Consultation Statement

Local Plan Consultation Document 2015

August 2016

Consultation Statement:

Local Plan Consultation Document 2015

August 2016

Colin Haigh Head of Planning Welwyn Hatfield Borough Council Council Offices The Campus Welwyn Garden City Hertfordshire AL8 6AE

Tel: 01707 357000 Fax: 01707 357285

E Mail [email protected]

Contents Introduction 1

Statement of community Involvement 1

How we consulted 3 Targeted consultation 4 Other consultations 4

Participation levels 5 Summary of main issues and the Council’s response 6

Introduction 7

Part 1 Strategic Policies 10 Emerging Core Strategy 11 Policy CS2 Meeting the Needs for Growth 13 Policy CS2 Meeting the Needs for Growth – Housing 22 CS2 Meeting the Needs for Growth - Figure 1 – Housing Market Area 29 Policy Intention CS2a – Housing Target 30 CS2 Meeting the Needs for Growth – Employment 36 Policy Intention CS2B Employment Land and Job Growth 40 CS3 Settlement Strategy 43 Table 1 – Potential distribution of housing growth 53 Policy Intention CS3 58 CS4 Green Belt Boundaries and Safeguarded Land – CS4 and Policy Intention CS4 64 Movement Strategy and New Policy Intention Movement 80 CS19 Strategic Green Infrastructure and Policy Intention CS19 86 Spatial Policies and Spatial Policies Intention 90

Part 2 Sites 93 Section 10 Welwyn Garden City, Welwyn Garden City Housing and Table 4 94 10 Welwyn Garden City Site Pea94 Bridge Road East 100 10 Welwyn Garden City Site WGC1, Creswick 101 10 Welwyn Garden City Site WGC4, Panshanger Aerodrome 104 Site WGC5 and Appendix A finely balanced site 114 Appendix B Less Favourable Sites – Welwyn Garden City – Site WGC3, The Holdings, Cole Green Lane 122 Appendix B Less Favourable Sites – Welwyn Garden City – Site WGC6, East of Digswell Hill 123 10 Welwyn Garden City - Gypsy and Traveller Sites 124 10 Welwyn Garden City Gypsy and Traveller Sites and Site GTLAA06, Panshanger Aerodrome 126 10 Welwyn Garden City Table 5 - Sources of housing supply for WGC 129 10 Welwyn Garden City – Employment 131 10 Welwyn Garden City Town Centre Strategy, Figure 7 (Town Centre Boundary Map), Retail Frontages, Development sites in the Primary Retail Core, Welwyn Garden City Town Centre North133 10 Welwyn Garden City - Urban Open Land 135 10 Welwyn Garden City – Site Hal02, Land at Waterside 136 10 Welwyn Garden City – Site Hal03, Ratcliff Tail Lift Site 138 10 Welwyn Garden City – Site Hol19, Hyde Valley House & First House 139 10 Welwyn Garden City – Site Pan01, Land between Bericot Way and Waterbeach 140 10 Welwyn Garden City – Site Pan02, Land behind 1-17 The Poplars 141 10 Welwyn Garden City Site Pea08, Land adjacent to Ravenfield Road 142 10 Welwyn Garden City Site Pea24, St Michaels House and Day Centre, Holwell Road 143 Section 11 - Hatfield 144 11 Hatfield - Housing 147 11 Hatfield – Employment 150

11 Hatfield Town Centre Strategy, Definition of Town Centre Boundary and Sub Areas, Figure 21 (Hatfield Town Centre Boundary Map), Retail Frontages, Development Sites in the Primary Retail Core 151 11 Hatfield – Large Neighbourhood Centres and Small Neighbourhood Centres 152 11 Hatfield– Urban Open Land 153 11 Site HE23, Factory adjacent to Wellfield Road Depot 154 11 Hatfield – Site HS12, Garages off Garden Avenue 156 11 Hatfield – Site HS31, Garages off Hollyfield 157 11 Site HW12 Land North of Toms Field 158 11 Site Hat1 North West Hatfield 159 Appendix A - Finely balanced sites – remainder of Hat1, North West Hatfield 164 11 Site Hat 2 West of Hatfield 165 Appendix A Finely balanced sites – remainder of Hat2, West of Hatfield 171 Appendix B Less Favourable Sites – Hatfield – Site Hat3, West of Ellenbrook 172 Appendix A Finely Balanced Sites – Hatfield Site Hat4 Land south of Ellenbrook 174 Appendix A Finely Balanced Sites – Hatfield – Site Hat5, North of Roehyde 178 Appendix B Less Favourable Sites – Hatfield – Site Hat11, South of Hatfield 183 Appendix B Less Favourable Sites – Hatfield – Site Hat12, Nast Hyde Farm 185 11 Hatfield - Gypsy and Traveller Sites 186 11 Hatfield – Table 7 – Sources of housing supply for Hatfield 187 12 Woolmer Green 188 12 Woolmer Green – Housing 191 12 Woolmer Green Site WGr1, East of Great North Road 192 Appendix B Less Favourable Sites – Woolmer Green – Site WGr3, Land adjacent to 52 London Road 195 Appendix B Less Favourable Sites – Woolmer Green – Site WGr4, Land in front of 17 Twin Foxes 197 Appendix B Less Favourable Sites – Woolmer Green – Site WGr5, Land in front of 9 Twin Foxes 198 12 Woolmer Green – Employment 199 13 Oaklands & Mardley Heath - Housing and Table 10 - Summary Table – Oaklands & Mardley Heath Capacity 200 13 Oaklands & Mardley Heath– Site WE01, 52 Great North Road 202 13 Oaklands & Mardley Heath – Site WN11, 17 Canonsfield Road 203 13 Oaklands and Mardley Heath – Site OMH5, Land rear of 1-12 Great North Rd and Site OMH8, Great North Rd 204 Appendix B Less Favourable Sites – Oaklands and Mardley Heath – Site OMH7, Land at 22 The Avenue 206 13 Oaklands and Mardley Heath – Gypsy and Traveller Sites and GTLAA04, Four Oaks 207 13 Oaklands & Mardley Heath – Village Centre 210 13 Oaklands & Mardley Heath – Urban Open Land 211 Section 14 Welwyn 212 14 Welwyn – Table 12 - Summary Table – Welwyn Capacity 214 14 Welwyn – Site Wel3, School Lane 215 14 Welwyn – Site Wel4, Sandyhurst 217 14 Welwyn – Site Wel11, The Vineyards, Codicote Road 219 Appendix A Finely Balanced Sites – Welwyn – Site Wel1, Land at Kimpton Road 221 Appendix A Finely Balanced – Welwyn Consultation Point – Site Wel2, Land east of Welwyn Cemetery 223 14 Welwyn – Village Centre 225 14 Welwyn – Urban Open Land 226 Section 15 Digswell – Housing 227 Appendix B Less Favourable Sites –Digswell - Site Dig1, Land behind 2 New Road 228 Appendix B Less Favourable Sites – Site Dig4, Land at Digswell Road and Bessemer Road 233 15 Digswell – Village Centre 235 Section 16 Welham Green 236 16 Welham Green – Housing and Table 16 points 239 16 Welham Green – Employment – Site WeG4b – Marshmoor 244 16 Welham Green – Site WeG1, Welham Manor House 249 16 Welham Green – Site WeG2 – Welham Manor Grounds 252 16 Welham Green – Site WeG3 – South of Welham Manor 254 16 Welham Green – Site WeG6 – Skimpans Farm 257

