Welwyn Hatfield Local Plan Stage 2 Hearing Statement Aurora Properties (UK) Ltd 9 October 2017 Welwyn Hatfield Local Plan Stage 2 Hearing Statement – Aurora Properties (UK) Ltd Contents 1 Introduction 2 2 Full Objectively Assessed Housing Need 3 3 Green Belt Review 4 4 Spatial Vision & Settlement Strategy 6 5 Targets for Growth 8 6 Five Year Land Supply 9 7 Conclusions 10 Appendix 1: SHMA (2014) Figure 5.19 Appendix 2: Brookmans Park Historic Maps Appendix 3: Housing Distribution, Coalescence & Cumulative Impact Report Appendix 4: Site Selection Analysis Appendix 5: Aurora Report on Primary School Capacity Appendix 6: Hogan Lovells Correspondence 1 Welwyn Hatfield Local Plan Stage 2 Hearing Statement – Aurora Properties (UK) Ltd 1 Introduction This hearing statement has been prepared by Deloitte LLP on behalf of Aurora Properties (UK) Limited (Aurora). Aurora is promoting two sites in Brookmans Park, BrP1 and BrP12. Both sites passed the Stage 2 HELAA process. BrP12 was considered suitable for allocation in the Housing Sites Selection Paper 2016 (HOU/20); but was not then allocated by WHBC due to a perceived lack of primary school capacity in Brookmans Park. It was the only site in WHBC to be found suitable for allocation, but not allocated. The reason for not allocating BrP12 is contrary to national planning guidance. The Council’s reasons for not allocating BrP1 are disputed by Aurora. Those are matters for the Stage 3 and 4 sessions. Aurora’s detailed representation is dated October 2016 (the Representation). The Representation remains Aurora’s primary evidence supporting its objection. Aurora has also submitted a Stage 1 Hearing Statement. Aurora maintains its position that the Local Plan is not sound, however it can be made sound through the examination process. 2 Welwyn Hatfield Local Plan Stage 2 Hearing Statement – Aurora Properties (UK) Ltd 2 Full Objectively Assessed Housing Need Aurora supports the uplift to the demographic starting point for the Council’s FOAHN. Paragraphs 6.4 -6.16 of Aurora’s Stage 1 Statement addresses concerns with the Council’s approach. These adjustments are necessary due to acute affordability problems and economic factors. Figure 5.19 (Appendix 1) of the 2014 SHMA identifies the affordability of homes in the borough. Welwyn Hatfield has an affordability ratio of approximately 10 times income within the borough1. The affordability ratios are even more acute for villages such as Brookmans Park (19.7:1) and Cuffley (16.8:1). Paragraph 2.18 of the Submission Local Plan identifies WHBC as having 1.11 jobs for every working age resident. This is the 13th highest for all UK local authorities excluding inner London. Significant weight should be given to these market signals as part of the FOAHN and the housing distribution strategy. The lack of development, in the absence of an up to date Local Plan, has constrained growth in the borough. This is exemplified in the villages such as Brookmans Park, Cuffley and Welham Green, where the Green Belt has remained unaltered since the 1980s. HOU/22 describes the negative impacts arising from not meeting the FOAHN2. These impacts relate particularly and significantly to younger people and the affordability of homes. This could restrict the retention and attraction of a high quality workforce. 1 The figures are based on the lower quartile house price and lower quartile income. 2 Please refer to paragraph 6.16 of Aurora’s Stage 1 Hearing Statement. 3 Welwyn Hatfield Local Plan Stage 2 Hearing Statement – Aurora Properties (UK) Ltd 3 Green Belt Review Objective Assessment The Council’s review of the Green Belt3 has been flawed from inception. This has resulted in the overstated importance of the Green Belt in certain areas and significant inconsistency. Aurora’s evidence has focussed on the south of the borough. The Council has persisted with a flawed ‘local settlement pattern’ test for Green Belt which is inappropriate and poorly defined. The adopted Local Plan 2005 (paragraph 4.2) claims that the settlement pattern in the borough has unique qualities based on “….medium sized towns and villages, situated along main road and railway routes radiating northwards from London”. There is no evidence to support the unique qualities or distinctive settlement pattern that necessitates this test. It goes against the tests set out in the Framework. The primary purpose of this test appears to be the protection of the larger villages. The larger villages have only been developed in the post-war period and do not have any significant historic merit. Brookmans Park was developed from the 1930s following the construction of a new railway station in 1928 for the specific purpose to create a commuter settlement for London and other nearby towns. That purpose remains as relevant today as it did in the 1930’s. The historic maps in Appendix 2 show the development and growth of Brookmans Park since 1930. Housing growth ceased in the mid 1960’s and the village has remained