The Greens, Hertford

Birch Green, Cole Green & Letty Green

Draft East Hertfordshire District Plan Preferred Options Consultation Representations on behalf of the Gascoyne Cecil Estates

These representations The representations have been prepared by support the identification JB Planning Associates of Birch Green, Cole Green (JBPA) on behalf of and Letty Green as Group the Gascoyne Cecil 2 Villages but recommend Estates (the Estate) in some amendments to the relation to the Preferred draft Plan to ensure that Options Consultation sufficient scope is retained on the emerging East to allow the villages to Hertfordshire District Plan remain sustainable and (the draft District Plan). vibrant communities.

May 2014 Historical Context

The Gascoyne Cecil Estates

The Estate has been at the Development will always be a New development does heart of local communities for contentious matter – change not have to be bad. Careful more than four hundred years, will always give rise to fears for planning and design can and continues to flourish in what the future might hold. The overcome many of the spite of the challenges that the Estates believe that change is shortcomings of more typical passage of time has brought. not only inevitable but in many housing developments. We To quote from the Gascoyne cases is desirable. However it believe that well-designed Cecil Estates prospectus: must take place in partnership urban extensions can be with local communities and a vital driver of prosperity “Estates cannot stand still; the Estates have worked hard and in turn assist in the nothing is more certain than in recent years to engage regeneration of other parts of terminal decline if preservation with communities and key our existing towns and villages. of the past outweighs the needs stakeholder partners. We of the present and future. The strongly believe that local Adopting a longer term vision Estates are managed on behalf communities should have and having a desire to remain of the Marquess of Salisbury their say in how towns and at the heart of our communities by Gascoyne Cecil Estates. villages might evolve. means we will listen to people’s aspirations and concerns While the challenges evolve, Release of farm land for and strive to achieve the best the ethos behind the Estates’ development will always be a possible results that build approach to management difficult decision. We believe, upon our own history.” remains constant: however, that where such development is necessary it is • To enhance our environment important to engage and lobby and secure the long- for the best possible standard term prosperity both of development. Thus, we will of the Estates and their ensure that the Estates remain extended communities. at the heart of any debate on future expansion of towns and • To preserve the best of what villages and that development we already hold, improving built on Estates land creates this with new homes, high- places of which people can quality public spaces and be proud and which provide thriving businesses – all sustainable communities for of which will provide many generations to come. employment and support to local communities for years to come.

2 The Three Greens, Hertford Representations to the emerging Birch Green, Cole Green & Letty Green East Hertfordshire District Plan R ive r M im ram Henry Wood

NG5855 0.35

Gascoyne Cecil Estates land ownership NG4537 13.88 surroundingPanshanger House the Three Villages Birchall Wood

High Grove

Chisel Shelf

NG6986 7.20

Hertingfordbury School Colegreen NG6458 House NG8760 Forge Cottage 0.28 4.50 Birch Green B NG6058 NG1659 IRC 0.40 HA 0.24 LL Cole Green LA Greater Captain's Wood NE NG8950 Garden Centre 0.17 Kit's Stockings NG5845 0.30 D NG6750 A NG6049 0.20 O 0.49 NG8749 R 45.63 NG9536 Howellpark Wood H NG1540 C 0.01 0.26 A O NG1740 C 0.20 D L NG6534 NG7530 O NG6029 6.36 E Munn's Farm 0.04 H NG8928 0.55 T Farthing Hall 0.11

NG0321 Labby Green 20.06 NG6918 NG1115 0.03 0.04 NG7612 NG2314 Cowper Arms NG9312 0.06 0.02 0.09 (PH) Maitland Wood

NG3704 0.28 Pumping NG3904 Balancing Station NG3803 NG4905 Pond NG6704 0.08 0.05 4.17 0.17 NG6601 S 4 T 1 0.45 A 4 T E I N A O LA h) N (Pat EL y R reen Wa AP Civic Cole G O H NG2188 A C Amenities D 14.84 Site

L M

E DEAD NG0670 Letty Green R FIEL S D LAN (T 0.08 E rack) L A Nursery N Piper's End E Orchard House Holwell Court Farm NG9458 The Elms 8.95

Woolmer's Park

The Three Greens, Hertford Representations to the emerging 3 Birch Green, Cole Green & Letty Green East Hertfordshire District Plan

Hatfield Park Estate Office, Hatfield House, Hatfield, Hertfordshire, AL9 5NF Tel: 01707 287000 Fax: 01707 275719

Land ownership – Cole Green, Birch Green, Letty Green

SCALE: DATE: 1:9000 28/06/2007

MAP FILE REFERENCE: Munns Farm pink.mpd Produced by Pear Technology Services Ltd www.peartechnology.co.uk [email protected] Based on Ordnance Survey 1:2500 Land-Line data with the permission of the Controller of HMSO ©Crown Copyright Strategic Context

East Hertfordshire District Plan

Housing Need

The draft District Plan states that the “evidence indicates” a need for 15,000 new homes between 2011 and 2031 – an average of 750 new homes a year (draft Policy DPS1). We understand that this figure is a rounding of the Government’s 2011 (as published in April 2013) population projection for the District of 14,716 new households (an increase from the 2008 population projection of 13,224 new households). In justifying the proposed Thus the true need for However, the housing use of the 15,000 new homes housing within the District requirement projections1 set out figure, the Council has stated2 could be up to 3,600 new in the Council’s latest Strategic that there is “no justifiable homes higher than is being Housing Market Assessment reason for not relying on such planned for by the Council. (SHMA) of March 2013 suggest official projections as a basis a need for between 16,900 and for informing planning for New Homes 18,600 new homes; notably housing and related policy SHMA 16,800–18,600 these figures are based on work”; however to do so would Draft Plan 15,000 the lower 2008 population be contrary to the NPPF (para. projections as opposed to 159), which requires that the the higher 2011 projections. need and demand for housing is also taken into account.

2. East Herts Council District Planning Executive Panel 25 July 2013 Report by Executive Member for Strategic Planning and Transport, Population 1. Excluding the Net Nil-Migration and Household Projections: household projection figure (xref NPPG). Update Report, Paragraph 2.20.

