Examination of the Welwyn-Hatfield Local Plan 2013-32 Comments on Inspector’s Matters and Issues Documents EX238 & EX239 Report compiled by: I.F. Skidmore MA DPhil (Oxon) Welwyn Parish Plan Group W.G. Morris MSc CEng MIET Welwyn Parish Council R.J. Haggar MA Welwyn Planning & Amenity Group Approved by: Submitted on behalf of the Council by: Welwyn Parish Council Caroline Williams Planning & Licensing Committee Clerk to Welwyn Parish Council Version 1.1 12th February 2021 Contents Introduction .......................................................................................................................... 3 EX239: Digswell Site Dig 1, East of New Road .................................................................. 4 General Comment ........................................................................................................... 4 Response to Inspector’s Questions ................................................................................ 4 Conclusion for Digswell Site Dig 1 ................................................................................... 8 EX239: Oaklands/Mardley Heath ........................................................................................ 9 General Comment on Sites OMH 6, 7 & 9. ..................................................................... 9 EX239: Site OMH 6, Land East of Danesbury Park Road (58 dwellings) ................ 10 General Comment ................................................................................................ 10 Response to Inspector’s Questions...................................................................... 10 EX239: Site OMH 7, 22 The Avenue ....................................................................... 12 General Comment ................................................................................................ 12 Response to Inspector’s Questions ..................................................................... 12 EX239: Site OMH 9, Rear of 19-23 The Avenue (12 dwellings) .............................. 14 General Comment ................................................................................................ 14 Response to Inspector’s Questions...................................................................... 14 Conclusion for Oaklands/Mardley Heath Sites – OMH 6, 7 & 9 ..................................... 16 EX238: Welwyn (Sites Wel 1, Wel 2, Wel 6 & Wel 15) ..................................................... 16 General Comment ......................................................................................................... 16 Response to Inspector’s Questions .............................................................................. 17 Conclusion for Welwyn Sites – Wel 1, 2, 6 & 15 ............................................................ 26 Page | 2 Introduction Welwyn Parish Council (WPC) has responded in the past to various invitations to consultation on both the Draft Local Plan and individual papers, to Welwyn Hatfield Borough Council (WHBC) and to the Inspector directly. We are therefore again pleased to offer further comments to the Inspector in respect of the Matters and Issues he has raised in Documents EX238 and EX239. Our comments have been co-ordinated by a Working Group operating under the aegis of the Council’s Planning and Licensing Committee and which included representatives from: • Welwyn Planning and Amenity Group - WPAG - formed over 60 years ago, to encourage, and coordinate public interest in all aspects of Planning and Amenities in and around Welwyn Parish. • Welwyn Parish Plan Group - WPPG – responsible for compiling the Parish Plan in 2008 which represented the wishes and ideas of residents in Welwyn Parish at that time and which has been used to help drive change and to influence policy since then. These groups may also directly contribute their own responses. The Local Plan is an important piece of strategic planning for our parish and our communities and it is particularly significant as the fundamental backdrop for our own Parish Neighbourhood Plan 1. Some of our responses involve visual perception and so we have included recent photographs of some of the locations. For ease of assimilation, statements and questions from the Inspector’s original EX238 and EX239 documents are presented in italic type and our responses are intercut as appropriate, in normal type. Within this response, when it helps to present a coherent and comprehensive response, we have included some relevant statements from previous responses, to obviate continual cross-referencing between multiple documents. 1 This is currently in the early stages of formulation (the process has been protracted due to the Covid-19 regime in 2020 and 2021). Page | 3 EX239: Digswell Site Dig 1, East of New Road This site is currently used for agricultural purposes and has no physical features defining its south-eastern boundary, other than the route of a public footpath. The site is within the Green Belt and the potential harm through development, to its purposes, was assessed as moderate in the Stage 3 Green Belt Review. The proposal would develop the site for residential purposes. General Comment The current green belt boundary of Digswell was very tightly drawn to ensure that the settlement did not expand to the east over open countryside towards Tewin and to the west across the Lockleys estate. Encroachment into either of these would degrade the views from the surroundings of Digswell: to the east across the Mimram Valley towards Tewin/Hertford and to the west towards the viaduct and across open countryside to Danesbury and beyond, again to the Mimram valley and to the green gap that separates Welwyn Village from Oaklands/Mardley Heath. The railway station itself is not a key factor. The inner suburban trains from London terminate at Welwyn Garden City (WGC), which picks up most of the local traffic, although the outer suburban services, which stop at Welwyn North station (especially the few more direct services to Kings Cross during the peak morning and evening periods) are popular with commuters from Digswell, Welwyn village, Oaklands and outlying hamlets. Dig 1 is a hillside site behind New Road. It abuts the Green Belt boundary and thus has the potential to be excluded from the Green Belt by extending that boundary. Whilst the new boundary would “even out” the building line, it would have no defensible features against future expansion. In its HELAA analysis WHBC was also concerned about water run-off on this hillside site. Response to Inspector’s Questions The site is close to Tewin Water Registered Park and Garden and to Digswell viaduct, which is a Grade II* listed structure. 1. To what extent would there be harm to these heritage assets? Would it be substantial? There would be no direct physical harm to these sites themselves. However, the long- admired settings of both would be greatly compromised. See photographs. The view of the viaduct from the proposed Dig 1 and beyond would cease to exist. It is more difficult to argue for the Park and Garden (because there is a field created by a ridge that separates Dig 1 from the site); however, part of the reason given for failure in 2016 was Heritage England’s concern about overlook/enclosure of the Park. The development would be visible from the Park. 2. Is the harm capable of remediation by appropriate landscaping, with or without earth mounding? Landscaping or mounding would not help as the view would be blocked by the buildings. Page | 4 Viaduct from path that would be the Dig 1 boundary View of Tewin Water from Dig 1 3. Is there any objective basis on which the assessed Green Belt harm could be challenged or the weight attached to it changed? In addition to the visual impact on Tewin Water Park and the Viaduct, the open nature of the land is important for views to the east and for the pathways that stretch across it giving access to the land and to Tewin and Burnham Green. Views of this area are amongst the most attractive in the parish; they are much-admired and loved by both visitors and residents. We also consider visibility over long distances is of at least as much importance as the view of the Park or the viaduct. 4. Could an appropriate new boundary to the Green Belt be established that could endure and have less impact on the wider Green Belt than the existing one? If so, how would this be achieved? We believe that any new boundary that Dig 1 would provide is weak: it would just be a line across open farmland, with no physical or firm vegetative features that could define a defensible boundary, other than the lone oak tree shown in the photograph, which would be the only marker, totally surrounded by field. Tree on border of Dig 1, from the Dig 1 boundary 5. How many dwellings could the site deliver? The promoted capacity in the 2016 and 2019 HELAA was 130 units (on 4.3Ha. at 30 dwellings per Ha). No further assessment of capacity was done as the site failed at stage 2. However the 130 number is misleading. The Digswell Character Appraisal 2 states, for 2 Produced for Welwyn Hatfield Borough Council and after consultation in 2003, published in January 2004 and adopted by them as a Supplementary Planning Document,. Page | 5 the area of New Road 3: “ Houses along this stretch of the road are only fleetingly visible behind well-screened green boundaries. The deep set-backs, generous spaces between houses, and varied design on derivations of the vernacular style set the pattern for any new development”. An associated