16 Welham Green – Site WeG10 – Dixons Hill Road 262 Appendix A Finely Balanced Sites – Welham Green – Site WeG4a, Marshmoor 265 16 Welham Green – Gypsy and Traveller Sites 267 16 Welham Green – Site GTLAA01 – Foxes Lane 269 16 Welham Green – Site GTLAA02 – Highdene 271 16 Welham Green – Site GTLAA03 – The Willows 272 17 Brookmans Park 273 17 Brookmans Park – Housing 276 17 Brookmans Park – Table 18 Summary Table - Brookmans Park Capacity 279 17 Brookmans Park – Site BrP14, Land East of Golf Club Road 280 Appendix A Finely Balanced Sites Brookmans Park – Site BrP1, Land at Bell Lane 282 Appendix A Finely Balanced Sites Brookmans Park – Site BrP4, West of Brookmans Park 285 Appendix A Finely Balanced Sites Brookmans Park – Site BrP6, Land at Bluebridge Road 288 Appendix A Finely Balanced Sites – Brookmans Park – Site BrP12, Peplins Wood 17 291 Appendix B Less Favourable Sites – Brookmans Park – Site BrP2, Land North East of Great North Road 294 Appendix B Less Favourable Sites – Brookmans Park – Site BrP9, Friday Grove 296 Appendix B Less Favourable Sites – Brookmans Park – Site BrP10, Raybrook Farm 298 Appendix B Less Favourable Sites – Brookmans Park – Site BrP13, Land West of Golf Club Road 300 18 Little Heath 302 18 Little Heath – Housing 304 18 Little Heath – Site BPLH30 – Land to the rear of Builders Arms Public House 306 18 Little Heath – Site LHe1 – Land North of Hawkshead Road 307 18 Little Heath – Site BrP7, Land South of Hawkshead Road 312 18 Little Heath – Employment 319 19 Cuffley 320 19 Cuffley Housing and Table 23 Sources of housing supply for Cuffley 322 19 Cuffley – Site No02, 36 The Ridgeway and land to the rear 324 19 Cuffley – Site No10, Land west of St Martin de Porres Catholic Church 325 19 Cuffley – Site Cuf1, The Meadway 326 Appendix A Less Favourable Sites – Cuffley – Site Cuf4, Cuffley Hills Farm 329 Appendix A Less Favourable Sites – Cuffley – Site Cuf5 Land West of Northaw Road East 331 Appendix A Less Favourable Sites – Cuffley – Site Cuf7 Wells Farm 333 Major Developed Sites and Policy Intention on Major Developed Sites 335 Cemeteries 336 Cemeteries Site CEM01 337 Cemeteries Site CEM02 338

Part 3 Development Management Policies 339

Appendix C – Sites that failed the first SHLAA test 348 Appendices 350

Appendix A 351

Appendix B 359

Appendix C 362

Appendix D 363

Appendix E 364

Appendix F 365

Appendix G 367

Introduction

Consultation on the Local Plan Consultation Document 2015 (LPCD 2015), the Sustainability Appraisal and the Draft Infrastructure Delivery Plan 2015 (IDP 2015) took place between 23 January and 20 March, 2015.

This statement sets out which bodies and persons were invited to make representations to that consultation under Regulation 18 of the Town and Country Planning (Local Planning) (England) Regulations 2012 as amended, how those bodies were invited to make such representations, a summary of the main issues raised by those representations, and how those main issues have been addressed in the Local Plan Proposed Submission 2016 in accordance with Regulation 17 of the aforementioned Regulations.

