for the release of greenbelt not met - council acting for own financial gain [Denice Gately ID 189]

Requested Modification  Implementation of monitoring and enforcement measures[Denice Gately ID 189] GB2: Object: Residential  This policy does not conform to the provisions of the NPPF. Two Development storey homes in the Green Belt has a more harmful impact on on Derelict openness than glass houses. [Mrs Pierce, ID 291]. Glass House  Self-build plots are not an exceptional circumstance to justify the Sites allocation of Green Belt sites [Mrs Pierce, ID 291].  This policy is not deliverable, particularly as the clearance and decontamination of the glass house sites must take place [Mrs Pierce, ID 291].  There has been no assessment of the potential impacts dispersed forms of sporadic development may have or if these impacts can be adequately mitigated [Mrs Pierce, ID 291].  This form of development is not adequately assessed in the Sustainability Appraisal. [Mrs Pierce, ID 291].  Promoting for self build should not be a first option [Denice Gately ID 190]  Nockold/FJD nurseries site is suitable for residential development [Aldwyck Housing Group, ID534]  Object to limiting development on glass house sites to self-build housing to allow flexibility as to the development allowed [Matthew Rowe (Agent) ID 598]  Policy wording is unsubstantiated and does not allow for flexibility [Charlotte Hutchinson (Agent) ID 572]

Modifications Requested:  Either the Plan should allocate these sites and set clear parameters for the development or this policy should be removed [Mrs Pierce, ID 291].  Criterion 1 (v) should be deleted as some responsible landowners have already knocked down their glasshouses [Tony Sawyer 399]  Amend to allow sensitive open-market and affordable housing [Fusion Residential , ID463]  Amend to allow a wider range of residential development types on Glass House sites [Matthew Rowe (Agent) ID 598]

26.6 Objections:  Disputes status of land used to grow food as ‘contaminated’ [Denice Gately ID 195] 26.8 Object:  Plan does not follow recommendations set out in 2013 Glasshouse Study [Denice Gately ID 191] 26.10 Object:  Policy not adequately restrictive on size [Denice Gately ID 192] 26.11 Object:  The need to remove permitted development rights on these properties demonstrates that the development is intrinsically harmful to the openness of the Green Belt [Mrs Pierce, ID 292].

27.Natural Environment and Biodiversity Whole Chapter Object:

 Plan should require that developments adjacent to the Lee Navigation respect and enhance the biodiversity of the waterway environment [Canal & river Trust ID565]  Expect the plan to include policies to protect and enhance valued landscapes as set out in the NPPF as well as consideration of soils and geodiversity [Natural England, ID 675].  NEB1: General Support strategy for 1. General support for environmental strategy [Hertfordshire County Biodiversity Council, Environment Department, ID490]

Modifications requested:

 Amend V. to include ‘where appropriate’ [Hertfordshire County Council, Environment Department, ID513]

27.4 Modifications Requested:  Changes to last sentence of policy wording [Herts. and Middlesex Wildlife Trust ID595] 27.7 Modifications Requested:  Legislation has changed as of 30th Nov 2017 - statement to be updated to reflect this [Herts. and Middlesex Wildlife Trust ID596]  Add reference to Hertfordshire Environmental Records centre data [Hertfordshire County Council, Environment Department, ID519] 27.8 Modifications Requested:  In order to take account of updates or potential local modification of the DEFRA metric that underpins the calculator HMWT recommend the following small change: 'The DEFRA and NE endorsed Biodiversity Impact Calculator (BIC, Environment Bank 2014, v2 or as subsequently 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 an appropriate method for determining ecological value and delivering net ecological gain. [Herts and Middlesex Wildlife Trust, ID 23]

27.12 Object:  Expect reference to the mitigation strategy for impacts on Epping Forest within plan policy.Note that Broxbourne is likely to fall partially within the zone of influence for both air quality impacts and recreational pressure [Natural England, ID 676].

NEB2: Wildlife Object: Sites  If a site is on international or national importance it is normally because the habitat is specific to that location or is particularly rare. Compensation of such sites will not normally be possible. [Mrs Pierce ID 294]  The tests being applied in these policies seems more stringent for locally important sites than for national or internationally important sites [Mrs Pierce ID 294].  Wildlife outside protected sites not protected [Denice Gately ID 193]  Policy treats International and Nationally designates sites equally

therefore not compliant with NPPF [Natural England, ID 271].

