Homes for Herts

P87 - Wells Farm, Cuffley Borough Council Local Plan Consultation Introduction

P87 - Site Location

Cuffley Hill Farm

CUFFLEY

Broxbourne

Hempshill Brook P87 Council

HS29

HS30 Sports Fields

Colesdale Farm Northaw Brook

Cattlegate Wood Wildlife Site

Cattlegate Farm

2 King & Co Executive Summary

In September 2018 King & Co submitted This report also identifies (where to Welwyn Hatfield Borough Council appropriate) inconsistencies across an Appraisal of Land Use Consultant’s Purpose Scoring and Harm Ratings, and (LUC) Stage 3 Green Belt Study, which the relationship between them. This is a highlighted several limitations within contribution in terms of the Inspector’s LUC’s methodology. This included a comments about the consistency of review of LUC’s three-point assessment analysis. ratings system, which the Appraisal concluded did not provide enough Utilising LUC’s analysis of separating separation between comparative results and connecting features, ‘absolute (suggesting a ten-point alternative constraints’, and present urbanising would be more advantageous), and an influences, the conclusion drawn here inconsistent application of subdivision recognises that the southern-most edge across the Borough. The content of this of Parcel 87 (P87) is qualitatively different Appraisal was presented during Stage 5 of from the rest of the parcel; its impact on the Inspector’s Hearing Sessions. openness obscured by present built-form.

We note that whilst the Inspector did In light of these discrepancies, this report note that many of the respondents did suggests that the P87 parcel should be raise significant concerns in terms of sub-divided, and by doing so it would methodology, he was more focused upon result in a different rating of harm. the application of that methodology on a parcel-by-parcel basis. Taking a We would specifically encourage that pragmatic approach therefore, the LUC consider the sub-division scenarios Inspector decided that the methodology we have proposed. Specifically, the harm was sufficiently sound but did invite the ratings that should be attributed to the opportunity for respondents to note southern part of the parcel in isolation (and justify) where parcels should be would be considerably lower than the reconsidered in terms of their granularity harm rating where the parcel comprised and also for the conclusions drawn to be solely of or also included the more open based upon a consistent approach. parcels of land to the north of P87.

As such, we do not seek to identify or raise matters in respect of the LUC methodology as that will not assist the Inspector.

We do however seek to identify where the LUC approach could have taken a different approach to sub-division and where this would have resulted in a different and potentially lesser degree of Green Belt harm.

P87 - Wells Farm, Cuffley 3 CUFFLEY

Hempshill Brook

Chain Walk

7 11 5 6 10 4 Northaw Road East

2

12 8 9 1

B156 Sports Fields

3

3

Northaw Brook

Colesdale Farm

Northaw Road West

4 King & Co Site and Context

Site Photographs - Northaw Road East - B156

1. Looking north east along Northaw Road East

2. Looking south west along Northaw Road East

3. South west corner of site looking towards Chain Walk running along Hempshill Brook P87 - Wells Farm, Cuffley 5 Site and Context

Site Photographs

4. Panorama looking north and west

5. Looking east towards the farmhouse 6. Existing sheds on site

7. Looking east towards the eastern hedgerow boundary and brook 8. Looking south at the swale on the south west corner 6 King & Co Site and Context

9. Looking north east across the site 10. View of the existing buildings and hardstandings

11. View of the farmhouse 12. Looking north west at the farmyard P87 - Wells Farm, Cuffley 7 P87 - Green Belt Study Stage 3 - LUC

Extract of Figure 3.1 - Absolute Constraints

HS30

8 King & Co

0 2.5 5 E km

Welwyn Hatfield Borough Council Absolute constraints WELWYN HATFIELD Green Belt Assessment Neighbouring councils Registered Parks and Gardens

Green Belt Scheduled Monument Figure 3.1: Absolute and Non- Non-absolute constraints Special Area of Conservation Absolute Constraints Flood zone 2 and 3 Site of Special Scientific Interest