Statement of community Involvement

Welwyn Hatfield Statement of Community Involvement (SCI), adopted 3 December 2013, sets out how the Council will involve the community in plan-making and when considering planning applications. With regard to Local Plan preparation, the SCI explains when the Council will consult the community; how the Council will engage with them; and who the Council will involve. The SCI sets out the following activities relevant to preparing the Local Plan:

Stage 1 – Prepare Plan

What  As a minimum, the Council will ensure that the Council comply with the will we relevant current planning regulations. The Council will consult more widely do where it is relevant and appropriate to do so  The Council will advertise any consultation and make it clear where material can be viewed by the community  When possible, summary documents, maps and diagrams explaining the key issues and proposals will be published  The Council will maintain and add people to our planning database at any time  Comments received at this stage will be taken into account, together with any available technical evidence as well as national policies and guidance

Who  The Council will notify specific consultation bodies that may have an interest will we  The Council will engage with general consultation bodies, and other consult consultation bodies as appropriate.  The Council will consult with the wider community at least once during this stage in the production of the document.  The list of Duty to Cooperate, specific and general bodies and other key stakeholders that were notified of the consultation is set out in Appendix A  In total, around 4380 individuals, bodies and organisations were notified of the consultation and invited to make representations. Notification of additional consultation events was also issued by letter and email (copies of letters/emails are set out in Appendix B) How The Council will use a range of types of consultation during this stage in order to will we understand key issues and views. Methods will include one or more of the consult following:

 Surveys and questionnaires  Correspondence through letters or email  Workshops or focus groups  Drop-in events, displays or exhibitions  Meetings (one to one or group)  Make plans available on our website and at public inspection points  (Council offices and local libraries)  Targeted measures for hard to reach groups

How we consulted

A variety of consultation methods were used to raise awareness of the consultation and engage with specific and general consultation bodies, other key stakeholders and the wider community. (Refer to Appendix B and as indicated below where relevant).

 The LPCD 2015 (and a range of associated papers) was make available on the Council’s consultation portal1  The LPCD 2015 was made available at various inspection points across the borough (Appendix C)  Email or letter notification to the several thousand residents registered on the Council’s consultation database;  A series of drop-in events were held in Brookmans Park; Cuffley; Welwyn; Welwyn Garden City, Hatfield, Welham Green and Little Heath (Appendix D).  A notice was placed in the Welwyn Hatfield Times and Hertfordshire Mercury advertising the consultation and drop-in events (Appendix E);  The Autumn/Winter 2014 edition of the Council’s Life Magazine was delivered to every household in the borough and contained a double page article on the Local Plan (See Appendix F);  The LPCD had extensive coverage on local radio (Bob FM) with extracts of interviews with Councillors broadcast in early 2015;  An easy to read summary guide was posted on the Council’s consultation portal as a supporting document to the LPCD 2015 (link at footnote 1);  Flyers were distributed to the various inspection points (Appendix G);  Posters were displayed at various locations throughout the borough including libraries, Council and town and parish Council office; some local shops also agreed to display the posters;  The Local Enterprise Partnership and Local Nature Partnership was made aware of the LPCD 2015 consultation by letter and invited to comment.  Members of the Welwyn Hatfield Alliance (the Local Strategic Partnership) were advised of the consultation  Parish and Town Councillors were notified of the consultation and Parish/Town clerks were briefed by officers of the Council. All the documents, together with posters, flyers, and response forms were sent to their offices;  Presentation to Church of England Deanery Synod of Welwyn Hatfield by officers and Councillors  The Press were briefed, resulting in the Welwyn Hatfield Times running a number of articles, together with letters published in the local press;  The consultation was publicised on the Council’s Facebook and Twitter pages to encourage responses from younger people.

1 http://consult.welhat.gov.uk/portal/planning_policy/local_plan_consultation_january_2015/loca l_plan_consultation_january_2015?tab=info

During and after the LPCD 2015, a number of new sites were promoted and amendments made to existing sites within the LPCD 2015. The Council undertook awareness raising of these new and amended sites in the following ways:

 Two drop-in events (Hatfield on the 20th October 2015 and Welwyn Garden City on 11th November 2015) where information on the new and amended sites was made available.  Emails and Local Plan Newsletter (October 2015) were sent to the several thousand residents registered on the Council’s consultation database notifying them of the drop-in events and the information on the Council’s website  The Press were briefed, resulting in the Welwyn Hatfield Times running a number of articles, together with letters published in the local press.  Information on the new and amended sites was published on the Council’s Local Plan webpages.

In response, a number of letters, emails and petitions were received until the Local Plan Proposed Submission was taken to Cabinet Housing and Planning Panel in July 2016.

Other letters and emails on the Local Plan (but not specifically related to the new and amended sites) were also received during this time, and meetings with various community organisations and parish Councils to discuss the Local Plan also took place.

Targeted consultation

A range of consultation methods (e.g. summary guide, use of the Council’s website and social media channels) and locations for events were chosen to help reach under-represented and hard to reach groups and meet the requirements of the Statement of Community Involvement. The approach taken recognised that different individuals and organisations may want to be involved in different ways. A presentation was also made to students of the University of Hertfordshire.

The Council also consulted all of the bodies on the Local Plan database that represent the interests of ethnic minority and religious groups.

Other consultations

The Council organised and ran a number of stakeholder workshops during 2015 and 2016 on the concept of the Green Corridor and on garden city principles for Welwyn Garden City, the outputs of which were used to inform a number of objectives, policies and guidance within the Local Plan Proposed Submission document.

The Hatfield Visioning project was also instigated by the Hatfield Renewal Partnership, of which the Council is a member, during 2015 and 2016, with a number of consultation and engagement exercises taking place. Many of the outputs of these exercises informed the Hatfield section of the Local Plan Proposed Submission document.

Participation levels

Around 5,481 comments on the LPCD 2015 from 1,597 individuals and organisations, with a further 297 comments on the IDP 2015 from 79 individuals and organisations and 102 comments on the Sustainability Appraisal of the LPCD 2015 from 34 individuals and organisations.

All but 5 of the respondents to the IDP 2015 and all but 1 of the respondents to the Sustainability Appraisal had also commented on the LPCD 2015. The total number of respondents across all three documents was therefore 1,603.