largely in its present form since then. The Council’s site selection process has introduced the concept of cumulative impact to restrict the allocation of sites in the Green Belt. However, Aurora is not aware of any objective assessment by the Council to analyse options or consider alternative options. In the absence of such an assessment, Aurora commissioned its own study4 (Appendix 3). This report focuses on the villages in the south of the borough. The report also identifies a number of issues with the Council’s Green Belt review relating to the strategic gaps. Map 1 of Appendix 3 (page 6) assesses the strategic and fragile gaps in the south of the borough. This is broader than the Council’s assessment as it considers the cross boundary impact on the strategic gap between South Hatfield and Potters Bar (within Hertsmere), west of the East Coast Mainline Railway. The Aurora study provides a thorough analysis of the cumulative impact of releasing sites around Brookmans Park, Welham Green and Little Heath. No such assessment has been undertaken by the Council, yet it makes judgements in the site selection process. Aurora’s assessment identifies that sites for 790 new homes could be released from the Green Belt in this area where harm is limited and no cumulative impact is caused. The report also concludes that HAT11/HS11 and BrP4/HS22 are within a fragile gap, in open countryside, beyond a strong and permanent Green Belt boundary and should not be preferred for allocation. 3 GB/1, GB/2, GB/3 4 Housing Distribution, Coalescence and Cumulative Impact Study for Brookmans Park, Welham Green, Little Heath and South Hatfield; Liz lake Associates; Appendix 20 of the Representation. 4 Welwyn Hatfield Local Plan Stage 2 Hearing Statement – Aurora Properties (UK) Ltd Exceptional Circumstances Aurora agrees with the Council that exceptional circumstances have been demonstrated to release land from the Green Belt5. There would be significant and negative economic and social consequences arising from the failure to meet its FOAHN and support economic growth. Having identified the exceptional circumstances for the release of land from the Green Belt, the Council has not adopted robust or consistent criteria to identify and allocate those sites which are most appropriate for release to meet its FOAHN. Acknowledging that exceptional circumstances exist, the Council should have followed the guidance in paragraph 14 of the Framework. The Council should have (i) examined the sustainability and suitability of each individual site, (ii) identified whether any adverse impacts would significantly and demonstrably outweigh the benefits of allocating that site and (iii) weighed any adverse impacts against the benefits of meeting the FOAHN in full. These three stages should be followed sequentially, objectively, consistently and with the balance in favour of sustainable development. Green Belt Boundaries A number of allocations proposed will result in significantly weaker long term Green Belt boundaries than the existing and, in several instances, breach very strong and permanent Green Belt boundaries. For example: BrP4 breaches the strong and permanent western boundary of Brookmans Park, defined by the East Coast Mainline Railway. This creates a much weaker Green Belt boundary to the west of the village, it creates a disconnected community and it encroaches into the strategic gap between South Hatfield and Potters Bar6. HAT11 crosses the strong and permanent Green Belt boundary of South Hatfield as defined by South Way7. It encroaches into a fragile gap between Hatfield and Welham Green, creating a weaker Green Belt boundary and a disconnected community. It also encroaches into the strategic gap between South Hatfield and Potters Bar. The Council has not created long-term boundaries that will endure beyond the Local Plan period (paragraph 85 of the Framework). The Council’s current strategy relies on an early review of its Local Plan, which contradicts its “Borough-wide Strategic Objectives”8 which state “Green Belt boundaries will not need reviewing before 2032”. The failure to allocate sufficient sites, thus causing the need for an early review of the Local Plan, will inevitably lead to further alterations to Green Belt boundaries in the plan period. This is contrary to the Local Plan and paragraph 83 of the Framework. There are a number of sites around the existing settlements that, if released, would satisfy paragraphs 83, 84 and 85 of the Framework. These sites are identified in Appendix 39. 5 Paragraphs 1.2 and 1.7 of TPA/2 Topic Paper – Green Belt. 6 Please refer to Appendix 3, page 6, Map 1. 7 Please refer to Appendix 3, page 17, paragraph 5.11 8 WHBC Submission Local Plan, Objective 1, page 30 9Appendix 3 page 36 - Table 3 Site Selection and Map 4 page 37 5 Welwyn Hatfield Local Plan Stage 2 Hearing Statement – Aurora Properties (UK) Ltd 4 Spatial Vision & Settlement Strategy The Representation considered this matter at paragraphs 4.1 – 4.6.