27.17 Requested Modifications  Plan to address lack of facilities and cycling in Goffs Oak [Denice Gately ID 194] NEB3: Green Object: Infrastructure  Applications should be required to set out a management and maintenance programme for such sites in order to ensure they do not become a financial burden in the future [Mrs Pierce ID 295].  Cannot support a blanket approach to naturalisation or restoration [Canal &River Trust ID 564]

Modifications requested:

 Add a strategic GI plan for the borough and cross-reference existing GI work [Hertfordshire County Council, Environment Department, ID493]  Policy to be amended include "where appropriate". [Canal & River Trust ID564] 27.24 Modification Requested:  Delete first two lines of paragraph 27.26 as repeats para 27.24 [Mrs Pierce ID 296]. NEB4: Modifications requested: Landscaping and Biodiversity  Add reference to landscape work to inform masterplanning, visual in new impact assessment, and mitigation hierarchy [Hertfordshire County Developments Council, Environment Department, ID494] NEB5: Ancient Object: Woodland,  There is an inconsistency in approach between Part I of this policy Protected Trees and Policy NEB2. This states that loss of ancient woodland must and Hedgerows be wholly exceptional, yet the same loss can occur if the site is of international importance provided it is replaced elsewhere [Mrs Pierce ID 297].

28.Environmental Quality ENV1: Modifications requested: Residential and Environmental  Include reference to the production of Site Waste management Quality Plans [Hertfordshire County Council, Environment Department, ID517] EQ2: Air Quality Object:  Banning turns onto the A10 will force more traffic on to local roads, decreasing air quality in these areas [Mrs Pierce, ID 305].  Fails to deal with the cumulative impacts on air quality arising from proposed development [Mrs Pierce, ID 305].

Modifications Requested:  Amend point II to apply to all development in the borough, not just within an AQMA [Public Health Service, Hertfordshire County Council, ID 81]  Further strengthen policy to apply to all developments, not just those in AQMA [Hertfordshire County Council, Environment Department, ID478]

28.15 Support  1. Welcome reference to Sport England’s Artificial Sports Lighting Guide [Sport England, ID 17] EQ4: Noise Support  Criterion e) will allow weight to be given to noise mitigation measures [Sport England, ID 18]

Modifications Requested:  It is requested that the reasoned justification to Policy EQ4 be amended to refer to Sport England’s guidance on acoustics for artificial grass pitches as initially proposed by the Council the Regulation 18 Draft Local Plan Consultation Council Responses (October 2017) document (page 473). [Sport England, ID 18]

28.27 Support:  Co-locating a HWRC and Borough Council Depot should be considered. Co-location of waste operational facilities should be considered as part of the Brookfield Master Planning process. [Herts County Council Development Services, ID 666]

29.Historic Environment Whole Chapter Object:  Chapter including all policies except for HA12 needs to be redrafted to better reflect the balancing test in the NPPF [CEG, ID 361].  Local Plan should better recognise certain assets and encourage development to protect and enhance the historic character of the canals [Canal & River Trust ID563] 29.1 Support  Welcome recognition of the historic environment as an irreplaceable resource and the contribution it makes to local distinctiveness and sense of place [Historic England, ID 206]. 29.3 Modifications Requested:  Areas of Archaeological Interest are not national designation and do not belong in this list. Clarify whether they include the 8 Scheduled Monuments [Dr Carol Cragoe, ID 95] 29.4 Object:  Policy needs to reflect balancing test in NPPF [CEG, ID 389]

Support  Welcome the identification of heritage assets within Borough at paras 29.3 and 29.4 [Historic England, ID 206]. HA1: General Support Strategy for the  Welcome inclusion of overarching policy [Historic England, ID Historic 207]. Environment Object:  Does not comply with the NPPF (CEG, ID 362].

29.6 & 29.7 Modifications Requested  The requirement for a Heritage Statement and desk based assessment to be submitted for sites with potential archaeological interest, should be reiterated in the Policy [Historic England].

29.8 Object:  Policy needs to reflect balancing test in NPPF [CEG, ID 386]

29.10 Modifications Requested:  Historic England not ‘Heritage’ England [Dr Carol Cragoe] & [Historic England, Hertfordshire County Council - Environment Department, ID496]. 29.11 Object:  Policy needs to reflect balancing test in NPPF [CEG, ID 387]

HA2: Object: Conservation  Does not comply with the NPPF (CEG, ID 363]. Areas Modifications Requested  (i) of the policy should be amended to read [Historic England, ID 208] "…. development preserves or enhances the established character or appearance of the conservation area". This is to ensure the policy is in line with the statutory obligations of the Planning (Listed Building and Conservation Areas) Act 1990. The test to preserve or enhance the character and appearance is a more stringent one than that outlined within the Act, which is to preserve or enhance the character or appearance.

HA2: Modifications Requested: Conservation  Welcome (iii) of the policy which recognises the opportunities that Areas development has to make a positive contribution to the conservation area [Historic England, ID 208].

HA2: Modifications Requested: Conservation  Welcome point (iv) but recommend that it makes explicit reference Areas to setting [Historic England, ID 208].

