Homes for Herts

P1 - Hatfield Borough Council Local Plan Consultation Response to P1 Consultation

P1 - Site Location

KNEBWORTH

Brokers WOOLMER Garden P1 GREEN Wood

Heath Field Nature Reserve B197

OAKLANDS

2 King & Co Response to P1 Consultation

Executive Summary

In September 2018 King & Co submitted the relationship between them. This is a to Borough Council contribution in terms of the Inspector’s an Appraisal of Land Use Consultant’s comments about the consistency of (LUC) Stage 3 Green Belt Study, which analysis. highlighted several limitations within LUC’s methodology. This included a Utilising LUC’s analysis of separating review of LUC’s three-point assessment and connecting features, ‘absolute ratings system, which the Appraisal constraints’, and present urbanising concluded did not provide enough influences, the conclusion drawn here separation between comparative results recognises that the southern-most edge (suggesting a ten-point alternative of Parcel 1 (P1) is qualitatively different would be more advantageous), and an from the rest of the parcel; its impact on inconsistent application of subdivision openness obscured by present built-form. across the Borough. The content of this Appraisal was presented during Stage 5 of We also through this report raise the Inspector’s Hearing Sessions. specific points about the application of methodology, because we conclude that We note that whilst the Inspector the boundaries to the east, west and did note that respondents did raise south should be considered as defensible. significant concerns in terms of For the eastern and western boundaries, methodology, he was focused upon the we would also conclude that these should application of that methodology on a be read as absolute constraints. parcel-by-parcel basis. Taking a pragmatic approach, the Inspector decided that This report suggests that the P1 parcel the methodology was sufficiently sound should be sub-divided, which would but did invite respondents to justify result in a different rating of harm. We where parcels should be reconsidered in would encourage that LUC consider the terms of granularity and in terms of the sub-division scenarios we have proposed consistency of the conclusions drawn. for P1. We would also ask that they reconsider their analysis in terms of As such, we do not seek to identify absolute constraints with specific regard or raise matters in respect of the LUC to the railway line and a designated methodology as that will not assist the Ancient Woodland. Inspector. Specifically, the harm ratings that We do however seek to identify where should be attributed to the southern the LUC approach could have taken a part of the parcel in isolation would be different approach to sub-division and considerably lower than the harm rating where this would have resulted in a where the parcel comprised solely of or different and potentially lesser degree of also included the more open parcels of Green Belt harm. land to the north. This should mean that this more modest part of P1 should be This report also identifies (where capable of being released. appropriate) inconsistencies across Purpose Scoring and Harm Ratings, and

P1 - Woolmer Green 3 Green Belt Study Stage 3 - LUC

Extract of Figure 3.1 - Absolute Constraints

4 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 Green Belt Study Stage 3 - LUC

Extract of Figure 7.1 - Assessment of Potential Harm

P31 P3 P2 P32

P4 P34 P33 P1 P5 P35

P15 P6

P30 P36 P1 - Woolmer Green 5

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 P64

P77 P86 P81 P76 P89 P80 P79 P78 P85 P87 P84

P82 P88

P83

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 17 16 15 14 12 13

Brokers Garden WOOLMER Wood GREEN P1

B197 1 3 5 8 2 4 6 7

9 10

Heath Field Nature Reserve 11

OAKLANDS

6 King & Co Site Photographs

Heath Road

1. View looking Northeast towards the rail line and Woolmer Green with Brokers Garden Wood to the left

2. Looking East along Heath Road 3. Looking West towards Brokers Garden Wood

4. Houses along Heath Road 5. Looking East towards Woolmer Green P1 - Woolmer Green 7 Site Photographs

London Road

6. Rail tracks looking North from Heath Road bridge 7. Looking West towards Heath Road bridge

8. Looking North towards Woolmer Green housing 9. Looking Northeast along the B197 London Road

10. Looking Southeast along London Road to Mardley Hill bridge 11. Looking North from Mardley Hill Bridge to Heath Road bridge 8 King & Co Site Photographs

Wych Elm Lane

12. Looking East along Wych Elm Lane 13. Semi-detached housing on Wych Elm Lane

14. Looking West to the rail bridge over Wych Elm Lane 15. Looking Southwest along Bridleway 11 to Brokers Garden Wood

16. View of the site looking South from Wych Elm Lane 17. Looking West along Wych Elm Lane P1 - Woolmer Green 9 P1b Brokers Garden WOOLMER Wood GREEN New Landscape Buffer

P1a

B197

Heath Field Nature Reserve

OAKLANDS

10 King & Co A More Granular Approach

Alternative Development Areas

We propose a more granular analysis of the parcel where Parcel 1 (P1) is split into two sections, with P1a being to the South and P1b being to the North.

