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Response to CPRE's initial commentary on Draft Local Plan

Last Modified May 09, 2024


Cllr Nik Oakley, our Cabinet Member for Planning, Infrastructure and Transport, has provided a response to Campaign to Protect Rural England (CPRE) Hertfordshire, a countryside charity,  following its initial commentary on Hertsmere’s Draft Local Plan. You can read the letter in full, below. To take part in our Draft Local Plan consultation, and to find out more, please go to: https://www.hertsmere.gov.uk/newlocalplan


I note the contents of the CPRE Hertfordshire initial commentary on Hertsmere Local Plan: Green, sustainable growth: Towards 2040 – additional public consultation, April 2024. I look forward to reading the more detailed technical report, to be published later this month.

I am disappointed that the initial commentary contains several examples of information which are either incorrect or contain inaccuracies and, as such, it is misleading for our residents. For example, it states:

  • “Approximately 600 hectares of land in the Green Belt are still proposed to be removed for the allocation of development”.


This is incorrect. In fact, we are proposing just over 360 hectares of land in the Green Belt for the allocation of new homes with development. A further 95 hectares of existing built form in the Green Belt would be subject to a boundary review, comprising existing developed sites, as well as larger villages which (under national planning policy) should be considered for insetting. Around 15 hectares of land in the Green Belt, most of which is already consented (subject to s106), is earmarked for employment development but would remain in the Green Belt. 

  • (Bowmans Cross) “The Local Plan proposes the removal of 469 hectares of land from the Green Belt…”


This is incorrect. Your own spreadsheet, included as part of the initial commentary, evidences that more than 200 hectares of Green Belt land at Bowmans Cross would not be developed. Our Regulation 18 document shows a smaller area being removed from the Green Belt at Bowmans Cross - approximately 290 hectares.

  • “The Council’s own brownfield register shows there is enough identified, previously developed land currently available for 2,260 new dwellings”.


This is misleading as you have included sites on the brownfield register already to have been granted planning permission in your total of available brownfield sites (more than half of 2,260 units already have planning permission and most of those have now been built out). The Brownfield Land Register Regulations require that existing permissioned schemes are included in the published register.

I am extremely concerned that misinformation, such as in the above examples and several other instances in your initial commentary, will detrimentally affect some residents’ abilities to provide a well-informed response to our Draft Local Plan as part of the ongoing consultation. You may be aware that, in 2021, our officers wrote to CPRE Hertfordshire regarding inaccurate information which your organisation calculated and published on the amount of Green Belt land previously proposed for development during the public engagement undertaken at the time.

As such, we do intend to publish this letter through the council’s communications channels. I would also like to invite you to meet with myself and members of our Planning team so that we can ensure that all incorrect and inaccurate information is rectified prior to you publishing your more detailed technical report.


Yours sincerely,

Cllr Nik Oakley,

Cabinet Member for Planning, Infrastructure and Transport,

Hertsmere Borough Council

Posted on Wednesday 8th May 2024

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