Hertsmere Draft Local Plan, Reg. 18 – April 2026, our consultation response

CPRE Hertfordshire presents our analysis and submission to Hertsmere Borough Council regarding their latest draft Local Plan consultation document. We have many significant concerns.

Among our headline concerns are the following.

This is not a credible Regulation 18 consultation as there is no draft policy wording. It is stated that this will be the final opportunity to comment on the Local Plan content before moving to Regulation 19. This is unacceptable without specific policies.

There are no specific policies relating to the positive future for the Green Belt, which is the largest designated land area in the Borough. The consultation document seeks to allocate even more Green Belt land for development (over 1,000 hectares) than the previous complete Regulation 18 consultation in November 2021.

The supporting Green Belt Assessment by consultants Aecom indicates that virtually all of the existing Green Belt in the Borough can be reclassified as ’grey belt’. This is ridiculous and could lead to the coalescence of major towns like Bushey and Radlett, and also Borehamwood and Potters Bar.

The Council claims that it must accept central Government figures for future housing land but councils all over the country are fighting back and Hertsmere has a very strong case to argue for reduced requirements and should do so. In any case, with the Candidate Sites, Hertsmere has significantly over-provided potential sites and this is both unnecessary and damaging.

The consultation document repeatedly confuses ‘need’ and ‘requirement’ using the terms interchangeably with regard to how much land the Local Plan should allocate for housing. This is misleading as it devalues the technical task of applying policy constraints to the allocation of land in the Local Plan as required by the National Planning Policy Framework (NPPF).

The case for including a new settlement at Bowman’s Cross is not justified. Most of the allocation for housing is made outside the Local Plan period and there are serious concerns about deliverability.

The consultation closing date of 29th May provides an inadequate period for a comprehensive response. The consultation website is not fit for purpose, being unnecessarily complicated to access and there are significant difficulties in making a response.

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In our CPRE Hertfordshire consultation response, we also respond separately to many of the specific consultation questions. Use the download button to read our full consultation response, and also to see our detailed site analysis of all the proposed allocations.

Download

These can be used to support your own consultation response. Please note that we do not intend to comment on individual sites, but we do encourage all interested parties to comment on specific sites of concern.

Comments on the Plan can be submitted to Hertsmere Borough Council by 29^th May 2026 either on the Council website at https://www.hertsmere.gov.uk/newlocalplan

Or via email or post.  Although not mentioned on the Hertsmere website, we have been told that they will accept comments by post and by email, provided that representations include full name and address and specify which question, site or part of the plan is being commented on.

Email contact details are: Local.Plan@hertsmere.gov.uk

Or post to:  Planning Policy Team, Hertsmere Borough Council,  Civic Offices, Elstree Way, Borehamwood, Herts WD6 1WA