P1 is 5.5 hectares (excluding the rail tracks) P1a is approximately 2.6 hectares P1b is approximately 2.9 hectares

P1a is more well contained by existing development and the Absolute Constraints of Brokers Garden Wood to the West and the Tail tracks to the East.

On the following pages we reassess P1 and the sub parcels of P1a and P1b in terms of the Green Belt Purposes and the LUC Harm Ratings.

P1 - Woolmer Green 11 P1 - Green Belt Study Stage 3 - LUC

Parcel Reassessment

The parcel of land P1 is described by LUC Wildlife Sites and Sites listed on the it is contained by woodland in Mardley as follows: ancient woodland inventory. Heath to the west and existing built “The parcel is located on the western development to the south and east.” edge of the inset settlement of Woolmer Through the Hearing Sessions held during Green. The parcel consists of a single November 2018, the Inspector clarified In addition to the above, LUC note that large arable field which slopes gently that other more significant features such release of P1 as it stands preserves “a downhill to the east towards Woolmer as railway lines and trunked roads should degree of distinction between Oaklands Green. There is no development within properly be considered as absolute and and Woolmer Green.” the parcel. The woodland adjacent to the constraints because they provide very Insofar as other parcels are assessed in parcel to the west is ancient woodland substantial permanence. relation to an actual gap, LUC does not and designated as a Local Wildlife Site acknowledge the distinctive closure of and a Local Nature Reserve. As illustrated on page 2 of LUC’s Stage 3 P1 from views along the B197 and a layer Green Belt Study, Parcel 1 is bordered to of trees and foliage that bounds the The parcel directly adjoins residential the west by adjacent ancient woodland parcel when viewed from Mardley Heath. dwellings on the urban edge to the east (Brokers Garden Wood) and southwest by Failure to recognised the subjectivity at Woolmer Green on the other side a Local Wildlife Site and Nature Reserve of P1’s role in inhibiting physical and/ of the railway line and to the south at ‘Heath Field’. To the immediate east a or visual coalescence in turn neglects Oaklands and Mardley Heath. The parcel railway facilitates an urbanising influence whether a gap is at all perceived. is contained by woodland to the west of P1, which is further lessened in rural From key connecting roads a gap is while there is connectivity to the wider character by the presence of residential unobserved. open countryside to the north.” dwellings on the fringe of Woolmer Green. Given P1’s closure on three sides and LUC’s Green Belt Study recognises its location as a natural ‘wedge’ into an that NPPF paragraph 136 states: ‘once In contradiction with LUC’s assessment existing settlement pattern that straddles established, Green Belt boundaries that prospective release of P1 would the Great North Road, the weight given to should only be altered where exceptional represent “encroachment on an area of Purpose 3: safeguarding the countryside circumstances are fully evidenced and open countryside”, its spatial and visual from encroachment is disproportionate justified, through the preparation or openness is reduced by its connectivity to its influence in the wider Green Belt updating of plans.’ It includes reference with the existing settlement edge and context. to ‘absolute constraints’ which they thick, wooded screening from Mardley confined to environmental or heritage Hill. features, including Registered Parks and Gardens, Scheduled Monuments, In their analysis of P1, LUC themselves Special Areas of Conservation, Sites of concede that “release of the site would Special Scientific Interest, Natural Nature not have a significant impact on the Reserves, Local Nature Reserves; Local integrity of the remaining Green Belt as

Analysis in Relation to Purpose Assessment Criteria Purpose P1 LUC Rating Our Rating P1a Our Rating 1 Whole Parcel Limited or no Contribution Limited or no Contribution Southern Part of P1 Limited or no Contribution 2 Whole Parcel Partial Contribution Limited or no Contribution Southern Part of P1 Limited or no Contribution 3 Whole Parcel Significant Contribution Significant/Partial Contribution Southern Part of P1 Partial Contribution 4 Whole Parcel Limited or no Contribution Limited or no Contribution Southern Part of P1 Limited or no Contribution 5 Whole Parcel Significant Contribution Significant Contribution Southern Part of P1 Significant Contribution Local Purpose Whole Parcel Partial Contribution Limited or no Contribution Southern Part of P1 Limited or no Contribution