In addition to a number of standardised responses, two petitions were received:

 501 signatures opposing development around Ellenbrook in Hatfield;  238 signatures opposing ‘urban sprawl’ and advocating the development of a new garden city as an alternative.

Summary of main issues and the Council’s response

The follow section sets out, for each of the consultation points in the LPCD 2015, a summary of the main issues raised by respondents followed by a summary of how the Council has responded to those issues in the preparation of the Local Plan Proposed Submission Document 2016 (the LPPS 2016).

Introduction

Number of responses received: 29 (General 4, Support 4, Object 21)

Support o Welcome constructive approach taken to identifying a local housing requirement and to Green Belt release to allow for development to meet future needs (Hertsmere Borough Council). o Whilst supporting the document in the main there are a number of site specific comments (Hertfordshire County Council). o Support the general approach taken by the Council (St Albans Diocese). o Welcomes the review of evidence on which the Local Plan is to be based and significant changes to the consultation document which have taken into account the NPPF, responses to previous consultations, a review of the evidence and best practice (Oshwal Association UK).

Main Issues

Document content and preparation o The Local Plan is well-written and explains the options clearly (Wheathampstead Parish Council). o Request we be informally consulted upon before proposed submission (Environment Agency) o The document should set out general information on minerals and waste, including the county Council responsibilities in this area (Hertfordshire County Council ). o Plan period is unclear (Homes Building Federation). o It would have been helpful to include the previous policies from the Emerging Core Strategy. o Excluding finely balanced and less favourable sites from the main body of text and site details from the summary or exhibition has resulted in a flawed process with only limited feedback on these sites (Living Villages). o Lack of any section for comments on more favourable sites.

Consultation process o Unclear why previous consultation responses have not led to a different strategy particularly for Panshanger where proposals are nearly identical to the Emerging Core Strategy. o Views of local residents not taken into account. Consultation responses have not shaped the plan. There is no collective vision for Hat 1 Hat2 and WGC4 or an agreed set of priorities. o Because of a conflict of interest the people of Panshanger had no one to speak for them o Little Heath residents were not properly notified /had no opportunity to engage in the process.

7 o Concern that local people have been excluded from /were unaware of the consultation. SCI policies do not appear to have been followed (Panshanger People and others). o Consultation not widely publicised. Poor awareness of the document, lack of debates and focus groups. People were not allowed the opportunity to speak o Consultation needs to be simpler if the Council expect people to respond. o Over reliance on consultation database and online portal. Not everyone uses email. Access to hard copies is difficult. No letters sent to residents or reference to Panshanger in the adverts (Panshanger People). o Extend the consultation to allow comments on the more favourable sites. o Local Councillors should represent their constituents and not ignore their pleas and should not be allowed to wear two hats if there is a conflict. o All households should receive a detailed submission.

How these views have been taken into account

Dialogue with the Environment Agency through the Duty to Co-operate has informed policy drafting. Paragraph 2.9 of the LPPS 2016 notes the County Council’s responsibility for minerals in the county. Paragraph 14.36 acknowledges their role as minerals and waste authority.

The Council indicate the plan period, 2013 to 2032, in various parts of the plan, including Policy SP 2 Growth.

The LPCD 2015 included former ECS policies which have been revised or are to be revised but excluded ECS policies where no significant change was anticipated.

Consultation process

The Council has consulted in line with the Statement of Community Involvement and will continue to do so in future. For the submission stage responses are invited by hard copy, e mail and online. This choice was also available to those who wished to respond to the LPCD 2015. The Council will publicise local plan consultations in line with the Statement of Community Involvement. A consultation statement will summarise how the consultation was carried out in light of the SCI, key issues raised and how consultation responses have been taken into account in drafting the Plan.

Consultations are on occasion extended and exceed the statutory period as happened for the LPCD 2015 and Emerging Core Strategy and the Council intends to exceed the statutory period (6 weeks) for the proposed submission plan allowing 8 weeks for responses.

With regard to summary documents the Council aim to ensure these broadly represent the key content from the Local Plan. However, inevitably for reasons of conciseness and brevity such documents are selective and cannot cover every aspect of the Local Plan.

The LPPS 2016 sets out a vision for the borough as a whole and a separate vision for Welwyn Garden City and for Hatfield. As well as borough wide objectives, local objectives have been developed for Hatfield. The Council is part of a wider group of

8 key stakeholders who have come together to develop a strategy for the town's renewal.

Part 1 Strategic Policies

Emerging Core Strategy

Number of responses received: 10 (General 1, Support 3, Object 6)

Support o Supports statements in paragraphs 2.4 -2.6 with regards to the interpretation of recent Local Plan decisions, meeting housing need and the impact of development o Support Emerging Core Strategy aim to protect areas of highest environmental value o Reaffirm support for Local Plan strategic policies the University sees as important objectives and measures to deliver sustainable growth and development

Main Issues o Refer to previous comments on ECS strategic policies (Historic England). o The review of strategic policies has not sufficiently reflected on the social dimension. The Plan should refer to cultural heritage. Will be found unsound without an infrastructure assessment of the needs of the Oshwall Association. Amend to set out how it has been positively prepared to meet the needs of the Oshwall Association and its community o Misinterprets government advice on development in the Green Belt and the need to meet OAN. Because the approach is dispersed harm to the Green Belt is spread across the borough o Redevelopment of Panshanger Aerodrome would result in the loss of community facilities, biodiversity and the historic environment and reduce the character of the town. o Disagree that exceptional circumstance exist for building in the Green Belt. o The Sustainability Appraisal notes that certain ecological and wider environmental resources will be detrimentally affected. Expect to see a rigorous approach to site selection and mitigation o Stronger recognition needs to be given to the role of the University o Reconsider and reduce the scale of proposed housing development). o Spread development across the borough to give a fairer distribution. o Build a new Garden City.

