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LEPUS CONSULTING LANDSCAPE, ECOLOGY, PLANNING & URBAN SUSTAINABILITY

Sustainability Appraisal of the Broxbourne Emerging Local Plan

July 2016

Assessment of the Regulation 18 Draft Local Plan

Sustainability Appraisal of the

Broxbourne Emerging Local Plan

Assessment of the

Regulation 18 Draft Local Plan

Photo: Peter O’Conner

LC-214 Document Control Box

Client Broxbourne Borough Council

Report Title Sustainability Appraisal of the Broxbourne Regulation 18 Draft Local Plan

Number 1

Status Draft

Filename LC-214_Reg 18 Report_3_290616RB.docx

Date July 2016

Author RB

Reviewed SS

Approved ND

Sustainability Appraisal of the Broxbourne Emerging Local Plan June 2016 LC-214_Reg 18 Report_3_290616RB.docx

© Lepus Consulting for Broxbourne Borough Council i

About this report & Notes for reader

Lepus Consulting Ltd (Lepus) has prepared this draft report for

the use of Broxbourne Borough Council. There are a number of

limitations, which should be borne in mind when considering the

results and conclusions of this report. No party should alter or

change this report whatsoever without written permission from

Lepus.

© Lepus Consulting Ltd

SEA is a tool for predicting potential significant effects. The

actual effects may be different from those identified. Prediction

of effects is made using an evidence-based approach and

incorporates a judgement.

The assessments above are based on the best available

information, including that provided to Lepus by the Council and

information that is publicly available. No attempt to verify these

secondary data sources has been made and they have assumed

to be accurate as published.

Every attempt has been made to predict effects as accurately as

possible using the available information. Many effects will

depend on the size and location of development, building design

and construction, proximity to sensitive receptors such as wildlife

sites, conservation areas, flood risk areas and watercourses, and

the range of uses taking place. The assessment was prepared

between March and June 2016 and is subject to and limited by

the information available during this time.

This report has been produced to assess the sustainability effects

of the Emerging Local Plan. It is not intended to be a substitute

for Environmental Impact Assessment (EIA) or Appropriate

Assessment (AA). For further information on the differences

between the products please see:

http://www.rspb.org.uk/Images/environmentalassessment_tcm

9- 257008.pdf

Client comments can be sent to Lepus using the following

address.

1 Bath Street,

Cheltenham

Gloucestershire

GL50 1YE

Telephone: 01242 525222

E-mail: [email protected]

www.lepusconsulting.com

Sustainability Appraisal of the Broxbourne Emerging Local Plan July 2016

LC-214_Reg 18 Report_3_290616RB.docx

© Lepus Consulting for Broxbourne Borough Council i

Contents

1 Introduction ........................................................................................................................ 1 1.1 Background .................................................................................................................................. 1 1.2 Purpose of this report .............................................................................................................. 1 1.3 About the Broxbourne Local Plan 2016-2031 ................................................................ 3 1.4 Using this document ................................................................................................................ 3

2 Methodology ..................................................................................................................... 4 2.1 Approach to assessment ....................................................................................................... 4 2.2 Appraisal process ..................................................................................................................... 5 2.3 Geographic scale ...................................................................................................................... 9 2.4 Impact magnitude .................................................................................................................... 9 2.5 Significance ................................................................................................................................. 11 2.6 Assumptions and limitations to assessment ................................................................. 13

3 Assessment of Places .................................................................................................. 18 3.2 DS1: The Development Strategy ....................................................................................... 18 3.3 DS2: Housing Provision ........................................................................................................ 19 3.4 DS3: Urban Capacity Sites .................................................................................................. 19 3.5 PM1: Sustainable Place Making ......................................................................................... 29 3.6 BR1: Brookfield ........................................................................................................................ 30 3.7 BX1: Broxbourne Village Improvement Plan ............................................................... 34 3.8 BX2: Broxbourne Station and Environs ......................................................................... 34 3.9 BX3: Broxbourne School ..................................................................................................... 34 3.10 PP1: Park Plaza West ......................................................................................................... 36 3.11 PP2: Park Plaza North ....................................................................................................... 38 3.12 PP3: Plot D, Park Plaza ..................................................................................................... 39 3.13 CH1: Cheshunt Lakeside ................................................................................................... 39 3.14 CH2: Rosedale Park ............................................................................................................ 41 3.15 CH3: Cheshunt Old Pond ................................................................................................ 43 3.16 CH4: Old Cambridge Road Corridor ........................................................................... 44 3.17 CH5: Cheshunt Football Club ........................................................................................ 44 3.18 CH6: Albury Farm Landscape Protection Zone ..................................................... 45 3.19 CH7: Bury Green and Churchgate ............................................................................... 46 3.20 CH8: Maxwells Farm West and Rush Meadow Safeguarded Land ................. 49 3.21 CH9: South of Hammondstreet Road ........................................................................ 50 3.22 GO1: Goffs Oak Village Improvement Plan ............................................................... 50 3.23 GO2: North of Goffs Lane ................................................................................................. 51 3.24 GO3: South of Goffs Lane ................................................................................................ 52 3.25 GO4: Newgatestreet Road ............................................................................................. 53 3.26 GO5: North of Cuffley Hill ............................................................................................... 54 3.27 GO6: Oakfield ...................................................................................................................... 56 3.28 HOD1: Hoddesdon Town Centre .................................................................................. 56 3.29 HOD2: Turnford Surfacing Site ...................................................................................... 57 3.30 HOD3: Rye Park .................................................................................................................. 58 3.31 HOD4: Hoddesdon Business Park ............................................................................... 58 3.32 HOD5: High Leigh Garden Village ............................................................................... 59



© Lepus Consulting for Broxbourne Borough Council ii

3.33 HOD6: Barclay Park and Spital Brook ........................................................................ 60 3.34 WC1: Waltham Cross Town Centre ............................................................................. 60 3.35 WC2: Waltham Cross Northern High Street ............................................................. 61 3.36 WC3: Waltham Cross Renaissance Area Action Plan .......................................... 62 3.37 WT1: Wormley Conservation Area Improvement Plan ........................................ 62 3.38 WT2: Macers Estate ........................................................................................................... 62 3.39 LV1: Lee Valley Regional Park ....................................................................................... 63 3.40 LV2: Lee Valley White Water Centre ......................................................................... 63 3.41 LV3: Broxbourne Leisure Pool Site ............................................................................. 64 3.42 LV4: Spitalbrook ................................................................................................................. 64 3.43 LV5: Lee Valley Park Gateways .................................................................................... 64 3.44 C1: Cheshunt Country Club ............................................................................................. 65 3.45 C2: Countryside Protection and enhancement ...................................................... 65 3.46 NR1: New River Conservation Area ............................................................................. 65 3.47 NR2: New River Path ......................................................................................................... 66 3.48 GT1: Provision for Gypsies, Travellers, and Travelling Showpeople ............... 66 3.49 GT2: Travelling Showpeople .......................................................................................... 67 3.50 INF1: Infrastructure ............................................................................................................ 68 3.51 INF2: Road Infrastructure ............................................................................................... 68 3.52 INF3 : Crossrail 2 / four tracking .................................................................................. 68 3.53 INF4: Rail Stations ............................................................................................................. 69 3.54 INF5: Level Crossings ....................................................................................................... 69 3.55 INF6: Bus Transport .......................................................................................................... 69 3.56 INF7: Walking and Cycling Strategy ........................................................................... 70 3.57 INF8: North to South Paths ............................................................................................ 70 3.58 INF9: Reserve Secondary School ................................................................................... 71 3.59 INF10: New and Expanded Primary Schools ............................................................ 72 3.60 INF11: Educational Facilities ............................................................................................. 72 3.61 INF12: Health Care ............................................................................................................... 72

4 Assessment of Development Management Policies ....................................... 74 4.2 DSC1: General Design Principles ...................................................................................... 74 4.3 DSC2: Sustainable Construction ....................................................................................... 75 4.4 DSC3: Designing out Crime ................................................................................................ 75 4.5 DSC4: Comprehensive Urban Regeneration ............................................................... 76 4.6 DSC5: Shop Fronts and Fascias ....................................................................................... 76 4.7 H1: Affordable Housing ........................................................................................................ 76 4.8 ED1: New Employment Uses ............................................................................................... 77 4.9 ED2: Loss of Employment Uses - Rest of the Borough ........................................... 77 4.10 ED3: Visitor Attractions .................................................................................................... 77 4.11 RTC1: Hierarchy of Town and Local Centres ........................................................... 78 4.12 RTC2: Development within designated town centres ......................................... 78 4.13 RTC3: Evening Economy ................................................................................................. 79 4.14 RTC4: Hot Food Take-Away Uses ............................................................................... 79 4.15 ORC1: New Open Space, Leisure, Sport and Recreational facilities ............... 79 4.16 ORC2: Loss of Open Space, Leisure, Sport and Recreational facilities ........ 80 4.17 ORC3: Local Green Space ............................................................................................... 80 4.18 ORC4: Amenity Spaces .................................................................................................... 80 4.19 ORC5: Community Uses ................................................................................................... 81 4.20 ORC6: Equestrian Development ................................................................................... 81



© Lepus Consulting for Broxbourne Borough Council iii

4.21 W1: Improving the quality of the water environment ........................................... 81 4.22 W2: Water Quality ............................................................................................................. 82 4.23 W3: Water Efficiency ........................................................................................................ 82 4.24 W4: SuDS .............................................................................................................................. 82 4.25 W5: Flood Risk .................................................................................................................... 83 4.26 GB1: Green Belt ................................................................................................................... 83 4.27 GB2: Residential development on Derelict Glasshouse Sites ........................... 83 4.28 GB3: Rural Diversification ............................................................................................... 84 4.29 GB4: New Glass House Sites and Nursery Developments ................................. 85 4.30 GB5: Occupancy Conditions .......................................................................................... 85 4.31 NEB1: Wildlife, Wildlife Sites and Biodiversity ........................................................ 85 4.32 NEB2: Green Infrastructure ............................................................................................ 86 4.33 NEB3: Landscaping and Biodiversity in New Developments ........................... 86 4.34 NEB4: Protected Trees and Hedgerows ................................................................... 86 4.35 EQ1: Air Quality ................................................................................................................... 87 4.36 EQ2: Lighting ....................................................................................................................... 87 4.37 EQ3: Noise ............................................................................................................................ 88 4.38 EQ4: Contaminated Land ............................................................................................... 88 4.39 EQ5: Waste and recycling .............................................................................................. 88 4.40 EQ6: Minerals ....................................................................................................................... 89 4.41 HA1: Heritage Assets ......................................................................................................... 89 4.42 HA2: Non-Designated Heritage Assets ..................................................................... 90 4.43 HA3: Conservation Areas ................................................................................................ 90 4.44 HA4: Demolition in a Conservation Area .................................................................. 90 4.45 HA5: Listed Buildings ........................................................................................................ 91 4.46 HA6: Locally Listed Buildings ......................................................................................... 91 4.47 HA7: Works Within the Setting of Listed and Locally Listed Buildings ........ 91 4.48 HA8: Demolition of Listed Buildings ........................................................................... 92 4.49 HA9: Historic Parks and Gardens ................................................................................. 92 4.50 HA10: Archaeology ............................................................................................................ 92 4.51 HA11: Scheduled Monuments ......................................................................................... 93 4.52 HA12: Works affecting the setting of a Nationally Designated Building, Structure, Landscape, Park or Garden or Other Feature .................................................. 93 4.53 TM1: Sustainable Transport ............................................................................................ 93 4.54 TM2: Transport and New Developments .................................................................. 94 4.55 TM3: Access and Servicing ............................................................................................. 94 4.56 TM4: Parking Standards .................................................................................................. 95 4.57 TM5: Vehicle Cross Overs ............................................................................................... 95 4.58 PO1: Planning Obligations ............................................................................................... 96 4.59 PO2: Community Infrastructure Levy ........................................................................ 96

5 Mitigation Considerations and Recommendations ......................................... 97 5.1 Introduction ............................................................................................................................. 97 5.2 SA Objective 1: Cultural Heritage ..................................................................................... 97 5.3 SA Objective 2: Landscape ................................................................................................ 98 5.4 SA Objective 3: Biodiversity .............................................................................................. 98 5.5 SA Objective 4: Climate Change mitigation .............................................................. 100 5.6 SA Objective 5: Climate Change Adaptation ............................................................ 100 5.7 SA Objective 6: Natural Resources ................................................................................. 101 5.8 SA Objective 7: Pollution .................................................................................................... 101



© Lepus Consulting for Broxbourne Borough Council iv

5.9 SA Objective 8: Waste ........................................................................................................ 102 5.10 SA Objective 9: Transport ............................................................................................. 103 5.11 SA Objective 10: Housing .............................................................................................. 104 5.12 SA Objective 11: Health ................................................................................................... 104 5.13 SA Objective 12: Economy and employment ......................................................... 105 5.14 SA Objective 13: Education ........................................................................................... 105

6 Conclusions and Next Steps ................................................................................... 107 6.1 Conclusions ............................................................................................................................. 107 6.2 Next Steps ............................................................................................................................... 107

APPENDIX A: SA Framework APPENDIX B: Combined Assessment Results



© Lepus Consulting for Broxbourne Borough Council v

Tables Table 1.1 SA Objectives

Table 2.1 Guide to impact significance matrix

Table 2.2 Geographic scales

Table 2.3 Impact magnitude

Table 2.4 Guide to terms used in the significance matrix (Barton et al, 2010)

Table 2.5 Sustainable distances to facilities and amenities

Acronyms BBC Broxbourne Borough Council

BOS Borough Wide Options and Scenarios Report

CAMS Catchment Area Management Strategies

CIL Community Infrastructure Levy

ELP Emerging Local Plan

GI Green Infrastructure

HRA Habitat Regulations Assessment

LNR Local Nature Reserve

LWS Local Wildlife Site

NERC Natural Environment and Rural Communities

NNR National Nature Reserve

SA Sustainability Appraisal

SAC Special Area of Conservation

SEA Strategic Environmental Assessment

SLAA Strategic Land Availability Assessment

SPA Special Protection Area

SSSI Site of Special Scientific Interest



© Lepus Consulting for Broxbourne Borough Council vi

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Sustainability Appraisal of the Broxbourne Emerging Local Plan July 2016 LC-214_Reg 18 Report_3_290616RB.docx

© Lepus Consulting for Broxbourne Borough Council 1

1 Introduction

1.1 Background

1.1.1 Lepus Consulting Ltd (Lepus) has been instructed by Broxbourne

Borough Council (BBC) to undertake a Sustainability Appraisal (SA) of

the Emerging Local Plan. This document presents an assessment of the

reasonable alternatives for the Broxbourne Emerging Local Plan (ELP).

1.1.2 Please note that this document does not constitute an Environmental

Report in line with the SEA Directive1. It is a record of the assessment of

the draft policies set out in the Regulation 18 Draft Local Plan

Consultation Document.

1.2 Purpose of this report

1.2.1 This interim assessment report has been prepared to help inform BBC’s

preparation of their Emerging Local Plan (ELP). It is not the role of the

SA to decide which is the most appropriate alternative from those set

out in the plan, rather it is an assessment of the alternatives to be given

due consideration in the decision making process.

1.2.2 Article 5(1) of the SEA Directive states that ‘Where an environmental

assessment is required under Article 3(1), an environmental report shall

be prepared in which the likely significant effects on the environment of

implementing the plan or programme, and reasonable alternatives taking

into account the objectives and the geographical scope of the plan or

programme, are identified, described and evaluated. The information to

be given for this purpose is referred to in Annex I.’

1.2.3 PPG Paragraph: 018 Reference ID: 11-018-20140306 states that

‘Reasonable alternatives are the different realistic options considered by

the plan-maker in developing the policies in its plan. They must be

sufficiently distinct to highlight the different sustainability implications of

each so that meaningful comparisons can be made. The alternatives

must be realistic and deliverable.’

1 European Directive 2001/24/EC



1.2.4 The first step of this process was the assessment of the broad spatial

options set out in the Broxbourne Local Plan ‘Duty to Co-operate

Document’2. A draft vision and objectives for the Duty to Cooperate

Document were approved by BBC in October 2015. Based on these

agreed principles, the Duty to Cooperate Document set out how BBC

proposed to deliver their objectives through growth targets and land

allocations. The Duty to Cooperate document formed the basis of BBC’s

requirement to hold discussions with its Duty to Cooperate Partners and

as such was not intended for either public consultation or consultation

with other stakeholders.

1.2.5 The Duty to Cooperate Document set the interim direction of travel for

the Local Plan and informed the preparation of the ‘Borough-Wide

Options and Scenarios 3 ’ report. The ‘Borough-Wide Options and

Scenarios’ report included a long-list of sites that represented the

potential development capacity within the urban area of the borough.

From the long-list of sites, the report then identified those sites that

were reasonable. The reasonable sites were also drawn together into

three alternative scenarios for development. Those reasonable

alternative sites and scenarios were assessed in the SA of the Borough

Wide Options and Scenarios report (June 2016).

1.2.6 This Regulation 18 SA presents an assessment of the policies set out in

the Regulation 18 Draft Local Plan Consultation Document4 with the

following key intentions:

• To identify the environmental, social and economic effects of the Regulation 18 Local Plan; and

• To set out mitigation considerations and enhancement opportunities that would help to enhance the overall sustainability of the Local Plan at a sufficiently early juncture that they be given due consideration as the plan progresses.

1.2.7 Cumulative effects are not assessed in this document. As this document

represents the reasonable alternatives stage, it is not known which of the

options presented will be carried forward to the next stage of plan

making.

2 Broxbourne Borough Council (October 2015) The Broxbourne Local Plan: A Duty to Co-operate Document 3 Broxbourne Borough Council (April 2016) Emerging Local Plan: Borough-Wide Options and Scenarios 4 Broxbourne Borough Council (July 2016) Regulation 18 Draft Local Plan Consultation Document



1.3 About the Broxbourne Local Plan 2016-2031

1.3.1 This Local Plan will set out proposals for how Broxbourne will grow and

develop to become a more desirable place to live, work and visit. It will

outline how much, what type and where development should be

delivered. The Draft Local Plan is expected to consist of the following:

• A spatial portrait of the borough;

• A vision of how the borough will develop over the next 15 years;

• Objectives to guide the strategy and detailed content of the plan;

• A Spatial Development Strategy;

• Strategic policies that will allocate land for development and determine how strategic planning decisions are to be taken;

• Development Management policies; and

• A policies map.

1.4 Using this document

1.4.1 The Regulation 18 Draft Local Plan Consultation Document is split into 3

sections:

• Part 1: Introduction;

• Part 2: Development Strategy;

• Part 3: Places;

• Part 4: Infrastructure and Planning Obligations; and

• Part 5: Development Management Policies.

1.4.2 All of the policies within the Regulation 18 Draft Local Plan Consultation

Document are contained within Parts 2 to 5. For ease of reference, this

SA Report mirrors that structure as follows:

• Chapter 1 presents the introduction;

• Chapter 2 presents the methodology used to undertake the SA;

• Chapter 3 presents the assessment results for places;

• Chapter 4 presents the assessment results for the development management policies;

• Chapter 5 presents mitigation considerations and recommendations; and

• Chapter 6 presents the conclusions and next steps.



2 Methodology

2.1 Approach to assessment

2.1.1 The approach to assessment uses geographic information, the SA

Framework and established standards (where available) to help make

the assessment decisions transparent and robust.

2.1.2 The sites and policies have been assessed against the SA Framework

(see Appendix A). The SA Framework is composed of Objectives and

decision-making criteria. Acting as yardsticks of sustainability

performance, the SA Objectives are designed to represent the topics

identified in Annex 1(f)5 of the Directive. Including the SEA topics in the

SA Objectives helps ensure that all of the environmental criteria of the

SEA Directive are included. Consequently, the thirteen SA Objectives

seek to reflect all subject areas to ensure the assessment process is

transparent, robust and thorough. For ease of reference, the SA

Objectives are set out in Table 1.1 .

Table 1.1: SA Objectives

SA Objectives

1. Cultural heritage: Protect, enhance and manage sites, features, areas and landscapes of archaeological, historical and cultural heritage importance, their setting and significance.

2. Landscape: Protect, enhance and manage the character and appearance of the landscape and townscape, maintaining and strengthening local distinctiveness and sense of place.

3. Biodiversity and geodiversity: Protect, enhance and manage biodiversity and geodiversity.

4. Climate change mitigation: Minimise the borough's contribution to climate change.

5. Climate change adaptation: Plan for the anticipated levels of climate change.

6. Natural resources: Protect and conserve natural resources.

7. Pollution: Reduce air, soil and water pollution.

8. Waste: Reduce waste generation and disposal, and promote the waste hierarchy of reduce, reuse, recycle/compost, energy recovery and disposal.

9. Transport and accessibility: Improve the efficiency of transport networks by increasing the proportion of travel by sustainable modes and by promoting policies which reduce

5 Annex 1(f) identifies: ‘the likely significant effects on the environment, including on issues such as biodiversity, population, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage including architectural and archaeological heritage, landscape and the interrelationship between the above factors’.



the need to travel.

10. Housing: Provide affordable, environmentally sound and good quality housing for all.

11. Health: Safeguard and improve community health, safety and well being.

12. Economy: Develop a dynamic, diverse and knowledge-based economy that excels in innovation with higher value, lower impact activities.

13. Education, skills and training: Raise educational attainment and develop and maintain a skilled workforce to support long-term competitiveness.

2.1.3 To expand on the central focus of each SA Objective (as they are high-

level and potentially open-ended) the SA Framework includes a series of

questions or ‘decision making criteria’ for use when applying the SA

Framework to the assessment of sites or proposed policies.

2.1.4 The purpose of the SA Objectives is to provide a way of ensuring that

the proposed plan considers each site on a fair and consistent basis.

2.1.5 It should be noted that the ordering of the SA Objectives does not infer

any prioritisation.

2.2 Appraisal process

2.2.1 The appraisal process has used the SA Framework, the review of plans,

programmes and policies, and the baseline (including various mapped

data sources), as presented in the SA Scoping Report, to assess each

option. Assessments have been undertaken using this empirical

evidence and, to a lesser extent, expert judgement.

