Cuf15 Matter Number: 9 Issues: Green Belt, Infrastructure, Ecology, Sustainability, Noise, Air Quality, Heritage, Delivery Question Numbers: 124-144

Examination of the Welwyn Hatfield Local Plan

Council’s Statement - Stage 9 Hearing session

Potential additional sites, for housing development, at villages excluded from the Green Belt

Settlement: Cuffley Policy Number: SADM33 Site References: Cuf15 Matter number: 9 Issues: Green Belt, Infrastructure, Ecology, Sustainability, Noise, Air Quality, Heritage, Delivery Question Numbers: 124-144

Cuffley Matter 9 - Site Cuf15 Land to the south-east of King George V playing fields. Cuffley The Settlement Strategy classifies Cuffley as a large excluded village. These locations are to be secondary foci for limited amounts of new development where this is compatible with the scale and character of the village and the maintenance of Green Belt boundaries. Development should be supported by appropriate infrastructure and the need to travel minimized. The proximity and frequency of public transport, including the location of railway stations are also important considerations?

Cuffley contains a sizeable local centre and a railway station with frequent services to London and Stevenage. However, it is some distance from most of Welwyn-Hatfield Borough and has greater commuting and socio-economic ties with areas that are not within Welwyn-Hatfield, than with most of the Borough.

In this context, is Cuffley an appropriate location within which to meet the parts of the Borough wide housing requirement that are not generated locally?

What would be an appropriate amount of new residential development to be provided at Cuffley?

Welwyn Hatfield Response: a) The settlement hierarchy taken from policy SP3 is summarised in the following table (excluding the new village of Symondshyde):

Settlement Hierarchy Settlements

Main Town Welwyn Garden City

Town Hatfield

Large Excluded Villages Welwyn, Welham Green, Brookmans Park, Cuffley

Small Excluded Villages Woolmer Green, Oaklands and Mardley Heath, Digswell, Little Heath

Green Belt Villages Lemsford, Essendon, Newgate Street, Northaw

Small Green Belt Villages Various b) Cuffley has a good village centre (39 units within the former A classes or similar uses), a mainline railway station, a primary school, playing fields, a number of community halls, a branch surgery and a range of employment opportunities. As a result it is in the third tier of settlements, below only Welwyn Garden City and Hatfield. Accordingly it is an appropriate location for development at a lower level than Hatfield, but more than the small excluded villages such as Digswell and Oaklands and Mardley Heath with their much narrower range of services and facilities. This general approach is of course subject to settlement character and

other constraints and green belt harm. c) As a starting point for analysis, Cuffley contains about 4% of the households in the Borough (2011 Census). Submitted allocations minus those proposed for deletion total 186 dwellings which represents 2.1% of the overall allocations now proposed. The number of commitments and completions since the start of the plan period comprise another 71 dwellings giving an overall total of 258 dwellings. This can be considered on the low side for its status in the hierarchy. However the Council considers that this is justified by minimising green belt harm as far as possible by locating sites in other sustainable settlements with lower green belt harm ratings. d) Primary school provision is a potential constraint. The County Council has advised that there is only sufficient capacity for 300 dwellings in Cuffley arising from the current educational infrastructure proposals for additional primary school capacity in Goffs Oak agreed with Broxbourne Council under the duty to cooperate.

Matter 9 – Site Cuf15, Land to the south-east of King George V playing fields.

The proposal would develop agricultural land to provide about 180 dwellings. The site’s development has been assessed as causing moderate-high harm to the Green Belt’s purposes.

Considerations

124) Is there any objective basis on which the assessed Green Belt harm could be challenged, or the weight given to the findings reduced?

Welwyn Hatfield Response: a) No, the Council considers that the overall assessment of Moderate-High harm is a sound interpretation of the contribution that this site makes to the purposes of the Green Belt. The Green Belt Assessment Stage 3 ( EX99) assessed the release of Parcel 88. The study found that:

The parcel is largely open and rural in character and its release would lead to encroachment on the countryside both within the parcel and on the surrounding Green Belt. It would reduce the perceived separation between the Tier 1 settlements of Cheshunt to the east and Potters Bar to the southwest. The Borough boundary along the eastern edge of the parcel has no distinct definition on the ground but the well-treed stream a little beyond it would form a clear boundary. b) Consultation was held in December 2018 on the consistency of the scorings and subdivision of parcels. The LUC Green Belt Report Final – Addendum ( EX99B ) includes the responses made in relation to the assessment of Parcel 7a. c) Several comments were made in relation to the release of parcel 88, as a whole. Including a representation stating that the assessment of harm is unjustified because the parcel uses the Borough boundary, which is not a defensible feature. The LUC response to this noted that the parcel boundary reflects the scope of the assessment, limited to the Borough. The response went on to state that this in no way invalidates the assessment of harm: parcel edges are not defined as potential Green Belt boundaries but to reflect variations in contribution to Green Belt purposes within the Borough, and the harm assessment does not assume that the Borough boundary would also constitute a revised Green Belt boundary. d) A concern was also raised questioning the justification for identifying areas of lower harm within the parcel. The representation made comparison with Parcel P3, which has higher harm ratings. In response LUC noted that there are stronger boundary features to contain releases in P88, and harm to settlement separation is less of a concern to the south of Cuffley than in the gap between Woolmer Green and Knebworth. e) It was suggested that the parcel straddles both sides of a railway line, which leads to a skewed assessment of contribution to Green Belt purposes. The LUC response stated that they do not see any need to define separate parcels wherever a significant boundary feature occurs; only if the feature marks a distinction in

contribution to Green Belt purposes. The methodology allows for subdivision of a parcel into separate harm scenarios, so if it was judged that the railway line would form a boundary that would result in a lower harm rating for the area contained by it, a scenario would be defined to reflect this. f) An alternative assessments was presented, with a subdivision into harm scenarios that suggest lower harm for Stage 2 sites Cuf3 and Cuf6. LUC noted that this does not raise consistency issues and they stand by the assessment for these parcels. g) The rating of Moderate-High harm did not change following the consultation. The Council considers the assessment of Moderate-High Harm to be robust and there are no exceptional circumstances to justify the sites removal from the Green Belt.

125) Could a permanent and robust boundary to the Green Belt be provided along the south-eastern boundary of this site?

Welwyn Hatfield Response: a) As recognised in the Green Belt Study Stage 3 (EX99C) the parcel, in which the site is located, the parcel makes a significant contribution to safeguarding the countryside from encroachment. The assessment states that The land contains the characteristics of open countryside, being predominantly uncontained and comprising of arable fields. With the exception of the school located adjacent to the urban area in the northeast, the railway line in the centre and floodlit pitches in the west, the parcel lacks urbanising development and is open b) The Council’s approach to the treatment of the Green Belt boundaries of allocations is outlined in the note of December 2020, EX223 . It states that as a rule, the tree- planting and other strategic landscaping needed to strengthen the green belt boundary will take place adjoining but outside the development allocation, and within the green belt. In other words, generally the green belt boundary would divide the landscaping from the built development. c) This site is not proposed for allocation. However, proposed GB boundaries were considered as part of the Site Selection Paper (included in EX219B). Figure 22.1 of the Site Selection Paper is a settlement map of Cuffley illustrating how a change to the Green Belt boundary could have looked in the event the site was selected for allocation. A copy of this plan is provided as Appendix One. As shown, the boundary follows the site boundary.

126) Would this boundary require strengthening by earth mounding and/or further planting?

Welwyn Hatfield Response: a) It is considered likely that new planting would be required to strengthen the southern boundary. The HELAA (included in EX219B) has lowered the density assumptions to 30dph to take into consideration site constraint. This includes land to the south within Flood Zones 2/3 along the path of the Hempshill and Northaw Brook. Through the sites masterplan planning on the southern boundary is considered achievable.

127) If so on which side of Northaw Brook should this be located?

Welwyn Hatfield Response: a) The Framework Plan submitted by the site’s promoter shows planting on land north of the Northaw Brook. 128) If this site is not allocated for development but the adjacent site to the north (HS28) is, would it be appropriate to remove this site from the Green Belt in order to safeguard it for development beyond the plan period?

Welwyn Hatfield Response: a) The Green Belt Study Stage 3 ( EX99C ) considers the release of Stage 2 site Cuf6 including Local Plan site HS28 (Parcel 88c). The conclusion is that the release of this parcel would cause a rating of Moderate harm. LUC state that the release of this parcel would ‘not extend the urban area of Cuffley further downslope to the south and therefore would not reduce the perceived separation between the Tier 1 settlements of Cheshunt to the east and Potters Bar to the southwest’. b) A defensible Green Belt boundary can be achieved on the southern boundary of the Local Plan site HS28. The Council does not consider Cuf15 is required be safeguarded to improve the long-term defensibility of Green Belt boundaries. c) The Council does not consider development of Cuf15 to be justified and there are no exceptional circumstances to alter the Green Belt in this location.

129) Are there any perceived infrastructure constraints that could delay the development of this site and/or are incapable of resolution before the end of the plan period?

Welwyn Hatfield Response: a) No. The Council does not consider that there are any infrastructure constraints that are incapable of resolution before the end of the plan period.

130) What impact would the proposed development have on ecological assets within or adjacent to the site and to what extent could this be mitigated or compensated for?