How these views have been taken into account

The Council has updated policy and supporting text (LPPS 2016) to better acknowledge the role and presence of the University, e.g. paragraph 2.2 and Policy SP 21 University of Hertfordshire (formerly CS 17).

The LPCD 2015 proposed a more dispersed, proportionate approach to distributing development in the borough than the ECS. The LPPS 2016 continues with this approach, with some refinement, including, for example, a proposed new village ‘Symondshyde” north west of Hatfield.

Green Belt

A Strategic Green Belt review has been carried out to assess Green Belt land across Dacorum, St Albans and Welwyn Hatfield Council areas (November 2013). The Welwyn Hatfield Green Belt Stage 2 Review (October 2014 and as subsequently updated through an addendum) then assessed Green Belt sites in terms of their contribution to these purposes and considered the strength of each site boundary and its overall contribution to the openness of the Green Belt. These reviews informed the LPCD 2015 and have informed the LPPS 2016.

The LPPS 2016 explains that having taken into account the supply of housing through completions, urban capacity, sites with planning permissions and a windfall allowance, the Council concluded that a strategy that would constrain housing growth to sites within the borough's urban areas would mean that there would be a significant shortfall of housing when considered against the Objectively Assessed Need. Therefore, achieving sustainable development within the borough without impinging on the Green Belt has been unavoidable and Green Belt boundaries have been amended, where exceptional circumstances existed, in order to achieve sustainable development in the borough.

Objectively Assessed Need

The LPPS 2016 housing target falls short of the full Objectively Assessed Need, although it represents a significant step change, with an increase (of 55%) in annual delivery compared with past rates of development in the borough (completions between 2001 and 2015).

Community infrastructure requirements are addressed in broad terms in the Draft Infrastructure Delivery Plan 2016 (IDP 2016) and where appropriate, site specific and wider plan policies.

Policy CS2 Meeting the Needs for Growth

Number of responses received: 405 (General 7, Support 4, Object 394)

Support o Broadly support approach and methodology used to calculate Objectively Assessed Need o Support the adjustments made to the SHMA to account for market signals, affordable housing need and the growth needs of the economy o Support the separation of the need for Use Class C2 from the housing figure o The Plan generally complies with soundness tests but the housing requirement for the borough must reflect needs outside the area and the duty to cooperate must met in full o Don’t object to housing. People have to live somewhere, provided it doesn’t grow into a large town. o Open land between settlements has the potential to act as wildlife, landscape and amenity corridors

Main Issues o Draft Local Plan does not set out phasing and delivery. Will be required in order to undertake infrastructure delivery strategy and viability assessment o Support managed growth provided it doesn’t prejudice the implementation of the airport’s approved development and increase in passenger numbers. Disappointed the Plan does not refer to the LLA within the area. Should consider future flight paths with regard to site allocations and liaise with us before selecting options for development.

Green Belt o Employment sites will need exceptional circumstances to justify altering the Green Belt boundary o Open land development will impact upon ecological functions to a greater or lesser extent. Avoiding coalescence helps to reduce further ecological fragmentation o Development areas should abut an existing settlement boundary and not result in coalescence. Avoiding coalescence helps limit ecological fragmentation. For each site, consider the impact of developing open land on ecological functions o Housing target too high. Demand for housing will destroy the purpose of the Green Belt - to constrain urban sprawl and prevent coalescence of settlements o The Green Belt is a much valued and appreciated asset for the well-being of all. o Fails to address Green Belt development is only permitted in exceptional circumstances and does not state adverse social and economic consequences o Meeting housing numbers is not an exceptional circumstance. Green Belt constraints have not been taken into account. Housing need does not justify harm to the Green Belt. Eric Pickles MP has stated that Councils should safeguard their area against urban sprawl, protecting the green lungs around towns and cities

13 o Excessive number of homes in the Green Belt. Disproportionate loss of Green Belt land. o North Mymms sites serve an important Green Belt function o WH Stage 2 Green Belt Review states that nearly half the sites assessed make a significant contribution to the Green Belt (encroachment o Retain New Barnfield and Marshmoor in the Green Belt o WeG10 has been put forward by the Council without the owner’s consent o Future generations should be able to enjoy the countryside. o Concentrate new housing in existing built up areas on brownfield sites and retain the Green Belt. o Less emphasis on economic growth and fewer incursions into the Green Belt.

Environmental Sustainability o Building on Green Belt will affect the character of the district, reduce access to countryside, harm wildlife, reduce biodiversity and result in a loss of high grade agricultural land, which the Sustainability Appraisal recognises is unsustainable o This is a water stressed area. Developing on Green Belt will reduce water levels further. Environmentally unsound. o Would be more sustainable to build at higher densities on employment land near town centres – attracting younger people to WGC and keeping the town centre alive. o Loss of agricultural land – needed to contribute to our economy and enhance food security. o Buy-to-let demand will not support community and social spirit. o Loss of wildlife, habitats and biodiversity– once it’s gone, its lost forever. Harm to biodiversity from urbanisation, restricting animal movement and dispersal of plants. o Question the removal of WS94 as a wildlife site (WeG6) o Open space is vital for human health. Less open space will reduce our quality of life. o Flooding in villages of concern. Surface water flooding and surface water run-off will increase. o Continuing to provide mass housing will lead to more demand until vast areas of the countryside are built on, leading to flooding and pollution. o Should improve the area and resist anything that degrades or significantly alters the area.

Settlement pattern / distribution of growth o Villages should share in meeting the needs for growth. Greater equality across the borough – share in meeting the needs for growth. o Villages should provide for housing and Gypsy and Traveller sites. o Use golf courses for housing. o School playing fields have been lost to housing leaving no areas for children to play sport. o Proposals will change the character of the area. o Plan should promote fair, equitable development taking into account people and the environment.

