Examination of the Hatfield Local Plan

Council’s Statement - Stage 9 Hearing session

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

Settlement: Woolmer Green Policy Number: SADM 27 Site References: WGr3 Matter number: 1 Issues: Green Belt, Trees/Ecology, Sustainability, Infrastructure, Highways, Deliverability, Consultation with Neighbouring Authority. Question Numbers: 1 - 12

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Woolmer Green Matter 1 - Site WGr3, 52 London Road Although in Woolmer Green Parish, this proposal is effectively a southerly extension to the town of Knebworth. It would remove open land, formerly used as pasture, from the Green Belt. Its development was assessed as being likely to cause moderate harm to the Green Belt’s purposes. Considerations The site forms a part of the fragile gap between Knebworth and Woolmer Green. 1) Is there any objective basis on which the assessed Green Belt harm could be challenged, or the weight given to the findings reduced? Response: a) No, the Council considers that the overall assessment provided in the LUC Green Belt Study Stage 3 (March 2019 – EX99C ) of High harm (as parcel P3 ) is a sound interpretation of the contribution that this site makes to the purposes of the Green Belt. The study notes that the presence of the care home in the Green Belt to the south of this site weakens the distinction between settlement and countryside that would be provided by a revised Green Belt edge if this site were to be released for development. b) The Stage 3 study also considered releasing the northern half of the site; to both reduce the land required to be released from the Green Belt and to allow for the retention of the wooded area to the south. This sub-parcel P3b scenario was considered to reduce the harm to Moderate and it was considered that a degree of separation from the wider countryside and a stronger association with the settlement edge could be achieved. c) Nevertheless, the land between Knebworth and Woolmer Green is a fragile gap and any development in this area along the B197 would intrude into the intervening land. Although views through the land are limited due to tree cover to the south, the sense of separation between the two settlements and experience of travelling between them would be compromised by further development.

2) In this context, would there be any justification for built development extending any further south than the built development on the eastern side of London Road or that to the west of the railway? Welwyn Hatfield Response: a) No, any development which extended the settlement of Knebworth southwards towards Woolmer Green would encroach into the fragile gap between these settlements. b) The Green Gap Assessment 2019 ( EX160 ) notes that the narrowest gap between these settlements is 300m due to past expansion along the B197 and any further development would further erode the sense of separation between these settlements.

2 c) In 2016 this site was not considered suitable for allocation as a new Green Belt boundary in this location was considered to be weaker than the existing boundary and the development of the site would significantly reduce an existing fragile Green Belt gap between the villages of Knebworth and Woolmer Green. If this site was developed alongside WGr2 (land to the south of Monread Lodge Care home), then the gap between these villages would be completely eroded. This highlights how fragile and narrow this gap is, developing site WGr3 in any capacity and even if a woodland buffer was retained this would effectively extend Knebworth to the care home.

3) Should further appropriate screening be established in the southern part of the site to prevent further visual intrusion into the openness of the remaining Green Belt area to the south. Welwyn Hatfield Response: a) Yes, if the woodland in the southern half of the site was retained and extended with additional planting to form a boundary which would align with the existing built form of Knebworth, this would reduce inter-visibility between the settlements in this area by screening the development. This would result in a reduced development capacity of 25 dwellings, as noted in the Site Selection Background Paper 2019 (included in EX219B ). The site would then be contained by the railway line to the west, woodland to the south and B197/London Road to the east, making the site relatively well contained and the harm to the wider Green Belt would be reduced. b) However, visual intrusion would not necessarily be the greatest harm of releasing this site. As discussed in question 2, the development of this site would erode the sense of separation between these settlements considerably. When travelling between these settlements via the B197, the sense of separation is already limited and despite tree cover along the road the interruption of the care home already compromises this gap.

4) 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) It is considered that on any site there is a need to retain and protect trees. Any trees/hedges which surround the site need to be retained where possible and at planning application stage development would need to be informed by an assessment of the vegetation on/adjacent to the site, any loss of trees or hedges would need to be mitigated with replacement planting. If this site was to be allocated there would be a need to include a requirement in the policy criteria for the site.