2.2.2 The first stage of assessment involves answering each of the questions

in the SA Framework in turn with a yes (+), no (-), uncertain (+/-) or

negligible / no effect / not applicable (0). The results of this indicate

whether the scenario is likely to bring positive, negative or uncertain

effects in relation to the SA Objectives. This information is then used to

inform the overall effect of the site on the SA Objective.



2.2.3 The second stage of assessment considers the level of significance of

the effects identified in the first stage (described above). Leading from

the likelihood of positive or negative effects, the assessment draws on

criteria for determining the likely significance of effects referred to in

Article 3(5) of the SEA Directive and presented in Annex II of the

Directive (see Box 2.1). The identified effects, where scored as positive

or negative, can be considered to be significant. Any assessment rated

as negligible is not considered to represent a significant effect. The

extent of significance is perhaps most helpfully expressed by orders of

magnitude.

2.2.4 At a strategic level it can be difficult to assess significant effects in the

absence of widespread data. Instead, orders of magnitude are used,

based on geographic significance and impact magnitude. Table 2.1

illustrates such orders of magnitude for positive and negative effects.

2.2.5 Each of the effects identified in the first stage of assessment are

assigned a colour and corresponding symbol to reflect the level of

significance of the effect and whether it is positive, negative uncertain or

negligible. Orders of magnitude are not assigned to uncertain effects. A

single value from Table 2.1 is allocated to each SA Objective and

presented in the text of the report (see Chapters 3 and 4).

2.2.6 When selecting a single value to best represent the sustainability

performance of the relevant SA Objective, the Precautionary Principle is

used. This is a worst-case scenario approach. Values presented at the

first stage of assessment (see the questions in the SA Framework) are

used to determine whether the single value for the SA Objective is

positive, negative, uncertain or negligable.

2.2.7 If a positive effect is identified in relation to one criteria within the SA

Framework and a negative effect is identified in relation to another

criteria within the same SA Objective, that Objective will be given an

overall negative value.

2.2.8 Assessment results are presented in a single matrix format with

accompanying narrative text to interpret the sustainability performance

of each site.



Table 2.1: Guide to impact significance matrix

Impact magnitude

Adverse

Neutral or

negligible

Positive

Uncertain

High Medium Low Low Medium High

Geographic

scale

(Sensitivity)

International /

National (High)

Major

---

Major

---

Moderate

-- 0

Moderate

++

Major

+++

Major

+++ +/-

Regional

(Medium)

Major

---

Moderate

--

Minor

- 0

Minor

+

Moderate

++

Major

+++ +/-

Local

(Low)

Moderate

--

Minor

-

Minor

- 0

Minor

+

Minor

+

Moderate

++ +/-

2.2.9 Whilst the orders of magnitude are determined by impact magnitude

and sensitivity, the determination of impact takes into consideration the

characteristics of the resultant effect as presented in Box 2.1.

2.2.10 As demonstrated in Table 2.1, significance is determined by the

sensitivity (expressed in terms of geographic scale) of the receptor and

the impact magnitude. The coloured boxes represent the level of

significance of the predicted effect. The text in each of these boxes

describes the level of significance, whilst the plus (+) and minus (-)

symbols, along with the colours, give a visual representation of this.

2.2.11 To understand the overall effect of the site or policy being assessed, the

effects identified against all objectives needs to be taken into account to

understand the overall effect, taking into account the environmental,

social and economic aspects of sustainability. A site or policy that is

found to have negative effects against certain objectives is not

necessarily unsuitable as these negatives must be considered in light of

any positive effects that may have been identified. Note too that the

impact magnitudes are not intended to be summed. For example, two

‘+’ are not to be considered equal to a single ‘++’. The scores assigned

are a matter of professional judgement taking into account the baseline

data, policy context and other sources of information available to inform

the assessment.



2.2.12 Geographic scale relates primarily to the level of importance of the

receptor, and hence it’s sensitivity, or the level at which it is designated,

if applicable. Geographic scale may also refer to the physical area of the

receptor, or the part of the receptor likely to be affected.

2.2.13 Impact magnitude relates to the degree of change the receptor will

experience, including the probability, duration, frequency and

reversibility of the effects (see Box 2.1). The terms used in Table 2.1 are

explained in more detail below.

Box 2.1 Annex II of the SEA Directive

Criteria for determining the likely significance of effects referred to in Article 3(5) of the SEA Directive

The characteristics of plans and programmes, having regard, in particular, to

• the degree to which the plan or programme sets a framework for projects and other activities, either with regard to the location, nature, size and operating conditions or by allocating resources;

• the degree to which the plan or programme influences other plans and programmes including those in a hierarchy;

• the relevance of the plan or programme for the integration of environmental considerations in particular with a view to promoting sustainable development;

• environmental problems relevant to the plan or programme;

• the relevance of the plan or programme for the implementation of Community legislation on the environment (e.g. plans and programmes linked to waste- management or water protection).

Characteristics of the effects and of the area likely to be affected, having regard, in particular, to

• the probability, duration, frequency and reversibility of the effects;

• the cumulative nature of the effects;

• the transboundary nature of the effects;

• the risks to human health or the environment (e.g. due to accidents);

• the magnitude and spatial extent of the effects (geographical area and size of the population likely to be affected);

• the value and vulnerability of the area likely to be affected due to:

• special natural characteristics or cultural heritage;

• exceeded environmental quality standards or limit values;

• intensive land-use;

• the effects on areas or landscapes which have a recognised national, Community or international protection status.



2.2.14 Limitations in terms of the level of detail and confidence of assessment

are cited in the explanatory text; the worst case scenario has been

assumed in accordance with the Precautionary Principle6.

2.3 Geographic scale

2.3.1 Impact assessment in the sustainability appraisal considers a range of

geographic scales and sensitivities at which the impact and subsequent

effects might be experienced. A guide to the range of scales used in the

impact significance matrix is presented in Table 2.2.

Table 2.2: Geographic scales

Sensitivity Typical criteria

International / national

The international level is aimed at designations that have an international aspect or consideration of transboundary effects beyond national boundaries. This also applies to predicted effects at the national level or designations/receptors that have a national dimension.

Regional This includes the regional and sub-regional scale, including county-wide level and regional areas such as the East of England.

Local This is the district and neighbourhood scale.

2.4 Impact magnitude

2.4.1 Impacts are assessed by combining judgements about susceptibility to

the type of change arising from the specific proposal with judgements

about the value attached to the receptor.

2.4.2 On a strategic basis, the appraisal considers the degree to which a

location can accommodate change without detrimental effects on

known receptors (identified in the baseline) and the degree to which

individual receptors will be affected by the change. This is determined

by considering factors included in Annex II of the SEA Directive:

• Probability;

• Duration;

• Frequency; and

• Reversibility. 6 The Precautionary Principle States that when human activities may lead to morally unacceptable harm that is scientifically plausible but uncertain, actions shall be taken to avoid or diminish that harm. Af full definion can be found here: http://unesdoc.unesco.org/images/0013/001395/139578e.pdf



2.4.3 SA and SEA are concerned with likely significant effects. As such, if an

effect is considered improbable, it will not be considered in assessment.

It is considered that most effects cannot be predicted with absolute

certainty, as many impacts depend on the design of development and

may be subject to mitigation.

Table 2.3: Impact magnitude

Magnitude of Effect

Typical criteria

High

Likely total loss of or major alteration to the receptor in question.

OR

Provision of a new receptor / feature

OR

The impact is permanent and frequent.

Medium

Partial loss of / alteration / improvement to one or more key elements / features / characteristics of the receptor in question.

OR

The impact is one of the following:

• Frequent and short-term

• Frequent and reversible

• Long-term (and frequent) and reversible

• Long-term and occasional

• Permanent and occasional

Low

Minor loss / alteration / improvement to one or more key elements / features / characteristics of the receptor in question.

OR

The impact is one of the following:

• Reversible and short-term

• Reversible and occasional

• Short-term and occasional



2.5 Significance

2.5.1 By combining the assessment of geographic scale and magnitude of

impact it is possible to predict the significance of a proposal.

Significance can be categorised as minor, moderate or major. The

nature of the effect can be either beneficial or adverse depending on the

type of development and the design and mitigation measures proposed.

Table 2.1 is a matrix for identifying significant environmental effects; it

combines the criteria used to define impact magnitude with receptor

sensitivity and geographic scale, in order to arrive at a judgement of the

likely level of significance. Terms used in the table are explained in

Table 2.4.



Table 2.4: Guide to terms used in the significance matrix

Significance Definition

Major adverse

The size, nature and location of a proposal would:

• permanently degrade, diminish or destroy the integrity of the receptor;

• cause a very high quality receptor to be permanently changed and its quality diminished;

• not be fully mitigated and may cumulatively amount to a severe adverse effect;

• be at a considerable variance to the location, degrading the integrity of the receptor; and

• be substantially damaging to a high quality receptor such as a specific regional or national designation.

Moderate adverse


• be out of scale with the location;

• leave an adverse impact on a receptor of recognised quality such as a specific district or county designation.

Minor adverse


• not quite fit into the existing location or with existing receptor qualities;

• affect undesignated yet recognised receptor qualities at the neighbourhood scale.

Minor beneficial


• improve undesignated yet recognised receptor qualities at the neighbourhood scale;

• fit into or with the existing location and existing receptor qualities;

• enable the restoration of valued characteristic features partially lost through other land uses.

Moderate beneficial


• fit very well with the location;

• improve one or more key elements / features / characteristics of a receptor with recognised quality such as a specific district or county designation.

Major beneficial


• enhance and redefine the location in a positive manner, making a contribution at a national or international scale;

• enhance and redefine the location in a positive manner;

• repair or restore receptors badly damaged or degraded through previous uses; and

• improve one or more key elements / features / characteristics of a receptor with recognised quality such as a specific regional or national designation.



2.6 Assumptions and limitations to assessment

2.6.1 There are a number of limitations, which should be borne in mind when

considering the results and conclusions of this assessment.

2.6.2 Sustainability Appraisal is a tool for predicting potential significant

effects. Prediction of effects is made using an evidence based approach

and incorporates a judgement.

2.6.3 Assessments are based on the best available information, including that

provided to us by the client team and information that is publicly

available. Every attempt has been made to predict effects as accurately

as possible using the available information.

2.6.4 Water supply and use is guided by the Environment Agency’s

Catchment Area Management Strategies (CAMS). CAMS are six-year

strategies developed for managing water resources at the local level.

Two CAMS cover the borough of Broxbourne. The Upper Lee CAMS

suggests the north of the borough is within an area that is over

abstracted. The London CAMS suggests the south of the borough is

within an area classed as over licenced, and the Lea Valley watercourses

being over abstracted. �It is assumed that all housing proposals in the

Local Plan will be subject to appropriate approvals and licencing for

sustainable water supply from the Environment Agency.

2.6.5 Distances have been measured from the closest boundary of the site to

the closest boundary of the receptor. This has been measured as the

crow flies. Distances to facilities and amenities have been considered

sustainable if they are within the maximum recommended distances

stated in Barton, Grant and Guise (2010) Shaping Neighbourhoods for

local health and global sustainability.

2.6.6 A limited number of site visits have been undertaken as a part of the

preparation of this SA, however due to the strategic nature of the

document and the number of sites involved, it has not been possible to

visit all of them.

SA Objective 1: Cultural Heritage

2.6.7 It is assumed that all historic statutory designations, including listed

buildings and conservation areas, will not be lost to development. The

effects of a development on any given historic asset depends

substantially on the design and implementation of development, with the

potential for both positive and negative effects to occur.



2.6.8 The design of any of the developments that may take place on the sites

identified by the ‘Borough Wide Options and Scenarios’ report is not

known at this stage. Ultimately therefore, the effect remains uncertain.

However there is a risk of adverse effects occurring, some of which may

be unavoidable. As such, this risk has been reflected in the assessment

as a negative effect where sites are in close proximity to historic assets.

The severity of the effect has been assigned based on the sensitivity of

the historic asset in question.

SA Objective 3: Biodiversity

2.6.9 The assessment of effects has been undertaken prior to the outcomes of

a Habitat Regulations Assessment (HRA) Screening exercise. The HRA

Screening will identify whether the Plan will have a significant effect on

any European designated sites. At this stage, the effects identified are

based on reasonable assumptions and take into account informal

discussions between BBC with Natural England. The HRA Screening will

be undertaken prior to the Regulation 19 iteration of the Local Plan and

the SA will be updated accordingly

2.6.10 No site visits have been undertaken to survey and record habitat or

species information at each site.

2.6.11 Loss of ancient semi-natural woodland and ancient replanted woodland

represents a permanent loss and cannot be mitigated or re-created.

2.6.12 Without species-specific data for each site, assessment of impacts has

concentrated on habitat presence and diversity.

2.6.13 Where new residential development is either adjacent or in close

proximity to Local Wildlife Sites (LWSs), it is assumed that there will be

a risk of adverse effects on the LWS as a result of, for example,

predation from domestic cats, noise and light pollution or litter, and

increased disturbance from people.

2.6.14 The following list of species is associated with particular habitat types. It

is assumed that detailed species surveys to determine presence will be

prepared at the planning application stage:

• Great Crested Newts are associated with ponds, lakes and other suitable water features.

• Bats are associated with mature woodland, certain buildings, quarries and caves.

• Reptiles are associated with railway embankments, allotments, quarries and rough grassland.



• Dormice are associated with coppiced woodland and mature hedgerows, especially ancient semi-natural woodland, in the vicinity of suitable woodland locations.

• White-Clawed Crayfish are associated with freshwater streams, rivers, canals and lakes.

• Badgers are associated with hedgerows, arable and pasture farmland and grassland.

• Breeding and wintering Birds are associated with woodland, trees, hedgerows, and other shrubby structures.

• Otters are associated with freshwater habitats, particularly rivers.

• Water Voles are associated with vegetated river, stream, canal, ponds and ditch banks.

• For the purpose of this document, habitats of principal importance are those listed under s.41 of the NERC Act.

• For the purpose of this document, species of principal importance are those listed under s.41 of the NERC Act.

SA Objective 6: Natural Resources

2.6.15 It is assumed that development within Mineral Consultation Areas7 will

sterilise important mineral resources.

SA Objective 7: Pollution

2.6.16 It is assumed that housing options will not impact groundwater source

protection zones. Employment options have been assessed as

uncertain, as impact will depend on the use of the option area.

SA Objective 8: Waste

2.6.17 It is assumed that development will be aligned with the Hertfordshire

Waste Development Framework: Waste Core Strategy & Development

Management Policies Development Plan Document 2011-2016

(Hertfordshire County Council, 2012).

2.6.18 The Council has identified that the volume of waste produced by the

borough has reduced over the past couple of years. It is assumed all

sites will contribute towards continued improvements in waste reduction

and disposal management.

7 Hertfordshire County Council (date unknown) Minerals Consultation Areas supplementary planning document) available at: http://www.hertsdirect.org/docs/pdf/m/mcaspd.pdf accessed: 03/02/16



2.6.19 The implications of these development scenarios on the amount of

waste disposed through landfill remains uncertain as this largely

depends on whether recycling facilities are easily accessible to residents

(i.e. incorporated into development). Waste generation per capita is not

generally expected to increase, as any new residents are expected to

live similar lifestyles to existing residents.

2.6.20 Employment sites have been assessed as uncertain for SA Objective 8.

The amount of waste generated depends on the type of business

operating at this site.

SA Objective 9: Transport

2.6.21 For the purpose of this assessment, in line with Barton et al, 20108, 400m

is the recommended distance for travelling to a bus stop, and 1km is

used for train stations.

2.6.22 It is assumed that the presence of bus stops will lead to positive

sustainability effects. The level of significance is likely to be ‘minor’ since

magnitude of impact is low, and at a local scale.

2.6.23 Presence of train stations are assumed to have a moderate level of

significance since magnitude of impact is likely to be medium and at a

regional scale.

2.6.24 There is an assumption that the majority of residents moving into new

residential developments will own a car, or other private vehicle. There

is an assumption that car use is likely to be lower if local services and

amenities are close enough to be accessible by foot or if there are good

links to sustainable modes of transport, particularly buses and

cycleways.

SA Objective 10: Housing

2.6.25 For development options that include the provision of housing, any

option proposing <100 homes is given single plus scoring, 100 – 300 a

double plus score and >300 homes a triple plus scoring.

SA Objective 11: Health

2.6.26 It has been assumed that all public rights of way will be retained or re-

routed around the site.

8 Barton et al (2010) Shaping Neighbourhoods for local health and global sustainability. 2nd edition



2.6.27 Barton et al (2010) gives target distances and maximum distances to

certain facilities and amenities as show in Table 2.5.

Table 2.5: Sustainable distances to facilities and amenities (Barton et al, 2010)

Features Target distance Maximum distance

Local park/ green space 400m 600m

Leisure centre 1.5km 2km

Doctor’s surgery 800m 1km

Hospital 5km 8km



3 Assessment of Places

3.1.1 This section of the Regulation 18 Draft Local Plan Consultation Document

sets out BBC’s approach to developing and regenerating the borough’s

towns and villages. The first two polices within the section set the

overall development strategy.

3.2 DS1: The Development Strategy

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3.2.1 The population of Broxbourne is expected to increase throughout the

period of the plan. This policy provides for 7,484 new homes, which is

considered sufficient meet the additional housing required. The policy

also makes provision for 6,500 net additional jobs, new schools and

associated infrastructure.

3.2.2 The policy identifies the key requirements for the anticipated growth of

the borough over the plan period. The policy allocates a number of

strategic residential and employment sites and these have been

assessed under the specific policies that allocate the sites. The policy’s

approach to development growth in the borough would directly benefit

housing, transport, employment and education objectives, however as

the policy does not allocate all the sites required to deliver the stated

housing provision, the extent of the effect against a number of the SA

objectives is uncertain.

3.2.3 The policy emphasises BBC’s commitment to protecting the countryside

and, Green Belt and Lee Valley Regional Park. These are key assets for

the borough for both their contribution to the borough’s landscape and

biodiversity.

3.2.4 Reference should be made to the assessment of alternative housing

scenarios in the SA of the Borough-Wide Options and Scenarios, which

identified the anticipated effects of three different levels of housing in

the borough.



3.3 DS2: Housing Provision

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3.3.1 This policy provides for 419 new dwellings across the borough per

annum, which is sufficient to meet the anticipated demand for housing in

Broxbourne. As this policy does not allocate the sites on which the

housing would be delivered, the effects of the policy beyond the benefit

to additional housing delivery is largely uncertain.

3.4 DS3: Urban Capacity Sites

3.4.1 A cluster analysis has been undertaken of the urban capacity sites on a

settlement-by-settlement basis. The sites within each urban area are

expected to have similar effects against the SA Objectives and as such

the assessment sets out the anticipated environmental effects for each

settlement as a whole. The sites within each settlement have been

considered individually as a part of preparing the overall commentary

for each site. Additional commentary has been prepared where there is

an effect on a specific site.

Hoddesdon

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3.4.2 The following urban sites are included in this assessment:

• Former Turnford Surfacing Site, Rye Road;

• Salisbury Road Industrial Premises;

• 19 Amwell Street and Scania House;

• Lea Road Industrial works;

• Garages off Burnside;

• Crown Buildings and Squash Club;

• 25, 25a and 25b High Street;

• Lampit Mansard Roofs;

• Former Wormley Primary School;

• Westfield Primary School; and



• Gas Distribution Station, St Catherine’s Road.

3.4.3 The majority of Hoddesdon is an urban residential environment,

particularly to the north and west. The main retail area of the town is

the pedestrianised High Street in the south of Hoddesdon. The retail

area continues north from the High Street along Amwell Street. In the

south east of Hoddesdon is a 12ha light industrial estate. On the eastern

side of Hoddesdon are the John Walker School and Sports Centre and

Rye Valley Train Station. Hoddesdon is also served by Broxbourne

Station.

3.4.4 Rye Meads Sewage Works is approximately 620m to the east of

Hoddesdon and is in operational use. Being to the east of Hoddesdon

and therefore downwind on the majority of days, the risk of odour

pollution in Hoddesdon is minimal. In addition, it is sufficiently far from

Hoddesdon to make a reduction in amenity for residential sites as a

result of odours an unlikely effect.

3.4.5 The Lea Valley Site of Special Scientific Interest (SSSI) and Ramsar Site

and the Rye Meads SSSI are both adjacent to the eastern boundary of

Hoddesdon. The Amwell Quarry SSSI is approximately 1.1km to the north

of Hoddesdon. The Hertford Heath SSSI is approximately 1km to the

north west and the Wormley-Hoddesdonpark woods North SSSI is

approximately 900m to the south west. An area of open water north of

the John Warner Sports Centre between the railway line, River Lee and

A414 is designated as a Local Wildlife Site (LWS).

3.4.6 The LWS is in close proximity to The Former Turnford Surfacing site,

which is immediately south. Admirals Walk Lake is also designated as a

LWS and is in close proximity to the Lampit Mansard Roofs and Crown

Buildings and Squash Club, both approximately 50m north. Hoddesdon

has approximately 9,000 dwellings9 at present. The total additional

housing proposed for Hoddesdon from 2016 - 2026 is 229 units. Given

that this represents an increase of 2.5% in the total housing stock, it is

considered that the increase in recreational pressure on ecological sites,

including statutory designated sites, will be of minimal significance.

9 Office for National Statistics (2011) Total households for Hoddesdon North, Rye Park and Hoddesdon Town Wards



3.4.7 There is a network of green infrastructure (GI) and open space in

Hoddesdon including Rye Park and the Old Highway Recreation Ground.

None of the urban sites identified for development are greenfield sites

and in turn there would be no loss of GI. However, the sites identified

are likely to be too small or otherwise inappropriate (such as the

refurbishment of existing buildings) to be able to substantially increase

public open space in Hoddesdon.

3.4.8 Large areas of south east Hoddesdon are in Flood Zones 210 and 311. The

flood risk area covers the light industrial estate, with some additional

land to the north east between the railway line and the River Lee. None

of the proposed urban sites fall within the flood risk area.

