Dear Sir/Madam,

I am writing to make my separate and individual representation on the April 2026 Hertsmere Local Plan Reg 18 Consultation Document. You are required to take account of every representation from every person, as a matter of legal correctness, under your Statement of Community Involvement and the Town and Country Planning (Local Planning) (England) Regulations 2012 (as amended).

My representation focuses on the seven Radlett candidate sites SA1–SA7, and on the proposed Radlett allocation of 2,900 homes. I do not dispute the borough-wide housing target of 16,160 homes (Reg 18 para xxvii) or the use of the standard method (NPPF para 62). My representation is that the distribution of that target as proposed for Radlett is unsound under NPPF para 36(b), 36(c) and 36(d), and that a substantially smaller, evidence-led allocation in Radlett is both deliverable and consistent with the rest of the plan.

1. The plan over-supplies — Radlett's allocation can be safely reduced

Reg 18 Table 12.1 (p. 129) identifies 21,400 homes of supply against a need of 16,160 — a planned over-allocation of ~5,240 homes which para 12.1.9 expressly says provides "flexibility … should some of the site allocations not be brought forward for development or their delivery delayed". Reducing the Radlett allocation from 2,900 toward approximately 1,350 does not threaten the soundness of the plan against the standard-method target.

2. Three pieces of evidence are missing or in development

The Reg 18 consultation is being run before the publication of:

• the Level 2 Strategic Flood Risk Assessment (E7);
• the Water Cycle Study assessing sewer and wastewater capacity (E8);
• a Transport & Movement Assessment for Radlett (E14, not located in the published evidence base).

The Council's own IDP (doc 6.1) records existing AM-peak gridlock on Watford Road and Harper Lane, the absence of a step-free station, and only 0.8 FE primary-school surplus by 2029-30 in the Radlett school planning area. Without the three studies, the residents of Radlett cannot meaningfully consult on whether 2,900 new homes are deliverable. This is a soundness defect under NPPF para 36(b) (justified) and 36(c) (effective). I request that the Council publishes these studies and runs a further Reg 18 consultation, or proceeds to Reg 19 only after addressing the gap.

3. The settlement context

The Council's own spatial strategy (Reg 18 paras 3.16–3.19) recognises that "Radlett and Bushey would take a lesser level of growth", reflecting "low density and high value properties arrayed in a suburban/commuter-belt townscape" and "limited range of main town centre uses and community facilities". Radlett sits in a valley, with no continuous pavement on key approach roads, narrow single-track sections (Common Lane, Loom Lane, New Road), a non-step-free station, no secondary school, a primary-school capacity buffer of only 0.8 FE, and existing AM-peak congestion at Hartspring Roundabout, Theobald Street/Watling Street, Shenley Hill and Harper Lane. The proposed allocation of 2,900 homes is inconsistent with the Council's own spatial strategy for Radlett as a Tier-3 settlement.

4. Site-by-site representations

SA1 — Regency House, 205 Watling Street (20 homes): Support

Brownfield, central urban, extant planning permission. NPPF para 148 sequential preference for previously developed land applies — this site should be brought forward as the priority Radlett allocation.

SA2 — Car Park, Railway Cottages (37 homes): Support, with conditions

Brownfield within the urban boundary. However, the Reg 18 site sheet records that the site is "situated and partially covered by Flood Zones 2 and 3". NPPF paras 178–180 require the sequential and exception tests at allocation stage. The Level 2 SFRA (E7) is in development. The plan should commit, in the allocation policy, that the exception test will be reapplied at application stage once the SFRA is published, and that replacement station car-parking is secured before any consent.

SA3 — Land North of Watford Road and East of Kemprow (972 homes): Strongly object on this scale; conditional support only for a small infill allocation of approximately 150 homes on the eastern (Crown Estate) parcel

The Reg 18 figure of 972 homes for SA3 cannot be reconciled with the Council's own evidence base. I object to this allocation on six grounds, each anchored in published Council evidence or in national policy:

1. The Sustainability Appraisal flags that the western (Cemex-owned) part of SA3 "would not relate very well to the settlement edge" (SA para 5.4.62). The Council's own technical work supports a substantially smaller allocation. There is no published rationale in the consultation document for the increase from the 2021 plan footprint of 350 homes (with a primary school) to the 2026 figure of 972. NPPF para 36(b) (justified).
2. The site contains a Local Wildlife Site and Group Tree Preservation Orders within the boundary (Reg 18 site sheet, p. 289). NPPF para 188 requires plans to "allocate land with the least environmental or amenity value". NPPF para 192(a) requires plans to "identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity" — which expressly includes Local Wildlife Sites. A 972-home allocation predictably fragments and degrades the LWS; a 350-home allocation reduces but does not eliminate that fragmentation risk; only a small infill allocation in the south-eastern corner of the site, well buffered from the LWS, is consistent with paras 188 and 192.
3. The wider Kemprow / Aldenham area is in the recorded distribution of great crested newts (Hertfordshire Atlas of Mammals, Amphibians and Reptiles, 2015–24; DEFRA Great Crested Newt Risk Zones (Hertfordshire) dataset). Great crested newts are a European Protected Species under the Conservation of Habitats and Species Regulations 2017 (reg 43). The Council's Habitats Regulations Assessment (doc 7.2a) considers only impact pathways to European-designated habitats sites and does not address species-level protection. A Phase 1 habitat survey and a presence/likely absence GCN survey is required at plan-making stage before any allocation can be safely justified. NPPF paras 192–195.
4. Cumulative traffic impact already meets the "severe" test in NPPF para 116. SA3 + SA4 + SA7 all access the same approximately 1.5km of Watford Road (B462). The IDP records existing AM-peak congestion "stretching as far back as Colney Street" with impacts on Harper Lane, the key M25 route from Radlett (IDP Transport section, AM peak hour observations for Radlett). 972 homes cannot be added to that road network without severe residual cumulative impact, and even 350 homes plus SA7's 190 plus a re-cast SA4 would test it. A 150-home infill allocation is the largest figure for SA3 that can credibly be argued not to engage para 116, given no Transport & Movement Assessment (E14) has been published.
5. Sustainable pattern of development. The site is approximately 25–30 minutes' uphill walk from a station with no step-free access, on roads that lack continuous pavement and cycle provision. NPPF para 148 requires the sustainable pattern of development to determine whether grey-belt release is appropriate, with particular reference to para 115. Radlett does not meet the test for a strategic urban extension of any meaningful scale on its western edge.
6. Infrastructure capacity matches a 150-home figure, not a 350-home or 972-home figure. The IDP records only a 0.8 FE (~24 Reception places per year, ~168 across the school) primary-school surplus across the Radlett planning area by 2029-30. Using the DfE standard yield ratio of 0.29 primary pupils per dwelling, 150 homes generates approximately 44 primary pupils — comfortably absorbable by the existing primary surplus without requiring a new school. 350 homes generates ~100 pupils, requiring an on-site school. 972 homes generates ~280 pupils, requiring multiple new forms of entry that the consultation document does not commit to delivering.

I would conditionally support a small infill allocation of approximately 150 homes on the south-eastern (Crown Estate) parcel of SA3 only, on these conditions:

• the western (Cemex) parcel removed from the allocation entirely and reverted to Green Belt;
• a strengthened wildlife corridor designation around the Local Wildlife Site, with a minimum 50m buffer between any new built form and the LWS boundary;
• a coordinated access strategy with SA7, including bus-priority and active-travel improvements on Watford Road delivered before first occupation;
• a full Protected-Species survey and a Habitats Regs reg 55 licence pathway in place before consent;
• infrastructure contributions sized to the actual yield (no more than 44 primary pupils, no more than ~340 vehicle movements per peak hour using TRICS averages), not to a notional 972-home build-out.

I do not support the 350-home 2021 plan footprint as an alternative — the case for a smaller allocation is, on the published evidence, stronger than the 2021 footprint reflects. Five years on from 2021, both the Local Wildlife Site evidence base and the cumulative traffic position have strengthened the case for a more modest allocation, not the dramatic increase the 2026 draft proposes.

SA4 — Land South of Watford Road and West of New Road (450 homes): Object as proposed; recommend recasting as a smaller HCC-led allocation with safeguarded land for a Radlett secondary school

I object to the proposed 450-home allocation on three grounds:

1. Heritage setting. The site sheet records "development potential impact on the setting of Battlers Green listed buildings (Five Grade II and one Grade II* buildings)". NPPF paras 200, 205–208 require great weight to be given to the conservation of designated heritage assets and their setting.
2. Archaeology. The site sheet identifies an "identified archaeological site". A Heritage Impact Assessment and archaeological field evaluation should be in the evidence base at Reg 18.
3. Best and most versatile agricultural land. The Sustainability Appraisal describes SA6 as Grade 2 agricultural land; SA4 sits immediately adjacent and on the same ALC classification. NPPF para 187(b) and footnote 65 to para 188 prefer poorer-quality land where significant agricultural-land development is necessary.

However, SA4 is HCC public-sector land (SA para 5.4.62). The Sustainability Appraisal explicitly identifies this as a unique opportunity: "this is public sector owned land (HCC), such that there would be good potential to deliver public benefits alongside new homes. For example, at London Colney the St Albans Local Plan proposes to allocate a site owned by HCC for 324 homes alongside land for a secondary school." Radlett has no secondary school, and the IDP confirms only a 2.4 FE secondary surplus across the combined Radlett+Bushey planning area. Reducing SA4 to ~150 homes and safeguarding the bulk of the site for a future Radlett secondary school would address the most acute infrastructure gap in the town and use HCC's landholding for its highest public-value purpose.

I would support a substantially smaller HCC-led allocation of approximately 150 homes with safeguarded secondary-school land.

SA5 — Land South of Shenley Hill (195 homes): Support

The site has outline permission granted at appeal on 23 March 2026 (24/1211/OUT), with 50% affordable housing and land safeguarded for a primary school expansion and a medical centre. It is in the committed five-year housing land supply. No useful purpose is served by objecting.