5) What impact would the proposal have on ecological assets and to what extent could this be mitigated or compensated for? Welwyn Hatfield Response:

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a) The site is considered to have a low level of ecological sensitivity. There are no recognised ecological sites within the site boundary or adjoining/close to the site. Ecology have advised that there is potential for reptiles and birds on site and a phase 1 habitat survey would be required to assess habitat value prior to any development on site.

6) In the context of the site’s proximity to retail and community facilities and frequent public transport, is this a sustainable location for housing development? Welwyn Hatfield Response: a) Yes, this site is considered to be a sustainable location for development. The site adjoins the southern extent of Knebworth, a , but lies inside the Welwyn Hatfield borough boundary close to Woolmer Green. b) The village of Knebworth has a good range of facilities including a railway station, a primary school, doctors and dentists, a library, a range of shops, a village hall and several churches. Four residential sites have been proposed for development in the North Hertfordshire District Plan 2013-2031, along with completions and permissions this is expected to deliver over 700 new homes. The site is also within 1km of facilities and services in Woolmer Green which, as a small excluded village, is served by a limited number of local community facilities and village shops. The Entech House development (within 500m of site WGr3, as the crow flies) at Woolmer Green is also expected to deliver a new convenience shop. c) The site is within a straight line distance of 800m to Knebworth Train Station and within 400m of two bus stops with a regular service.

7) Are there any perceived infrastructure constraints that are incapable of resolution before the end of the plan period? Welwyn Hatfield Response: a) Foul Drainage: Thames Water indicated that the scale of development was likely to require upgrades to the wastewater network and phasing would need to be agreed. In the 2016 HELAA, deliverability was assessed at 6-10 years (within 5 years if wastewater upgrades could be designed and delivered early). b) Education : Education provision for Woolmer Green was discussed at the Stage 8 hearing session for housing site HS15 (WGr1), it was noted that the County Council Regulation 19 representation ( dlpps 2156 ) from October 2016 outlines the position of primary school education capacity for Woolmer Green when considering the proposed growth in the Draft Local Plan Proposed Submission 2016:

‘The Borough Council’s approach to development in Woolmer Green as outlined in Policy SADM27 is noted. Woolmer Green is within the Welwyn Primary Planning Area (PPA). Across the Welwyn PPA there is considered to be some limited existing capacity which could support the growth across Woolmer Green, Oaklands and Mardley Heath and Welwyn without the need to permanently expand existing

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schools. In the event that the yield could not be met in the existing schools there is assumed to be 1fe expansion potential at Welwyn St Mary’s VA C of E Primary.’ c) In January 2017 HCC also provided a Supplementary Education Statement ( TPA/5 Appendix 3 ) to confirming their position regarding allocated development as above. d) The Site Selection Background Paper 2019 (included in EX219B) considered any key infrastructure issues arising if this site was allocated alongside site HS15 (WGr1) and noted that the above provision of additional capacity within the PPA would provide capacity for this site. It was also noted that some additional capacity for the primary school planning area may also become available through the construction of a new 2FE primary school at Knebworth through the North Herts District Plan. This could be particularly relevant to for this site which would form a small extension to Knebworth. e) Woolmer Green is included in the Secondary Education Planning Area of alongside the villages of Oaklands and Mardley Heath and Welwyn. It is considered that provision would be made alongside the planned growth around Welwyn Garden City, to include the potential for expansion of 3.5fe at existing schools in Welwyn Garden City and the provision of a new secondary school at Birchall Garden Suburb (EWEL1 in East Herts District). f) Health : Existing health care provision for residents at Woolmer Green is located outside of the settlement at larger villages which support healthcare facilities for the wider area. It is likely that residents in this location at the edge of Knebworth would seek provision of GPs, Dentists and pharmacies within Knebworth. In line with Section 8 of the NPPF (2012), Policy SP13 of the Draft Local Plan notes that the Council will continue to work with its partners to address any existing deficiencies and secure appropriate levels of funding for necessary infrastructure.