3.4.9 The majority of the listed buildings in Hoddesdon are along the High

Street and Amwell Street, within the Hoddesdon Conservation Area.

They are typically early 18th Century buildings as a result of the rapid

expansion of the town during the ‘golden era’ for travel by horse and

coach (1780-1830)12. The urban sites identified for development are too

far from the Conservation Area and listed buildings to be expected to

affect its setting, with the exception of the Crown Buildings and Squash

Club and 25, 25a and 25b High Street sites. However as both proposals

are for the refitting of the existing buildings as flats, these developments

would not be expected to affect the setting of the Conservation Area

either.

3.4.10 There are eight primary schools and two secondary schools in

Hoddesdon. There are a number of leisure activities in the local area,

including a gym in the town centre and the John Warner Sports Centre

and the Haileybury Sports Complex on the outskirts of Hoddesdon. The

nearest railway stations are Broxbourne Station and Rye House Station,

which offer frequent services to London. The existing bus network

offers a sustainable method of transport within Hoddesdon. Hoddesdon

contains a number of high street retail opportunities and convenience

stores across the town. There are larger scale supermarkets easily

accessible on the A1170. As such, the level of accessibility to key

facilities and amenities is very high.

10 Land having between a 1 in 100 and 1 in 1,000 annual probability of river flooding. 11 Land having a 1 in 100 or greater annual probability of river flooding. 12 Broxbourne Borough council (November 2011) Borough of Broxbourne Conservation Areas: Hoddesdon.

https://www.broxbourne.gov.uk/sites/default/files/Documents/Planning_Policy/pp_BOB_HoddesdonCA.pdf



3.4.11 Overall, the urban sites identified in Hoddesdon have a high degree of

accessibility, minimal effects on historic assets and existing green space,

with all of the sites identified on previously developed land.

Cheshunt and Goffs Oak

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Goffs Oak 0 0 - - + + 0 0 - + + 0 -

3.4.12 The SLAA presents the urban sites in Cheshunt and Goffs Oak under a

single reference. However, in terms or their effects on the Sustainability

Objectives they perform differently to each other. As such, this section

has been sub-divided into ‘Cheshunt and ‘Goffs Oak’:

Cheshunt:

• Fourfields elderly peoples home;

• 23-25 High Street;

• Tanglewood & Windrush, Newgatestreet Road;

• Whitefields Estate Regeneration Plan;

• Wolsey Hall Redevelopment Scheme, Windmill Lane;

• Fieldings Road industrial site, Cadmore Lane;

• Land Rear of Halsey Masonic Hall, Turner’s Hill;

• Whit Hern, Whit Hern Ct;

• Office Building, 191-195 Windmill Lane; and

Goffs Oak:

• Gas Distribution Station, St Catherine’s Road.

Cheshunt

3.4.13 The town centre of Cheshunt is Old Pond, at the Junction of Turners Hill

and College Road. The eastern boundary of Cheshunt is formed by the

River Lee and its streams. Where Cheshunt’s early western boundary

was the New River, Cheshunt now extends substantially beyond the New

River. The suburban areas of Flamsted End and Hammond Street extend

the urban area to the west.



3.4.14 The Churchgate Conservation Area lies half a mile from Old Pond at the

western end of College Road. The area has a history stretching back to

the Palaeolithic period, with three hand axes found from that period in

1880. The Churchgate Conservation Area was designated in 1968 and

was one of the first historic centres in Britain to be classified as such13.

There are 23 listed buildings within the Conservation Area. In particular,

the Church of St Mary’s is one of five Grade I listed buildings in the

Borough. It was built between 1418-1448 by the Rector of Cheshunt,

Nicholas Dixon, on the site of an earlier church. Approximately 250m

west of the Churchgate Conservation Area is the Half Moat Manor House

Scheduled Monument 14 . The monument includes the remains of a

moated enclosure and associated overflow ditch. The site, which

survives in very good condition, is considered to be the remains of the

medieval Cheshunt Manor.

3.4.15 Cheshunt is for the most part in Flood Zone 115. The eastern side of

Cheshunt is in Flood Zones 2 and 3, typically extending 300-400m west

into Cheshunt from the River Lee. Of the urban sites identified, all are

within Flood Zone 1 with the exception of Fieldings Road Industrial Site

and the Wolsey Hall Redevelopment Scheme. Both of these sites are in

Flood Zone 2. In accordance with the Technical Guide to the NPPF16:

“The overall aim should be to steer new development to Flood Zone 1. Where there are no reasonably available sites in Flood Zone 1, local planning authorities allocating land in local plans or determining planning applications for development at any particular location should take into account the flood risk vulnerability of land uses and consider reasonably available sites in Flood Zone 2.”

3.4.16 The two sites in Flood Zone 2 have been identified as providing a

combined 31 dwellings. BBC are currently undertaking a sequential test

that will identify in greater detail the scale and nature of the flood risk at

these sites and their suitability from a flood risk perspective.

13 Broxbourne Borough council (November 2011) Borough of Broxbourne Conservation Areas: Churchgate

https://www.broxbourne.gov.uk/sites/default/files/Documents/Planning_Policy/pp_BOB_ConservationAreasChurchgate.pdf 14 Historic England Website:

https://historicengland.org.uk/listing/the-list/list-entry/1012163 15 Less than a 0.1 per cent (1 in 1,000) chance of flooding occurring each year. 16 Communities and Local Government (March 2012) Technical Guide to the NPPF.



3.4.17 Cheshunt’s eastern boundary is adjacent to the Lea Valley Ramsar /

Special Area of Conservation (SAC) and Turnford and Cheshunt Pits

SSSI. The Cheshunt Park Local Nature Reserve is north of Park Lane. All

of these sites are also designated as LWSs. Given the existing level of

housing in Cheshunt and the ambition of the Lee Valley Regional Park

Authority to enourage more visitors to the park17, the additional urban

development in Cheshunt would be expected to have a minimal effect

on the Lea Valley Ramsar / SAC and Turnford and Cheshunt Pits SSSI.

3.4.18 Cheshunt has extensive GI throughout the district centre, including

amenity green space, parks and gardens, natural and semi-natural open

space, outdoor sports facilities, allotments and green corridors. Outside

of the urban area, Cheshunt Park Local Nature Reserve is immediately

north of Cheshunt and the Lea Valley Regional Park offers a further

10,000 acres of open space.

3.4.19 The Whit Hern site would lead to the loss of community open space

(0.69ha). As Whit Hern is bound by roads to the south and east and the

New River to the west and north, it is not likely to have much

recreational value to the general public due to its impermeability.

However, consideration should be given to the potential loss of a visual

amenity for residents the Kingfisher Nursing Home, which is located to

the immediate east.

3.4.20 Cheshunt has an 11ha business centre area along Delamare Road, which

was the location of Tesco’s Head Office. However Tesco’s have given

notification of their intent to leave their current location and relocate to

Welwyn Garden City. The Old Pond area of Cheshunt offers a broad

range of retail stores including high street stores and a Tesco

supermarket, it is also home to the Laura Trott Leisure Centre.

Brookfield Shopping Park is an out-of-town retail park in the north of

Cheshunt adjacent to the A10, the largest such retail park in Broxbourne.

The existing bus network offers a sustainable method of transport

throughout Cheshunt. Theobalds Grove and Cheshunt train stations

offer frequent services to London. As such, the level of accessibility in

the town to key facilities, amenities and employment opportunities is

very high.

17 Lee Valley Regional Park Authority website:

https://www.visitleevalley.org.uk/pdfconsultation/visitors/



3.4.21 Overall, the assessment of urban development within Cheshunt has

identified a number of positive effects, including good accessibility to

key facilities and amenities and easily accessible sustainable transport

options. However, there are site-specific constraints with regards to

some of the urban sites with regards to flood risk and health and

wellbeing that are considered a minor negative.

Goffs Oak

3.4.22 The village centre is marked by Goffs Oak Cenotaph, which was unveiled

on the 18th December 192018. The village centre is also home to Goffs

Oak Village Hall, a community centre used for a variety of events19. The

Village Green is currently situated in the south east of the town.

3.4.23 At the eastern extent of Goffs Oak is the In-Ex Garden Centre and

adjacent to that, Tina Nursery. Goffs Oak is currently separated from the

small village of St James to the north east by agricultural land that forms

a local gap. St James is in turn separated from the western extent of

Cheshunt by Rags Valley. Goffs Oak is entirely within Flood Zone 1.

There is only one listed building in Goffs Oak, the Grade II listed Goffs

Oak House.

3.4.24 The centre of Goffs Oak is approximately 1km east of Cuffley Station,

with the station providing frequent trains to London, Hertford and

Stevenage. Goffs Oak is a rural village and the retail opportunities

reflect this, with the main store being a Co-Op at the junction of Goffs

Lane and Newgatestreet Road. The closest secondary school is over

2km from the village centre and the closest Town Centre is over 3km

away. Overall, access to key facilities and amenities is low in comparison

to other urban sites. In turn any development in Goffs Oak would be

expected to lead to relatively high levels of private car use by new

residents.

18 Imperial War Museum:

http://www.iwm.org.uk/memorials/item/memorial/1127 19 Broxbourne Borough Council:

https://www.broxbourne.gov.uk/leisure-venues-hire/goffs-oak-village-hall-0



3.4.25 The Tanglewood and Windrush Newgatestreet Road urban site is

currently used for two bungalows with large rear gardens. The site

currently forms the north eastern edge of Goffs Oak, with open land to

the north and east forming the local gap between Goffs Oak and St

James. The land to the north of the site is also a LWS. Whilst the

proposed density of the site is low at five units, it would nonetheless

represent a higher density than is currently the case for the majority of

Goffs Oak, which has little terrace housing and in turn a lower density

may be more in keeping with the local environment.

3.4.26 Overall, Goffs Oak has less readily available access to certain key

facilities and amenities than Cheshunt and in turn levels of private car

use would be expected to be higher. The Tanglewood and Windrush

Newgatestreet Road urban site is constrained, however it is also small

scale and within the current urban envelope.

Waltham Cross

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3.4.27 The following urban sites are included in this assessment:

• Conservative Club, Eleanor Cross Road;

• 232-285 High Street;

• Medlock Electrical, 107-115 Eleanor Cross Road and rear of 238 Eleanor way, The Friary Units;

• Land between Eleanor Cross Road and Monarchs Way;

• Royal Mail Sorting Office, Eleanor Cross Road;

• Waltham Cross Trade Centre, Trust Road;

• Industrial Premises off Bryanstone Road;

• PR Palletts, Station Road;

• Theobalds Grove Station Car Park, High Street;

• Shopping Centre, High Street; and

• Industrial unit Station Road, north of Waltham Cross.



3.4.28 Waltham Cross town centre is focused around Eleanor Cross, one of the

three surviving memorials commemorating the overnight resting place

of the coffin of Eleanor of Castile, wife of King Edward I, on its

processional journey from Lincoln to Westminster Abbey in 129020.

Waltham Cross town centre contains various pubs, bars and high street

retail stores. The south eastern area of Waltham Cross, around

Holdbrook South, contains an extensive light industrial area. Holdbrook

North is home to the Lea Valley White Water Centre, constructed to

host the canoe slalom events of the London 2012 Olympics21.

3.4.29 In the south west of Waltham Cross, adjacent to the A10 and M25, is the

Newsprinters (Broxbourne) Limited newspaper printworks. It is a 16ha

site that, when opened in 2008, was the largest printworks in the

world22. Waltham Cross is a highly urbanised area with relatively little

urban GI, however extensive open space is available in the Lea Valley.

3.4.30 Almost all of the Holdbrook area of Waltham Cross is within Flood Zones

2 and 3. The following urban sites are within this area:

• Medlock Electrical, 107-115 Eleanor Cross Road and rear of 238 Eleanor way, The Friary Units;

• Waltham Cross Trade Centre;

• Industrial Unit Station Road;

• Shopping Centre, High Street;


• 232-285 High Street; and

• PR Palletts, Station Road.

3.4.31 Whilst sites in Flood Zones 2 and 3 can utilise mitigation measures to

make the degree of flood risk acceptable, these sites should only be

developed where there are no sites in Flood Zone 1 that would constitute

an acceptable alternative. BBC are currently undertaking a sequential

test that will identify in greater detail the scale and nature of the flood

risk at these sites and their suitability from a flood risk perspective.

20 Historic England:

https://historicengland.org.uk/listing/the-list/list-entry/1173222 21 Lee Valley Leisure:

https://www.gowhitewater.co.uk 22 British Broadcasting Corporation:

http://news.bbc.co.uk/1/hi/uk/7299941.stm



3.4.32 Cedars Park, on the west of Waltham Cross adjacent to the A10 contains

Theobalds Palace Scheduled Monument and four Grade II listed

buildings, which are walls associated with the Palace. As set out above,

Eleanor Cross is a Grade I Listed Building and Scheduled Monument in

the centre of Waltham Cross. The following sites are all within 200m of

Eleanor Cross:



• Royal Mail Sorting Office, Eleanor Cross Road; and

• Shopping Centre, High Street.

3.4.33 As such all of these sites have the potential to adversely affect the

setting of Eleanor Cross.

3.4.34 To the north east of Waltham Cross is the Lea Valley Ramsar / Special

Protection Area (SPA), the Waltham Abbey SSSI and the Cornmill

Stream and Old River Lee SSSI. Given the existing level of housing in

Waltham Cross and the ambition of the Lee Valley Regional Park

Authority to enourage more visitors to the park23, urban development

would be expected to have a minimal effect on the Lea Valley Ramsar /

SAC and Turnford and Cheshunt Pits SSSI.

3.4.35 Waltham Cross bus station is in the town centre. It is a terminus

for London Buses and a link with services for Hertfordshire and Essex.

The town is the only settlement outside Greater London to be served by

a Transport for London night bus. The area is served by two railway

stations, Waltham Cross and Theobalds Grove, which are on different

lines to London Liverpool Street. Access to the majority of facilities and

amenities in Waltham Cross is very good, with the exception of

secondary schools. The closest is St Mary’s, which for urban sites such

as the proposed PR Palletts Station Road is 3km to the west and as such

not in accordance with the Shaping Neighbourhoods24 guidance.

3.4.36 Whilst Waltham Cross has strong public transport links, there are also

four Air Quality Management Areas (AQMAs):

1. Monarchs Way; 2. Eleanor Cross; 3. Arlington Crescent; and 4. Teresa Gardens.

23 Lee Valley Regional Park Authority website:

https://www.visitleevalley.org.uk/pdfconsultation/visitors/ 24 Barton et al (2010) Shaping Neighbourhoods for local health and global sustainability. 2nd edition



3.4.37 In addition, Waltham Cross is adjacent to the Enfield AQMA, which

borders the M25. The following sites are within or adjacent to the

AQMAs:



• Royal Mail Sorting Office, Eleanor Cross Road; and

• Shopping Centre, High Street.

3.4.38 There is therefore an increased risk to human health for these sites and

residential developments in these areas would be expected to have an

adverse effect on the Monarchs Way and Eleanor Cross AQMAs if they

increased local vehicle movements. This in turn would depend on the

parking associated with the new developments.

3.4.39 The assessment of Waltham Cross has three significant constraints to

development:

1. Four AQMAs; 2. A Grade I Listed Building and Scheduled Monument; and 3. Extensive areas of Flood Zone 2 and 3.

3.4.40 Access to the road network is very good, however this may just

encourage vehicle movements in an area already designated as an

AQMA.

3.5 PM1: Sustainable Place Making

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3.5.1 This policy focuses on the overall approach to place making, ensuring

that new developments are complementary to the town and country

around them. New developments are required to form their own

identities. The aims of this policy are reflected throughout the Plan in

terms of the location and scale of allocated sites in Part 2 of the Plan and

the development management policies to guide the subsequent

development in Part 3. The policy would benefit local landscapes and

townscapes by ensuring that new developments are suitable. The policy

also emphasises the importance of connectivity to existing towns and

villages.



3.6 BR1: Brookfield

3.6.1 The Brookfield area is approximately 180 hectares in size and is located

to the north of Cheshunt and west of Wormley and Turnford. It is also

within close proximity of the Turnford Junction of the A10. The

Brookfield area has been broken into two sub-areas for ease of

reference; Brookfield Riverside and Brookfield Garden Suburb.

3.6.2 Brookfield Riverside is to the west of the A10. The area south of New

River currently comprises three principle uses. Brookfield Retail Park

forms a large area of retail use. There is a gypsy and traveller site to the

north of Brookfield Retail Park. To the north of the gypsy and traveller

site is an allotment. The northern area of Brookfield Riverside is

currently green space. It is open fields interspersed with trees. It is

classed as Grade 3 good to moderate quality agricultural land and is

within the Green Belt.

3.6.3 Brookfield Garden Suburb comprises land to the north west of

Brookfield Riverside. It is primarily open space used for farming and

animal stabling. The site is within the Green Belt and contains various

agricultural fields, tracks, distinct woodland areas and hedgerows25.

Cheshunt Park Golf Course is to the south of the site. To the north and

west is open countryside.

3.6.4 The policy includes approximately 1,500 homes, up to 35,000sqm of

retail floorspace, approximately 50,000 sqm of commercial floorspace

and up to 10,000sqm of leisure floorspace for the Brookfield area as a

whole.

3.6.5 The policy includes facilities and amenities appropriate to a large scale

development, including elderly persons accommodation, community

facilities, a new local centre, public open space and two new primary

schools with up to four forms of entry. The policy also includes for a

new link road connecting Brookfield Lane West at Brookfield Retail Park

with the Turnford Interchange.

25 Broxbourne Borough Council (April 2016) Brookfield Area Development Options

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3.6.6 As discussed above, a part of the site is currently used for gypsies and

travellers and local allotments. The intention is to relocate these sites

within the overall development area. In doing so, the Council will need

to be cognisant of the sensitivities of relocating users that are likely to

have a strong attachment to place.

3.6.7 The majority of the area is greenfield and over 160 hectares is classified

as Green Belt land. The Green Belt area contains various agricultural

fields, tracks, distinct woodland areas and hedgerows. However the

presence of historic landfill sites, farm buildings and allotments provides

a human influence on the landscape.

3.6.8 The site includes two Scheduled Monuments:

• Hell Wood moated site and enclosure; and

• Perrior’s Manor moated site and fishpond.

3.6.9 English Heritage’s records with regards to the Hell Wood site state26:

“The site at Hell Wood is an unusual example of a relatively small moat

with a very large attached enclosure. The massive size of the enclosure

bank probably indicates a defensive function for the site boundary. The

well- preserved nature of the enclosure and moat together with the

waterlogged and silted condition of the ditches offers considerable

potential for the survival of archaeological and environmental remains.”

3.6.10 With regards to Perrior’s Manor, the records state27:

“The historical use and development of Perrior's Manor moated site has

been well-documented through archaeological excavation and shows

successive stages of occupation dating back to the 13th century.

Although the site is partially excavated a significant proportion of the

moat is undisturbed and will retain high archaeological potential.”

3.6.11 The policy states that scheduled monuments within the site will be

protected and enhanced.

26 Historic England Scheduled Monument Database (accessed May 2016)

https://historicengland.org.uk/listing/the-list/list-entry/1010746 27 Historic England Scheduled Monument Database (accessed May 2016)

https://historicengland.org.uk/listing/the-list/list-entry/1010747



3.6.12 There are no listed buildings within the site, however there are 16 listed

buildings within approximately 500 metres of the site boundary. Of

these, 12 are Grade II listed, three are Grade II* listed and one is a Grade I

listed building, namely Wormleybury Manor. Wormleybury Manor would

be approximately 300m from the site boundary. The grounds for

Wormleybury Manor are Grade II listed on the Register of Parks and

Gardens of Special Historic Interest. There is the potential for

development at Brookfield to affect the setting of Wormleybury Manor,

but this is considered unlikely given the woodland that screens

Wormleybury Manor from the Brookfield site. It should be noted that

the western area of Brookfield Garden Suburb is within an Area of

Archaeological Interest, as are the areas around the two Scheduled

Monuments.

3.6.13 There are six areas designated as LWS within the site boundary. The

Cheshunt Park LNR is adjacent to the site boundary. The Lea Valley is

approximately 900m east of the site and is designated as a Ramsar site,

SPA, SSSI and LWS. To the west are the Broxbourne Woods NNR and

the Wormley-Hoddesdonpark Woods, designated as a SAC and SSSI.

Due to the distance the effects on the majority of these receptors are

expected to be minimal, but care will need to be taken to avoid adverse

effects on the Cheshunt Park LNR.

3.6.14 The site is largely within the Green Belt. A review of the Green Belt28

undertaken by BBC identified that the Green Belt was a strong feature in

this area. In turn, development in this area would lose a large area of

Green Belt land.

3.6.15 The site is primarily within Flood Zone 1, however Turnford Brook, a main

River Line, passes through the site and has associated small areas of

Flood Zones 2 and 3 along its length. Given the size of the site, it is

anticipated that the areas of high flood risk would be taken into account

in the layout, with the area along the brook identified as local green

space.

28 Broxbourne Borough Council (March 2008) Review of the Green Belt for the Preparation of Local Development Framework



3.6.16 The site is currently greenfield with no transport access. In turn, access

to the site would need to be provided by new road building including

the aforementioned link road. This offers the opportunity to promote

and prioritise sustainable transport modes including bus routes through

the site or walking/cycling. Travel by train is less accessible, with the

site being more than 2km from the closest train station. The policy

emphasises the importance of walking and cycling and how this must be

connected to the existing urban areas of the borough. The policy also

includes for new multi-storey car parks. Whilst these can be an

important part of ensuring that the new retail offering is successful, they

can also encourage car use. At present, a number of car journeys are

made outside of the borough to retail opportunities elsewhere. As such

the multi-storey car parks may encourage residents to shop locally

rather than travelling further afield.



3.7 BX1: Broxbourne Village Improvement Plan

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3.7.1 This policy seeks to improve the streetscape and townscape of

Broxbourne Village. It is anticipated that this would be done through the

use of GI, which would have benefits for not only the townscape but

would also benefit local biodiversity and reduce flood risk.