4 The Three Greens, Hertford Representations to the emerging Birch Green, Cole Green & Letty Green East Hertfordshire District Plan Housing Land Supply The National Planning Policy plan period would be reached Guidance (NPPG) supports with almost a whole years’ The Council estimates that (para. 35) the approach worth of housing (731 homes) during the first 5 years of the whereby a shortfall in housing having not been delivered. plan period (2011–2016), only supply is made up in the short- 2,654 new homes will have term, usually over the course The NPPF also requires been built instead of the 3,750 of the next 5 years. Despite this, an “additional buffer of 5% required (5 × 750) – a shortfall the Council is proposing that (moved forward from later of 1,096 homes; the Council has the shortfall be made up over in the plan period) to ensure not provided any calculation to the course of the remaining choice and competition in support the 2,654 figure. Indeed, 15 years of the plan period (i.e. the market for land” – in this the Council’s latest (February 2016-2031), the only apparent case an additional 188 homes 2014) Annual Monitoring justification being that “it is (3,750 × 5%). (The Council Report (AMR) predicts that not realistic” to expect the erroneously (para. 3.3.6) applies only 2,341 homes will be proposed sites to contribute this 5% buffer to the 5 year delivered between 2011 and to reducing the shortfall in the requirement plus the shortfall 2016; if so, then the shortfall first 5 years (in fact the Council suggested by it rather than just will be 1,409 rather than 1,096 is referring to the second 5 to the 5 year requirement.) as stated in the draft Plan. years of the plan period (2016– 2021), or effectively the first half The Council thus proposes that The National Planning Policy of the plan period (2011-2021)). the District Plan provide for a Framework (NPPF) requires The Council therefore proposes total of 4,321 homes during the (para. 47) that local planning that the shortfall of 1,096 period 2016–2021, whereas the authorities should “identify homes (assuming that this is figure should be 5,034 homes and update annually a supply the shortfall rather than 1,409 (3,750 + 188 + 1,096) or 5,347 of specific deliverable sites homes mentioned above) be (3,750 + 188 + 1,409). Indeed, if sufficient to provide 5 years’ made up at a rate of 73.1 homes the overall need for housing is worth of housing” – in this case (1,096 / 15) per year over the as suggested by the Council’s sufficient land for 3,750 homes. remaining 15 years of the plan SHMA, then assuming the period rather than an average additional requirement is of 219.2 homes (1,096 / 5) per distributed over the remainder year if this same shortfall is to of the plan period (2016–2031), be made up within the first 5 the requirement for the period years. If this approach were to 2016–2021 could be as high be confirmed, then assuming as 6,547. The draft District that 823 homes (750 + 73) per Plan proposes delivery of year are delivered between 2016 just 4,423 new homes. and 2021, the mid-point of the