14 o Increasing Little Heath by 40% (land size) is disproportionate. Accept the need for an equitable distribution but not on the basis of dwellings. Little Heath has 20% of the land area of Brookmans Park. On this basis, the OAN for Little Heath should be 70, not 140 (or 20 when compared to the whole borough). Distance from centres: Little Heath has no centre, its nearest being Potters Bar, 1.1 miles from BrP7. o Brookmans Park cannot expect to be treated as a privileged oasis – we are all in this together. It has a railway station with car park and would be an ideal place to build a community. o Look at areas with infrastructure and transport links. Develop in suitable locations such as Welham Green and Brookmans Park which are served by underused stations, reducing reliance on cars. o Welwyn Garden City was designed for around 30,000 people. The New Towns Act planned for 40 – 50,000. By 2013, it was 48,300. A further 3,969 dwellings will bring the population to around 57,400. o Allow smaller scale sites on existing developed land, e.g. within gardens. o Use brownfield sites first. o Use unoccupied dwellings. o Economic activity and new housing will continue to concentrate in the south east to the detriment of the rest of the country. Direct growth northwards to Scotland or northern England. o Build a new Garden City in the north of Hertfordshire on non Green Belt land that doesn’t result in piecemeal expansion of settlements or the removal of land from the Green Belt.

Housing target and Objectively Assessed Need o No view on the level of growth but all growth should aim to create healthy communities o Basis of WHBC SHMA and the Housing Market Area unclear. Concern about how HMA needs are apportioned between sub-areas. Suggest the Local Plan reflects the SHMA, para. 9.107 which states treat the HMA figure with caution given assumptions used to derive it o The Plan says there are insufficient sites to meet needs in full but some finely balanced sites could be considered suitable o The OAN is uncertain given employment-led projections show a requirement for up to 800 dwellings per year. The Local Plan should explain how the OAN relates to planned employment numbers o The OAN of 625 underestimates housing need. The Local Plan does not explain why the target may be below the OAN. o Allocate sufficient housing land to meet ‘objectively assessed needs’ o Housing target too high. Should be 8,000. Can be lower than OAN when assessed against the NPPF. o Change the housing target to 6,000. o Borough is becoming over-populated. Other areas could better integrate new housing schemes. o Objectively Assessed Need appears to include Hatfield Aerospace development which should be treated as a one-off. Base figures should run from 2001 o Challenge and reassess the Objectively Assessed Need.

15 o Unclear why the borough needs so many new homes. Question basis for calculation. The RSS 10,000 was quashed in the High Court, why now increase from 7,500 to 12,500? Different needs assessments for different Councils means there has been some double counting. Accuracy is doubted. o Plans could result increase population by 30,000 o Reassess the 12,000 jobs target. o Approach too jobs led. Inward migrants will occupy surplus housing, create more commuting and new jobs locally. Local employment is currently well balanced. o WHBC and other Hertfordshire districts should plan housing for the existing population, not inward migration o Homes will be snapped up by Londoners – not local homes for local people. o Not all (adult) children will want to stay in the borough. o House 99% of students in Halls of Residences, reducing the number of new homes needed. o Build with Housing Associations – address older residents under-occupying large homes.

Locations, sites, site assessments o Paragraph 10.30 suggests full site assessments have not been made or potential cumulative impacts of a combination of sites. Align site assessments with OAN for housing, jobs and social infrastructure o Create a vision for WGC with a masterplan for Peartree ward which attracts younger people; sustains the town’s retail and leisure offer; grows the pool of skilled talent living here; attracts new business; moves low skilled employment uses towards the A1/A414 road network. o Little Heath: Inconsistent approach to protecting fragile gaps – e.g. protected between Woolmer Green and Knebworth but not between Little Heath and Brookmans Park (and Swanley Bar). Sites BrP7 and LHe1 should be Less Favourable. They would not benefit from strong defensible Green Belt boundaries and would be open to further urban sprawl. BrP7 and LHe1 are both highly visible – similar attributes as other sites, Dig1, BrP9, BrP10, Cuf4, Cuf5, Wel1. o Panshanger is not a sustainable location. o 600 homes around Cuffley would make local roads very congested. o Ellenbrook area unsuitable for development – traffic, flooding, loss of natural buffer between Hatfield and St Albans, Nature Reserve. No schools, doctors, shops, loss of trees. o WGC4 should be drawn to the borough boundary and extend to the east to land within East Herts- further land is available to the north and east of WGC4 (part in East Herts) – for housing and landscaping (Site Promoter(s). o Disproportionate number of Gypsy and Traveller sites in Welham Green. o 11 of the 19 sites in North Mymms are either adjacent or close to Wildlife Sites or Ancient Woodland o WeG10 has been put forward by the Council without the owner’s consent o Should consider the full extent of land at Cole Green (WGC5) a ‘more favourable site’ and allocate as it is deliverable o Unclear why sites around Brookmans Park been removed. o Welham Green: Flooding at WeG6 (Skimpans), WeG4b and WeG10. Village already hosts a concentration of traveller sites – no justification for more. [Welham Manor] too narrow for additional traffic/cars.

16 o Hatfield: No provision [at Hat1] for shops, PO, community centre, medical centre, church etc. Hatfield Town Centre. Hatfield Residents feel they are being used as a dumping ground. Hat1 would represent a disproportionate number of new homes. o Many proposed sites are havens for wildlife, including protected species such as bats and great crested newts. Development will harm habitats and reduce biodiversity

Affordable housing o Several sites are too small to deliver affordable housing; others may have viability difficulties. Gypsy sites will not contribute to affordable housing. o Young people cannot afford to live in the area – affordable homes are needed.