3.8 BX2: Broxbourne Station and Environs

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3.8.1 Broxbourne Train Station is currently proposed to become a terminus

station for Crossrail 2. This policy gives BBC’s support to the ongoing

planning work required to prepare for this. As the plan is not yet

prepared, the potential effects are uncertain.

3.9 BX3: Broxbourne School

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3.9.1 Broxbourne School is east of the A10, close to the centre of Broxbourne.

The extant school buildings are clustered to the north of the site, with

playing fields to the south. The residential development of part of this

site would enable the relocation and expansion of Broxbourne School

within the site from seven to eight forms of entry. The site is also

allocated as a leisure hub.

3.9.2 There are a number of listed buildings in close proximity to the site along

High Road Broxbourne, including The Red House at Broxbourne School,

a Grade II listed building. The north of the site is within the New River

Conservation Area. The Broxbourne Conservation Area is approximately

500m north east of the site.



3.9.3 The New River Conservation Area is mainly residential in nature and also

includes Broxbourne School. A particular feature of the New River

Conservation Area is the footpath running along New River. The New

River flows through the length of the borough. It was built between

1608 and 1613 by Sir Hugh Myddelton with financial help from King

James I to bring drinking water from springs near Ware into London.

The New River and associated footpath are not within the site boundary

and as such are unlikely to be affected. The Conservation Area also

contains a number of Grade II listed building from the 18th and 19

Centuries of very high aesthetic value29. Again these are outside of the

site boundary, however development of the site would have the

potential to adversely affect the setting of these historic assets. In

addition, the listed buildings set the built design context for the area and

should be taken into account in the design of residential dwellings on the

site.

3.9.4 The Top Field and Cozens LNR is in the north western corner of the site.

Whilst the LNR itself isn’t being considered for development,

nonetheless it may be adversely affected by residential development in

such close proximity to the site.

3.9.5 The site is within the Green Belt. Development of this site would be an

intensification of land partly already developed on the urban fringe,

however it would also introduce new residential development in an area

of open space either within or adjacent to the New River Conservation

area. As such the effects are considered to be moderate adverse.

3.9.6 The site is in Flood Zone 1 and therefore at minimal risk of flooding.

3.9.7 The site is close to the A10, and Broxbourne local centre is a short walk.

Broxbourne train station is also a short walk from the site. Access to

facilities and amenities is good in the area. Given the sites’ proximity to

the A10, there is a risk of noise pollution from the road for residents of

the new development. Air quality would also be a consideration,

however given that levels of pollutant drop very rapidly with distance

from roads, the minimum 200m gap between the site and the A10 may

be sufficient to result in a negligible effect.

29 Broxbourne Borough Council (November 2011) Borough of Broxbourne Conservation Areas: Broxbourne.



3.9.8 As discussed above, the site can also provide for the expansion of

Broxbourne School from seven to eight forms of entry, with up to 153

homes on site providing the enabling funding. Those new homes will

themselves create an increased demand for school places. Hertfordshire

County Council use a generic pupil yield ratio of 42 primary school aged

pupils per 100 dwellings, which in turn equates to 1 form of entry per

500 dwellings30. This would result in approximately 64 children from the

153 dwellings, or approximately one third of the new form of entry.

3.9.9 The overall effects of developing this site would depend heavily on an

approach to residential design that is sensitive to the sites’ Green Belt

and Conservation Area designations. Given the anticipated increase in

demand for secondary school places in the borough to 2031, the

provision of additional secondary schools’ capacity in the area is a

notable benefit of this site, as is the health benefits resulting from the

leisure hub.

3.10 PP1: Park Plaza West

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3.10.1 Park Plaza West is situated between the M25 to the south, Lieutenant

Ellis Way to the north, the A10 to the east and the New River to the

west. The site is predominantly open fields, with some trees and hedges

and a farm on the eastern side accessed directly from the A10.

3.10.2 There are three Grade II listed buildings within the site associated with

Theobalds Farm. There are a further 16 Grade II listed buildings within

500m of the site and in addition the Grade II* listed Theobalds Park

College and Capel House. Theobalds Palace Scheduled Monument is

250m to the north east of the site. The site contains both Grade 2 and

Grade 3 agricultural land.

30 Hertfordshire County Council Website: http://www.hertsdirect.org/services/edlearn/aboutstatesch/planning/



3.10.3 Delivery of this site would require a significant amount of land to be

taken out of the Green Belt. The Green Belt Review31 identified that the

Park Plaza area, including Park Plaza West, helps to prevent urban

sprawl and safeguard countryside. There are no weak inner Green Belt

boundaries i.e. all existing boundaries are of a permanent and defensible

nature. Park Plaza West specifically provides a barrier between main

urban areas and open Green Belt, whereas the other land parcels to the

north provide a more localised role by providing a barrier between

Cheshunt and Bury Green. The green buffer which helps separate

London and Hertfordshire would be compromised32.

3.10.4 The site is within Flood Zone 1. The Lea Valley Ramsar / SPA / SSSI is

approximately 1.4km to the east of the site. Due to the distance to the

site, the effects are expected to be minimal. The site is Grade 2

agricultural land and is currently used for agricultural purposes, so a

valuable resource would be lost if the site were developed.

3.10.5 The site has excellent transport links, being adjacent to the M25 and A10

making access for commercial vehicles very easy. It should be noted

though that the site is immediately north of the AQMA the covers the

entire London Borough of Enfield. The site is also very close to the

extensive commercial areas in Waltham Cross, so this site could be seen

as an extension of that use west across the A10.

3.10.6 As set out above, the site is within the Green Belt, contains three listed

buildings and development would lead to the loss of a significant area of

agricultural land. The site is very well placed in transport terms, the land

is available for development and is one of few such strategic

employment options in the borough. In light of the constraints, any

development in this area would have to be very sensitive in landscape

and design terms.

31 Broxbourne borough council (March 2008) Review of the Green Belt for the Preparation of Local Development Framework 32 Ibid.



3.11 PP2: Park Plaza North

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3.11.1 Park Plaza North is a 10 hectare site to the east of the A10 and south of

Winston Churchill Way (the A121). To the east is the urban area of

Waltham Cross and the News International Print Works is to the south.

It is a vacant greenfield site that is relatively flat but overgrown33. At the

northern end of the site it slopes downward to meet the A121, where

trees partially screen the site from view. The site is visible from the A10

to the west. The site is not within the Green Belt, but it is adjacent to the

current Green Belt boundary on the A10.

3.11.2 There are no historic statutory or non-statutory designations within the

site. There are three Grade II listed buildings 240m south west of the site

associated with Theobalds Farm. Theobalds Palace Scheduled

Monument is on the opposing side of the A121 to the north of the site,

which contains two Grade II listed buildings.

3.11.3 The site is Grade 2 agricultural land, a valuable resource that would be

lost if the site were developed. The Lea Valley Ramsar / SPA / SSSI is

approximately 1.2km to the east of the site. Due to the distance to this

site, it is unlikely to be affected. The site is within Flood Zone 1 and as

such at minimal risk of flooding.

3.11.4 The site has excellent transport links, being adjacent to the A10 and a

short distance to the M25, however, it is a short distance north of the

AQMA the covers the entire Borough of Enfield.

33 Broxbourne Borough Council (April 2016) Strategic Housing Land Availability Assessment



3.12 PP3: Plot D, Park Plaza

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3.12.1 This site is allocated for Use Class B1a/B1b and already has an outline

application approved for these uses. This policy continues to support

this allocation, which would provide employment floorspace to the

benefit of the local economy. The land is currently scrub to the south

and a cark park to the north.

3.12.2 Three Grade II listed buildings associated with Theobalds Park

farmhouse are 100m to the north. The site is screened to the west by

trees along the A10 and in the context of the print works that already

occupies much of the Park Plaza area, any effect on the listed buildings

would be expected to be minimal.

3.12.3 The site is Grade 2 agricultural land, a valuable resource that would be

lost if the site were developed. The Lea Valley Ramsar / SPA / SSSI is

approximately 1.2km to the east of the site. Due to the distance to this

site, it is unlikely to be affected. The site is within Flood Zone 1 and as

such at low risk of flooding.

3.12.4 The site has excellent transport links, being adjacent to the A10 and a

short distance to the M25, however, it is immediately north of the AQMA

the covers the entire Borough of Enfield.

3.13 CH1: Cheshunt Lakeside

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3.13.1 Cheshunt Lakeside isthe proposed name for a new urban village at what

is currently the Delamare Road employment area. The area formerly

included Tesco Headquarters, which has since relocated and the building

is currently vacant. The majority of the commercial premises on site at

present are light industrial units. The policy allocates the site for the

development of approximately 1,000 new homes including affordable

homes, elderly persons accommodation, business floorspace, a local

centre and a two forms of entry primary school.

3.13.2 The site is bordered to the east by the West Anglia main railway line, the

opposing side of which is the Lea Valley SPA / Ramsar / SSSI. This is a

highly sensitive ecological receptor. In particular, the SPA is sensitive to

groundwater pollution and changes to the hydrological regime. As such

development of Cheshunt Lakeside area would present a potential risk

of accidental contamination and / or potentially harmful changes to the

local hydraulic regime. There would also be increased recreational

pressure from the site as the area is readily accessible from Delamare

Road via Cadmore Lane and Windmill Lane. However, any level of

additional development needs to be taken in light of existing context.

To the west of the Lea Valley SPA / Ramsar / SSSI site are the urban

areas of Cheshunt and Broxbourne, so development of Cheshunt

Lakeside will add relatively few new dwellings compared to the existing

urban area. In addition, the Lea Valley has the capacity to absorb a high

level of recreational usage.

3.13.3 There are a number of Grade II listed buildings to the south west of the

site, approximately 350m away. Due to the intervening urban area, it is

unlikely that they would be effected by the Cheshunt Lakeside

development unless the height of the buildings increased substantially.

3.13.4 The majority of the site is within Flood Zone 2, with some areas to the

south of the Site in Flood Zone 3a, associated with a main river line that

passes along the south and west of the site. Therefore its use as a

residential site will be subject to the borough-wide sequential test being

undertaken in support of the Local Plan and potentially the exception

test.

3.13.5 The site benefits from its central Cheshunt location, with a full range of

facilities and amenities, including existing schools, available within less

than 1km. The mixed-use nature of the allocation would further add to

the facilities and amenities available in the local area including a new

primary school and Local Centre. The site also includes landscaped

open space, which would help to enhance the townscape compared to

its current commercial use.



3.13.6 The site is currently designated as the Delamare Road Employment Area

under policy ELP1 of the Broxbourne Local Plan34 and as such should

only be used for purposes other than employment in exceptional

circumstances. The change of use to residential premises would be

likely to increase vehicle movements on the local roads, with limited

options to amend the existing access arrangements.

3.13.7 The effects on local vehicle movements would require further technical

work to quantify as the additional housing would be negated by the

reduction in workers travelling to the existing commercial uses. As such,

the effect has been identified as uncertain at this stage.

3.14 CH2: Rosedale Park

Option

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Framework document

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3.14.1 Rosedale Park is in the gap between St James and the main urban area

of the borough, with open space to be maintained on the western and

eastern sides of Rosedale Park. Rosedale Park is comprised of two main

areas: Tudor Nursery and environs; and the Rags Valley.

3.14.2 The Tudor Nurseries area of Rosedale Park is a 15.7ha site, the western

half of which is an extensive area of horticultural glasshouses. The

eastern half is scrubland, with trees forming the perimeter.

3.14.3 There are 10 Grade II listed buildings in the local area. The closest are

five buildings to the south and west of the site along Goffs Lane and

Burton Lane. The site is currently in the Green Belt. The Green Belt

Review35 identified that the value of the Tudor Nurseries site to the

Green Belt is considered relatively small when the site is developed as a

part of the broader Rosedale Park area.

34 Broxbourne borough Council (2005) Broxbourne Local Plan Second Review 2001-2011 35 Broxbourne Borough Council (March 2008) Review of the Green Belt for the Preparation of Local Development Framework



3.14.4 The economic viability of the site and its potential to remain as a nursery

is uncertain, with the site owner contending that it is unviable36, however

BBC’s Glasshouse Study37 contends that the site is one of the more

viable Glasshouses. At present the site is in partial use for horticulture,

with a number of the glasshouses becoming derelict. The owner is

understood to be unwilling to invest in Tudor Nurseries, presumably as it

is a declining industry. If the site were not allocated for residential

development, it is reasonable to assume that it will continue to decline,

with the possibility of the site becoming entirely derelict.

3.14.5 There are no statutory wildlife designations in the local area, however

the open space to the west of Tudor Nurseries is a LWS.

3.14.6 The Rags Valley area of Rosedale Park is largely tree lined grazing land,

with some agricultural buildings. To the south east of Rags Valley there

are a number of playing fields around Cheshunt Rugby Club that would

form Rosedale Park.

3.14.7 There are nine Grade II listed buildings within 500 metres of the site,

eight of which are to the south west either on the opposite side of the

Tudor Nurseries site or within St James. One listed building is to the

north west, in Hammond Street.

3.14.8 The development of this site would lead to the loss of long views across

the area38. It would also lead to a reduction in the total amount of green

space in the area. However, at present the site isn’t accessible to the

public, so while the total amount of green space would be reduced, the

development of this site would have the potential to increase the total

amount of publically accessible green space substantially.

3.14.9 Rags Valley is classed as Grade 3 agricultural land in its entirety. The

other main use of the site is as a sports and recreation area, with both

Cheshunt Rugby Club / Rosedale Sports Ground to the south east of the

site. Redevelopment of the site would lead to the loss of the arable land,

however the sports uses would be retained and enhanced.

36 Broxbourne Borough Council (2016) Strategic Land Availability Assessment 37 Broxbourne Borough Council (March 2008) Review of the Green Belt for the Preparation of Local Development Framework 38 Broxbourne Borough Council (March 2008) Review of the Green Belt for the Preparation of Local Development Framework



3.14.10 There are no statutory wildlife designations in the Rags Valley area. The

Cheshunt Park LNR is 680 metres to the north west on the opposing

side of Flamstead End. The south eastern area of the site adjacent to

Cheshunt Rugby Club is a LWS.

3.14.11 The Rags Valley area will include a new two form of entry primary

school. Being adjacent to west Cheshunt, the site offers relatively

limited access to existing facilitates and amenities within the borough’s

main urban area, but the site is of a sufficient scale to provide facilities

and amenities both for residents of the site and existing residents in the

local area.

3.14.12 Development of this scale would be expected to see a significant

increase in vehicle movements in the local area. There may be a

substantial increase in the number of vehicles entering the main

strategic highway network system via the A10. The A10 is particularly

congested in the southern part of the borough at the south end of

Lieutenant Ellis Way approaching Junction 25 of the M25, which the

development may further exacerbate.

3.14.13 Rags Brook passes east-west through Rags Valley with associated

localised flood risk. The majority of the site is within Flood Zone 1 and as

such at minimal risk of flooding.

3.14.14 Overall development of Rosedale Park would lead to a change to the

local landscape. It is currently largely inaccessible to the public, limiting

its recreational value. Development of Rosedale Park has the potential

to provide additional facilities and amenities to existing and future

residents of Goffs Oak and St James’

3.15 CH3: Cheshunt Old Pond

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3.15.1 This policy will improve the streetscape and pedestrian environment of

Cheshunt Old pond. Improving the townscape would also encourage

more residents to visit the area, to the benefit of local businesses.



3.16 CH4: Old Cambridge Road Corridor

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3.16.1 This policy will improve the streetscape along the Old Cambridge Road.

Improving the streetscape would also encourage more residents to visit

the area, to the benefit of local businesses and would also be expected

to improve the setting of the historic buildings in the area.

3.17 CH5: Cheshunt Football Club

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3.17.1 The site is east of the A10, north of Cedars Park. The site is largely open

farmland, but also contains a number of dwellings and agricultural

buildings associated with Albury Farm and fields delineated by trees.

Cheshunt Football Club is also on the site. To the immediate north of

the football club in the centre of the site is a 1.2ha area of woodland used

as a rifle range. The site is allocated for approximately 120 homes plus

community and commercial floorspace.

3.17.2 There is one listed building within the site, the Grade II listed ‘Albury

Farm Section of Theobalds Palace Deer Park Wall on the north side of

Farmhouse Garden’. There are a further seven Grade II listed buildings

to the south of the site within Cedars Park. Theobalds Palace, Waltham

Cross Scheduled Monument is to the south of the site in Cedars Park,

along with the associated Area of Archaeological Interest.

3.17.3 The site is currently in the Green Belt, however the proposals are to

maintain a gap between the A10 and any development in order to

maintain a green gateway into Cheshunt, mitigating the effect on the

Green Belt.

3.17.4 The Lea Valley Ramsar / SPA / SSSI is approximately 1km east of the

site, which is a sufficient distance that any effect would be expected to

be minimal.



3.17.5 The land is Grade 2 agricultural land, therefore the development would

represent a loss of the best and most versatile agricultural land.


3.17.7 Theobalds Grove Railway Station, which is on the Southbury Loop

railway line from Cheshunt to Liverpool Street, is located just over 1km

south east of the site. Waltham Cross Railway Station is approximately

1.5km north east of the site. At present there are no bus services running

along the A10 that are directly capable of serving the area. However,

Waltham Cross bus station, which provides bus services into London and

into Hertfordshire and Essex, is located in Waltham Cross town centre to

the south east. Bus services are also available along Crossbrook Street

to the east of Albury Farm and College Road, approximately 400metres

to the north of Maxwells Farm West. Being on the south western edge

of Cheshunt, the site has very good access to the shops, facilities and

employment opportunities in both Waltham Cross and Cheshunt.

3.17.8 Housing in this area would help to enable Cheshunt Football Club to

expand their existing facilities. Cheshunt Football Club’s facilities are

currently available to hire by the public and it is assumed that any

additional facilities would also be available to hire, which would have a

beneficial effect on health and wellbeing. The northern area of the site

would be utilised to provide a primary school.

3.17.9 Development of this site would lose a significant area of Grade 2

agricultural land that is currently actively used for farming.

Development would be in the Green Belt, but there is the opportunity to

maintain the openness of the area by focusing development on the

eastern side and maintaining an open gap to the A1039. Overall the site

has good access to Waltham Cross and Cheshunt, could improve health

and fitness facilities and provide new community space.

3.18 CH6: Albury Farm Landscape Protection Zone

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3.18.1 This policy will create a landscape buffer to the west of Albury Farm and

Cheshunt Football Club, maintaining the open landscape currently visible

in this area from the A10.

3.19 CH7: Bury Green and Churchgate

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3.19.1 This policy allocates three housing developments:

• Housing at Dark Lane;

• Housing at Theobalds Brook Field; and

• Housing at Goffs Lane.

3.19.2 The housing site at Dark Lane is currently used as playing fields. The site

is partially within an area of archaeological interest associated with the

‘Half Moat Manor House, moated site and associated leat’ Scheduled

Monument. The remains of Cheshunt Great House, a Grade II listed

building said to have been built by Henry VIII for Thomas Wolsey, are

190m north of the site. The Grade II listed Cemetery Mortuary Chapel is

250m to the South. The development may adversely effect the

character and setting of the Grade I listed Church of St Mary’s, which is

approximately 280m to the east of the site.

3.19.3 The land is currently designated as Green Belt land, however the Green

Belt Review40 has suggested that the release of this land would be

appropriate to form a new, stronger delineated boundary on Lieutenant

Ellis Way.

3.19.4 There are no statutory biodiversity designations in the local area and the

closest LWS is an area of woodland 280m to the west of the site. It is

understood that the site is currently used as grazing / paddocks, with a

bridleway forming the eastern boundary of the site.




3.19.5 Development of this site would increase traffic on Lieutenant Ellis Way,

with additional vehicle movements heading southbound to Junction 25

of the M25, which is already congested. There is also a relatively limited

retail offering in the Bury Green and Churchgate areas with only local

convenience shops available. The Shaping Neighbourhoods guide to

creating sustainable neighbourhoods (Barton, 2010) recommends that

superstores be no further than 2km away from local residents. The most

accessible superstore from the site is the Tesco Extra superstore in

Waltham Cross, which is over 3km to the north east. The site is currently

used informally as open space, whose loss would have an adverse effect

on the health and wellbeing of residents.


3.19.7 The site is Grade 3 agricultural land. Whilst not used as agricultural land,

development of this site would lead to the loss of a valuable natural

resource.

3.19.8 The Goffs Lane site is located south of the roundabout joining Goffs

Land and Lieutenant Ellis Way. It is currently overgrown scrubland.

3.19.9 The Grade II listed remains of Cheshunt Great House and the Scheduled

Monument ‘Half Moat Manor House, moated site and associated leat,

Cheshunt’ are both 490 metres east of the Goffs Lane site.

3.19.10 The Goffs Lane site is within the Green Belt, however it is noted in the

Green Belt Review that the site is currently overgrown scrubland and as

such development would offer the opportunity to improve the visual

appearance of the site.

3.19.11 The Goffs Lane site is within Flood Zone 1 and as such at minimal risk of

flooding. There are no statutory biodiversity designations in the local

area, however land immediately south of the site is a LWS that may be

adversely effected by a residential development.

3.19.12 The Goffs Lane site is well located to access the facilities and amenities

in Cheshunt. With good access to existing facilities and amenities

combined with the low number of units considered for the site, the total

vehicle trip generation would be low. Whilst total increase in vehicle

movements would be expected to be low, a number of the trips would

be heading south on Lieutenant Ellis Way to a known traffic hotspot on

the A10.



3.19.13 The sites proximity to the A10 may mean that there may be adverse

noise and air quality effects on future residents of the site, particularly as

the site is close to a main roundabout. If the roundabout were to

become congested, pollutant levels would rise, potentially affecting the

health and wellbeing of residents.

3.19.14 Enabling access to the Goffs Lane site could require the V + E Judo Club

to move to alternative premises. The Club may have the opportunity to

move to better facilities; however small scale local clubs can be sensitive

to a relocation if it is to a site inconvenient for their existing membership.