The Three Greens, Hertford Representations to the emerging 5 Birch Green, Cole Green & Letty Green East Hertfordshire District Plan DEVELOPMENT Development will always be a contentious matter – change will always give Put simply we believe that; AND THE BUILT rise to fears for what the future might hold. Gascoyne Cecil Estates believes ENVIRONMENT that change is not only inevitable but in many cases is desirable. However it Neighbourhoods should include a mix of uses, including businesses and shops. must take place in partnership with local communities and Gascoyne Cecil Businesses and civic spaces should be located in close proximity. Estates have worked hard in recent years to engage with communities and key stakeholder partners Streets should be designed to be attractive, to encourage pedestrians with lively ground floor retail and ample civic spaces. DEVELOPMENT Development will always be a contentious matter – change will always give HERTFORDSHIRE WePut stronglysimply we believe believe that that; local communities should have their say in how towns DEVELOPMENT Development will always be a contentious matter – change will always give Put simply we believe that; AND THE BUILT GUIDE TO GROWTH–2021 rise to fears for what the future might hold. Gascoyne Cecil Estates believes HOW SHOULD THE COUNTY GROW? AND THEand BUILT villages might evolve. rise to fears for what the future might hold. Gascoyne Cecil Estates believes Housing should be provided to suit a range of incomes and ages, with units in a ENVIRONMENT rise to fears for what the future might hold. Gascoyne Cecil Estates believes that change is not only inevitable but in many cases is desirable. However it ENVIRONMENTNeighbourhoods should include a mix of uses, including businesses and shops. that change is not only inevitable but in many cases is desirable. However it range of sizes. Neighbourhoods should include a mix of uses, including businesses and shops. must take place in partnership with local communities and Gascoyne Cecil HertfordshireBusinesses and is civic of course spaces blessed should with be located many fine in close buildings proximity. and the early Garden must take place in partnership with local communities and Gascoyne Cecil Businesses and civic spaces should be located in close proximity. Estates have worked hard in recent years to engage with communities and key Cities of Letchworth and WelwynEstates Garden have City. worked Most hard people in recentwill accept years that to theengage with communities and key Thoroughfares and footpaths should connect well with a wider network, stakeholder partners laterStreets new should towns be and designed the development to be attractive, that cameto encourage with them pedestrians have in many with caseslively DRAFT stakeholder partners designed to provide numerous Streetsentry and should exit be points designed whilst to facilitatingbe attractive, smooth to encourage pedestrians with lively failedground to floor enhance retail the and lives ample of those civic whospaces. live or work there. traffic flows. ground floor retail and ample civic spaces. HERTFORDSHIRE We strongly believe that local communities should have their say in how towns HERTFORDSHIREDevelopment will always be aWe contentious strongly believe matter that – changelocal communities will always should give have their say in how towns GUIDE TO GROWTH–2021 DEVELOPMENT GUIDE TO GROWTH–2021 Put simply we believe that; HOW SHOULD THE COUNTY GROW? and villages might evolve. GUIDE TO GROWTH–2021RecentHousing years should have be seenprovided Gascoyne to suit Cecil a range Estates of incomes produce and design ages, withcodes units for inits’ a Neighbourhoods should feature discernible centres, well connected to greater AND THE BUILT HOW SHOULD THE riseCOUNTY to GROW?fears for what the futureand might villages hold. might Gascoyne evolve. Cecil Estates believes Housing should be provided to suit a range of incomes and ages, with units in a ENVIRONMENT corerange estatesof sizes. in an attempt to communicate its’ wider vision. We place great regional public transit networks. that change is not only inevitable but in many cases is desirable. However it Neighbourhoods should includerange a mix of ofsizes. uses, including businesses and shops. Hertfordshire is of course blessed with many fine buildings and the early Garden emphasis on the quality of designHertfordshire and materials, is of courselandscaping blessed and with attention many fineto buildings and the early Garden must take place in partnershipHertfordshire with local communities is of course blessed and Gascoyne with many Cecil fine buildings and the early Garden Businesses and civic spaces should be located in close proximity. Cities of Letchworth and Welwyn Garden City. Most people will accept that the detail.Thoroughfares Most importantly and footpaths of all we shouldbelieve that connect developments well with should a wider enjoy network, a sense Architectural styles should reflect local topography, history, building styles and Estates have worked hard in recentCities years of Letchworth to engage andwith Welwyn communities Garden and City. key Most people will accept that the Thoroughfares and footpaths should connect well with a wider network, later new towns and the development that came with them have in many cases DRAFT ofdesigned place and to beprovide pleasurable numerous locations entry in and which exit people points canwhilst enjoy facilitating their lives. smooth practices. DRAFT later new towns and the development that came with them have in many cases designed to provide numerous entry and exit points whilst facilitating smooth DRAFT stakeholder partners later new towns and the development that came with them have in many cases Streets should be designed to bedesigned attractive, to toprovide encourage numerous pedestrians entry andwith exit lively points whilst facilitating smooth failed to enhance the lives of those who live or work there. traffic flows. failed to enhance the lives of those who live or work there. failed to enhance the lives of those who live or work there. ground floor retail and ample civictraffic spaces. flows. In short, the draft District Plan Since 2006, Gascoyne Cecil Estates have sponsored and led three architectural Since the original charrette, Gascoyne Cecil Estates has worked tirelessly with does not appear to provide HERTFORDSHIRE We strongly believe that local communities should have their say in how towns Recent years have seen Gascoyne Cecil Estates produce design codes for its’ for sufficient housing to be GUIDE TO GROWTH–2021 charrettes.Neighbourhoods The first, should under feature Recentthe discernible auspices years centres,have of seen wellthe Gascoyne connectedUniversity Cecil to of greaterEstates Hertfordshire, produce design codes for its’ the local community and partnersNeighbourhoods to deliver the should vision feature for Old discernible Hatfield. centres,Two well connected to greater delivered either during the HOW SHOULD THE COUNTY GROW? and villages might evolve. Recent years have seen Gascoyne Cecil Estates produce design codes for its’ Housing should be provided to Neighbourhoodssuit a range of incomes should andfeature ages, discernible with units centres,in a well connected to greater core estates in an attempt to communicate its’ wider vision. We place great examinedregional public options transit for thenetworks. principles of future development in Hertfordshire. remainder of the plan period, core estates in an attempt to communicate its’ wider vision. We place great phases of housing have already beenregional completed public transitand major networks. investment in a heavily or during the next 5 years. range of sizes. emphasis on the quality of design and materials, landscaping and attention to The second and third took specific examples, Old Hatfield and the neighbouring revised bus and rail interchange has commenced. A comprehensive scheme of Hertfordshire is of course blessedemphasis with many on thefine quality buildings of designand the andearly materials, Garden landscaping and attention to Village Housing detail. Most importantly of all we believe that developments should enjoy a sense hamletArchitectural of Mill stylesGreen. should reflectdetail. local Most topography, importantly history, of all we building believe styles that developments and should enjoy a sense reconstruction and refurbishment for Salisbury Square is also fully approved and Cities of Letchworth and Welwyndetail. Garden Most City. importantly Most people of all willwe believeaccept that developmentsthe should enjoy a sense Thoroughfares and footpaths Architectural should connect styles well should with reflect a wider local network, topography, history, building styles and of place and be pleasurable locations in which people can enjoy theirNotably, lives. the District Plan practices. of place and be pleasurable locations in which people can enjoy their lives. awaiting its turn in the overall programme.practices. Development Strategy (draft DRAFT later new towns and the development that came with them have in many cases designed to provide numerous practices.entry and exit points whilst facilitating smooth Policy DPS2) references (at part VII) development coming failed to enhance the lives of those who live or work there. traffic flows. Since 2006, Gascoyne Cecil Estates have sponsored and led three architectural Since the original charrette, Gascoyne Cecil Estates has worked tirelessly with Development will always be a contentiousforward from matterwithin Group – change will always give Since 2006, Gascoyne Cecil Estates have sponsored and led three architectural Since the original charrette, Gascoyne Cecil Estates has worked tirelessly with DEVELOPMENT 1 villages (draft Policy VILL1) Put simply we believe that; charrettes. The first, under the auspices of the University of Hertfordshire, the local community and partnerscharrettes. to deliver The the first, vision under for Old the Hatfield. auspices Two of the University of Hertfordshire, AND THE BUILT rise to fears for what the future butmight fails hold. to reference Gascoyne any Cecil Estates believes Recent years have seen Gascoynecharrettes. Cecil Estates The first, produce under design the codes auspices for its’ of the University of Hertfordshire, Neighbourhoods should featurethe discernible local community centres, andwell partnersconnected to to deliver greater the vision for Old Hatfield. Two development coming forward ENVIRONMENTexamined options for the principles of future development in Hertfordshire. phases of housing have already beenexamined completed options and for major the principlesinvestment of in future a heavily development in Hertfordshire. that change is not only inevitablewithin but in Group many 2 villagescases is as desirable. However it core estates in an attempt to examinedNeighbourhoods communicate options its’ shouldfor wider the include vision.principles We a mix ofplace future of uses, great development including businesses in Hertfordshire. and shops. regional public transit networks.phases of housing have already been completed and major investment in a heavily The second and third took specific examples, Old Hatfield and theprovided neighbouring for within the draft revised bus and rail interchangeThe has second commenced. and third A tookcomprehensive specific examples, scheme ofOld Hatfield and the neighbouring must take place in partnership withPlan (draft local Policy communities VILL2) and Gascoyne Cecil emphasis on the quality of designTheBusinesses andsecond materials, andand civicthird landscaping spaces took specific should and beattentionexamples, located toinOld close Hatfield proximity. and the neighbouring revised bus and rail interchange has commenced. A comprehensive scheme of hamlet of Mill Green. despite the Plan making reconstruction and refurbishmenthamlet for Salisburyof Mill Green. Square is also fully approved and reconstruction and refurbishment for Salisbury Square is also fully approved and Estates have worked hard in recentclear years (para. to 3.3.10) engage that with the communities and key detail. Most importantly of all wehamlet believe of that Mill developments Green. should enjoy a sense Architectural styles should reflectreconstruction local topography, and refurbishment history, building for Salisbury styles and Square is also fully approved and awaiting its turn in the overall programme. stakeholder partners windfall allowance (of which awaiting its turn in the overall programme. development within Group of place and be pleasurable locationsStreets in shouldwhich peoplebe designed can enjoy to be their attractive, lives. to encourage pedestrians with lively practices. 2 villages would form part) ground floor retail and ample civic spaces. is one of the ways in which HERTFORDSHIRE We strongly believe that local communitiesthe Council should proposes have that their say in how towns Since 2006, Gascoyne Cecil Estates have sponsored and led three architectural Since the original charrette, Gascoyne Cecil Estates has worked tirelessly with GUIDE TO GROWTH–2021 its’ 15,000 home target (part 1 HOW SHOULD THE COUNTY GROW? and villages might evolve. of Policy DPS2) will be met. charrettes. The first, under Housingthe auspices should beof provided the University to suit a range of Hertfordshire,of incomes and ages, with units in a the local community and partners to deliver the vision for Old Hatfield. Two examined options for the principlesrange of of future sizes. development in Hertfordshire. phases of housing have already been completed and major investment in a heavily Hertfordshire is of course blessed with many fine buildings and the early Garden The second and third took specific examples, Old Hatfield and the neighbouring revised bus and rail interchange has commenced. A comprehensive scheme of Cities of Letchworth and Welwyn Garden City. Most people will accept that the hamlet of Mill Green. Thoroughfares and footpaths should connect well with a wider network, reconstruction and refurbishment for Salisbury Square is also fully approved and