National Nature Reserve

Local Nature Reserve

Local Wildlife Site

Ancient Woodland Inventory

Source: WHBC, Natural , Historic Enland, Environment Agency Map Scale @A3: 1:62,500 © Crown copyright and database rights 2018 Ordnance Survey LA 100019547 2018. CB:EL EB:lendak_e LUC FIG3-1_10294_r2_Cnstrnts_A3P 23/08/2018 P31 P3 P2 P32

P4 P34 P33 P1 P5 P35

P15 P6

P30 P36

P7 P8 P13 P37 P14 P17 P16 P38 P12 P9 P29 P40 P10 P39

P20 P11

P18 P19

P21 P32

P31 P22

P36 P33 P34 P39 P35 P23 P30 P40 P37 P45 P26 P24 P29 P44 P38 P25

P41 P28 P27 P43

P42 P49 P50

P46

P52 P47

P51 P48

P60 P57

P69 P70 P53 P56 P72

P55 P54 P68 P58 P71 P95 P61 P92 P59 P73 P94 P93 P63 P66 P62 P91 P65 P75 P67 P74 P90 P87 - Green Belt Study Stage 3 - LUC P64

P77 P86 P81 P76 P89 P80 Extract of Figure 7.1 - Assessment of Potential Harm P79 P78 P85 P87 P84

P82 HS30 P88

P83 P87 - Wells Farm, Cuffley 9

0 2.5 5 E km

Welwyn Hatfield Borough Council Lowest harm rating WELWYN HATFIELD Green Belt Assessment Neighbouring councils Very High

Green Belt parcel High Figure 7.1: Assessment of Moderate-High Potential Harm Moderate

Moderate-Low

Low

Main map scale @A3: 1:62,500 Source: WHBC, LUC Inset map scale @A3: 1:20,000 © Crown copyright and database rights 2018 Ordnance Survey LA 100019547 2018. CB:EL EB:lendak_e LUC FIG7-1_10294_r2_LowestScnr_A3P 17/08/2018 P87 - Green Belt Study Stage 3 - LUC

Inconsistencies in Parcel Analysis and Recommended Subdivision

Parcel Description Absolute environmental constraints Physical separators and built-form The parcel of land P87 is described by As illustrated on page 391 of LUC’s Stage Although the parcel is largely open and LUC as follows: 3 Green Belt Study, Parcel 87 is bordered rural in character, the southern-most to the west by functional floodplain where portion contains existing built-form to the “The parcel is located on the south- its edge “follows the course of a stream south and eastern edge that minimises western edge of the settlement of Cuffley, designated as flood zones 2 and 3.” LUC its urbanising influence in relation to the which is inset within the Green Belt. Land note on page 18 of their Final Report, adjacent countryside. within the parcel slopes down from the paragraph 3.5, that “Flood Zones 2 and 3 urban edge to the southwest and from are…not treated as absolute constraints The areas of built form to the south of the high land in the north there are open within the context of this study”, it is the parcel are subject of two separate views of the countryside across the parcel difficult to infer what they are otherwise positive allocations for housing in the and beyond. The area predominantly if not areas; or hard boundaries, with emerging Local Plan (HS29 and HS30) comprises arable fields, but an individual little or no potential to be proposed and which include Wells Farm. property is located in the northeast of the approved for development. Although parcel, a farmstead (an appropriate use LUC clarify that “the constraints used within the Green Belt) is located in the to inform this study are consistent with Achieving granularity southwest of the parcel and a farmstead those used in the Council’s Housing and Further sub-division would provide the and a few individual dwellings are present Economic Land Availability Assessment”, it opportunity to have greater appreciation in the south of the parcel. There is no appears illogical to exclude undevelopable of diverse openness and urbanising development present within the parcel floodplain from the constraints map for influences in different parts of the P87 that compromises its openness. consistency with previous Green Belt parcel. This will have ramifications both The Dell (Cuffley) Local Wildlife Site is studies conducted by WHBC when the for potential contribution to Green Belt located adjacent to the north of the Inspector recommended re-evaluation of Purposes and in respect of the potential parcel. Additionally, the western edge prior studies on the basis of their lack of for the extent of harm that may arise. of the parcel follows the course of a appropriate exclusion of undevelopable stream designated as flood zones 2 and land. 3. The parcel directly adjoins residential dwellings on the urban edge to the east. In addition to a separating watercourse The southern edge of the parcel adjoins a on the western extent of P87, the Dell B- road, with a tennis club, football club (Cuffley) Local Wildlife Site is located and bowling club present beyond this. adjacent to the north of the parcel, an The western edge and north-western ‘absolute constraint’ which effectively corner of the parcel adjoins the wider contains potential encroachment upon countryside to the west and northwest, the open countryside northwards and with a stream present along the western facilitates appropriate green space behind edge of the parcel. The remainder of the Thornton’s farmstead and across the northern edge of the parcel adjoins a Way. To the southwest, woodland, separating the parcel from the LUC adds that “there are blocks of residential developments to the north and woodland between the settlements [of providing some containment of the north Cuffley and ] which act as of the parcel – although open views of the separating features including an area of countryside to the south are still visible.” ancient woodland”. This, however, is only diagrammatically shown in the assessment of the adjoining P88.