3.19.15 Theobalds Brook Field is on the southern side of Bury Green, a

predominantly residential area west of Cheshunt. It is located between

the existing urban fringe of Bury Green to the north and Lieutenant Ellis

Way to the south and is currently used for arable grazing.

3.19.16 To the east of Theobalds Brook Field is St Marys High School, which will

be extended to include a primary school.

3.19.17 The Grade II Listed Broadfield Farm Farmhouse is approximately 370

metres to the north west of the site, with further listed buildings

associated with the cemetery north of Bury Green Road, 440 metres to

the north east. Development of this site would not be expected to have

an adverse effect on these historic assets.

3.19.18 Theobalds Brook Field is currently designated as Green Belt land,

however the Green Belt Review41 has suggested that the release of this

land would be appropriate as apart of forming a new, stronger

delineated boundary on Lieutenant Ellis Way.

3.19.19 There are no statutory biodiversity designations in the local area,

however the adjacent woodland to the south east of the site is

designated as a Local Wildlife Reserve. The site is currently grazing /

paddocks, with a bridleway forming the eastern boundary of the site.

Whilst it is anticipated that the bridleway would be unaffected by the

development, the informal open space would be largely lost in the event

of residential development.

3.19.20 Theobalds Brook Field is Grade 3 agricultural land and currently used in

part for grazing. As such development of this site would lead to the loss

of a valuable natural resource.




3.19.21 Development of this site may increase traffic on Lieutenant Ellis Way,

with additional vehicles heading southbound to junction 25 of the M25,

which is already congested. There is also a relatively limited retail

offering in the Bury Green and Churchgate areas with only local

convenience shops available. The most accessible superstore from the

site is the Tesco Metro superstore in Cheshunt, which is 1.8km to the

east. Schools, health and leisure facilities are all within 1km of the site. A

recently constructed cycle path and footbridge over the A10 to the east

of the site makes Cheshunt more easily accessible by these sustainable

modes of transport.


3.19.23 Development of Theobalds Brook Field site would lead to the loss of

Grade 3 arable land and would increase traffic southbound onto a busy

section of the A10. However, it would also help to create a new

defensible Green Belt boundary and has good access into Cheshunt.

3.20 CH8: Maxwells Farm West and Rush Meadow Safeguarded Land

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3.20.1 This policy safeguards Maxwells Farm West and Rush Meadow. The site

is at the junction of Lieutenant Ellis Way and Great Cambridge Road.

The site is currently being used in limited amount for industrial purposes,

with Grade 2 and 3 agricultural land making up the majority of the site.

The safeguarding of the site will ensure that the Green Belt boundary in

the area is persevered beyond the plan period, benefiting the local

landscape. Whilst it is anticipated that the site will be used for a mixed

use development following the end of the safeguarding period, the

development mix is not known at this stage and in turn the effects on

housing and economics uncertain.



3.21 CH9: South of Hammondstreet Road

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3.21.1 The Land South of Hammondstreet Road urban site is privately owned,

with a public footpath running down the western side. The site is

greenfield and not within the Green Belt. The site doesn’t contain any

statutory or non-statutory historic or environmental designations and is

in Flood Zone 1.

3.21.2 Development of this site for approximately 40 dwellings would be

expected to adversely affect the sense of open space and visual amenity

of the site. Hammond Street has good access to alternative open space,

particularly to the north. In addition, the Hammondstreet Road site itself

is enclosed by residential dwellings on its western, northern and eastern

periphery, so the loss would be expected to have a minimal effect.

3.21.3 Levels of accessibility for this site are relatively poor. The closest health

centre is 1.2km from the site. The site is within a short walking distance

from existing bus stops on Hammondstreet Road, offering connections

into the urban areas of Cheshunt and Broxbourne.

3.22 GO1: Goffs Oak Village Improvement Plan

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3.22.1 This policy will improve the streetscape and pedestrian environment of

Goffs Oak Village. It is expected to improve local footpaths and the

village green, benefiting the local landscape and townscape. These

improvements would also encourage more residents to visit the area, to

the benefit of local businesses.



3.23 GO2: North of Goffs Lane

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3.23.1 The North of Goffs Lane Site is currently occupied by the In-Ex Garden

Centre and Tina Nursery. The In-Ex Garden Centre and Tina Nursery are

brownfield sites in a predominantly greenfield area between Goffs Lane

and St James. Both sites are dominated by glasshouses, however due to

the declining viability of the glasshouse industry in the area, the

glasshouses are in an increasing state of disrepair.

3.23.2 There are eight Grade II listed buildings within 500m of the site. The

closest is Goffs Oak House, which is to the south of the site on the

opposing side of Goffs Lane. Burton Lane Farm is approximately 250m

to the east of the site, with open space between the two. A small part of

Tina Nursery is an Area of Archaeological Interest.

3.23.3 The site is currently within the Green Belt and is not considered to

contribute to the functional purpose of the Green Belt of maintaining a

gap between settlements42. The Green Belt Review considers that in

light of the high level of derelict/vacant brownfield land among other

factors, the site may be suitable for built development.

3.23.4 There are no statutory biodiversity designations in the area, however the

open land between the site and Tudor Nurseries is a LWS.





3.23.6 In light of the declining viability of nurseries in the local area, the change

of use of the In-Ex land from a nursery to a residential development

would be considered a more efficient use of the site. However at

present the In-Ex site operates as a successful garden centre and café,

with additional retail uses on site that do not have planning permission43.

Without further clarification on the existing lawful / unlawful uses of the

site, the economic effects of redevelopment of the site and whether the

existing use of the land or the potential residential use of land provides

for a more efficient use of the site remains uncertain. Tina Nursery is

currently in limited production and is a tree and plant retail centre. The

declining viability of the glasshouse industry44 makes a full return to

horticulture unlikely, in which case the land for residential development

may be preferable.

3.23.7 Due to the sites existing commercial use and the low density of

development being considered, the additional trip generation on the

local highway network would be minimal. The site benefits from existing

bus routes along Goffs Oak Road. The closest train station is Cuffley,

1.9km to the west. There are local food stores, a pharmacy, a primary

school and GP facilities within a short walk of the site. The closest

secondary school is 1.7km from the site. The nearest supermarket would

require travel to Cheshunt.

3.24 GO3: South of Goffs Lane

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3.24.1 The site is a mix of industrial uses and associated hard standing,

residential uses and an area of agricultural land to the south.

3.24.2 There are six Grade II listed buildings within 500m of the site, the closest

of which Goffs Oak House, adjacent to the west of the site.

Development of this site has the potential to provide development that

is significantly more sensitive to the local historic assets than the current

light industrial use that dominates much of the north of the site.

43 Laurence Gould Partnership Limited (2013) Broxbourne Borough Glasshouse Industry https://www.broxbourne.gov.uk/sites/default/files/Documents/Planning_Policy/pp_LGould_Glasshouse_study.pdf 44 Ibid



3.24.3 The site is currently within the Green Belt. The current character of the

site is largely developed with hardstanding and doesn’t add significantly

to the Green Belt Character of the area45.

3.24.4 There are no statutory biodiversity designations in the area. Land to the

southwest of the site is a LWS that may be adversely affected by

residential development.


3.24.6 The commercial area of the site is currently in limited use and as such

development of the site could lead to a more efficient overall use. The

agricultural area within the site is Grade 3 agricultural land, so

development of the site would lose a valuable natural resource.

3.24.7 Due to the sites existing commercial use and the low density of

development being considered, the additional trip generation on the

local highway network would be minimal. The site benefits from existing

bus routes along Goffs Oak Road. The closest train station is Cuffley,

1.9km to the west. There are local food stores, a pharmacy, a primary

school and GP facilities within a short walk of the site. The closest

secondary school is 1.7km from the site. The nearest supermarket would

require travel to Cheshunt.

3.25 GO4: Newgatestreet Road

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3.25.1 The site is predominantly open fields, with a farm building to the north

east, adjacent to St James. The site is in the local gap between St James

and Goffs Oak.

3.25.2 There are four Grade II listed buildings within 500m of the site, with

three in St James and one in the south-eastern area of Goffs Oak. The

site is within the Green Belt and in the local gap between Goffs Oak and

St James.




3.25.3 An option is for the release of part of the Whitehouse Farm site to

enable the relocation of Goffs Oak village green from its current location

on the south-eastern side of Goffs Oak to a new location within the local

gap to provide a permanent buffer between the two settlements. This

would also allow for the expansion of Woodside School, retaining the

former village green site to the south as school playing pitches, probably

with continued public access provided under a community use

agreement. If Woodside School (including playing pitches) were

expanded to the east, as is being considered by Hertfordshire County

Council, the relocation of the Village Green would not be necessary.

However, this scenario would mean that the opportunity to secure a

more central location for the village green and a permanent buffer with

St James’ would likely be lost.

3.25.4 The site is within Flood Zone 1 and as such there is minimal flood risk.

There are no statutory biodiversity designations in the local area,

however land immediately north of the site is a LWS that may be

adversely affected by residential development.

3.25.5 Goffs Oak provides local access to a primary school and convenience

store. The closest supermarket is in Cheshunt and the nearest secondary

school is Goffs School, 2.4km to the east. Local employment

opportunities are limited. Cuffley train station is approximately 1.2km to

the west. In light of the relatively low level of development in this area

(50 dwellings), the overall effect on vehicle movements would be

minimal. The site is relatively remote from certain destinations such as

town centres, supermarkets and secondary schools, so the number of

vehicle trips per resident would be expected to be relatively high.

3.25.6 The site is currently utilised as Grade 3 agricultural land, which will be

lost as a part of the development. The area lost is approximately

400sqm, which has to be balanced in terms of the overall value of the

site and the role that it could play in maintaining the local gap and

allowing for the expansion of Woodside School.

3.26 GO5: North of Cuffley Hill

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3.26.1 Part of the site is a disused and derelict former nursery that is currently

open grassland with some groups of shrubs/hedging along the

boundaries. The area of the site currently occupied by C.G. Edwards, is

terraced in places and they are held with retaining walls.

3.26.2 Areas of the site are overgrown with scrub and several groupings of

trees, with northern areas of the site particularly densely wooded. There

are further groups of trees interspersed in the southern half as well. If

the site were developed and trees lost, this could adversely affect

habitat for bats, breeding birds and dormice.

3.26.3 The only current active use of the site is by C.G. Edwards, a garden

landscape supplies business, with associated builders yard area at the

rear that may potentially pose a risk of contamination.

3.26.4 The site is within the Green Belt, however its development would only

lead to a minor change in the existing urban fringe.

3.26.5 There are no listed buildings within 500m of the site, there are no

biodiversity designations in the local area and the site is in Flood Zone 1.

3.26.6 Goffs Oak provides local access to a primary school and local

convenience store. The closest supermarket is in Cheshunt and the

nearest secondary school is Goffs School, 2.4km to east.

3.26.7 Cuffley train station is approximately 1km to the west. In light of the

relatively low level of development in this area (50 dwellings), the

overall effect on vehicle movements would be minimal, however the site

is relatively remote from certain destinations such as town centres,

supermarkets and secondary schools, so the number of vehicle trips per

resident would be expected to be relatively high.

3.26.8 If the site were to be developed careful attention would need to be

given to preserving as much of the woodland as possible.



3.27 GO6: Oakfield

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3.27.1 This site is allocated for eight homes and could have potential to provide

access to an extended Woodside Primary School, if the school is

extended to the south. When taken in combination with the lack of

environmental constraints in the Goffs Oak area, the development would

be expected to have a negligible effect against most of the SA

Objectives, however the site is within the Green Belt. Development of

this site could provide enhanced access to the allotments to the east of

the site, as well as a more traffic-free route to an enlarged Woodside

School.

3.27.2 In isolation, the adverse effects on the Green Belt and the trees on site

would make the site unfavourable for development, but this must be

considered against the value of enabling extension of Woodside Primary

School.

3.28 HOD1: Hoddesdon Town Centre

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3.28.1 This policy requires a review of the Hoddesdon Town Centre Strategy

with an emphasis on public realm improvements, a review of parking and

protection and enhancement of the towns’ historic character. Taken

together the aims of the Town Centre Strategy would be expected to

significantly improve the local townscape and vibrancy of the town, in

turn bringing people into the town, which would support local

businesses. Improvements to parking arrangements and access would

also be expected to reduce traffic congestion and promote public

transport. The protection and enhancement of the numerous historic

assets within Hoddesdon would help to maintain the area’s cultural

heritage.



3.29 HOD2: Turnford Surfacing Site

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3.29.1 This policy supports the redevelopment of the Turnford Surfacing Site in

accordance with the Turnford Surfacing Site Development Brief46. The

site is located to the east of Plumpton Road and to the west of the River

Lee Navigation. It is 1ha in size. The site was previously operated by

Aggregate Industries which converted aggregates into hard surfacing. It

is currently vacant. There is one redundant office building at the front of

the site; otherwise it is hard standing with a concrete surface

throughout.

3.29.2 Adjacent to the south eastern corner of the site on the opposing side of

the River Lee is the Grade I listed Rye House Gatehouse and Quay Side

Scheduled Monument and Area of Archaeological Interest. In light of the

sites current light industrial use, regeneration of the site has the

potential to improve the setting of these historic

3.29.3 Turnford Surfacing site is within Flood Zone 2 and partially within Flood

Zone 3a. As such it would be subject to the sequential and potentially

exception tests. The previous use of the site may have given rise to

contaminants within the site.

3.29.4 The Rye Meads SPA / RAMSAR / SSSI and Nature Reserve is on the

opposing side of the River Lee Navigation. Care would need to be taken

to ensure that this site is not adversely affected.

3.29.5 Rye House Speedway, the Rye House Go Kart Track and the railway

adjacent to the site are noise generating uses that may affect residential

amenity.

46 Broxbourne Borough Council (June 2011) Turnford Surfacing Site Development Brief

https://www.broxbourne.gov.uk/sites/default/files/Documents/Planning_Policy/pp_BOB_Turnford_Surfacing_DB.pdf



3.29.6 Access to a full range of facilities and amenities is available within

Hoddesdon. Hoddesdon Town Centre is 1.3km from the site. The closest

bus stop is 680m from the site and the closest primary school is 710m.

The closest healthcare centre is 1.2km from the site. Rye House train

station is adjacent to the southern boundary of the site, offering

sustainable transport further afield.

3.30 HOD3: Rye Park

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3.30.1 This policy promotes the regeneration of the current vacant47 industrial

premises at Plumpton Road.

3.30.2 The Grade I listed Rye House Gatehouse and Quay Side Scheduled

Monument and Area of Archaeological Interest are approximately 250m

to the south east of the site. There is some limited visibility between the

sites and in turn some limited potential for the seeting of the historic

assets to be affected.

3.30.3 The Rye Meads SPA / RAMSAR / SSSI and Nature Reserve is on the

opposing side of the River Lee Navigation. As the site is within the

existing urban area of Hoddesdon, effects of this site are considered

unlikely.

3.30.4 The site is within Flood Zone 1 and as such is at minimal risk of flooding.

3.30.5 Hoddesdon Town Centre is 1.2km west of the site. Bus services are

available local and Rye Meads train station is approximately 310m to the

south east of the site. The closest healthcare centre is 1.2km from the

site.

3.31 HOD4: Hoddesdon Business Park

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47 Broxbourne Borough Council (2016) Strategic Housing Land Availability Assessment



3.31.1 This policy endorses the exiting Hoddeston Park Business Improvement

Plan, which would not have an effect against the SA objectives as it

maintains the existing baseline position. The policy also commits BBC to

an early review of that plan, the outcomes of which are uncertain at this

stage.

3.32 HOD5: High Leigh Garden Village

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3.32.1 This policy provides support for the delivery of High Leigh Garden

Village in accordance with existing outline planning application

07/13/0899/O.

3.32.2 The site is approximately 84ha and within the Green Belt. The site is

located to the west of Hoddesdon, east of the A10. The site is

approximately 800m from Hoddesdon Town.

3.32.3 The area of the site north of Dinant Link Road is currently open fields

with hedgerow boundaries and stands of trees. There is a copse of trees

adjacent to the northern side of Dinant Link Road. The eastern edge of

the site abuts the urban area of Hoddesdon.

3.32.4 The King William IV Grade II listed building is 165m to the eat of the site

and the Grade II Listed ‘High Leigh Sunken Well and Donkey Track’ is

160m to the south on the opposing side of the High Leigh conference

centre. In both instances the historic assets have very limited if any

visibility from the site and adverse effects are considered unlikely.

3.32.5 There are of the site to the south of Dinant Link Road is also open fields

with stands of trees and hedgerows. High Leigh Farm is to the western

end of the area. The eastern edge of the site again abuts the urban area

of Hoddesdon.

3.32.6 The majority of the site is within Flood Zone 1, with some very limited

areas in Zones 2 and 3 associated with Wollens Brook on the eastern

boundary of the site.



3.32.7 The Wormley-Hoddesdon Park Woods SAC / SSSI / NNR is 200m to the

west of the site. It is not readily accessible from the majority of the site

due to the A10. It can be accessed via Lord Street, but Lords Street

doesn’t have a pavement for pedestrians. The site contains both grade 3

and Grade 4 agricultural land, which would be lost if the site were

developed.

3.32.8 The Bramble Lane bridleway runs through the site from north to south,

connecting onwards to Barclay Park. A public footpath branches east

joining onto Paddick Close. Existing bus routes pass through the site

along Dinant Link Road, which passes east-west through the site and

onto the A10. There is also a bus route along Hertford road to the north

of the site. With a site of this scale, the accessibility of the exiting buses

varies across the site. Rye house train station is 2km east of the site.

Whilst not

3.32.9 Hoddesdon Town Centre is 1km to the east, which has the greatest

concentration of facilities and amenities. A site of this scale could

provide for additional facilities and amenities in the western area of

Hoddesdon for both for residents on the site and existing residents in

the local area.

3.33 HOD6: Barclay Park and Spital Brook

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3.33.1 This policy includes for the extension of Barclay Park, which is a part of

the High Leigh Garden Village project (see Policy HOD:5 High Leigh

Garden Village). The policy also protects Spital Brook Valley from

development, maintaining the valley in its current use to the benefit of

the local landscape and biodiversity.

3.34 WC1: Waltham Cross Town Centre

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3.34.1 This policy will implement with Waltham Cross Town Centre Strategy,

which focuses on creating a vibrant town centre and redevelopment of

the northern high street (see policy WC2: Waltham Cross Northern High

Street). The focus of this policy would be expected to improve the

townscape and add additional green infrastructure to the area,

enhancing biodiversity. The policy also allows for additional dwellings in

Waltham Cross (see Policy PM2).

3.35 WC2: Waltham Cross Northern High Street

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3.35.1 The area of the site to the west of Sturlas way contains a Homebase

store and associated car parking. The area of the site east of Sturlas

Way contains a residential apartment block, Wickes store and associated

car parking at to the south east a number of retail stores fronting the

high street. It is understood that the existing Homebase / Wicks stores

on the site would be relocated within the borough. The site is allocated

for 300 dwellings.

3.35.2 Eleanor Cross, a Grade I Listed Building and Scheduled Monument is

125m to the south east of the site, with a limited line of sight between

the two along the High Street.

3.35.3 The eastern area of the site is partially within Flood Zone 2 and as such

would be subject to the sequential test.

3.35.4 The site is within the Monarchs Way AQMA. As such there is an

increased risk to human health for this site. A Transport Assessment and

Air Quality Assessment would need to be undertaken to identify whether

the change of use from commercial to residential would be expected to

have a positive or negative effect on air quality.

3.35.5 The site is in a central location in Waltham Cross and as such access to a

full range of facilities and amenities is very good. Public transport is

readily available from the bus depot on Eleanor Cross Road and

Theobalds Grove Train Station.



3.36 WC3: Waltham Cross Renaissance Area Action Plan

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3.36.1 This policy commits BBC to the production on an Area Action Plan for

Waltham Cross in support of HS2. As the Area Action Plan is yet to be

commenced the effects are uncertain at this stage. The Waltham Cross

Area Action Plan will be subject to a separate SA when it is produced.

3.37 WT1: Wormley Conservation Area Improvement Plan

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3.37.1 This policy commits BBC to the production of a conservation area

improvement plan for Wormley Conservation Area. As such, the policy

would not be expected to have any significant environmental effects.

3.38 WT2: Macers Estate

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3.38.1 This policy sets out the council’s support for additional improvements to

Macers Estate in Wormley. This includes improvements to the

community centre, environmental improvements and the potential for

additional homes. Whilst not fixed, it is anticipated that the number of

additional homes will be minimal. There are 13 Grade II listed buildings in

the local area, 12 of which are along High Road Wormley. The Turnford

and Cheshunt Pits SSSI is 480m to the south east of the site and the

Wormleybury Grade II Registered Garden is 700m to the west.



3.38.2 The potential for the enhancements to the local environment may

benefit the setting of the listed buildings, but this is unlikely.

Environmental improvements may also improve local biodiversity if they

include green infrastructure. As the policy includes for a small amount

of development in the existing urban area, the anticipated effects on

these receptors would be minimal.

3.39 LV1: Lee Valley Regional Park

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3.39.1 This policy sets out Broxbourne’s ongoing support for improvement

works to the Lee Valley. The Lee Valley has very high recreational and

amenity value alongside being an international designated habitat. The

council’s ongoing support would be expected to enhance and improve

these features.

3.40 LV2: Lee Valley White Water Centre

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3.40.1 This policy supports an Adrenaline Hub at the Lee Valley White Water

Centre. The Lee Valley White Water Centre hosted the white water

events at the London 2012 Olympic Games. The area is within Flood

Zone 3 and as such the Adrenaline Hub, which is a water-compatible use,

is highly appropriate for the area. The Site is approximately 175m to the

south east of the Lee Valley SPA / SSSI / Ramsar site. The policy is for

the expansion of an existing use and as there is no access to the Lee

Valley SPA / SSSI / Ramsar site from the White Water Centre, no

adverse effects are anticipated. The White Water Centre’s continuing

development would provide access to a world class recreation centre,

which would provide an opportunity for healthy activity. Given that

there are few white water centres such as the Lee Valley White Water

Centre in England, it is expected that people would travel to the Centre

from well outside the borough, boosting the local economy through

spend in the local area.