DRAFT later new towns and the development that came with them have in many cases designed to provide numerous entry and exit points whilst facilitating smooth awaiting its turn in the overall programme. failed to enhance the lives of those who live or work there. traffic flows.

Recent years have seen Gascoyne Cecil Estates produce design codes for its’ Neighbourhoods should feature discernible centres, well connected to greater 6 The Three Greens, Hertford Representations to the emerging core estates in an attempt to communicateBirch Green, Cole its’ Green wider & Letty vision. Green WeEast place Hertfordshire great District Plan regional public transit networks. emphasis on the quality of design and materials, landscaping and attention to detail. Most importantly of all we believe that developments should enjoy a sense Architectural styles should reflect local topography, history, building styles and of place and be pleasurable locations in which people can enjoy their lives. practices.

Since 2006, Gascoyne Cecil Estates have sponsored and led three architectural Since the original charrette, Gascoyne Cecil Estates has worked tirelessly with charrettes. The first, under the auspices of the University of Hertfordshire, the local community and partners to deliver the vision for Old Hatfield. Two examined options for the principles of future development in Hertfordshire. phases of housing have already been completed and major investment in a heavily The second and third took specific examples, Old Hatfield and the neighbouring revised bus and rail interchange has commenced. A comprehensive scheme of hamlet of Mill Green. reconstruction and refurbishment for Salisbury Square is also fully approved and awaiting its turn in the overall programme. Policy Context

East Hertfordshire District Plan

General Principles We generally concur with the assessment of the three The inclusion of the three villages as contained within villages as within Group 2 is the Council’s ‘Strategy welcomed – previously all Supporting Document’ (insert three villages were categorised ref) (Sieve 1: Areas 26, 30 and as Group 3, which prevented 43 – sections 4.9.5, 4.5.9 and any new housing (except 4.5.22) but would highlight a rural exception site affordable few points on which we differ: housing) or employment or social / community facilities • Whilst the Council states that from being developed Birch Green and Cole Green and thereby threatened do not have good access to to undermine the villages’ bus or rail services, both sustainability and vitality. are served by bus route 388 between Hertford and Welwyn Group 2 villages are described Garden City, which provides in Section 6 of the Strategy a connection to railway and Supporting Document as being bus stations within both “generally smaller villages with towns; Letty Green is served some services and facilities but on a less frequent basis by bus often without a primary school route 380 (as is Birch Green). [where] infill development may be appropriate … to support • Whilst the Council states existing facilities and services”. that Birch Green suffers In this context, in relation to from limited employment the three villages, the Council opportunities due to the lack concluded that “some limited of access to the main road infill development … would (taken as being the A414), not be inappropriate and could there are a number of existing assist with meeting local needs”. employers operating within the village (refer to page 14 of these representations) providing a range of existing employment opportunities, this despite a constraint over the previous decade on new employment development.

The Three Greens, Hertford Representations to the emerging 7 Birch Green, Cole Green & Letty Green East Hertfordshire District Plan We concur that the introduction of new development into can contribute to this by bringing new life to these established societies helping to sustain existing services and potentially generating custom for new facilities. Arguably, opportunities exist whereby one can strengthen provision of community facilities, • Whilst the Council states that We support the Council’s employment or housing apart from the Cowper Arms reasonable conclusion (Strategy provision in a sympathetic and Public House “there are no Supporting Document para complimentary manner. It is community facilities within 4.9.39.5) that, despite a shortage recognised that sympathetic Cole Green, nor the cluster of of services and facilities within development requires a villages of which it is a part”, villages across the District, detailed approach to design and makes a similar statement which might by some measures and construction, and close in relation to Letty Green of sustainability lead one to cooperation with existing without referencing the pub, conclude that that the villages communities, points which across the three villages there are unsustainable locations for are already advocated through are in fact 5 of the 11 types development, many villages Gascoyne Cecil Estates Design of facility identified by the are vibrant communities Codes (submitted alongside Council as being ‘community with a full and active social these representations). facilities’(Strategy Supporting calendar supporting vital Document para 3.18.4) – in local and rural enterprises, We also support the Council’s addition to the pub there is the proximity of Cole Green recognition (Strategy Supporting a children’s playground, a Way and access to primary Document para 4.9.39.8) that nursery / pre-school, playing education and public transport there are “instances where field (and accessible woodland) leading to a conclusion settlements have strong inter- and the primary school, plus that the Three Villages are relationships because of their both Birch Green and Letty more sustainable that they close proximity, despite not Green are served by the might at first appear to be. being immediately adjacent mobile library (libraries are to each other” and that the not listed by the Council as concept of clusters of villages a ‘community facility’). that share services and/or facilities needs to be recognised.