8) Are there any issues affecting highway safety and/or the free flow of traffic along London Road that are incapable of satisfactory resolution? Welwyn Hatfield Response: a) No, The County Council as highway authority has not identified a ‘severe’ or ‘unacceptable’ impact on highway safety and has not objected to the development on highway grounds. The Council was advised that access is acceptable from London Road (B197), however, this would be subject to the design of a sufficient priority junction to allow for safe access into the site. 9) Have the ramifications of noise pollution from the adjacent railway, on the ability to create acceptable living conditions at this site, been appropriately assessed and to what extent would any mitigation impact on the capacity of the site? Welwyn Hatfield Response: a) This site was assessed as suitable for residential development in the HELAA 2016 (HOU/19 ). The HELAA notes the potential for noise and air pollution, due to the proximity of the railway and B197/London Road. The Council’s Environmental Health

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team provided advice as part of the plan making process and this was used to inform the assessment of site suitability. Environmental Health raised no in principle objections to the allocation of these sites. However, capacity of the site was moderated from 40dph to 30dph to allow for mitigation measures on site. At planning application stage both air quality and noise surveys/reports would be required to demonstrate that future occupants would not be adversely affected. Any applicant will need to demonstrate that appropriate design, layout and mitigation measures can deliver satisfactory internal and external residential environments.

10) Would the proposal clearly be deliverable within the first five years following adoption?

Welwyn Hatfield Response: a) In 2019, the promoter indicates delivery would be possible within 5 years. Delivery within 5 years (post adoption) would be consistent with the Council’s evidence for a development of this scale. However, Thames Water has advised of the likely to the need for upgrades to the wastewater network, which could delay delivery. Therefore it has been estimated that delivery of this site could be delivered beyond the first five years into year six.

11) Has any formal consultation with North Hertfordshire District Council been undertaken? If so, what is its opinion on this proposal?

Welwyn Hatfield Response:

a) The Council has engaged with North Hertfordshire District Council (NHDC) throughout the plan making process and through the selection of suitable sites. The representations received from NHDC has been taken into account when assessing sites in this area for potential allocation.

b) In 2016 this site was not considered suitable for allocation and so was not included in the Draft Local Plan Proposed Submission 2016 consultation. However, this site was included in the ‘Sites Promoted to the Council through the Call for Sites 2019’ consultation. NHDC did not provide any site specific comments but did provide a general comment to sites in Oaklands and Mardley Heath, Woolmer Green and Welwyn:

‘there are a number of issues which the District Council should be take into account in determining which of the 140 sites should be allocated in the emerging Local Plan. In particular, whether the necessary infrastructure and mitigation measures can be provided in the right location. As you will be aware, the North Hertfordshire Local Plan is at an advanced stage of preparation. The Infrastructure Delivery Plan for North Hertfordshire has been prepared in the context of the allocations in the Local Plan but does not take into account any additional development on the periphery of the adjoining authorities.

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Further development in Welwyn and Woolmer Green may have an impact on traffic, transport, health and education provision. The District Council would anticipate that additional work would be required to ensure that the impacts of development has been adequately assessed and that the appropriate mitigation is identified in the Welwyn Hatfield Local Plan.

We would ask that you have regard to the aims of the emerging North Hertfordshire Transport Strategy and the detailed policy wording included in our Plan (as proposed to be modified) in relation to infrastructure and cumulative impacts. In particular, we would highlight the policy criteria attached to our own proposed sites in and Knebworth. At this stage, we request that any sites pursued by Welwyn Hatfield in close proximity to these settlements seek to incorporate similar requirements and / or do not frustrate the implementation of sites within North Hertfordshire. ’ c) Site requirements for sites around Knebworth include the need for Transport Assessment to accompany development proposals in and around these villages to consider the cumulative impact of sites on village centres, key junctions, minor roads and rail crossings for all users and secure the necessary mitigation or improvement measures.

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

Welwyn Hatfield Response: a) The Council does not consider there to be any further considerations which weigh against the suitability of this site. b) As noted in responses the questions 1-3, the Council consider the impact of developing land between Knebworth and Woolmer Green outweighs the benefit of developing this site for 25 dwellings.

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