12 King & Co P1 - Green Belt Study Stage 3 - LUC

Analysis in Relation to Purpose Assessment Criteria - P1a

Purpose 1: To Check the unrestricted conjunction with absolute constraints Purpose 4: Preserve the setting and sprawl of large built-up areas to the west. The parcel therefore special character of historic towns (Limited or no Contribution) contributes in part (but not significantly) (Limited or no Contribution) P1 is sufficiently separated or distant towards preventing the merging of The land forms little or no part of the from large built-up areas for there not neighbouring settlements. setting of and does to be any potential for urban sprawl. not contribute to its special character. Separating features (in addition to P1A is considerably smaller and does The reduction in parcel size will not containment deriving from neighbouring not include the northern areas of the impact upon the purpose rating, that is ‘absolute constraints’) reduces the parcel which (whilst still having absolute already at its lowest level. parcel’s relationship with the local constraints on both sides are somewhat countryside. P1A would lessen that effect, more open). P1A would therefore lessen Purpose 5: Assist the urban but it is already at the lowest level. these effects so the contribution reduces regeneration, by encouraging the to “limited or no contribution”. recycling of derelict and other urban Purpose 2: Prevent neighbouring towns land from merging Purpose 3: Assist in safeguarding the (Significant Contribution) (Limited or no Contribution) countryside from encroachment All Green Belt land can be considered P1 lies between the Tier 1 settlements (Partial Contribution) to support urban regeneration within of to the north and Welwyn Due to the presence of absolute Welwyn Hatfield and it is not possible to Garden City to the south. Both Tier constraints and separating features (such distinguish which parcels perform this to 1 settlements are located within as tall, dense cohesive woodland), P1 a stronger or weaker degree. approximately 6.6km of each other does not experience a strong connection The reduction in parcel size will not across the parcel. The settlements of to open countryside and does not impact upon the purpose rating, that is , Woolmer Green, Oaklands, compromise openness to the north to any already at its lowest level. Mardley Heath, Welwyn, Harmer Green significant degree. Given its containment, Local Purpose: To maintain the existing and lie between the first-tier the land itself relates strongly to the settlement pattern (Limited or no settlements. settlement edge. Against the ‘Significant Contribution) Contribution’ Purpose Rating assigned by The LUC report refers to the railway LUC, the notion of its ‘open countryside’ LUC suggest that “…The parcel adjoins line being identified as a connecting characteristics contradicts with its the northern edge of Mardley Heath and feature which are given less weight logical relationship with the settlement faces Woolmer Green across the railway than absolute constraints. The Inspector boundary. We would therefore conclude line, but its role in settlement separation clarified through the Hearings that that the parcel in its entirety should is imited by the fact that along the B197 features such as railway lines, trunk roads be downgraded from “Significant to the south the two villages are already and ecological designations should be contribution” to what would effectively separated only by the railway line. The identified with the status of absolute be a hybrid of “Partial and Significant”. parcel also lies between Oaklands and constraint. As such, the key constraints This is a regrettable consequence of a Mardley Heath and Knebworth, although to the east (railway line) and west scoring system that lacks finesse. Woolmer Green to the east of the railway (designated Ancient Woodland) between P1A is considerably smaller and does has already narrowed the gap between the settlements should be afforded more not include the northern areas of the the settlements.” weight. parcel which (whilst still having absolute constraints on both sides are somewhat The reduction in parcel size will not Although LUC have assessed this as more open. P1A would therefore lessen impact upon the purpose rating that is a ‘fragile gap’, P1’s role in settlement these effects so the contribution reduces already at its lowest level. separation is limited by the to “partial contribution”. aforementioned physical features in

P1 - Woolmer Green 13 P1 - Green Belt Study Stage 3 - LUC

Analysis in Relation to Green Belt Harm (P1 and P1a)