8 The Three Greens, Hertford Representations to the emerging Birch Green, Cole Green & Letty Green East Hertfordshire District Plan Policy Context

East Hertfordshire District Plan

Infill Development However, we object to the We note that guidance within narrow definition of limited the 2007 Local Plan defines We support the principle, as infill development (part II of infill development as “the set out within draft Policy draft Policy VILL2, and para. erection of up to five small VILL2, of allowing limited 10.2.5) that limits new housing dwellings”. However, it is infill development, limited development to five homes on important to recognise that affordable housing for local any particular site. No specific the 2007 Local Plan Inspector community identified needs, justification has been provided noted in his assessment of and the provision of small- as to why the Council considers the 2007 Local Plan that the scale employment, leisure, that a development of more definition was “for guidance recreation and community than five dwellings could not only and therefore provides facilities within Group 2 be considered as appropriate for flexibility”. Furthermore, villages where supported by limited infilling. The NPPF does the 2007 Local Plan Inspector the local community. Such an not define or provide guidance found that the definition was approach will ensure that the on what limited infilling in necessary in order to provide overall sustainability of these villages should be regarded as more flexibility for infill settlements can be improved constituting, and thus national development than a narrower and should also assist in policy is deliberately vague, definition which would meeting local needs for both allowing interpretation by construe infill development as market and affordable housing. decision makers taking account relating solely to a small gap of specific local circumstances. in an otherwise built frontage.

On a recent planning appeal The definition within the 2007 (APP/J1915/A/13/2205070) Local Plan thus permitted concerning a site within the larger development within District at Brickendon Green, Category 1 and 2 villages than an Inspector concluded that would have been permitted by the question of what “limited a narrower interpretation of infilling in villages” should infill development. Importantly, mean “is a matter of planning the 2007 Local Plan Inspector judgement for the decision did not comment on the maker”. The Inspector in that “up to five small dwellings” case took a broad view of wording, or in any way what limited infilling could suggest that a development constitute, and concluded of more than five dwellings that the underlying intention could not be regarded as of restricting development in appropriate infill development. villages to limited infilling was to avoid harm to the character and appearance of the village.

The Three Greens, Hertford Representations to the emerging 9 Birch Green, Cole Green & Letty Green East Hertfordshire District Plan Notably, given the need to Aside from the fact that a limit boost significantly the supply on the number of dwellings of housing and meet housing allowed on any particular site needs, as required by the NPPF as limited infill development (para. 47), and the requirement is both inappropriate to “optimise the potential and unjustified, it is also of the site to accommodate unnecessary. Collectively, the development” (para. 58), it criteria in part III of draft Policy would appear illogical and VILL2 requires development to contrary to national policy to be of a scale appropriate to the In light of the comments of the limit infill development to five size of the village, relate well to 2007 Local Plan Inspector and dwellings if a site was capable the village in terms of location, the recent appeal decision at of accommodating six or more layout and connectivity, and so Brickendon Green, we consider dwellings in an acceptable on. Such requirements on their it reasonable to conclude that manner; such a limitation own should effectively ensure infill development in excess would also be contrary to that any proposals for infill of five dwellings could be draft District Plan Policy HOU2, development will be of a limited considered as both limited and which requires development scale and thus we consider appropriate in certain contexts to make efficient use of land. it unnecessary to impose a where it would not have an In short, we consider that it is maximum number of dwellings unduly harmful impact on unreasonable to restrict infill across the board, regardless the character and appearance development to a maximum of of local circumstances. of the village. For example, five dwellings on any individual a particularly large or well site, particularly given the Given the above, we consider enclosed site may conceivably shortfall in housing delivery to that the limitation of infill be developed for more than five date and the lack of sufficient development to no more than dwellings whilst not having a provision for housing in the 5 new homes on any particular harmful impact on the character draft District Plan in general. site within Group 2 villages and appearance of the village. is unjustified, inconsistent with the NPPF and thus unsound (NPPF para. 182).

10 The Three Greens, Hertford Representations to the emerging Birch Green, Cole Green & Letty Green East Hertfordshire District Plan Policy Context

East Hertfordshire District Plan

Village Boundaries In undertaking this assessment On this basis, we have to the Council considered the question why the Council The draft District Plan potential for each village to considers itself able to proposes, for the first time (as grow by up to 10% (at 30 propose definitive village compared to the 2007 Local dph) – in relation to the three boundaries, when there is Plan), that Group 2 villages be villages the Council has thus a distinct possibility (as yet encompassed within a village considered the scope for an unbeknownst to the Council boundary described in the Plan additional 9 new homes at due to its SLAA not yet having as the “built-up area” of the Birch Green, 2 new homes at assessed sites around Group village. The draft Plan clarifies Cole Green and 8 new homes 2 villages) that the only sites that the village boundaries at Letty Green. However, the that might come forward for have “generally been defined Council has not published any development at villages might by the current outer extent of information on which potential be, even only slightly, outside the built-up area of villages”. sites it considered in this regard, the boundaries and thus However, in most cases, these or whether these were located for this reason alone, would boundaries have been prepared within the village boundary as then have to be considered with no apparent consistency now proposed, or elsewhere. unacceptable even were they and limited regard to the true to otherwise satisfy the criteria extent of the village as detailed As with the proposed definition of part III of draft Policy VILL2. later in these representations. of ‘limited infill development’, we consider that the proposed In short, there is currently a In preparing the draft Plan definition of village boundaries complete lack of justification the Council assessed various is inappropriate, unjustified for the village boundaries, not ‘areas of search’ and in doing and unnecessary. Collectively, to mention a complete lack so considered whether these the criteria in part III of Policy of evidence to support the areas had a ‘clear boundary’ VILL2 requires development to proposed boundaries as defined. (insert ref); however the areas be of a scale appropriate to the of search were materially larger size of the village, relate well to than the actual extent of the the village in terms of location, existing village and thus cannot layout and connectivity, and be used as village boundaries. so on. Such requirements on their own should effectively ensure that any proposals for infill development will be on an appropriate site and thus we consider it unnecessary to seek to artificially define a village boundary, regardless of contextual circumstance.