3.41 LV3: Broxbourne Leisure Pool Site

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3.41.1 This policy seeks to update the existing development brief for the site.

The development brief allows for recreational uses. The policy sets out

the intention to update the brief to include the potential for housing.

Whilst there isn’t sufficient certainty about the proposals at this time to

be able to assess the effects on housing on this site in full, it should be

noted that the site is within Flood Zones 2 and 3 and as such would be

subject to the sequential and exception tests. The site is also within an

Area of Archaeological Interest.

3.42 LV4: Spitalbrook

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3.42.1 Spitalbrook is currently a mix of derelict uses and scrubland. This policy

seeks to create a new wildlife habitat in the area. In light of the flood

risk and contamination issues for the site this is considered to be an

efficient use of the land that would benefit local biodiversity.

3.43 LV5: Lee Valley Park Gateways

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3.43.1 This policy seeks to improve accessibility to the Lee Valley Park.

Additional access would help more residents to access the recreational

and amenity value of the park, with the associated health benefits for

local residents. It is anticipated that the improved access would be to

the benefit of pedestrians and cyclists.



3.44 C1: Cheshunt Country Club

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3.44.1 The Cheshunt Country Club area has been considered for a number of

uses. At present the site is not allocated, with no use identified. The

policy identifies that BBC will seek to identify an appropriate use in due

course. At this stage, the use of the potential future use of the club

remains uncertain.

3.45 C2: Countryside Protection and enhancement

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3.45.1 This policy seeks to protect and enhance Cheshunt Park, Cheshunt

Common, Wormley Wood and Turnford Brook. These areas all provide

valuable habitat alongside amenity value to local residents. The policy

seeks a balanced approach that would enhance the wildlife value of the

sites while maintain an appropriate degree of access, benefiting both

biodiversity and the health of local residents.

3.46 NR1: New River Conservation Area

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3.46.1 This policy commissions a conservation area appraisal to look at the

merits of changing the existing New River Conservation Area Boundary.

As the conservation area appraisal has not yet been undertaken, the

effects of the policy are uncertain.



3.47 NR2: New River Path

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3.47.1 The New River path passes through the length of the borough, making it

a very valuable recreational resource. This policy seeks to improve

access to, and the quality of, the New River path. This would be

expected to increase the number of people using the path for both

recreational purposes and for commuting / shopping. Improvements to

the path would also be expected to improve the landscaping along the

path, which also offers the opportunity to improve function of the New

River path as a wildlife corridor.

3.48 GT1: Provision for Gypsies, Travellers, and Travelling Showpeople

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3.48.1 This policy allocates four sites for traveling communities as follows:

• Expansion of Hertford Road by 3 pitches;

• Expansion of St James Road by 3 pitches;

• Relocations of Halfhide Lane to accommodate 20 pitches in total; and

• Authorised Site at Wharf Road to accommodate 20 pitches in total.

3.48.2 The Hertford Road site is an existing traveling community site and is

identified for a limited expansion to the south. The land is currently

open grassland, grazed by horses. The boundaries are delineated by

trees. The area to the south west of the site is a LWS. There are no

statutory environmental designations in the local area. The site is within

Flood Zone 1 with some small areas of Flood Zone 2 associated with

Woollens Brook.



3.48.3 The St James Road site is between St James and Goffs Oak. The site is

already a traveling community site and some limited capacity has been

identified to expand the site to the north. The area for expansion is

currently grassland interspersed with trees. There are no statutory

environmental designations in the local area.

3.48.4 The site at Wharf Road in the Lee Valley already has a traveller

community. There are a number of unlicensed plots along the River Lee

and the policy seeks to bring these plots back within the established

central area, where they can be licensed and fully serviced. Moving

unauthorised pitches from the edge of the River Lee would be expected

to improve the landscape setting of the River Lee and would minimise

the risk of accidental pollution entering the river.

3.48.5 As discussed under policy BR1: Brookfield Riverside, the Halfhide Lane

traveller site will be redeveloped as a part of the Brookfield Riverside

development. The intention is to relocate these sites within the overall

development area. In doing so, the Council will need to be cognisant of

the sensitivities of relocating users that are likely to have a strong

attachment to place.

3.48.6 The Gypsy, Traveller and Travelling Showpeople Accommodation Needs

Assessment undertaken by BBC48 found that the existing communities

on all four of these sites considered themselves to have access to

healthcare and educational facilities.

3.49 GT2: Travelling Showpeople

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3.49.1 This policy allocates a site to the west of Lieutenant Ellis Way. The

northern area of the site is hardstanding already used by the travelling

showpeople community. The additional area of the site being allocated

to the south is currently predominantly overgrown scrubland, with one

existing dwelling and areas of private garden. It is understood that the

resident of the existing dwelling is willing to relocate if the site were

allocated for use by travelling showpeople.

48 Broxbourne Borough Council (October 2014) Gypsy, Traveller and Travelling Showpeople Accommodation Needs Assessment: Technical Report



3.49.2 There are no statutory environmental designations in the local area. The

site is within Flood Zone 1. The site is Grade 3 agricultural land that

would be lost if the site were developed.

3.50 INF1: Infrastructure

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3.50.1 This policy requires the preparation of an annual delivery Plan by BBC.

The plan would be expected focus on the provision of utilities, health

services, transport and the provision of education with consequent

benefits for sustainable design and construction.

3.51 INF2: Road Infrastructure

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3.51.1 This policy sets out five improvements to the transport network that

would seek to reduce the extant congestion problem in certain areas of

the borough. This includes improvements to the A10 in particular.

Reducing congestion would be expected to reduce emissions of

greenhouse gasses and also pollutants the adversely affect human

health, such as PM10 emitted by diesel engines. Improvements to local

infrastructure would also be expected to provide construction

employment for local residents.

3.52 INF3 : Crossrail 2 / four tracking

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3.52.1 This policy sets out BBC’s support for Crossrail 2 and the potential

expansion of the West Anglia mainline to a four rail network, which is

currently being examined by the West Anglia Task Force. In support of

these actions, which are subject to a separate planning process, BBC has

identified a supportive land allocation at Cheshunt Lakeside. The

assessment of Cheshunt Lakeside can be found in Section 3.15. However

the timing of the four tracking of West Anglia Railway and the potential

effects during the plan period are uncertain.

3.53 INF4: Rail Stations

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3.53.1 This policy sets out the BBC’s intention to work with other key

stakeholders to undertake a feasibility study for new railway stations at

Turnford and Park Plaza. As the outcomes of the feasibility study are

not yet known, the potential effects are uncertain.

3.54 INF5: Level Crossings

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3.54.1 This policy seeks to continue the current work to identify unsafe level

crossings and provide alternative points of access. Whilst the primary

benefit of this is a major improvement to health and safety, it would also

be expected to improve accessibility for pedestrians, as the alternative

means of access would be safer and permanently accessible.

3.55 INF6: Bus Transport

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3.55.1 This policy focuses on the provision of new and enhanced bus routes to

serve the anticipated expansion of Broxbourne’s population as set out

elsewhere in the plan. As such this policy would be expected to enhance

the public transport offering in the borough, in turn reducing greenhouse

gas emissions.

3.56 INF7: Walking and Cycling Strategy

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3.56.1 This policy seeks to promote walking and cycling in the borough and

commits the borough to producing a walking and cycling strategy within

5 years. The strategy would be expected to promote sustainable modes

of transport. It would also be expected to benefit health and fitness by

promoting walking and cycling as an alternative means of commuting

for work or to local facilities and amenities. It would also be expected to

identity and promote safe infrastructure for walkers and cyclists, such as

segregated cycle lanes.

3.57 INF8: North to South Paths

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3.57.1 This policy promotes walking and cycling along three of the key routes

in the borough. These three routes would be included within the walking

and cycling strategy assessed under policy INF6: Walking and Cycling

Strategy. In turn, this policy would also be expected to benefit health

and fitness by promoting walking and cycling and an alternative means

of commuting for work or to local facilities and amenities. The lanes

identified by this policy extend the length of the borough and as such

have a high recreational value.



3.58 INF9: Reserve Secondary School

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3.58.1 This policy safeguards land at Church Lane for the development of a

new secondary school, providing for the borough’s potential future

educational capacity requirements. The site is adjacent to the A10 and is

currently open land interspersed with trees.

3.58.2 There are 20 listed buildings within 500m of the site, including the Grade

I listed Wormleybury Manor, 400m west of the site. The Hell Wood

Scheduled Monument is 450m to the south west of the site. The

Wormley Conservation Area is adjacent to the north eastern boundary

of the site. The site is within the Green Belt, however it is south of

Broxbourne School, so development of the site as a secondary school

would be in keeping with existing development in the local area.

3.58.3 The site is Grade 2 agricultural land and is currently used for grazing, so

development of the site would lead to the loss of a valuable natural

resource.

3.58.4 The Top Field and Cozens Grove LNR is 780m north of the site. The

Cheshunt Park LNR is 800m to the south west of the site. The Lea

Valley Ramsar / SPA / Site is 620m to the south east. The northern area

of the site is designated as a LWS, namely the ‘Wormley Parkland East of

A10’ LWS, a 19.2ha site. The LWS would be lost of the site were to be

developed. The loss of the site has been identified as of moderate

adverse significance at this stage; a detailed ecological appraisal would

be required to fully understand the significance of the loss of habitat and

the potential effect species and in turn the detailed potential mitigation

measures required.

3.58.5 The southern area of the site is in Flood Zone 3.

3.58.6 The number of vehicle movements to and from the site would be

relatively low if it were developed as a school. The site has good

transport links and it is expected that there would be sufficient highway

capacity in the local area.



3.59 INF10: New and Expanded Primary Schools

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3.59.1 This policy makes provision for eight either new or expanded primary

schools in the Borough to meet the anticipated increase in demand

associated with new housing. As such this policy would make a

substantial contribution to education provision in the borough. This

policy would also provide improved access to primary schools for

existing residents by providing greater choice.

3.60 INF11: Educational Facilities

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3.60.1 This policy seeks to ensure that sufficient schooling provision is provided

as a result of additional demand created by new residential dwellings.

This can either be through the provision of new educational facilities on

site or through a contribution to offsite provision.

3.60.2 The policy also sets out the criteria by that expansions to schools should

met. This includes promoting sustainable transport, providing for high

quality flexible design and the retension of outdoor play space,

promoting helahty activity for young people.

3.61 INF12: Health Care

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3.61.1 This policy requires BBC to work alongside the local health authorities to

provide new healthcare capacity to meet the borough’s needs. As such

this policy would make a substantial contribution to healthcare provision

in the borough. This policy would also provide improved access to

healthcare facilities for existing residents by providing greater choice.



4 Assessment of Development Management Policies

4.1.1 This section presents the assessment of Development Management

Policies set out in Part 5 of the Plan.

General Design Principles

4.2 DSC1: General Design Principles

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4.2.1 This policy includes a broad range of requirements across five

categories:

• New Development;

• Development Standards;

• Extensions and alterations to existing development; and

• Design Affecting the Public Realm.

4.2.2 The ‘New Development’ section of the policy sets the design standards

for all new development across a broad range of sustainability criteria

including the protection of significant natural features, sustainable

drainage, enhancing local character and accessibility. As such it makes a

positive contribution to the majority of the environmental and social SA

objectives.

4.2.3 The ‘Development Standards’ section of the policy seeks to ensure that

residential development will meet with national and local development

and amenity standards, contributing to health and wellbeing for local

residents.

4.2.4 The ‘Alterations and Extensions to Existing Development’ section of the

policy primarily seeks to ensure that extensions to buildings don’t unduly

effect the parent building on those within the wider setting, which would

benefit the local townscape / landscape and potentially historic assets.



4.2.5 The ‘Design affecting the Public Realm’ section of the policy seeks to

ensure that development with the potential to effect the public realm

provides for attractive open and permeable public spaces and also

encourages urban greening, which would contribute to climate change

mitigation and adaptation objectives.

4.2.6 Overall, the policy would also be expected to have a positive economic

effect by creating places in which people want to live and work.

4.3 DSC2: Sustainable Construction

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4.3.1 This policy promotes sustainable construction with a particular focus on

the use of sustainable materials and sustainable waste management.

The promotion of sustainable waste management would also help to

mitigate climate change as it reduces the embedded energy used in new

materials. In addition, where waste materials are reused on site it

reduces the greenhouse gas emissions associated with transport for

disposal. The policy also seeks to ensure buildings are adaptable,

including the changing needs of occupants, which in some

circumstances would be expected to have health and wellbeing benefits

such as adapting buildings to suit disabilities be adapted for the elderly.

4.4 DSC3: Designing out Crime

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4.4.1 This policy seeks to integrate measures to reduce crime into the design

of the new developments, which would reduce the fear of crime as well

as the risk of crime. This would be expected to have a positive effect on

the health and wellbeing of residents. In addition, the policy also seeks

to ensure that such measures respect the overall character of the area,

which would have a positive effect on the local townscape / landscape.



4.5 DSC4: Comprehensive Urban Regeneration

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4.5.1 This policy promotes comprehensive masterplanning and design, rather

than allowing for piecemeal development to come forward that may

lead to landlocked sites. A comprehensive approach to design would be

expected to benefit all of the SA Objectives as a result of an integrated

approach to development.

4.6 DSC5: Shop Fronts and Fascias

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4.6.1 This policy seeks to manage the aesthetic of shop signs and

advertisements, ensuring their suitability to the local character and

environment. This would also be expected to benefit the local economy

by providing an attractive business environment.

Housing

4.7 H1: Affordable Housing

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4.7.1 This policy sets out the affordable housing requirements for the

borough, requiring 40% affordable housing. This will create a mix of

housing in the borough to suit a variety of tenancy requirements.

Employment



4.8 ED1: New Employment Uses

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4.8.1 This policy encourages new knowledge based businesses, seeking to

locate them in suitable areas and with flexible floor space to

accommodate potential future changes in use. The policy also requires

employment sites to be accessible by several modes of transport, which

would be expected to reduce reliance on the private car and encourage

the use of public transport. It would also be expected to encourage

walking and cycling, with consequent health benefits.

4.9 ED2: Loss of Employment Uses - Rest of the Borough

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4.9.1 This policy seeks to protect existing employment sites. Whilst policy

ED1 takes the more proactive approach to enhancing the economy, this

policy would maintain existing employment sites and prevent

unnecessary loss, maintaining the economy of the borough in the long

term.

4.10 ED3: Visitor Attractions

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4.10.1 This policy seeks to encourage new visitor facilities, tourist attractions

and hotels in the borough, helping to boost the borough’s economy.

The policy also promotes the creation of an adrenaline hub at the Lee

Valley White Water Centre and the Broxbourne Lido for recreational use,

which would have both economic and health benefits. The policy also

supports creation of a wildlife habitat at the former mineral workings at

Spitalbrook, which benefits habitat creation and biodiversity.



Retail and Town Centres

4.11 RTC1: Hierarchy of Town and Local Centres

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4.11.1 This policy establishes the hierarchy of town centres within Broxbourne,

which is intended to ensure that retail uses are directed to town centres

in the various centres in the hierarchy in the first instance. This will

reduce the risk of piecemeal development and help to ensure that the

various centres remain viable and attractive places to visit. This will help

to reduce use of the private car by developing retail uses in areas that

have good access via public transport, walking and cycling. By

maintaining the viability and vitality of town centres, this policy would

also help to enhance the townscape of the town centre.

4.12 RTC2: Development within designated town centres

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4.12.1 This policy directs retail development, with the exception of small-scale

retail stores, towards the borough’s main retail centres. It then sets out

the criteria for acceptable development in these areas. The policy seeks

to enhance the character of the town centre, provide safe access, and

minimise adverse effects on the amenity of the residents in the town

centre. This would be expected to minimise odour and noise pollution,

with consequent health benefits. The policy will also help to ensure that

vehicle movements in the town centre are appropriately managed. The

policy would benefit the local townscape by helping to maintain the

viability and vitality of town centres.



4.13 RTC3: Evening Economy

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4.13.1 This policy looks to locate evening and nighttime uses within the

identified borough centres. Measures to ensure the safety and amenity

of residents would have a positive health and wellbeing benefit.

Measures to protect the character and vitality of the shopping frontages

would benefit the townscape of the district centres.

4.14 RTC4: Hot Food Take-Away Uses

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4.14.1 The appropriate location of hot food take-aways would have a number

of benefits. By maintaining appropriate distances from secondary

schools it would help to reduce unhealthy eating among secondary

school children. Controlling odour would benefit the amenity of nearby

residents and appropriate access would ensure that take-aways do not

contribute to congestion.

4.15 ORC1: New Open Space, Leisure, Sport and Recreational facilities

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4.15.1 This policy requires developer contributions to the provision of open

space and leisure facilities, helping to ensure that there is sufficient

space to meet community requirements, with subsequent health

benefits. The policy also seeks to utilise opportunities for a net gain in

biodiversity on leisure and recreational sites, benefiting the health and

wellbeing of local residents.



4.16 ORC2: Loss of Open Space, Leisure, Sport and Recreational facilities

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4.16.1 This policy seeks to prevent the loss of playing fields in all but

exceptional circumstances unless certain criteria are met. In light of

these criteria, which include alternative or better provision in the

immediate area, the overall effect would be expected to be negligible.

4.17 ORC3: Local Green Space

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4.17.1 This policy prevents the development of identified Local Green Spaces.

These spaces have recreational value, contributing to health and

wellbeing, visual amenity value contributing townscape/landscape and

contribute to climate change adaptation. They also form an important

part of the GI network and form part of a broader habitat network,

promoting biodiversity.

4.18 ORC4: Amenity Spaces

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4.18.1 This policy protects amenity spaces provided that they meet certain

requirements. Amenity spaces have recreational value, contributing to

the health and wellbeing of residents. Amenity spaces also have visual

value contributing townscape/landscape. They also form an important

part of the GI network and form part of a broader habitat network,

promoting biodiversity and contributing to climate change adaptation.



4.19 ORC5: Community Uses

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4.19.1 This policy seeks to prevent the loss of community buildings and allow

for new buildings / uses where certain criteria are met. The policy seeks

to minimise the potential adverse effects associated with new buildings,

including ensuring no adverse effects on traffic flows. Community

facilities play an important role in community cohesion, so this policy

would be expected to have health and wellbeing benefits.

4.20 ORC6: Equestrian Development

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4.20.1 This policy sets out the criteria for small-scale equestrian development.

It seeks to ensure that adequate drainage is provided, which will ensure

that premises are adapted to climate change. Measures to protect the

amenity of nearby properties will benefit health and wellbeing. The

preference for the use of existing buildings will help to minimise waste.

The Water Environment

4.21 W1: Improving the quality of the water environment

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4.21.1 This policy seeks to maintain the natural functioning of water courses,

and return water courses to their natural state where possible. This

would be expected to minimize flood risk, both at a given site and

downstream of the site as many of the interventions that have been

made to the natural flow of waterways increase the rate of discharge

downstream. In addition, this policy would also maintain and enhance

riparian habitats, promoting biodiversity. These habitats also have a

function in minimising pollution and enhancing the aesthetic appeal of

waterways.

4.22 W2: Water Quality

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4.22.1 This policy protects Groundwater Source Protection Zones by requiring

a drainage strategy to be submitted with a proposed development,

which would show sewage would be adequately dealt with, minimising

the risk of pollution. It would also detail how surface run-off would be

managed, minimising flood risk.

4.23 W3: Water Efficiency

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4.23.1 This policy promotes water efficiency in new and existing developments,

including commercial developments. Water efficiency is a key part of

adapting to climate change and is an efficient use of a valuable natural

resource.

4.24 W4: SuDS

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4.24.1 The principal purpose of SuDS is to mitigate flood risk. The use of SuDS

has a number of benefits beyond flood risk management. SuDS features

can create new habitats, improving biodiversity. Swales can be

attractive features of the landscape / townscape. They help to improve

water quality. They can also reduce the discharge rate to sewers,

reducing the amount of water requiring treatment and in turn reduce the

amount of energy required to do so.

4.25 W5: Flood Risk

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4.25.1 This policy protects land within Flood Zone 3b (the functional

floodplain) from development. Developments in Flood Zones 2 and 3

that aren’t in the flood plain are required to include onsite flood storage

and flood resilient features. As such this policy is expected to ensure

that development is appropriately located when taking into account

climate change and flood risk.

Green Belt

4.26 GB1: Green Belt

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4.26.1 This policy protects the Green Belt from inappropriate development

unless very special circumstances are demonstrated. The Green Belt is a

key landscape designation and as such appropriate protection of the

Green Belt is essential to maintaining the borough’s landscape quality.

4.27 GB2: Residential development on Derelict Glasshouse Sites

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4.27.1 This policy allows for self-build housing on glasshouse sites where the

ongoing use of the site as a commercial glasshouse has been proven to

be unviable. The self-build approach will continue to explore

opportunities for promoting local scale food production whilst accepting

that in some instances glasshouses are no longer viable. The total level

of housing coming forward under this approach is expected to be

relatively minor. The policy provides a number of design requirements

that would act to ensure that the development of the site would not

adversely affect the Green Belt.

4.28 GB3: Rural Diversification

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4.28.1 This policy allows for farm diversification schemes. This reflects the

changing rural economy. Approximately half of all UK farms use some

form of diversified activity in their farming business, bringing an average

of £10,400 extra revenue per farm. It can involve diversifying into non-

agricultural areas such as:

• Tourist accommodation;

• Retail outlets and catering;

• Rural tourism;

• Converting redundant buildings to other uses;

• Making and selling non-agricultural products;

• Training and promotion of rural crafts and arts; and

• Energy markets.

4.28.2 Flexibility to accommodate these types of businesses would be

expected to provide an economic benefit for the borough and ensure

the health of the rural sector49.