10 King & Co P87 - Green Belt Study Stage 3 - LUC

Parcel P87A and P87B

P87B

P87A

Analysis in Relation to Purpose Assessment Criteria Purpose P87 LUC Rating P87A Our Rating P87B Our Rating 1 Whole Parcel Limited or no HS30 only Limited or no Land north and Limited or no Contribution Contribution east of HS30 contribution 2 Whole Parcel Partial HS30 only Limited or no Land north and Partial Contribution Contribution east of HS30 Contribution 3 Whole Parcel Significant HS30 only Partial Land north and Significant Contribution Contribution east of HS30 Contribution 4 Whole Parcel Limited or no HS30 only Limited or no Land north and Limited or no contribution Contribution east of HS30 contribution 5 Whole Parcel Significant HS30 only Significant Land north and Significant Contribution Contribution east of HS30 Contribution Local Purpose Whole Parcel Partial HS30 only Limited or no Land north and Partial contribution Contribution east of HS30 contribution

P87 - Wells Farm, Cuffley 11 P87 - Green Belt Study Stage 3 - LUC

P87/P87A: Inconsistencies in Purpose Analysis

Purpose 1: To Check the unrestricted Purpose 3: Assist in safeguarding the Purpose 4: Preserve the setting and sprawl of large built-up areas countryside from encroachment special character of historic towns (Limited or No Contribution) (Limited or no Contribution) (Limited or no Contribution) P87 is sufficiently separated or distant from large built-up areas for there not to Due to the presence of existing built form The land forms little or no part of the be any potential for urban sprawl. P87A to the south of the parcel, P87 does not setting of Welwyn Garden City and does would lessen that effect, but it is already experience a strong connection to open not contribute to its special character. at the lowest level. countryside and the strong distinction The reduction in the parcel size will not between settlement and countryside impact upon the purpose rating, which is Purpose 2: Prevent neighbouring towns is diluted. We would therefore raise already at its lowest level. from merging surprise in terms of the ‘Significant Purpose 5: Assist the urban regeneration, (Limited or No Contribution) Contribution’ Purpose Rating assigned by encouraging the recycling of derelict P87 lies between the settlements of by LUC for the P87 Parcel as a whole. and other urban land (Significant to the east and Potters Bar The notion of its ‘open countryside’ Contribution) to the south west. The settlements are characteristics contradicts with its located within approximately 6.5km of logical relationship with the settlement All Green Belt land can be considered each other across the parcel. The smaller boundary. to support urban regeneration within settlements of Goff’s Oak, Northaw and Welwyn Hatfield and it is not possible to most notably Cuffley lie between the With reference to the smaller parcel distinguish which parcels perform this to first tier settlements thereby limiting the P87A, the land itself relates strongly a stronger or weaker degree. perception of separation. There are no to the settlement edge closer to the The reduction in the parcel size will not connecting features which run directly southern edge of the wider P87 parcel. impact upon the purpose rating, which is between the towns. The gap between This further subdivision is recommended already at its lowest level. the towns is relatively fragile due to the to ascertain the extent to which Local Purpose: To maintain the existing presence of the intervening settlements, release of P87 would compromise settlement pattern (Limited Contribution) though modest development to the openness. P87A would lessen the While LUC suggest that “the land within south of the parcel would have negligible effect considerably, given that it is the parcel plays a partial role in inhibiting impact on the potential merging of already occupied by built form and the physical and/or visual coalescence settlements. the contribution reduces to “partial of the settlements as the gap is visually contribution”. open with few separating features”, P87A would lessen that effect, given that further subdivision of the parcel would it is already occupied by built form and enable a more granular and comparative the contribution reduces to “limited or no study between effects on settlement contribution”. patterns in the north of P87 vis-à-vis the south (Wells Farm).