Duty to co-operate o Overall, plan generally complies with soundness tests but the borough housing requirement must reflect needs outside the area and the duty to cooperate must be met o The need for further evidence and cooperation with other authorities may delay plan making. o Lack of evidence of DTC having taken place o Approach unjustified: no allowance has been made for cross- boundary need o Understand that evidence for the OAN has been prepared with adjoining LPAs

Infrastructure o Planning for infrastructure after sites are allocated is unsound. This must be accounted for now as infrastructure issues may make sites undeliverable. A failure to plan for coherent places for our community (Standard comment made by multiple respondents). o Insufficient infrastructure – schools, post offices, hospitals (A&E has moved to Lister), GPs, public transport, library, roads, parking at railway stations, jobs, social centres, drainage, sewerage. o Infrastructure hasn’t kept up with current demand. There has been no assessment of services. No confidence that improvements will take place in the future. New infrastructure should be in place before new development/ sites are allocated. o Ignores supporting infrastructure e.g. 850 homes at Broadwater Road with no plans for school additions and healthcare services o Ensure the consequences of growth do not harm the community and wider infrastructure. o Insufficient parking for new build developments. o When allocating Green Belt sites, consider if the area is suitable for active, sustainable transport o Road traffic and air quality implications a concern o Severe traffic congestion on A1(M)and and around Hatfield. New main artery roads are vital. o How will transport links be improved to enable residents to go to work?

17 o Require early implementation of green infrastructure, prioritising pedestrians and other sustainable modes of transport

Evidence, SHMA o SHMA does not use the most up to date (2012 based) population projections. o Windfall projection too low, schools may come forward, and dwellings made available due to care home provision and offices to residential o Understates urban figures which exclude office to residential conversions which would reduce need for Green Belt sites o The Plan should afford the three dimensions of sustainable development [economic, social and environmental] equal consideration o Overestimates job forecasts so housing need is too high. Population and job projections too high. LEP estimates 19,000 jobs in the A1(M) growth corridor by 2030, mostly in Stevenage, yet the Local Plan expects 12,000 in Welwyn Hatfield. o Statistics used are questionable. Calculation flawed – assumes industrial and business growth on the same scale as the past decade. Homes will be built where they are not required. o Average completions, 200 homes per annum (2011-2014), leave a significant shortfall in delivery.

Consultation Process o Cabinet decision (December 2014) to only consult on More Favourable sites. Brookmans Park sites then omitted from the consultation. A political rather than planning decision. o No acknowledgement or response to previous concerns. o Overall process needs explaining with timelines and decision points. o Provide an explanation for the excluded villages and confirm members of the Council who live in these villages.

Other o Object to the incinerator being built in Hatfield. o Rethink the redevelopment of garages for housing – roads are being blocked by parked cars and vans.

How these views have been taken into account

The LPPS 2016 sets out a housing trajectory. The LPPS 2016 indicates phasing for housing delivery in broad terms, in site allocations policies – for strategic sites this would be addressed in more detail through masterplanning.

OAN and housing target

The ECS (CS2) identified a target of 6,800 dwellings for the borough within the context of 7,200 homes between 2011 and 2029. Following the ECS, the 2014 Strategic Housing Market Assessment (SHMA) identified Welwyn Hatfield’s objectively assessed housing need at around 625 dwellings per annum, (12,500

18 dwellings between 2011 and 2031) which is the level of growth consulted upon in the LPDCD 2015. SHMA updates in 2015 and in 2016 reviewed this to between 664 and 707 dwellings p.a (2013-2032). Opportunities to meet this need have been reviewed, including proposing a more proportionate approach to distributing housing and identifying further potential housing sites, thereby increasing capacity. Due to the high level of housing need and the availability of suitable sites, the LPPS 2016 housing target of 12,000 dwellings (498 dwellings per annum to 2021, then 752 dwellings per annum to 2032) set out in Policy SP2 is less than the borough’s full OAN. It does, however, represent a significant step change - a 55% increase - in annual delivery, compared with the past 15 years’ completion rates.

Green Belt

Environmental Sustainability

While the SA notes that there would be adverse impacts due to the loss of agricultural land and impact on wildlife, it also cites benefits in terms of new housing. The LPPS 2016 contains a number of policies that require development during the plan period to protect natural and heritage assets, address flood risk, use water sustainably and be a high quality and sustainable design.

Development opportunities within the borough’s urban areas have been exhaustively pursued, and around half of new dwellings coming forward during the plan period will be within the urban areas.

Site assessments

The Council has assessed sites further through the Housing and Employment Land Availability Assessment 2016 (HELAA) and other studies (such as the Sustainability Appraisal, SFRA, Green Belt Study), including consideration of cumulative impacts.

While it is acknowledged that some site allocations, particularly strategic sites, would lead to a loss of open land, improving access to green spaces, including country parks and nature reserves, is an important aim of the Plan. Plan policies and objectives seek to achieve this in conjunction with the development of such sites.

Settlement pattern / distribution of growth

The Council has reviewed opportunities to meet development needs, proposing a more proportionate approach to distributing housing and identifying further potential housing sites, thereby increasing capacity. However, a mathematically proportionate approach does not necessarily equate to the most sustainable strategy or result in the most sustainable sites being allocated..

A garden city in North Hertfordshire lies outside the scope of the Welwyn Hatfield local plan. The LPPS 2016 does, however, propose a new garden village at Symondshyde.

Student accommodation

LPPS 2016 Policy SP 21 seeks to ensure new student accommodation is on campus wherever possible.

Sites and locations

For specific sites, please see the responses within the site–specific sections of this statement

The Plan recognises the role of infill sites in making more efficient use of land provided there is no adverse impact. New policies SADM 1 Windfall Development and Policy SADM 34 Development within the Green Belt address related aspects.