HA3: Demolition Object: in Conservation  Policy needs to reflect balancing test in NPPF [CEG, ID 391] Areas Modifications Requested:  Recommend that "material" is removed from point (i) as is a less stringent test [Historic England].  Policy should specify that in situations where demolition or substantial demolition can be supported, a suitable replacement building must also be agreed [Historic England ID 209].

29.16 Support 1. We welcome the supporting text at paragraph 29.16 which outlines the Council’s intentions to prepare Conservation Area Appraisals. This could perhaps be a useful monitoring indicator. HA4: Listed ?? Blank - check original submission Buildings  Policy is not clear. It is possible for a proposal to meet all the criteria from a) – e) and for listed building consent to still be refused [Historic England, ID 212].  Policy under-represents the importance of historic fabric [Historic England, ID 212].

 Policy places too much emphasis on the impact of external changes to a listed building [Historic England]  Each listed building must be assessed on its own merits and will have different attributes which make up its significance. [Historic England, ID 212]  Needs to separate listed and locally listed buildings [CEG, ID 368]  Overly restrictive and needs to include balancing test in NPPF [CEG, ID 368, ID 369, ID 394].

Modifications requested:  Amend (a) in point II of the policy to replace the word "original" with "historic" [Historic England.  Amend to read: "whether any historic features or aspects of significance will be lost, altered or negatively impacted upon as a result". ry feature of interest or significance as such the policy should not refer to "aspects that led to the building being listed" as these will ultimately not be known in full. [Historic England, ID 212] 29.18 Object:  Inclusion of both nationally and locally listed buildings in this paragraph is confusing. Delete reference to locally listed buildings and provide add into 29.24 [CEG, ID 392].

29.20 Object:  Needs to reflect balancing test in NPPF [CEG, ID 393]

29.22 Support  Welcome recognition that the best use for a historic building is usually its original use [Historic England]. HA5: Locally Object: Listed Buildings  Policy needs to reflect balancing test in NPPF [CEG, ID 376, ID 395]

Support:  Welcome standalone policy [Historic England, ID 213]. HA6: Works Object: affecting the  Needs to better reflect NPPF [CEG, ID 370] setting of Heritage Assets Modifications Requested:  Policy would be strengthened if the supporting text outlined that setting is an important aspect of significance and that significance can be harmed through development within the setting of a heritage assets [Historic England, ID 214]. Modifications requested:  Include locally listed assets, as per HA6: I [Hertfordshire County Council, Environment Department, ID497]

HA7: Demolition Object: of Listed  Criteria within policy does not reflect NPPF. [Historic England, ID Buildings 215].  Needs to better reflect NPPF [CEG, ID 371]

HA8: Historic Object: Parks and  Policy needs to reflect balancing test [CEG, ID 374]. Gardens Modifications Requested:  Should refer to Historic England rather than English Heritage [Historic England, ID 216].  Rename policy "Registered Parks and Gardens" [Historic England, ID 216].  Remove "materially" from point (i).  Recommended that the requirements for a Historic Landscape Assessment/archaeological assessment to be submitted within the policy itself [Historic England, ID 216].

29.32 Object:  Needs to be clarified to state which applicants are required to prepare a landscape assessment (CEG, ID 374) HA9: Modifications requested: Archaeology  Amend II to insert reference to appropriate management or archaeological investigation [Hertfordshire County Council, Environment Department, ID498]  Conflation of Areas of Archaeological interest and Scheduled monuments is confusing. Also amend supporting text at 29.33-5. [Dr Carol Cragoe, 98] 29.42 Modifications requested:

 Amend evaluation report with ‘site impact assessment report’. [Hertfordshire County Council, Environment Department, ID499] HA11: Non- Support: Designated  Welcome standalone policy which will increase the soundness of Heritage Assets plan [Historic England, ID 217]. Object:  Needs to better reflect NPPF [CEG, ID 377]

Modifications requested:  Text of HA9.II should be added to HA11 also [Hertfordshire County Council, Environment Department, ID495]