Welwyn Hatfield Response: a) The site is largely farmed agricultural land and therefore considered to be of low nature conservation interest. The HELAA 2019 assessment (included in EX219B) notes that ‘Due to the woodland habitats on the embankment to the east and potential for badgers, a Preliminary Ecological Assessment may be required at planning application stage.’ Also, while the site falls within an SSSI Impact Risk Zone, residential development in this location would not trigger a Natural England consultation.

131) Should some or all of the trees on the site be retained and their retention referred to in the policy criteria?

Welwyn Hatfield Response: a) There are no protected trees on the site. It is considered that policies SP9, SP10 and SADM 16, requiring proposals to maintain, protect and wherever possible enhance biodiversity, provide sufficient bases to ensure development of the site respects trees on the site.

132) In the context of the site’s proximity to retail and community facilities and frequent public transport; to what extent can this site be considered to be a sustainable location for development?

Welwyn Hatfield Response: a) Cuffley is categorised in Policy SP3: Settlement Hierarchy as a large excluded village. This applies to villages excluded from (not in) the Green Belt with large service centres, but a more limited range of employment opportunities and services than the two towns. Shops and facilities mainly serve the community needs of these villages and those living in surrounding rural areas. Accessibility to the main road network is good and they are served by rail and/or bus networks. The village is a secondary focus for new development where this is compatible with the scale and character of the village, and the maintenance of Green Belt boundaries. b) The site is located within:  400m of four bus stops  1km of Cuffley train station.  970m of Cuffley shops (Measured in a straight line “as the crow flies” from a median location on site)

133) What is the nature of the alleged flood risk and is it incapable of resolution through mitigation?

Welwyn Hatfield Response: a) The Strategic Flood Risk Assessment (SFRA, 2019)1 states that 90% of the site is within Flood Zone 1. Land along the southern edge of the site lies within Flood Zones 2/3 along the path of the Hempshill and Northaw Brooks.

b) It would be feasible to keep the footprint of development within Flood Zone 1 following a sequential approach to site layout. The areas within Flood Zones 2 and 3 (2.24ha) have been deducted when calculating the developable area of the site. A plan from the Level 1 and 2 Strategic Flood Risk Assessment 2016 ( ENV/10 ) is included as Appendix Two showing areas of Flood Zones 2 and 3. c) The southern part of the site is also subject to surface water flood risk, although much of this largely overlaps the Flood Zones 2 and 3. There is a lower (although extensive) risk of surface water flooding elsewhere within the site including along the path of a ditch. Surface water flood risk site could be suitably managed using Sustainable Drainage Systems (SuDS). A plan from the Level 1 and 2 Strategic Flood Risk Assessment 2016 ( ENV/10 ) showing surface water flood risk is included as Appendix Three.

134) Could noise or air pollution be an issue that precluded development at this site?

Welwyn Hatfield Response: a) As noted in the HELAA assessment of the site (included in EX219b) , the close proximity of the site to the railway (and also road traffic to the west) means that a noise survey and report is likely to be required at planning application stage to demonstrate that appropriate mitigation measures can deliver a residential development with a healthy internal and external living environment that satisfies the requirements of the local planning authority. b) The promoted capacity of the site was 240 dwellings on a 6ha developable area (40dph). The HELAA assessment lowered the density assumptions to 30dph to take into consideration site constraints including noise. The assessment resulted in the identified capacity of 176 (based on a developable area of 5.86ha and 30dph). c) Proposed allocation site HS28 (Cuf6) is on land to the north (discussed at the Stage 8 Hearing Sessions). An outline planning application has also been submitted for this site, (ref: S6/2015/1342/PP), which includes an acoustic survey and report. Environmental Health has considered this and has advised that at Cuf6, subject to mitigation to be secured through appropriate planning conditions, development can deliver a satisfactory environment to protect the residential amenity of the residents. d) Noise or air pollution are not considered factors that would preclude development at this site.

1 SFRA Site Summary Table available here: 3._Cuf15_L2_Table.pdf (welhat.gov.uk)

135) Would the odour emanating from the anaerobic digestion plant at Cattlegate Farm preclude development on some or all of the site?

Welwyn Hatfield Response: a) The Environment Agency advises the site is located within 250m of Cattlegate Farm Green Waste Composting Facility, they noted that the proximity of which could result in a residual impact from odours and bio-aerosol emissions although they note that this does depend upon the size of the facility, the way it is operated and prevailing weather conditions. The advice from the EA is that provided the operator takes reasonable precautions to mitigate odours, the facility and community can co-exist. b) Consent for the creation of a digestate storage lagoon by the anaerobic digestate plant was granted subject to planning condition by Hertfordshire County Council (ref: PL\0656\14) in June 2015. An Odour Impact Assessment was submitted and agreed by the Council at the time of the decision. It is required by planning condition that development takes place in accordance with the agreed plans and Odour Impact Assessment. c) The Council’s Environmental Health has not raised any air quality concerns at this plan-making stage which would affect the suitability of the site for allocation.