49 https://www.gov.uk/guidance/diversifying-farming-businesses



4.29 GB4: New Glass House Sites and Nursery Developments

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4.29.1 This policy supports the development of glasshouses and nurseries in

the borough. The glasshouse industry has traditionally been an

important part of the borough economy, however more recently the

industry has been in decline, with some glasshouse sites now becoming

derelict. Steps taken to either expand existing nurseries or replace

existing nurseries with newer facilities would be to the economic benefit

of the borough. As the location of any potential expansion is not known

at this time, the potential effects on ojectives including cultural heritage,

landscao and biodiversity remain uncertain.

4.30 GB5: Occupancy Conditions

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4.30.1 This policy deals with occupancy conditions and as such would not be

expected to have an effect against any of the SA Objectives.

4.31 NEB1: Wildlife, Wildlife Sites and Biodiversity

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4.31.1 This policy provides protection for habitats and species from local to

international importance. Where development is found to be

acceptable, the policy seeks to ensure that provision is made for a net

gain in biodiversity overall. Many protected wildlife sites also have

recreational and amenity value. For example, areas of the Lea Valley are

protected as a Ramsar Site, SAC, and SSSI. The area also has a high

level of recreational and amenity value. LWS can also play a role in flood

risk management by reducing run off rates and providing flood water

storage areas.

4.32 NEB2: Green Infrastructure

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4.32.1 This policy seeks to crease an interlinked network of green spaces in the

borough. Green infrastructure provides an important part of the

network of habitats in the borough. Green infrastructure also provides

amenity and aesthetic value and can play a role in managing flood risk

by reducing run-off rates.

4.33 NEB3: Landscaping and Biodiversity in New Developments

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4.33.1 This policy sets out the requirements for landscaping in new

developments, ensuring that landscaping measures seek to promote and

enhance biodiversity. This policy also requires the landscaping features

to take into account the health and amenity of future residents / users of

the site.

4.34 NEB4: Protected Trees and Hedgerows

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4.34.1 This policy protects trees and hedgerows from partial loss or removal

unless certain requirements are met. Trees and hedgerows provide

important habitats for mammals and insects. Since the Second World

War, the UK’s ancient hedgerows have dramatically declined due to

removal to increase field size and to make way for development, so

protection of hedgerows in an important part of maintaining biodiversity

in the UK and also benefits the landscape.

Environmental Quality

4.35 EQ1: Air Quality

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4.35.1 This policy seeks to ensure that new developments do not adversely

affect air quality in the first instance and where they do, sufficient

mitigation is in place to address the effect. Improvements to air quality

would also benefit human health, which is particularly important for

developments in urban areas where exposure to pollutants tends to be

highest.

4.36 EQ2: Lighting

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4.36.1 New lighting in an area has the potential to enhance sky glow, disturb

the amenity of existing residents and disturb wildlife. For example, it

can adversely affect the activity of bats. This policy seeks to ensure that

only the minimal necessary level of lighting is used in new developments,

minimising the potential adverse effects on residents, drivers and

wildlife.



4.37 EQ3: Noise

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4.37.1 Noise pollution has the potential to affect the borough’s existing tranquil

areas, whose amenity value is dependent upon a peaceful environment.

A common source of noise disturbance is vehicle traffic, with other

sources including noise and vibration during the construction of new

developments and potentially further noise disturbance during the

operational life of the building. Locating noise sensitive development

next to existing sources of industrial noise can also place restraints on

the existing use. This policy seeks to manage the noise environment,

preventing development that would disturb existing tranquil areas or

place undue restrictions on existing development, benefiting both local

businesses and residents.

4.38 EQ4: Contaminated Land

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4.38.1 The regeneration of contaminated land is an important part of

sustainable development. It is an efficient use of a low value resource

and focussing on these areas can reduce pressure to develop on higher

quality land and greenfield sites. There is also the potential to enhance

the visual appeal of land that has become derelict. In regenerating

contaminated land care must be taken to avoid risks to health, both

during the remedial works themselves and once the site is occupied.

The policy acknowledges these risks and promotes development of

contaminated land, recognising the benefits.

4.39 EQ5: Waste and recycling

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4.39.1 This policy encourages waste segregation prior to collection to ensure

as much material can be recycled as possible. This policy should be

considered in the context of the Hertfordshire Waste Development

Framework 2011 - 202650, which provides the broader waste policy

context as a part of the development plan.

4.40 EQ6: Minerals

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4.40.1 This policy does not permit development that would be likely to sterilise,

or prejudice the extraction of, known workable materials. This will

ensure that potentially valuable resources are not rendered unworkable.

This policy should be considered in the context of the Hertfordshire

Minerals Local Plan51, which provides the broader policy context for

minerals extraction in Broxbourne.

Heritage Assets

4.41 HA1: Heritage Assets

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4.41.1 This policy seeks to protect heritage assets and their settings. New

developments have the potential to adversely affect or the setting of

historic assets. With sympathetic design not only can such adverse

effects be mitigated, there is also the opportunity for the setting of

historic buildings to be enhanced. The policy will protect historic assets

by avoiding developments that would adversely affect historic assets,

also acknowledging the potential cumulative effect a number of smaller

developments may have when considered together.

50 Hertfordshire Waste Development Framework: Waste Core Strategy & Development Management Policies Development Plan Document 2011 – 2026 (November 2012)

http://www.hertsdirect.org/docs/pdf/w/twcsadmpd.pdf 51 Minerals Local Plan 2007

http://www.hertsdirect.org/services/envplan/plan/hccdevplan/



4.42 HA2: Non-Designated Heritage Assets

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4.42.1 This policy requires BBC to engage with the local community to identify

local non-designated heritage assets. Non-designated heritage assets

are buildings, monuments, sites, places, areas or landscapes identified as

having a degree of significance meriting consideration in planning

decisions but which are not formally designated heritage assets52. This

policy therefore forms an important part of understanding the local

historic environment, and in turn being able to monitor whether non-

designated historic assets are being adversely affected or lost.

4.43 HA3: Conservation Areas

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4.43.1 This policy sets out the approach to managing development in

conservation areas, both for new build developments and shop fronts /

signage. The policy will ensure that development is in keeping with the

unique character of each of the borough’s six conservation areas. The

policy also protects important views into conservation areas and takes

into account landscape features and GI, which are important parts of

maintaining the character of the area.

4.44 HA4: Demolition in a Conservation Area

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52 Planning Practice Guidance (2014)

http://planningguidance.communities.gov.uk/blog/guidance/conserving-and-enhancing-the-historic-environment/what-are-non-designated-heritage-assets-and-how-important-are-they/



4.44.1 This policy sets out the circumstances in which the demolition of a

building would be allowed within a conservation area. As such it

provides an important check and balance to development in

conservation areas.

4.45 HA5: Listed Buildings

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4.45.1 This policy seeks to preserve listed buildings in the conservation area,

maintaining Broxbourne’s cultural heritage.

4.46 HA6: Locally Listed Buildings

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4.46.1 Locally listed buildings are not subject to the same protections as listed

buildings on the national list. This policy seeks to preserve and enhance

locally listed buildings in the conservation area, maintaining

Broxbourne’s cultural heritage.

4.47 HA7: Works Within the Setting of Listed and Locally Listed Buildings

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4.47.1 This policy sets out the requirements that new development will need to

meet if it is within the setting of an existing listed building. This includes

enabling development. Development in such close proximity to listed

buildings has the potential to adversely affect them and this policy

provides protection to ensure that the setting of listed buildings is

maintained.



4.48 HA8: Demolition of Listed Buildings

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4.48.1 This policy sets out the circumstances in which the demolition of a listed

building would be allowed. This policy will ensure that listed buildings

are only lost in rare circumstances where there is an overriding issue that

necessitates the loss.

4.49 HA9: Historic Parks and Gardens

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4.49.1 Wormleybury, a Grade II registered park dating from the 1770s, is the

only Registered Park or Garden in Broxbourne. The policy protects both

Historic Parks and Gardens and also protects locally important gardens

as identified by the Hertfordshire Gardens Trust. Historic Parks and

Gardens are a part of the cultural heritage of the borough and contribute

to the local landscape. If open to the public, parks and gardens also

have amenity value for residents.

4.50 HA10: Archaeology

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4.50.1 This policy seeks to both protect sites of archaeological importance and

requires trial trenching for developments where there is the potential for

archaeological remains. Archaeological remains are finite and it is

essential that they be managed correctly to ensure that they are not lost

or destroyed unnecessarily.



4.51 HA11: Scheduled Monuments

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4.51.1 Scheduled Monuments are nationally important archaeological sites that

benefit from close management. This policy will protect Scheduled

Monuments from development in all but exceptional circumstances,

protecting the borough’s cultural heritage.

4.52 HA12: Works affecting the setting of a Nationally Designated Building, Structure, Landscape, Park or Garden or Other Feature

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4.52.1 In some circumstances it is possible for the setting of historic assets to

be adversely affected by developments not within their immediate

curtilage. This can be the case when there is a line of sight between two

features, for example. This policy ensures that the potential for such

effects is identified and managed; with the appearance, character and

setting of the historic asset in question sustained or enhanced.

Transport and Movement

4.53 TM1: Sustainable Transport

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4.53.1 This policy requires developments to undertake a full review of the

potential modes of sustainable developments that may be appropriate.

The policy also promotes walking and cycling. Sustainable transport has

a number of benefits. By promoting a modal shift away from the private

car it would reduce air pollution, particularly in town centres where the

potential for exposure to pollutants is highest. A modal shift away from

the private car would also be expected to lead to a reduction in

greenhouse gas emissions, minimising the borough’s contribution to

climate change. Encouraging walking and cycling will improve health

and wellbeing, as would the focus given to appropriate safety features

for pedestrians and cyclists.

4.54 TM2: Transport and New Developments

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4.54.1 This policy seeks to avoid development that would have an

unacceptable adverse effect on the transport network. It requires

developments to prepare a Transport Assessment / Transport Statement

and for large-scale developments, a Travel Plan. These measures would

encourage a modal shift away from the private car by designing

measures into new developments that would make alternatives more

attractive and safer. Home Zones are also encouraged, which would

reduce traffic speeds and provide for a safer environment.

4.55 TM3: Access and Servicing

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4.55.1 This policy includes a requirement for electric car charging points for

residential developments of over eight homes or major commercial

developments. Electric vehicles are becoming increasingly popular.

From January to May 2016, 16,056 cars eligible for the plug in car grant

were registered. This represents a 33.6% rise on the 12,022 registered

during the same period in 201553. Alongside having lower emissions

compared to fossil fuel powered vehicles, electric cars are particularly

beneficial in urban environments as they do not cause local point source

pollution, such as PM10 and the associated adverse effects on human

health.

4.56 TM4: Parking Standards

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4.56.1 This policy sets out the parking standards for the borough. The

intention is to reduce private car use. Restricting parking is a key part of

promoting a modal shift away from private car use, but must go hand in

hand with suitable alternatives being provided to prevent nuisance

parking in inappropriate areas.

4.57 TM5: Vehicle Cross Overs

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4.57.1 This policy deals with the installation of dropped kerbs and vehicle

crossovers and would not be expected to affect any of the SA

Objectives.

53 http://www.smmt.co.uk/2016/05/april-2016-ev-registrations/



Planning Obligations and the Community Infrastructure Levy

4.58 PO1: Planning Obligations

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4.58.1 Planning obligations are an important aspect of ensuring the

sustainability of new developments as they can make certain

developments viable, offset potentially adverse effects that a

development may cause or go to paying for essential new infrastructure.

The effects of planning obligations are therefore considered to be

typically positive against the SA Objectives, however as a bespoke

planning obligation arrangement is created for each scheme, the

magnitude of the effect against any of the SA Objectives is uncertain.

4.59 PO2: Community Infrastructure Levy

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4.59.1 Similar to planning obligations, the Community Infrastructure Levy (CIL)

is a key part of securing funds to provide finance for the social

infrastructure requirements associated with new developments. At

present BBC doesn’t have a CIL charging schedule, so whilst it is

expected that the effects would be positive, they are uncertain at this

time.



5 Mitigation Considerations and Recommendations

5.1 Introduction

5.1.1 The information presented in this chapter has been prepared in response

to negative or uncertain assessment findings. In circumstances where

negative or uncertain circumstances have not been identified within an

objective, e.g. SA Objective 10: Housing, the narrative includes best

practice recommendations for sustainable development. For each

objective, information is presented about mitigation considerations and

recommendations. Mitigation considerations identify the key issues that

have arisen during assessment. Recommendations are identified for the

purpose of either informing local planning policy or to inform conditions

when considering planning applications.

5.1.2 The mitigation hierarchy54 is a policy for ensuring activities do not have

unnecessary impacts on the environment:

• In the first instance harm should be avoided, for instance by locating development at a different site.

• Where harm cannot cannot be avoided it should be reduced, for instance by reducing the total quantum of development.

• Where this is not possible the impacts should be mitigated, for instance through the detailed design of the development.

• Lastly any residual impacts should be compensated for, for instance by restoring or recreating habitat elsewhere.

5.2 SA Objective 1: Cultural Heritage

Mitigation consideration (1) The setting of cultural assets

5.2.1 The setting of a cultural/heritage asset is the surroundings in which it is

experienced; often expressed by reference to visual considerations.

Paragraph 013 of the NPPF states that ‘although views of or from an

asset will play an important part, the way in which we experience an

asset in its setting is also influenced by other environmental factors such

as noise, dust and vibration from other land uses in the vicinity, and by

our understanding of the historic relationship between places.’

54 DEFRA (2013) Biodiversity offsetting in England; Green paper



5.2.2 Development that may affect the setting of a heritage asset may need to

consider the cumulative implications of change. Paragraph 013 of the

NPPF further highlights that development that materially detracts from

the asset’s significance may also damage its economic viability now, or

in the future. This then threatens the assets’ ongoing conservation.

Cultural heritage mitigation recommendations

5.2.3 Cultural Heritage recommendation 1: Loss of heritage features is an

irreversible adverse effect. Excavation of features prior to development

should be carefully documented and added to the local historic record.

5.2.4 Cultural Heritage recommendation 2: Where possible, cultural features

should be designed into new development to recognize and help

develop a strong sense of place. New development should avoid

compromising existing qualities.

5.3 SA Objective 2: Landscape

Mitigation consideration (1) Landscape character and local distinctiveness

5.3.1 Landscape character is a distinctive quality that should be upheld when

considering impacts and designing new development. One of the core

planning principles listed in Para 17 of the NPPF includes the

requirements to ‘recognise the intrinsic character and beauty of the

countryside’. Mitigation is best served through careful design. This may

have the added benefit of green infrastructure.

Landscape mitigation recommendations

5.3.2 Landscape recommendation 1: Where possible, development should

incorporate mitigation through careful design including planting

strategies. Key characteristics for Landscape Character Areas should

be maintained where possible. Development should not hinder the

successful delivery of management prescriptions for Landscape

Character Areas.

5.3.3 Landscape recommendation 2: New development should seek to

incorporate new planting schemes or landscape buffers into the

development design in keeping with the local character.

5.4 SA Objective 3: Biodiversity

Mitigation consideration (1) Habitat loss



5.4.1 It is possible that habitats lost through development may be important55.

Paragraph 109 of the NPPF56 states that the planning system should

provide net gains in biodiversity, where possible. The European Union

(EU) has committed to halt the loss of biodiversity by 2020, principally

by introducing the ‘no net loss’ initiative, which works to ensure that

there is no net loss of ecosystems and their services.

5.4.2 Loss or fragmentation of habitats should be reduced by avoiding loss

and providing buffers to important habitats, where possible. If habitat

loss is unavoidable, this may be mitigated by the introduction of

compensation and offsetting schemes help to ensure no net loss in local

biodiversity, and to replace those which will be lost through

development.

5.4.1 Policy INF8 safeguards land at Church Lane that is designated as a LWS

for the future development of a secondary school An ecological

appraisal should be undertaken of the land at Church Lane to identify

the habitats and species present and the recommendations of the

ecologist followed.

Mitigation consideration (2) Habitat connectivity

5.4.2 Development may result in the loss of wildlife corridors such as

hedgerows and patches of woodland. Loss of habitat corridors is likely

to cause fragmentation and problems to species that rely on habitat

connectivity, such as bats.

5.4.3 The Lawton review57 concluded that England’s designated wildlife sites

did not comprise a coherent wildlife and ecological network. The report

suggests making the network of sites bigger, better and more joined up.

Biodiversity mitigation recommendations

5.4.4 Biodiversity recommendation 1: Where habitats present may have the

potential to support protected species, surveys should be undertaken to

determine presence/absence and population size. This will determine

whether protected species are likely to be lost if the site were to be

developed.

55 As they may be rare, irreplaceable or support protected species 56 Communities and Local Government (2012) National Planning Policy Framework [online] Available at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/6077/2116950.pdf 57 Sir John Lawton (2012) Making Space for Nature: A review of England’s Wildlife Sites and Ecological Network [online] Available at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/218690/201009space-for-nature.pdf



5.4.5 Biodiversity recommendation 2: Where possible, development should

seek to ensure ‘no net loss’ in biodiversity at any given site.

5.4.6 Biodiversity recommendation 3: Habitat features can be incorporated

into developments and help overcome the effects of habitat

fragmentation. Where possible, removal of existing linear features such

as hedgerows, tree lines and aquatic networks should be avoided.

5.5 SA Objective 4: Climate Change mitigation

Mitigation consideration (1) Carbon footprint

5.5.1 Paragraph 95 of the NPPF states that to support the move to a low

carbon future, local planning authorities should:

• Plan for new development in locations and ways which reduce greenhouse gas emissions;

• Actively support energy efficiency improvements to existing buildings; and

• When setting any local requirement for a building’s sustainability, do so in a way consistent with the Government’s zero carbon buildings policy and adopt nationally described standards.

5.5.2 The NPPF goes on to state that ‘to support the move to a low carbon

future, local planning authorities should plan for new development in

locations and ways which reduce greenhouse gas emissions. This could

include reducing reliance on personal vehicles and supporting low

carbon transport.’

5.5.3 In line with the NPPF, new developments should deliver appropriate

mitigation mechanisms to reduce per capita carbon footprint.

Climate change mitigation recommendations

5.5.4 Climate Change mitigation recommendation 1: Mitigation methods

include supporting sustainable transport modes, i.e. through reducing

the need to travel, minimizing walking distance to public transport links,

and increasing frequency of public transport services.

5.5.5 Climate Change mitigation recommendation 2: Where possible

development should maximize renewable energy generation and use of

energy from renewable sources.

5.6 SA Objective 5: Climate Change Adaptation

Climate change adaptation recommendations



5.6.1 Climate change adaptation recommendation 1: Retain existing GI and

incorporate this into the development where possible. Seek to augment

and strengthen Broxbourne’s strategic network of GI58.

5.6.2 Climate change adaptation recommendation 2: Incorporate new, high-

quality GI into the development, including a variety of habitats and

publically accessible green space. This should be well connected to the

existing GI network.

5.7 SA Objective 6: Natural Resources

Mitigation consideration (1) Utilise previously developed, degraded and under-used land

5.7.1 Paragraph 111 of the NPPF states that planning decisions should

encourage the effective use of land by re-using land that has been

previously developed (brownfield land), provided that it is not of high

environmental value.’

Mitigation consideration (2) Loss of best and most versatile agricultural land

5.7.2 Any loss of Grade 1 or 2 agricultural land is a permanent loss and

represents an adverse effect. The economic and other benefits of the

best and most versatile agricultural land should be taken into account

prior to development59. The Government has re-affirmed the importance

of protecting our soils and the services they provide in the Natural

Environment White Paper The Natural Choice: securing the value of

nature (June 2011), including the protection of best and most versatile

agricultural land.

5.8 SA Objective 7: Pollution

Mitigation consideration (1) Maintain and improve air, soil and water quality

5.8.1 Paragraph 110 of the NPPF states that ‘in preparing plans to meet

development needs, the aim should be to minimize pollution and other

adverse effects on the local and natural environment. Plans should

allocate land with the least environmental or amenity value.’ �

58 Ibid 59 Natural England (2012) Natural England Technical Note TIN049 Agricultural Land Classification: protecting the best and most versatile agricultural land



5.8.2 The Environment Agency manages water use, balancing consumer

supply with environmental preservation111. Water quality can be

affected by a range of factors including run-off from fields and the

weather. Sustainable development is encouraged, which includes

regulation and monitoring of water quality. �

5.8.3 Planning and development has an important influence on air quality and

also, therefore, the health of humans and ecosystems 112. Housing

development in or near an existing AQMA is likely to exacerbate air

quality issues in the area. This is due to the fact that most households

are expected to own at least one vehicle, which will increase traffic

movements in the AQMA, thus increasing congestion and air pollutants

associated with vehicles exhaust fumes.

5.8.4 The type of measures proposed to improve air quality will depend on the

nature and scale of the proposed development. Where the proposal is

for a small number of new residential units in an area of high pollutant

concentrations, it would be reasonable to examine design and

ventilation arrangements to reduce impacts. Where proposed

development is larger and impacts are greater, measures such as traffic

management and improvement of public transport emissions should be

considered113.�

5.8.5 Soil pollution has long-term implications for soil quality, and pollutants

enter the soil from many sources114. Paragraph 109 in section 6.2.9 of the

NPPF states why soil should be conserved, and highlights the need to

prevent development from unacceptable levels of soil pollution. DEFRA

continues to work to ensure that those developing and implementing

planning policy have the tools and skills to allow them to give

appropriate consideration to soils. Mitigation includes careful

development design and incorporation of green space to provide

effective protection of soils. �

Pollution mitigation recommendations

5.8.6 Pollution recommendation 1: Air quality mitigation methods include

careful development design arrangement, and sustainable traffic

management principles. Support the local and strategic GI network.

5.9 SA Objective 8: Waste

Mitigation considerations (1) Minimise waste generation and encourage recycling of waste



5.9.1 The Waste Management Plan for England60 sets out the Government’s

ambition to work towards a more sustainable and efficient approach to

resource use and management. In 2012 the Government amended the

Waste (England and Wales) Regulations 2011 61 , supporting local

authorities in improving quality and quantity of recycling.

5.9.2 DEFRA work to ensure that waste management is considered alongside

other spatial planning concerns, such as housing and transport,

recognising the positive contribution that waste management can make

to the development of sustainable communities62. Mitigation methods

include improved waste collection schemes and supporting the use of

recyclates, minimizing the landfilling or incineration of such recyclates

whenever possible.