The Three Greens, Hertford Representations to the emerging 11 Birch Green, Cole Green & Letty Green East Hertfordshire District Plan RESIDENTIAL UNITS BREAKDOWN COLE GREEN SITE PLAN USE FIGURED DIMENSIONS ONLY DO NOT SCALE FROM THIS DRAWING. RESIDENTIAL UNIT BREAKDOWN 1 Bedroom (17%): 6 units Gascoyne Cecil Estates proposal ALL DIMENSIONS MUST BE CHECKED ON SITE ANY - Site area: 2.82 hectares (ha) INCONSISTENCIES MUST BE REPORTED BACK TO THE ARCHITECT. - 25 new housing units THIS DRAWING AND ANY DESIGNS INDICATED THEREON ARE THE COPYRIGHT OF BROOKS / MURRAY ARCHITECTS. - Site density: 8.86 units/ha ALL RIGHTS ARE RESERVED. NO PART OF THIS WORK MAY BE PRODUCED WITHOUT PRIOR PERMISSION IN WRITING FROM BROOKS / MURRAY ARCHITECTS. Cole Green Works - Site area: 0.67 hectares (ha) - 9 additional housing units - Site density: 13.43 units/ha

Combined - Site area: 3.49 hectares (ha) - 34 housing units 1B - Type E 1B - Type K - Site density: 9.74 units/ha - 2 No. proposed - 3 No. proposed Site boundary added - 2.5 storeys - 2 storeys B 2013.11.11 - G.I.A.: 69 m² Residential unit mix: - G.I.A.: 59.2 m² Unit breakdown revised A 2013.11.07 1 Bedroom (17%): 6 units Rev. Amendment Date 2 Bedroom (21%): 7 units 2 Bedroom (21%): 7 units 3 Bedroom (50%): 17 units 4 Bedroom (12%): 4 units

2B - Type C 2B - Type G 1B / 2B - Type J - 2 No. proposed - 2 No. proposed - 1 No. proposed - 2.5 storeys - 2 storeys - 2 storeys - G.I.A.: 73.9 m² - G.I.A.: 73 m² - 1B ground floor flat - G.I.A.: 60.6 m² - 2B first floor flat - G.I.A.: 70.3 m²

3 Bedroom (50%): 17 units 100m 50

N 20

3B - Type L 3B - Type M 3B - Type M 3B - Type P 10

- 4 No. proposed - 4 No. proposed - 4 No. proposed - 4 No. proposed 0 - 2 storeys - 2 storeys - 2 storeys - 2 storeys Site- G.I.A.: Identification 127 m² - G.I.A.: 139 m² In explaining the- G.I.A.:next 139 steps, m² Despite this,- G.I.A.: and 139 m²the October 0 10 20 50 100m the Council stated that a 2012 SLAA Technical Study In 4 2009 Bedroom the (12%): Council 4 units undertook technical assessment would (para. 2.5) noting that the BROOKS / MURRAY a ‘call-for-sites’ as part of be undertaken by the SLAA SHLAA Practice Guidance (insert ARCHITECTS preparing its’ Strategic Land Partnership during summer/ ref) is clear that “sites should 8-10 NEW NORTH PLACE Availability Assessment (SLAA). autumn 2011, which would not be excluded from the LONDON EC2A 4JA TEL 020 7739 9955 set out when, if and how a assessment because of existing FAX 020 7739 9944

At the time, the Council site could be developed, with planning policy designations”, [email protected]

described the purpose of the the SLAA then informing the the Council then comment CLIENT: SLAA (SLAA FAQ) as being District Plan. The Council that “approximately one third GASCOYNE CECIL ESTATES to identify the development explained that the SLAA of the District is Metropolitan potential of sites across the would show that the option(s) Green Belt and the remainder 4B - Type R JOB: - 1District No. proposed – in other words, how chosen by the Council are is designated as the Rural COLE GREEN - 2many storeys houses could be built feasible, that there is sufficient Area beyond the Green Belt” - G.I.A.: 139 m² on a site – and to provide an deliverable land in different and that “as such, outside DATE: SCALE: assessment of when, if and how areas, and would provide a of the identified settlements, NOV 2013 1:2000@A2 DRAWING TITLE: the siteSite could boundary be developed. The list of sites from which the development is considered PROPOSED UNIT CouncilCole stated Green Works the SLAA boundary would Council can select the most inappropriate in principle” BREAKDOWN help it take policy decisions on sustainable. The shortfall in (also para. 2.5). We consider how to best meet its housing housing delivery to date and that such a statement clearly DRAWING NUMBER: requirement and how much the lack of sufficient provision demonstrates that the Council 1004 - 201 - B development should go where. for housing in the draft District has predicated its SLAA by Plan in general emphasises taking into account the existing the need for a robust SLAA. planning policy designations that the same paragraph categorically states should not be taken into account.

12 The Three Greens, Hertford Representations to the emerging Birch Green, Cole Green & Letty Green East Hertfordshire District Plan In relation to ‘Stage 4: In other words, these Determining which sites statements further confirm that and areas will be surveyed’, the Council has predicated its the Council explains (para. SLAA by taking into account 3.20) that the SLAA is being existing planning policy undertaken in rounds reflecting designations, even to the extent its approach whereby different of assuming the categorisation parts of the District are of villages in the 2007 Local assessed in different manners Plan rather than as proposed at different times, with the six in the draft District Plan. main settlements and Group 1 villages (notably as defined in In short, the Council has not the 2007 Local Plan as opposed systematically reviewed any to as proposed in the draft potential development sites District Plan) being assessed outside the main settlements prior to the publication of and Group 1 villages (as defined the draft District Plan, with in the 2007 Local Plan), yet it Group 2 and 3 villages and the appears to consider itself able to remainder of the rural area propose definitive boundaries then being assessed in Round around Group 2 villages within 3 post the publication of the which all new homes should draft District Plan. The Council be delivered – this approach is justifies this approach by clearly unjustified, inconsistent explaining (‘importantly’) that with the NPPF and thus in the main settlements and unsound (NPPF para. 182). Group 1 villages, “the principle of development is established through the Local Plan Second Review 2007” and that “it is for this reason” that sites elsewhere including in Group 2 villages will be considered in Round 3.