P87A would lessen the effect considerably, given that it is already occupied by built form and the contribution reduces to “partial contribution”.

12 King & Co P87 - Green Belt Study Stage 3 - LUC

Summary Conclusion

Our view is that the assessment of Analysis in Relation to Green Belt Harm the extent of harm through release of Scenario Description LUC Harm Rating Our Harm Rating the whole site is perhaps overstated. P87 Whole parcel High Moderate-High This view is reached because the P87A HS30 Not Assessed Moderate-Low comments about the perception of both P87B Land north and east of HS30 Not Assessed Moderate-High openness and separation require further PARCEL P1 considerations, and it isGreen unclear Belt whether Harm rating Moderate LUC have given proper Greenregard Belt to absoluteparcel Very High Moderate - Low constraints in the form Councilof a watercourse boundary High Low E which is in Flood Zone 3 and a local Moderate - High © Crown copyright and database rights 2018 Ordnance Survey LA 100019547 2018. PARCEL P1 Greenwildlife Belt reserve. Harm rating Moderate Green Belt parcel Very High Moderate - Low Regardless of this comment, the Council boundary High Low E sub-division of Parcel P87 to retain © Crown copyright and database rights 2018 Ordnance Survey LA 100019547 2018. Moderate - 0High 350 700 the southern element (P87A) makes m for a substantive change which will considerably reduce any potential for harm. 0 350 700 From a topographical perspective,m however, LUC note that ‘land within the parcel slopes down from the urban edge to the southwest and from the high land in the north there are open views across the parcel and beyond.’ Though this is arguably the case when viewed from the north of P87, Wells Farm and its southern-most edge exhibits dramatically different views, and its openness is compromised by existing built form. In the draft allocation of ‘Cuf7’ this was further explores, suggesting that open views of the countryside and its relationship with its surroundings are reduced by urbanising influences.

We recommend that LUC should reconsider the sub-division of parcel P87 and expressly this should include a scenario which looks at the draft allocations of HS29 and HS30. We feel that this will demonstrate that the draft allocations process was robust in this particular respect and that these sites should remain positively allocated.

P87 - Wells Farm, Cuffley 13

Welwyn Hatfield Green Belt Study 5 August 2018 Appendix 6.1

Welwyn Hatfield Green Belt Study 5 August 2018 Appendix 6.1 P87 - Green Belt Study Stage 3 - LUC

14 King & Co P87 - Green Belt Study Stage 3 - LUC

Site P87

View looking west from the settlement edge of Cuffley

Parcel Description The parcel is located on the south-western edge of the settlement of Cuffley, which is inset within the Green Belt. Land within the parcel slopes down from the urban edge to the southwest and from the high land in the north there are open views of the countryside across the parcel and beyond. The area predominantly comprises arable fields, but an individual property is located in the northeast of the parcel, a farmstead (an appropriate use within the Green Belt) is located in the southwest of the parcel and a farmstead and a few individual dwellings are present in the south of the parcel. There is no development present within the parcel that compromises its openness.