Waste mitigation recommendations

5.9.3 Waste recommendation 1: Sufficient opportunities should be identified

to meet the needs of the development area for management of waste

streams.

5.9.4 Waste recommendation 2: Where economically and environmentally

practical, development should promote re-use of recycled materials, and

high quality recycling facilities.

5.10 SA Objective 9: Transport

Mitigation consideration (1) Sustainable transport modes

5.10.1 Paragraph 17 of the NPPF gives one of the core planning principles as

focusing development in areas which are, and can be made sustainable,

by making use of public transport, walking and cycling.

60 DEFRA (2013) Waste Management Plan for England [online] Available at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/265810/pb14100-waste-management-plan-20131213.pdf 61 Official Journal of the European Union (2008) Directive 2008/98/EC of the European Parliament and of the Council of §9 November 2008 on waste and repealing certain Directives [Online] Available at: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/218586/l_31220081122en00030030.pdf 62 Ibid.



5.10.2 Section 4 of the NPPF relates to promoting sustainable transport. This

includes making sustainable transport the most prominent and easiest

option for people, particularly by tailoring transport solutions for

different areas. Development with poor public transport links and

limited local services and amenities may result in residents being reliant

on car use. Due to the existing road infrastructure and capacity, this

may lead to increased congestion and decreased road safety.

Development should avoid contributing to congestion issues in the area,

and instead increase accessibility. This includes developing supporting

infrastructure to accommodate sustainable development. Transport

Statements or Transport Assessments and a Travel Plan are required for

developments that generate ‘significant’ amounts of movement. The

NPPF supports plans that minimise the need to travel and maximize use

of sustainable transport modes. The NPPF encourages maximization of

the accessibility of services, amenities and streets, and sustainable

transport for all.

Transport mitigation recommendations

5.10.3 Transport recommendation 1: Development should look to improve the

existing sustainable transport network and encourage behavioural

change to promote the use of sustainable transport.

5.10.4 Transport recommendation 2: To mitigate potential impacts on local and

national road networks, development should aim to be located near to

existing amenities and transport links, as well as including new amenities

and new sustainable transport links, particularly in larger developments.

5.11 SA Objective 10: Housing

Housing recommendations

5.11.1 Housing recommendation 1: Careful consideration should be given to

density, design and future proofing in terms of climate change and

potential expansion.

5.12 SA Objective 11: Health

Mitigation consideration (1) Limited accessibility to health and recreation facilities



5.12.1 Paragraph 156 of the NPPF states that the Local Plan’s strategic

priorities should deliver health, security, community and cultural

infrastructure and other local facilities. Some sites are further than the

recommended distances (Barton et al, 2010) from formal health and

recreation facilities. Such distances have been measured from the

centre of each site to represent the average distance residents or

workers would have to travel, although some would be nearer and some

would be further away.

Health mitigation recommendations

5.12.2 Health recommendation 1: Where health and recreation facilities are not

within the recommended distances, it may be possible to provide these

on site. Where this is not possible, facilities should be easily accessible

by sustainable modes of transport, e.g. via affordable, frequent bus

services.

5.13 SA Objective 12: Economy and employment

Mitigation consideration (1) Loss of existing businesses/accessible employment

5.13.1 Section 1 of the NPPF considers building a strong, competitive economy.

Paragraph 19 of the NPPF states that sustainable economic growth

should be supported. Local planning authorities should plan proactively

to meet the development needs of businesses and support an economy

fit for the 21st century. Paragraph 21 further states that local planning

authorities should set criteria for local and inward investment to match

the strategy and meet anticipated needs over the plan period.

5.13.2 Economy and employment mitigation recommendation

5.13.3 Economy and employment recommendation 1: If operating businesses

will be removed from the site, there should be suitable alternative

business premises nearby. Existing businesses could be given support in

finding new premises and moving over from one to the other.

5.13.4 Economy and employment recommendation 2: Access to employment

opportunities should be maximised by either providing employment

opportunities within a development, or by ensuring easy access to

employment elsewhere, via sustainable modes of transport.

5.14 SA Objective 13: Education

Mitigation consideration (1) Limited access to education and training opportunities



5.14.1 Paragraph 72 of the NPPF states that great importance is attached to

ensuring that a sufficient choice of school places is available to meet the

needs of existing and new communities. Local planning authorities

should take a proactive, positive and collaborative approach to meeting

this requirement, and to development that will widen choice in

education.

Education mitigation recommendation

5.14.2 Education recommendation 1: Existing schools could be given support in

expansion, alteration or finding new premises and moving over from one

to the other, if necessary. Sustainable transport should be promoted as

a safe and easy way to access educational facilities. This may require

improvements to road infrastructure to make it more pedestrian-friendly

or dedicated school transport services.



6 Conclusions and Next Steps

6.1 Conclusions

6.1.1 The Local Plan contains a comprehensive suite of policies, both relating

to places and to development management.

6.1.2 This assessment of site allocations found that the additional detail

provided regarding the anticipated development at the allocated sites

led to more positive assessment findings that had been found in the SA

of the Borough-Wide Options and Scenarios report. It was noted that

many of the previous recommendations have been taken on board.

6.1.3 Care will need to be taken at sites with low levels of accessibility to

ensure that the level of accessibility is suitable once the site has been

regenerated and there is every indication that this will be the case.

Flood risk is also an issue for certain areas of the borough, particularly at

Waltham Cross but again the site allocations acknowledge this and have

put in place a suitable approach to ensuring that the risk is managed.

6.1.4 The assessment of the development management policies identified

largely positive effects against the SA objectives. The breadth of policy

coverage would be expected to ensure that key sustainability issues for

the borough, such as development in the Green Belt, flood risk and

accessibility will be appropriately addressed.

6.1.5 A combined table containing the outcome of the assessments can be

found in Appendix B.

6.2 Next Steps

6.2.1 This report represents the latest stage of the SA process. This report

presents assessment results for the policies within the Regulation 18

Draft Local Plan Consultation Document, which this report should be

read alongside. The SA process will take on-board any comments on

this SA Report and use them during the next round of assessments for

the next iteration of the Plan.

6.2.2 Once finalised, the Plan will be subject to further SA, via the preparation

of an Environmental Report, also known as a full SA Report. This

Environmental Report will meet all of the legal requirements set out in

Annex I of the SEA Directive.

Appendix A: SA Framework

Appendix A, SEA Framework Page 1

Q1a

Will it preserve features of architectural or historic interest

and, where necessary, encourage their conservation

and renewal?

Q1b Will it preserve or enhance archaeological sites/remains?

Q1cWill it preserve or enhance the

setting of cultural heritage assets?

Q2a

Will it safeguard and enhance the character of the landscape and local distinctiveness and

identity?

Q2bWill it protect and enhance

visual amenity, including light and noise pollution?

Q2c Will it reuse degraded landscape/townscape?

Q2d

Will it compromise the purpose of the Green Belt e.g. will it lead to coalescence of settlements

and/or urban sprawl?

Q2eWill it protect and enhance the characteristics and setting of the Lee Valley Regional Park

• Broxbourne Landscape Character Assessment profile

• Tranquility rating of area

• Re-use of derelict buildings or re-use of buildings in a prominent location

• Impact of development on areas

within the Green Belt and/or Lee Valley Regional Park

Decision making criteria: Will the option/proposal…

2

Landscape: Protect, enhance and manage the character and appearance of the landscape and townscape, maintaining

and strengthening local distinctiveness and sense of

place.

1

Cultural heritage: Protect, enhance and manage sites,

features, areas and landscapes of archaeological, historical and

cultural heritage importance, their setting and significance.

• Number and type of features and areas of historic designations in the

borough

• Statutory and non-statutory sites in the Historic Environment Record (HER)

• Number of historic assets on the Heritage at Risk register

Broxbourne Local Plan SA Framework

Indicators (this list is not exhaustive)SEA Objective


Decision making criteria: Will the option/proposal… Indicators (this list is not exhaustive)SEA Objective

Q3a Will it protect and enhance biodiversity?

Q3b Will it contribute to habitat connectivity?

Q3c

Will it maintain and enhance sites designated for their

biodiversity or geodiversity interest and increase their area?

Q4aWill it help reduce the per capita carbon footprint of

Broxbourne?

Q4b

Will it encourage renewable energy generation or use of

energy from renewable sources?

• Number and diversity of European Protected Species, BAP species and

Section 41 species in the area.

• Area and condition of BAP priority habitats

• Area and condition of sites designated for biological and geological interest

• Proximity to public transport links

• Frequency of nearby public transport services

• Distance to local services and amenities

• Energy efficiency of buildings and transport

• Percentage of energy in the area generated from renewable sources

4Climate change mitigation:

Minimise the borough's contribution to climate change.

3Biodiversity and geodiversity: Protect, enhance and manage biodiversity and geodiversity.



Q5a Will it avoid development in areas at high risk of flooding?

Q5bWill it increase the area and

connectivity of Green Infrastructure?

Q5c

Will it promote use of technologies and techniques to adapt to the impacts of climate

change?

Q6a Will it utilise derelict, degraded and under-used land?

Q6bWill it lead to the loss of the

best and most versatile agricultural land?

Q6cWill it safeguard the Borough's minerals resources for future

use?

Q7a Will it maintain and improve air quality?

Q7b Will it maintain and enhance soil quality?

Q7c Will it maintain and improve water quality?

• Proximity to an AQMA

• Provision of Green Infrastructure

• Remediation of contaminated land

• Proximity to watercourses with poor quality status

• Percentage change in pollution incidents

• Re-use of previously developed land

• Area of best and most versatile agricultural land lost to development

• Area of Mineral Safeguarding Area(s) developed

7 Pollution: Reduce air, soil and water pollution.

Natural resources: Protect and conserve natural resources.6

Climate change adaptation: Plan for the anticipated levels

of climate change.

• Number of properties at risk of flooding

• Area of new greenspace created per capita

• Connectivity of GI

• Implementation of adaptive techniques, such as SUDS and passive

heating/cooling

5



Q8a Will it encourage recycling of waste and materials?

Q8bWill it minimise and where

possible eliminate generation of waste?

• Number and capacity of waste management facilities

• Reuse of recycled materials

• Distance to place of work

• Distance to local amenities and key services

• Distance to existing or proposed bus routes

• Frequency of bus services

• Proximityand connectivity of walking and cycling links

• Distance to train station

8

Waste: Reduce waste generation and disposal, and

promote the waste hierarchy of reduce, reuse, recycle/compost, energy recovery and disposal.

Q9a Will it reduce the need to travel?

Q9b

Will it provide adequate means of access by a range of

sustainable transport modes (i.e. walking/cycling/public

transport)?

9

Transport and accessibility: Improve the efficiency of

transport networks by increasing the proportion of travel by sustainable modes and by promoting policies which reduce the need to

travel.



Q10a

Will it provide a mix of good-quality housing, including

homes that are suitable for first-time buyers?

Q10bWill it reduce the number of households on the Housing

Register?

Q10cWill it ensure all groups have access to decent, appropriate

and affordable housing?

Q11aWill it improve access for all to health, leisure and recreational

facilities?

Q11bDoes is consider the needs of Broxbourne's growing elderly

population?

Q11cWill it improve access to areas

of open/green space in Broxbounre?

• Varied housing mix

• Percentage of dwellings delivered as affordable housing

• Travel time by public transport to nearest health centre and sports

facilities

• Provision of and accessibility of open accessible greenspace and GI

• Accessibility to sports facilities e.g. football pitches, playing fields, tennis

courts and leisure centres

10 Housing: Provide affordable, environmentally sound and good quality housing for all.

Health: Safeguard and improve community health, safety and

well being.11



Q12aWill it increase accessibility of suitable employment within

Broxbourne?

12bWill it support or encourage

diversification of the economy and new business sectors?

Q12c Will it encourage inward investment in the area?

13aWill it improve access for all to education and training opportunities?

13bWill it encourage a diversity of education and training opportunities?

• Number of residents working within Broxbourne

• Number of employment opportunities in professional occupations

• Number of new business start-ups as a result of the development

13

Education, skills and training: Raise educational attainment and develop and maintain a skilled workforce to support long-term competitiveness.

• Distance to education and training, particularly primary schools and

secondary schools

• Provision of new education and training facilites and oportunities

12

Economy: Develop a dynamic, diverse and knowledge-based

economy that excels in innovation with higher value,

lower impact activities.

Appendix B: Combined Assessment Results

1 2 3 4 5 6 7 8 9 10 11 12 13

Policy

Cultu

ral

herit

age

Land

scap

e

Biod

iversi

ty

C. C

hang

e

Mitig

ation

C. C

hang

e

adap

tatio

n

Natu

ral

reso

urce

s

Pollu

tion

Was

te

Trans

port

Hous

ing

Healt

h

Econ

omics

Educ

ation

Assessment of Places

DS1 +/- ++ ++ +/- +/- +/- +/- +/- ++ +++ +/- ++ ++

DS2 +/- +/- +/- +/- +/- +/- +/- +/- +/- +++ +/- +/- +/-

DS3

Hoddes

don 0 0 - ++ + ++ 0 0 ++ ++ + + ++

DS3

Cheshun

t -- 0 - ++ - ++ 0 0 ++ ++ - + ++

DS3

Goffs

Oak 0 0 - - + + 0 0 - + + 0 -

DS3

Waltha

m Cross

-- 0 - 0 +/- ++ -- 0 ++ ++ + + -

PM1 0 ++ 0 0 0 0 0 0 + 0 0 0 0

BR1 +/- -- -- - -- - +/- 0 - +++ 0 ++ ++

BX1 0 ++ + 0 + 0 0 0 0 0 0 0 0

BX2 +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/-

BX3 - -- - 0 + 0 0 0 + ++ ++ 0 +++

PP1 -- -- - 0 + -- +/- 0 ++ 0 0 +++ 0

PP2 - 0 - 0 + - +/- 0 ++ 0 0 ++ 0

PP3 - 0 0 0 0 - - 0 + 0 0 + 0

CH1 0 + +/- 0 +/- 0 - 0 +/- +++ + ++ ++

CH2 - -- - 0 + ++ 0 0 -- +++ + ++ ++

CH3 0 + 0 0 0 0 0 0 0 0 0 + 0

CH4 + + 0 0 0 0 0 0 0 0 0 + 0

CH5 - - - 0 + -- 0 0 + ++ ++ + +

CH6 0 + 0 0 0 0 0 0 0 0 0 0 0

CH7 -- - 0 0 + - 0 0 - + - 0 ++

CH8 0 + 0 0 0 0 0 0 0 +/- 0 +/- 0

CH9 0 - 0 0 0 0 0 0 - + - 0 +

GO1 0 + 0 0 0 0 0 0 0 0 0 + 0

GO2 - - - 0 + +/- 0 0 + + + +/- ++

GO3 + + - 0 + - 0 0 + + + + 0

GO4 - + - 0 + + 0 0 - + + 0 -

GO5 0 - - - + - - 0 - + + + -

GO6 0 - 0 0 0 0 0 0 ++ 0 + 0 ++

HOD1 ++ ++ 0 0 0 0 + 0 + 0 0 + 0

HOD2 +/- 0 - 0 -- + - 0 + + - 0 -

HOD3 - 0 0 0 + + 0 0 + + - - +

HOD4 0 0 0 0 0 0 0 0 0 0 0 +/- 0

HOD5 - - - 0 - - 0 0 + +++ + 0 +

HOD6 0 + + 0 0 0 0 0 0 0 0 0 0

WC1 0 + + 0 0 0 0 0 0 + 0 0 0

WC2 - 0 + 0 - 0 +/- 0 ++ +++ + - +

WC3 +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/-

WT1 +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/-

WT2 +/- + +/- 0 0 0 0 0 + 0 ++ 0 +

LV1 0 + + 0 0 0 0 0 0 0 + 0 0

LV2 0 0 0 0 ++ 0 0 0 0 0 ++ + 0

LV3 0 0 0 0 +/- 0 0 0 0 +/- 0 0 0

LV4 0 0 ++ 0 0 ++ 0 0 0 0 0 0 0

LV5 0 0 0 0 0 0 0 0 + 0 + 0 0

C1 +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/-

C2 0 0 + 0 0 0 0 0 0 0 + 0 0

NR1 +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/-

NR2 0 + + 0 0 0 0 0 ++ 0 ++ 0 0

GT1 0 + + 0 0 0 0 0 0 ++ 0 0 0

GT2 0 - - 0 0 - 0 0 0 + 0 0 0

INF1 0 0 0 0 0 0 + + + 0 ++ 0 +

INF2 0 0 0 + 0 0 + 0 ++ 0 0 + 0

INF3 +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/-

INF4 +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/-

INF5 0 0 0 0 0 0 0 0 + 0 +++ 0 0

INF6 0 0 0 0 0 0 + 0 ++ 0 0 0 0

INF7 0 0 0 0 0 0 + 0 ++ 0 ++ 0 0

INF8 0 0 0 0 0 0 + 0 ++ 0 ++ 0 0

INF9 -- -- -- 0 - -- 0 0 ++ 0 0 0 +++

INF10 0 0 0 0 0 0 0 0 + 0 0 0 +++

INF11 0 0 0 0 0 0 0 0 + 0 + 0 +

INF12 0 0 0 0 0 0 0 0 + 0 ++ 0 0

Development Management Policies

DSC1 ++ ++ ++ + ++ 0 0 ++ ++ 0 ++ + 0

DSC2 0 0 0 + 0 ++ 0 ++ 0 0 + 0 0

DSC3 0 + 0 0 0 0 0 0 0 0 ++ 0 0

DSC4 + + + + + + + + + + + + +

DSC5 0 ++ 0 0 0 0 0 0 0 0 0 + 0

H1 0 0 0 0 0 0 0 0 0 ++ 0 0 0

ED1 0 0 0 0 0 0 0 0 ++ 0 + ++ 0

ED2 0 0 0 0 0 0 0 0 0 0 0 + 0

ED3 0 0 ++ 0 0 0 0 0 0 0 ++ ++ 0

RTC1 0 + 0 0 0 0 0 0 + 0 0 + 0

RTC2 0 + 0 0 0 0 + 0 + 0 + + 0

RTC3 0 + 0 0 0 0 0 0 0 0 + + 0

RTC4 0 + 0 0 0 0 0 0 + 0 + 0 0

ORC1 0 0 + 0 0 0 0 0 + 0 ++ 0 0

ORC2 0 0 0 0 0 0 0 0 0 0 0 0 0

ORC3 0 + + 0 + 0 0 0 0 0 + 0 0

ORC4 0 + + 0 + 0 0 0 0 0 + 0 0

ORC5 0 0 0 0 0 0 0 0 + 0 + 0 0

ORC6 0 + 0 0 + 0 0 + + 0 + 0 0

W1 0 + ++ 0 ++ 0 + 0 0 0 0 0 0

W2 0 0 0 0 ++ 0 + 0 0 0 0 0 0

W3 0 0 0 0 + + 0 0 0 0 0 0 0

W4 0 + + + ++ + + 0 0 0 0 0 0

W5 0 0 0 0 ++ 0 0 0 0 0 0 0 0

GB1 0 ++ 0 0 0 0 0 0 0 0 0 0 0

GB2 0 + 0 0 + 0 0 0 0 + 0 0 0

GB3 0 + 0 0 0 0 0 0 0 0 0 ++ 0

GB4 +/- +/- +/- 0 +/- 0 0 0 +/- 0 0 ++ 0

GB5 0 0 0 0 0 0 0 0 0 0 0 0 0

NEB1 0 + ++ 0 + 0 0 0 0 0 ++ 0 0

NEB2 0 ++ ++ 0 + 0 0 0 0 0 + 0 0

NEB3 0 ++ ++ 0 0 0 0 0 0 0 + 0 0

NEB4 0 + ++ 0 0 0 0 0 0 0 0 0 0

EQ1 0 0 0 0 0 0 ++ 0 0 0 ++ 0 0

EQ2 0 + + 0 0 0 + 0 0 0 + 0 0

EQ3 0 0 0 0 0 0 + 0 0 0 + + 0

EQ4 0 0 0 0 0 0 ++ 0 0 0 + 0 0

EQ5 0 0 0 0 0 0 0 ++ 0 0 0 0 0

EQ6 0 0 0 0 0 ++ 0 0 0 0 0 0 0

HA1 ++ 0 0 0 0 0 0 0 0 0 0 0 0

HA2 ++ 0 0 0 0 0 0 0 0 0 0 0 0

HA3 ++ + 0 0 0 0 0 0 0 0 0 0 0

HA4 + 0 0 0 0 0 0 0 0 0 0 0 0

HA5 + 0 0 0 0 0 0 0 0 0 0 0 0

HA6 + 0 0 0 0 0 0 0 0 0 0 0 0

HA7 + 0 0 0 0 0 0 0 0 0 0 0 0

HA8 + 0 0 0 0 0 0 0 0 0 0 0 0

HA9 + + 0 0 0 0 0 0 0 0 0 0 0

HA10 ++ 0 0 0 0 0 0 0 0 0 0 0 0

HA11 ++ 0 0 0 0 0 0 0 0 0 0 0 0

HA12 ++ + 0 0 0 0 0 0 0 0 0 0 0

TM1 0 0 0 ++ 0 0 ++ 0 ++ 0 ++ 0 0

TM2 0 0 0 ++ 0 0 ++ 0 ++ 0 ++ 0 0

TM3 0 0 0 + 0 0 + 0 ++ 0 ++ 0 0

TM4 0 0 0 + 0 0 + 0 + 0 + 0 0

TM5 0 0 0 0 0 0 0 0 0 0 0 0 0

PO1 +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/-

PO2 +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/- +/-

© Lepus Consulting Ltd

1 Bath Street Cheltenham GL50 1YE

T: 01242 525222

E: [email protected]

www.lepusconsulting.com

CHELTENHAM

Lepus Consulting 1 Bath Street CheltenhamGloucestershire GL50 1YE

t: 01242 525222w: www.lepusconsulting.come: [email protected]