136) Should the location of high voltage power lines weigh against development on some or all of this site?

Welwyn Hatfield Response: a) The HELAA 2019 assessment of the site concluded that due to the presence of a 275kv HV overhead National Grid powerline which crosses the site, a 30m easement corridor either side of conductors has been deducted from the developable area, but this area could form a green corridor through the centre of the site. b) It is considered that while a site constraint, the power lines do not preclude development of the site. 137) Are there any issues affecting highway safety and/or the free flow of traffic along Northaw Road or within Cuffley more generally, that are incapable of satisfactory resolution?

Welwyn Hatfield Response: a) Hertfordshire County Council (HCC) as Highway Authority has not objected to the site. The Highway Authority has undertaken modelling and assessments and has advised the Council that development in the Cuffley area will not result in a severe impact. b) The Parish Council has commissioned consultants to conduct more localised junction modelling. However, the Highway Authority have raised concerns about how the model has been created and that the baseline model is not representative of real life. It is understood agreement between the Highway Authority and the Parish Council’s appointed consultant has not been reached.

9 c) The Highway Authority’s position that the development in the Cuffley area will not result in a severe impact remains. Therefore, the Council considers there to be no highway safety and/or traffic flow matters that are incapable of resolution during the plan period.

138) To what extent could development on the site harm heritage assets?

Welwyn Hatfield Response: a) There are no listed buildings on the site or immediately adjacent land. The site is also not in or adjacent to a Conservation Area. However, the Sustainability Appraisal (EX200 ) notes the site is between 250m and 1km of Cattlegate Farmhouse Grade II Listed Building and an area of archaeological significance. Historic England have not raised an objection to the site’s allocation.

139) Could any of this be significant?

Welwyn Hatfield Response: a) No. Based on the information available, the Council does not consider development of the site to cause significant harm to heritage assets. The Cattlegate Farmhouse Grade II Listed Building is approximately 900m to the south, as measured from the centre of the site. 140) Could any perceived harm be appropriately mitigated?

Welwyn Hatfield Response:

a) See response to Question 139.

141) Could there be any adverse impacts on archaeology resulting from the development of any of the sites?

Welwyn Hatfield Response: a) The HELAA 2019 assessment (included in EX219b ) notes the site is located entirely within AAS37. Hertfordshire County Council (HCC) has advised that a pre-application or pre-determination Archaeological Assessment would be required. b) As the site has not been subject to an objection from Hertfordshire Archaeology the Council considers that the approach outlined in paragraph 12.49 of the submitted Local Plan applies, which states that: Where proposals may affect remains of archaeological significance, or may be sited in an area of archaeological potential, developers will be required to undertake an archaeological assessment (if necessary, with a field evaluation). The scope of any programme of archaeological investigation should be agreed in consultation with the County Council’s Natural, Historic and Built Environment Advisory Team. A full report of this recording work and any findings should be submitted to the Local Planning Authority and the County Council Archaeological Advisor for approval before an application can be determined. (emphasis added)

c) This was the case for the development proposal on allocation site HS28 (Cuf6) to the north. The outline application included archaeological investigations and resulted in a response from Herts Archaeology noting that

“no significant heritage assets with archaeological interest were found and in this instance there did not appear to be any indication that the rest of the site could contain heritage assets with significance either”.

142) If so are they likely to be resolved through mitigation?

Welwyn Hatfield Response: a) If significant heritage assets with archaeological interest were found the scope of any mitigation would need to be informed by archaeological investigation and in agreement with Hertfordshire Archaeology. At this stage in the plan making process it is not considered that archaeology presents a ‘show stopping issue’. Also, as stated in response to earlier Questions, the site’s density has been reduced to allow for the constraints.

143) How many (if any) dwellings could be built on this site during the first five years following the plan’s adoption?

Welwyn Hatfield Response: a) It is considered that 50 dwellings could be delivered in the first five years of the plan period (year 5) with the remaining in years 6-7.

144) Are there any other matters that weigh against this site being proposed for residential development?

Welwyn Hatfield Response: a) The Council considers that the site’s constraints have been discussed in the preceding questions, and that the site’s overall assessment of Moderate-High harm to the Green Belt is sufficient in isolation for the non-inclusion of the sites within the Local Plan.

Appendix One

Appendix Two Extract from Level 1 and Level 2 Strategic Flood Risk Assessment (SFRA) Appendix C (EA Flood Zones)

Appendix Three Extract from Level 1 and Level 2 Strategic Flood Risk Assessment (SFRA) Appendix F (Surface Water Flood Maps)