The Dell (Cuffley) Local Wildlife Site is located adjacent to the north of the parcel. Additionally, the western edge of the parcel follows the course of a stream designated as flood zones 2 and 3. The parcel directly adjoins residential dwellings on the urban edge to the east. The southern edge of the parcel adjoins a B- road, with a tennis club, football club and bowling club present beyond this. The western edge and north-western corner of the parcel adjoins the wider countryside to the west and northwest, with a stream present along the western edge of the parcel. The remainder of the northern edge of the parcel adjoins a woodland, separating the parcel from the residential developments to the north and providing some containment of the north of the parcel – although open views of the countryside to the south are still visible.

P87 - Wells Farm, Cuffley 15

Welwyn Hatfield Green Belt Study 392 August 2018 Appendix 6.1 P87 - Green Belt Study Stage 3 - LUC

Site P87 Assessment of Contribution to Green Belt Purposes Purpose/Rating Assessment

P1: Checking the The parcel is sufficiently separated or distant from a large built-up area for there not to be any unrestricted sprawl of potential for urban sprawl from the large built up area. large built-up areas

Limited or no contribution

P2: Preventing the The parcel lies between the settlements of Cheshunt to the east and Potters Bar to the south merging of neighbouring west. The settlements are located within approximately 6.5km of each other across the parcel. towns The smaller settlements of Goff’s Oak, Northaw and most notably Cuffley lie between the first tier settlements thereby limiting the perception of separation. There are no connecting features Partial contribution which run directly between the towns. The gap between the towns is relatively fragile due to the presence of the intervening settlements, and the parcel makes a partial contribution to preventing the merging of the towns.

P3: Safeguarding the The land contains the characteristics of open countryside, being predominantly uncontained and countryside from comprising of arable fields. The land is open, containing no urbanising development, and slopes encroachment down from a ridge at the urban edge, marking a strong distinction between settlement and countryside. Significant contribution

P4: Preserve the setting The land forms little or no part of the setting of Welwyn Garden City and does not contribute to and special character of its special character. historic towns

Limited or no contribution

P5: Assist the urban All Green Belt land can be considered to support urban regeneration within Welwyn Hatfield and regeneration, by it is not possible to distinguish which parcels perform this to a stronger or weaker degree. encouraging the recycling of derelict and other urban land Significant contribution

Local purpose: Maintain The parcel lies between the settlements of Cuffley which it adjoins to the north east and Potters the existing settlement Bar to the west. The settlements are located within approximately 3.1km of each other across pattern the parcel. There are blocks of woodland located to the south west of the parcel between the settlements which act as separating features including an area of ancient woodland. The smaller settlement of Northaw lies between Cuffley and Potters Bar thereby limiting the perception of Partial contribution separation. The gap between the settlements is relatively fragile. The land within the parcel plays a partial role in inhibiting the physical and/or visual coalescence of the settlements as the gap is visually open with few separating features.

Assessment of Harm to the Green Belt

Scenario Rating

P87 High Release of the parcel as a whole, or in part (including Stage 2 parcels Cuf4, Cuf5, Cuf 7, Cuf10 and Cuf12, and Local Plan allocations HS29 and HS30)

Comments The parcel is open and rural in character and strongly distinct from Cuffley which slopes down eastwards from the parcel edge. Its release would also reduce the perceived separation between the Tier 1 settlements of Cheshunt to the east and Potters Bar to the southwest as well as the perceived separation between the inset settlement of Cuffley to the east and Potters Bar to the west. A new Green Belt boundary within or bordering the parcel would be weaker than the current ridge crest inset boundary.

16 King & Co

Welwyn Hatfield Green Belt Study 393 August 2018 Appendix 6.1 P87 - Green Belt Study Stage 3 - LUC

PARCEL P87 Green Belt Harm rating Moderate Green Belt parcel Very High Moderate - Low Council boundary High Low E Moderate - High © Crown copyright and database rights 2018 Ordnance Survey LA 100019547 2018.

0 1,000 2,000 m

P87 - Wells Farm, Cuffley 17

Welwyn Hatfield Green Belt Study 394 August 2018 Appendix 6.1 Homes for Herts

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King & Co | Marquis House | 68 Great North Road | Hatfield | Hertfordshire | AL9 5ER www.kingandcompany.co.uk