The Three Greens, Hertford Representations to the emerging 13 Birch Green, Cole Green & Letty Green East Hertfordshire District Plan Local Context

The Three Villages

Sustainable Communities Services and Facilities Cole Green

As noted by the Council, Existing services, facilities, • Served by bus route 388 many villages are vibrant employment opportunities, • Immediate access to an communities with a full and so on within the extensive network of public and active social calendar Three Villages include: rights of way including the supporting vital local and rural Cole Green Way footpath enterprises – the Three Villages Birch Green and SUSTRANS route of Birch Green, Cole Green and • Munns Farm children’s Letty Green are no exception. • Served by bus routes 380 day nursery and 388 (with bus shelters) • Cowper Arms public The introduction of new • Immediate access to an house and restaurant development into villages extensive network of public • Various industrial and brings new life to these rights of way including the related companies at established communities Cole Green Way footpath Cole Green Works helping to sustain existing and SUSTRANS route, • Motor salvage works services and generating custom via which access will be • Stables for new or enhanced facilities available to the proposed • Cattery such as the existing bus Panshanger Country Park • Garden and pet centre service (388) between Hatfield • Hertingfordbury Cowper • Aquatic shop and Welwyn Garden City. C of E Primary School • Post box • Served by mobile library • Parish Council notice board. Also as noted by the Council, • Children’s playground there are instances where (equipped) Letty Green settlements – such as the • Playing field (football) Three Villages – have strong (informal) • Served by bus route 380 inter-relationships because • Maitland wood (public access) • Immediate access to an of their close proximity, such • Rochfords wholesale extensive network of public ‘clusters’ of villages sharing plant nursery rights of way including the services and/or facilities. • New England plant nursery Cole Green Way footpath • Antiques shop and SUSTRANS route • Bed & breakfast • Served by mobile library • Post box • Rochfords wholesale • Phone box plant nursery • Parish Council notice board. • Post box • Phone box • Parish Council notice board.

14 The Three Greens, Hertford Representations to the emerging Birch Green, Cole Green & Letty Green East Hertfordshire District Plan Employment premises Education premises Community facility Recreation facility Post Box Phone Box Notice Board Bus stop Other Services and Facilities Public Right of Way in the Three Villages Public transport route â

A414 Hertford Hertford

THE OLD COACH ROAD

Cole Green

á Birch Green Welwyn Garden City Garden Welwyn

Letty Green

Cuffleyâ

The Three Greens, Hertford Representations to the emerging 15 Birch Green, Cole Green & Letty Green East Hertfordshire District Plan

Birch Green

Village Boundary C The two largest homes on the eastern edge of the The draft District Plan explains village are excluded from that the proposed village the village boundary in their boundaries have “generally entirety, as are the lower been defined by the current halves of four residential outer extent of the built- gardens, this suggesting that up area of villages”. there are some thresholds relating to residential Notwithstanding our view plot size that have been that there is a complete lack applied in the drawing of of justification for the village the proposed boundary boundaries, not to mention although other, larger plots a complete lack of evidence are included in their entirety to support the proposed (no such thresholds / boundaries as defined, we have criteria have been explained considered where the boundary within the draft District Plan should be drawn if the Council, or any of the supporting and ultimately an Inspector, / technical studies). conclude that boundaries are necessary / appropriate. The Council is proposing that limited infill / windfall Boundary Issues developement can come forward within the village in A The proposed village order to ensure that the housing boundary around Birch target requirement is met, yet Green includes the majority the Council has no evidence of the core of the village as to whether this is possible but inexplicably excludes within the village boundary the pocket of housing on as proposed thus we suggest the northern side of the that some clearly deliverable The Old Coach Road. sites are considered to assist with the current shortfall B It also excludes from the in housing land supply. village boundary, for no apparent reason, a small area of car parking on the western boundary that is associated with adjacent housing.

16 The Three Greens, Hertford Representations to the emerging Birch Green, Cole Green & Letty Green East Hertfordshire District Plan Chisel Shelf Foot Bridge

Track

T A r 41 a 4 c

Tr ac Village boundary as proposedk in the draft District Plan and recommended amendments (shown in the darker blue)

Pond

10 D

r a

i An 4 2 12 14 GP

THE OLD COACH ROAD 5

Shelter

2 73.5m

16 6

D Well

r a i n Hertingfordbury Cowper C of E VA War Primary School Silo Memorial

Staines G

1 1

Birchwood 2 Birch Green 1

Play Area ) (um th Pa

Pond

B i

5 c 1 h

r e e

3 8

a r LB

Sinks

3 1

Posts

6 3

2 5

4 9

0 C

2 7 El Sub

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4 7

Path (um) ) Nursery )

m um

(u ( 6

8 th h 6 t 5 a Pa P Pond

1 7

F OXD

ELLS

9 8

2 1

7 3

P a th (u m )

69.0m

Maitland Wood Hazeldene

P ath (um)

Pumping ) Station (Path Way Green Cole FB

25 69.5m

4 60.1m 4 a The Three Greens, Hertford Representations to the emergingth 17 (

um 4

2 Birch Green, Cole Green & Letty Green East Hertfordshire District Plan )

3 8

6 4

8 5 Pond

Track

Letty Green Fruit Farm

Track

0m 50m 100m 150m Barn Cottage

Cole Green

Village Boundary

Again, notwithstanding our view that there is a complete lack of justification for the village boundaries, not to mention a complete lack of evidence to support the proposed boundaries as defined, we have considered where the boundary should be drawn if the Council, and ultimately an Inspector, conclude that boundaries are necessary / appropriate.

Boundary Issues

A Inexplicably, the proposed village boundary excludes the most built-up part of the village – the The Council is proposing Cole Green Works. that limited infill / windfall developement can come B The proposed boundary forward within the village in also, again inexplicably, order to ensure that the housing excludes all of Munns target requirement is met, yet Farm – currently in use as the Council has no evidence a children’s day nursery. as to whether this is possible within the village boundary C The boundary as proposed as proposed thus we suggest fails to include a number of that some clearly deliverable dwellings and employment sites are considered to assist premises on the western with the current shortfall side of the village. in housing land supply.