SA6 — Home Farm (1,040 homes): Object on this scale; conditional support for the promoter's 600-home Garden Suburb scheme with bound infrastructure conditions

I object to the 1,040-home figure on three grounds:

1. The Sustainability Appraisal flags single-access, BMV-land and trail constraints. SA para 5.4.59: "a single road access point could limit the number of homes that can be delivered. A further constraint is the Hertfordshire Way, which runs through the site… this is likely an area of better quality agricultural land in the Borough." NPPF paras 116, 148, 187(b) and footnote 65 to para 188 all bear on this.
2. Heritage setting. The site sheet records impact on Grade II Little Kendalls Farm, four Grade II and one Grade II* listed buildings at Battlers Green. NPPF paras 200, 205–208.
3. A deliverable smaller scheme already exists. The site promoter (Mac Mic Strategic Land) submitted EIA scoping request 25/1456/EI2 in 2025 for "up to 600 residential units" and consulted Radlett residents on a 600-home Garden Suburb scheme in March 2026, with 50% affordable, a primary school, GP/dentist potential, a country park, a community stewardship trust, custom/self-build homes and care/elderly living. The plan should align with the deliverable scheme, not exceed it.

I would support an allocation of up to 600 homes on SA6, with the following bound as policy: primary school and nursery, GP/dentist provision, 50% affordable housing, country park, integration of the Hertfordshire Way, surface-water management through SuDS as set out in the promoter's exhibition, and a community stewardship trust modelled on Hampstead Garden Suburb.

SA7 — Starveacres and land to the west (190 homes): Support, with conditions

Safeguarded for housing in the 2013 Local Plan; SA para 5.4.58 describes it as "a relatively strongly performing site". The principal cumulative concern is access onto Watford Road in combination with the reduced SA3 infill. I would support 190 homes subject to a coordinated SA3/SA7 access strategy that delivers bus-priority and active-travel infrastructure on the Watford Road before either site commences.

5. Cumulative impact and the spatial strategy

The plan over-allocates by ~5,240 homes against the standard-method need. The Radlett allocation can be reduced from 2,900 to approximately 1,350 by adopting the recommendations above. The "saved" capacity should be redirected through three mechanisms, each anchored in NPPF:

• Test brownfield density at Borehamwood and Potters Bar. Reg 18 para 3.17 lists Borehamwood Town Centre Retail Park, large-format food stores and time-expired office buildings as opportunities. NPPF para 147 requires Green Belt release to follow full brownfield exploitation and density optimisation.
• Strengthen the Bowmans Cross commitment. The plan currently delivers only 500 of Bowmans Cross's 4,000–7,500 capacity within the plan period. The Council should publish the M25-access, water and education work that would bring forward 1,000–1,500 in years 6–15. NPPF para 22 requires a 30-year horizon for new settlements. Bowmans Cross is the genuinely sustainable strategic urban extension; Radlett's valley topography is not.
• Press cross-boundary cooperation. NPPF paras 35, 36(c) and 11 require the duty-to-cooperate to be properly evidenced. The duty-to-cooperate appendices show ongoing engagement with St Albans, Watford and Three Rivers; the response should test whether more growth can be accommodated cross-boundary.

6. On the "consensus" claim

I am aware of an alternative consultation letter circulating in Radlett that asserts a "broad approach … that is the least unacceptable settlement wide response" in favour of building out SA3 and SA7 while refusing SA4 and SA6. I do not support this position and I do not believe it represents a documented consensus. No minuted Parish Council vote or show-of-hands at any Radlett public meeting in 2026 has been published in support of that claim, and it has been publicly disputed by named Radlett residents. Each representation must, as a matter of law, be considered separately on its planning merits. I respectfully ask the Council to weigh individual personalised responses without treating any template letter (mine or any other) as a substitute for individual representation.

7. Summary of representation

I support the principle of meeting the borough's housing need in full through the standard method, and I support the development of brownfield and previously safeguarded sites at SA1, SA2, SA5 and SA7. I object to the proposed scale of SA3, SA4 and SA6.

For SA3 specifically, the published evidence does not support an allocation of any meaningful scale. I would conditionally support only a small infill of approximately 150 homes on the south-eastern (Crown Estate) parcel — buffered from the Local Wildlife Site, sized to existing primary-school capacity, and conditional on a coordinated access strategy with SA7. For SA4, I would support a smaller HCC-led allocation of approximately 150 homes with safeguarded secondary-school land. For SA6, I would support up to 600 homes on the promoter's Garden Suburb scheme with the infrastructure bound as policy.

This represents an indicative Radlett total of approximately 1,350 homes — roughly 1,550 fewer than the Reg 18 draft proposes. The borough's existing 5,240-home headroom plus a strengthened Bowmans Cross commitment readily absorbs this reduction without compromising the standard-method target.

This representation relates to the plan as consulted. If the planning status of any site changes, or if the supporting evidence base (E7 Level 2 SFRA, E8 Water Cycle Study, E14 Transport Assessment, Protected Species surveys for SA3, Heritage Impact Assessments for SA4 and SA6) is published, I reserve the right to submit further representations.

Yours faithfully,

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