 Hertfordshire historic environment record [Hertfordshire County Council, Environment Department, ID500] HA12: Enabling Object: Development  Query inclusion of policy. By definition (NPPF), enabling development is development that is not in accordance with adopted policy and is therefore not a necessary component of a local plan [Historic England, ID 218].  Policy on enabling development is not necessary as it covered entirely by paragraph 140 the NPPF [Historic England, ID 218].  Criteria within the policy do accurately reflect paragraph 140 of the NPPF [Historic England, ID 218]. 29.44 Modifications Requested:  Insert a more specific reference to Areas of Archaeological Interest [Dr Carol Cragoe, ID 93] Monitoring Modifications Requested:  Recommend indicators to measure how successful historic

environment policies are e.g. preparation of a local list, completion of CA action and management plans, reduction in assets classified as at risk [Historic England, ID 220]. 30. Transport and Movement 30. Transport Object: and Movement  Plan should seek to enhance the waterways and access to them to encourage active travel [Canal & River Trust ID561]  Impacts of development on the waterway infrastructure are mitigated through clear measures [Canal & River Trust ID561]  Plan does not address waterborne freight [Canal & River Trust ID562] 30.2 Object:  B156 cannot cope with proposed levels of development [Robert Henbest, ID 72].  The Transport Strategy is driven by making improvement only to north-south journeys on the A10, to the detriment of other routes, which undermines the aim to increase modal shift to non- motorised means [Mrs Pierce, ID 310]. 30.4 Modifications requested:  Delete the words “including the management of development construction.” [Hertfordshire County Council, Environment Department, ID487] TM1: Modifications requested: Sustainable  clearer reference to user hierarchy or principle of reducing travel Transport first. [Hertfordshire County Council, Environment Department, ID467] 30.8 Modifications requested:  Manual for Streets (2007) is also still relevant [Hertfordshire County Council, Environment Department, ID485] TM2: Transport Modifications requested: and New  insert reference to ‘evaluation and support contributions’ for Travel Developments Plans [Hertfordshire County Council, Environment Department, ID476] TM4: Electric Modifications requested: Vehicle  Clarify County Council position that it will not provide or manage Charging Points charging points [Hertfordshire County Council, Environment Department, ID477] TM5: Parking Support: Guidelines  Car parking standards for educational establishments would potentially require up to 8 additional parking spaces for every classroom added to an existing school. Would be helpful if standard was applied flexibly [Herts County Council Development Services, ID 667]. 30.18 Object:  Unclear what reductions can be applied to maximum levels based on PTAL areas [Hertfordshire County Council, Environment Department, ID487] Appendices Appendix A:  Delete reference to Jones Road under A.4 (informal open spaces) Schedule of as it is correctly shown as a Registered Village Green under A.9. Open Spaces [Goffs Oak Community Association, ID 36] Appendix B: Modifications requested:

Car and Cycle  One space per bedsit and one space per one bedroom dwelling Parking would be more appropriate [Crest Nicholson, ID 431] Guidelines Appendix D:  Clarify if Area of Archaeological interest includes Scheduled Glossary Monuments or only refers to areas identified as important locally [Dr Carol Cragoe, ID 97]  Glossaries should include consistent definitions for all heritage assets mentioned in the local plan [Historic England, ID 221].

Policies Map Designated We recommend that designated heritage assets are marked on maps, heritage assets where appropriate [Historic England].

Park Plaza Object: West and Local Green Space  The extent of the proposed Local Green Space designation shown adjoining is larger than the 12.5Ha envisaged in policy PP1 or the masterplan. The boundary between the Employment Area and proposed green space is arbitrary and does not reflect evidence including the masterplanning work [CEG, ID 304].  The provision of an open area adjacent to M25 junction 25 should be a requirement of Policy PP1 and is not appropriate as a separate Local Green Space designation [CEG, ID 304]. Modifications Requested:  Amend by extending the Park Plaza West Employment Area to cover the entire area to be delivered as part of the business park development. The Local Green Space designation should be deleted [CEG, ID 304].

Sustainability Appraisal Overall Object:  SA contains considerable uncertainty on impact of the Plan on the historic environment - a concern given the late stage in the plan preparation process and sites have been allocated [Historic England].  SA displays an overreliance on the development management policies to mitigate the adverse impacts of site allocations on SA Objective 1 [Historic England].  Findings indicate that the Plan and site allocations will result in harm to the significance of heritage assets. Given the lack of acknowledgement to the historic environment in the majority of the site specific policies, this is extremely concerning [Historic England].  The SA does not evidence that the site allocations will conserve and enhance the historic environment (para 7 NPPF) [Historic England].  SA not clear on the effects of high-density development at Cheshunt Lakeside (Dr Ian Tucker, ID440]  SA does not include details of the impact of air pollution from Cheshunt Lakeside (Dr Ian Tucker, ID441]

Underlying Object: Evidence base  The Evidence base available on the Council’s website does not contain any work which would be helpful in understanding the current significance of the Borough’s historic environment. This indicates that the SA has not made use of the most appropriate evidence to allow baseline trends to be identified [Historic England].

Habitats Regulation Assessment 7.1.5 Object:  MoU is not sufficiently progressed and a mitigation strategy will need to be agreed before the plan is adopted [Natural England, ID 676].

Process Object:  Comments that have been processed are not visible to those reading the document. The consultation is not transparent in this respect [Mrs Pierce, ID 317].