18 The Three Greens, Hertford Representations to the emerging Birch Green, Cole Green & Letty Green East Hertfordshire District Plan w

y 14 A 4 Village boundary as proposed in the draft District Plan and recommended amendments (shown in the darker blue)

4 41 A

r a c k

Issues

Track n Drai

Tr a c k

OAD CH R COA OLD THE

Colegreen House 5

73.2m

Cole Green

Garden Centre 6 8 n Drai Cattery Cole Green

Cumberland Green Well 17 The Bungalow Lyes Gove Kit's

74.4m Cottage 0 Ponds

BIRCHA 1 LB

LL LANE Well 71.3m 9

BIRCHALL 1 1 LANE

Pond

D 4 r d 1 a n i n la r e n b e e Pond m r u G

2 0

C 1 Pond

D A O R H C A O C D L O E H

4 Pp 2

) m (u Pond th

A Pa 2

Works 6 Munn's Farm

Farthing Hall B

El Sub Sta

Farthing Hall Stables

Spriggs

5 5

64.3m Pumping Station

Cowper Arms (PH) Labby Green Car Park

in a r D

The Three Greens, Hertford Representations to the emerging 70.4m 19 Birch Green, Cole Green & Letty Green East Hertfordshire District Plan

1 4 S T A T IO N R O A D

(Path) n Way Cole Gree Well

8 16 TCB 10 to

Well

8 2 20 3

2 3

0m 50m 100m 150m Pond 5

0 4

Letty Green

Village Boundary The Council is proposing that limited infill / windfall As above, notwithstanding developement can come our view that there is a forward within the village in complete lack of justification order to ensure that the housing for the village boundaries, target requirement is met, yet not to mention a complete the Council has no evidence lack of evidence to support as to whether this is possible the proposed boundaries as within the village boundary defined, we have considered as proposed thus we suggest where the boundary should that some clearly deliverable be drawn if the Council, and sites are considered to assist ultimately an Inspector, with the current shortfall conclude that boundaries are in housing land supply. necessary / appropriate.

Boundary Issues

A The proposed village boundary stops short of the western end of the existing village.

B The proposed boundary includes existing homes along the eastern side of Woolmers Lane but excludes, for no apparent reason, one home on the western side of the Lane.

20 The Three Greens, Hertford Representations to the emerging Birch Green, Cole Green & Letty Green East Hertfordshire District Plan Issues

Shelter Village boundary as proposed in the draft District Plan and 73.5m 16

r a i n Track n recommendedDrai amendments (shown in the darker blue)

T ra c k

Forge Cottage

Birchwood

OAD CH R COA OLD THE

egreen ouse 5

73.2m

Cole Green

)

in m ra u

D (

a Cole Green P

D Well

Kit's Stockings

0 Ponds 1 LB

Well

71.3m 9

1 1

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Pond

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Pa 2

Works 6 Munn's Farm

Farthing Hall

)

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El Sub Sta

Farthing Hall Stables

Spriggs

5 5

64.3m Pumping Station Pond

Cowper Arms (PH) Path (um) Labby Green Car Park C ole Green W T a y (p r ath) a

c k P ath (um)

Pumping Station

(

m 25

) 69.5m

4 60.1m 4

4 2

5 3 1 8 6

70.4m 4

8 5

3 11 4

1 4 S Letty Green T A T Fruit Farm IO Wr Twr N R O A D NE LA L

PE A 2

CH 0

Well

1 8

2 Ponters 1

4 Grove

El Sub Sta LB GP Pond 8 Church 16 TCB 10 to Residence St John's Well

1 Meadow Issues Well 8 Cottage 2 20 3

2 3

9 a

1 1

Pond 5 0

4 Nursery

8 42 3 W O Pond O L M

E Letty Green R S

L The Oaks A N E

1 9 K) Letty Green Lambourne AC A (TR E LAN ELD DFI DEA Pond

2 70.9m 5 Nursery ) Hall

Pond

2 9

Orchard House 5 m) Path (u

Shingles

a 0 Piper's i

n 3 B End

The Elms 4

70.3m 2

Pond

Wo olme r's P ark M ews

Gardeners Cottage

The Three Greens, Hertford Representations to the emerging 21 Birch Green, Cole Green & Letty Green East Hertfordshire District Plan

n i

a r

D TennisWoolmer's Court Park

Mansion House

a r

0m 100m 200m 300m t k c h ra T ( u

Spring Wood )

Summary are vibrant communities • The limitation of infill with a full and active social development to no more than • The true need for housing calendar supporting vital 5 new homes on any particular within the District could local and rural enterprises, site within Group 2 villages is be up to 3,600 new homes the proximity of Cole Green unjustified, inconsistent with higher than is being planned Way and access to primary the NPPF and thus unsound. for by the Council. education and public transport leading to a conclusion • There is currently a complete • The draft District Plan does that the Three Villages are lack of justification for the not provide for sufficient more sustainable that they village boundaries, not to housing to be delivered might at first appear to be. mention a complete lack either during the remainder of evidence to support the of the plan period, or • We also support the Council’s proposed boundaries as defined. during the next 5 years. recognition that there are instances where settlements • The Council has not • The inclusion of Birch have strong inter-relationships systematically reviewed any Green, Cole Green and Letty because of their close potential development sites Green as Group 2 villages is proximity, despite not being outside the main settlements welcomed – previously all immediately adjacent to each and Group 1 villages (as three villages were categorised other and that the concept defined in the 2007 Local Plan), as Group 3, which prevented of clusters of villages that yet it appears to consider itself any new housing (except share services and/or facilities able to propose definitive rural exception site affordable needs to be recognised. boundaries around Group 2 housing) or employment or villages within which all new social / community facilities • We support the principle, as homes should be delivered from being developed set out within draft Policy – this approach is clearly and thereby threatened VILL2, of allowing limited infill unjustified, inconsistent with to undermine the villages’ housing development, limited the NPPF and thus unsound. sustainability and vitality. affordable housing for local community identified needs, • We support the Council’s and the provision of small- reasonable conclusion that, scale employment, leisure, despite a shortage of services recreation and community and facilities within villages facilities within Group 2 across the District, which villages where supported might by some measures by the local community. of sustainability lead one to conclude that that the villages are unsustainable locations for development, many villages

22 The Three Greens, Hertford Representations to the emerging Birch Green, Cole Green & Letty Green East Hertfordshire District Local Plan Conclusion

• In conclusion, we support the identification of Birch Green, Cole Green and Letty Green as Group 2 villages.

• However we consider it unnecessary to limit infill development to no more than 5 new homes on any site and thus object to this part of draft Policy VILL2.

• We also consider that it would be regrettable if unnecessary boundaries drawn around these villages with the intention of protecting them and their communities from unwelcome development, ultimately stifled them. For this reason, we also object to the proposed definition of boundaries around Group 2 villages

Hertingfordbury Cowper C of E 23 Primary School, Birch Green