We feel that the LUC conclusions in Analysis in Relation to Green Belt Harm terms of the harm arising from the Parcel Description LUC Harm Rating Our Harm Rating release of P1 as drawn are overstated, P1 Whole of Parcel P1 High Moderate-High and perhaps stem from a view in terms P1a Southern Part of P1 Not Assessed Moderate-Low of absolute constraints that downplays P1b Northern Part of P1 Not Assessed Moderate-High the permanence and importance of the PARCEL P1 railway line. Green Belt Harm rating Moderate Green Belt parcel Very High Moderate - Low More fundamentally, theCouncil reduction boundary in the High Low E scale of development and its relocation Moderate - High © Crown copyright and database rights 2018 Ordnance Survey LA 100019547 2018. PARCEL P1 Greenaway Belt from the moreHarm open rating northern Moderate Greenelements Belt parcel would result inVery a parcel High which Moderate - Low is much more capable of sustaining Council boundary High Low development in Green Belt terms. The E © Crown copyright and database rights 2018 Ordnance Survey LA 100019547 2018. Moderate - 0High 350 700 areas to the north of the identified parcel m P1A are considerably more sensitive.

0 350 700 m P1b

P1a

Moderate-Low P1a - Southern part of P1 Moderate-High P1b - Northern part of P1

14 King & Co

Welwyn Hatfield Green Belt Study 5 August 2018 Appendix 6.1

Welwyn Hatfield Green Belt Study 5 August 2018 Appendix 6.1 P1 - Green Belt Study Stage 3 - LUC

Analysis in Relation to Green Belt Harm

View of P1a from the Southwest

View of P1b from the North P1 - Woolmer Green 15 P1 - Green Belt Study Stage 3 - LUC

P1 7.2ha

16 Welwyn Hatfield Green Belt Study 2 August 2018 KingAppendix & 6.1 Co SustainabilityP1 - Green Belt Appraisal Study Stage 3 - LUC

Site P1

View looking northeast from the south west of the parcel

Parcel Description The parcel is located on the western edge of the inset settlement of Woolmer Green. The parcel consists of a single large arable field which slopes gently downhill to the east towards Woolmer Green. There is no development within the parcel. The woodland adjacent to the parcel to the west is ancient woodland and designated as a Local Wildlife Site and a Local Nature Reserve.

The parcel directly adjoins residential dwellings on the urban edge to the east at Woolmer Green on the other side of the railway line and to the south at Oaklands and Mardley Heath. The parcel is contained by woodland to the west while there is connectivity to the wider open countryside to the north.

Welwyn Hatfield Green Belt Study 3 P1 - Woolmer AugustGreen 2018 17 Appendix 6.1 P1 - Green Belt Study Stage 3 - LUC

Site P1 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 first tier settlements of Stevenage to the north and Welwyn Garden merging of neighbouring City to the south. The settlements are located within approximately 6.6km of each other across towns the parcel. The settlements of Knebworth, Woolmer Green, Oaklands and Mardley Heath, Welwyn, Harmer Green and Digswell lie between the first tier settlements. Connecting features Partial contribution between the settlements include the railway line which runs along the eastern boundary of the parcel and the A1M (which lies to the west but does not pass through the parcel). The gap between the settlements is relatively fragile as the areas of openness between the inset settlements are no more than 500m apart. The parcel forms part of the gap between Oaklands and Knebworth but its role in settlement separation is limited by the fact that along the B197 to the south Woolmer Green and Oaklands are already separated only by the railway line.

P3: Safeguarding the The land contains the characteristics of open countryside as it is an open arable field and lacks countryside from any urbanising development. encroachment

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 adjoins the northern edge of Oaklands and Mardley Heath and faces Woolmer Green the existing settlement across the railway line, but its role in settlement separation is limited by the fact that along the pattern B197 to the south the two villages are already separated only by the railway line. The parcel also lies between Oaklands and Mardley Heath and Knebworth, although Woolmer Green to the east of the railway has already narrowed the gap between the settlements. Partial contribution

Assessment of Harm to the Green Belt

Scenario Rating

P1 High Release of all, or part of parcel

Comments Release would represent encroachment on an area of open countryside that contributes to preserving a degree of distinction between Oaklands and Mardley Heath and Woolmer Green. Release of the site would not have a significant impact on the integrity of the remaining Green Belt as it is contained by woodland in Mardley Heath to the west and existing built development to the south and east. Its release would however result in a less clearly defined boundary to the north of the parcel.

18 Welwyn Hatfield Green Belt Study 4 August 2018 KingAppendix & 6.1 Co P1 - Green Belt Study Stage 3 - LUC

PARCEL P1 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.

0 350 700 m

Welwyn Hatfield Green Belt Study 5 P1 - Woolmer AugustGreen 2018 19 Appendix 6.1 Homes for Herts

For further information, contact:

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