Infrastructure

LPPS 2016 Policy SP 13 Infrastructure Delivery will require new development to demonstrate that sufficient infrastructure exists or can be provided to meet needs generated by that development. The Council’s IDP will support the delivery of the Local Plan. The IDP 2016 identifies what infrastructure is required to support growth, where it is needed and when it should be delivered.

Further traffic modelling has been carried out and is to be carried out to identify measures needed.

Technical evidence, SHMA

The Council has updated our evidence to support the LPPS 2016 on housing and economic development needs to take account of more recent data, projections and forecasts. Policy SP 2 and supporting text draw on evidence from this technical work, including Welwyn Hatfield Strategic Housing Market Assessment Partial Update 2015 and Partial Update Addendum (2016), SHMA Size and Type of

Housing Required 2016. The Council has revised jobs figures in light of updated evidence, including The Economy Study (December 2015).

The LPPS 2016 includes a higher windfall allowance to reflect the anticipated increase in office to residential conversions over the plan period.

Consultation Process

The Council’s adopted District Plan 2005 outlines which are the small and large excluded villages within the borough. The LPPS 2016 assesses Welham Green and Brookmans Park as suitable locations for further development, along with some other excluded villages. Allocations are proposed commensurate with facilities and local circumstances and subject to site specific constraints being addressed.

Consultation has been carried out in line with the Council’s Statement of Community Involvement. Timeline for preparing the Local Plan is explained in the Summary & Guide which was a supporting document to the LPCD 2015, as well as at consultation events where information on the process was provided.

Environmental Sustainability

The Council recognise the importance of protecting and providing land for growing food and have amended policies, adding a principle in SP 10 Sustainable Design and construction “Proposals seek to create space for growing food, both at a building and wider community scale” and revising text in Policy SP 11 Protection and enhancement of critical environmental assets to state “The best and most versatile agricultural land that has the greatest potential for local food security will be protected”.

Other

Impact on heritage assets has been considered through the SA and HELAA (both 2016).

Policy CS2 Meeting the Needs for Growth – Housing

Number of responses received: 69 (General 18, Support 10, Object 41)

Support o The Objectively Assessed Need is generally supported. o The intention to meet the full OAN is supported o Support the Council’s approach to identifying new sites outside urban areas – necessary to meet housing need o Broadly support approach and methodology used to arrive at the OAN. The evidence base has been prepared in partnership with adjoining local authorities. o The correct approach has been adopted to meeting OAN o The need to release land around more sustainable settlements, including larger rural settlements with a range of facilities (such as Welwyn, Oaklands and Mardley Heath, Welham Green and Brookmans Park) is supported o Support the Council’s statement that exceptional circumstances exist to review Green Belt boundaries. o The Council has had due regard to demographic trends including the needs of the elderly and disabled requiring specialist care.

Main Issues

Green Belt o Green Belt boundaries should be long term. Should plan to meet current and future needs. o Should not limit the release of Green Belt land around sustainable rural settlements to identified sites. A longer term view should enable further land to come forward without the need for future piecemeal alterations to the Green Belt o Object to any Green Belt incursion. Unmet need is unlikely to outweigh harm to the Green Belt to constitute very special circumstances justifying inappropriate development. o The claim that limited urban capacity amounts to exceptional circumstances to review the Green Belt is inconsistent with the NPPF paragraphs 14. Exceptional circumstances have not been demonstrated (NPPF para 83) o The Communities Secretary (Eric Pickles) has said that not being able to meet housing numbers is not exceptional circumstances (a school or GP surgery might be exceptional circumstances). o The Green Belt Review Stage 2 states that nearly half the sites make a significant contribution to the national Green Belt purpose of protecting the countryside from encroachment. o Encroachment into the Green Belt from Hat1 and Hat2 would cause significant harm to the Green Belt with a risk of coalescence with St Albans o The government attaches great importance to the Green Belt – the presence of constraints might limit the ability of planning authorities to meet their needs o Reclassify Green Belt land as safeguarded. Build only on brownfield, urbanised sites at higher densities.

22 o Lack of consideration given to brownfield sites in the Green Belt in sustainable locations. Undertake a strategic assessment of available brownfield sites within the Green Belt – don’t rely upon developers promoting sites

Settlement pattern / distribution of growth o Recognise that ‘proportionate growth’ is designed to take a fair approach to housing allocations o Need a proportionate plan to spread homes more evenly across more sites across the borough o Accept the need for some housebuilding in North Mymms, but the projections are excessive and disproportionate. o Previous study showed a limited need for affordable housing in Brookmans Park – build houses where they are needed in WGC and Hatfield and where jobs are located. o Sites around the larger villages could be found more favourable. o Increasing the size of Welwyn Garden City to a large town would destroy the Garden City ethos and intent of Ebeneezer Howard. 5,600 houses equates to just over 12,000 additional people. This goes beyond the intended Garden City principles and will erode separateness and the character of villages. o Little Heath: Proportionally, proposed growth would be far higher than other settlements. It would no longer be a village. Little Heath does not benefit from a range of shops, services or local amenities. It is not a sustainable location for development. o Woolmer Green: Cannot cope with a dramatic increase in car journeys. o Meet any shortfall by building a new Garden City in North Herts, not in Green Belt. This would also cater for expansion beyond the life of the local plan o Put pressure on government to revitalise parts of the country where there is spare capacity. Build houses elsewhere where regeneration is required. o Find other ways to provide housing, e.g. more brownfield sites, more use of redundant sites. Take over empty properties and regenerate run-down areas.

Housing target, OAN o 625 dwellings p.a. too close to demographic baseline projections. Little capacity for the needs of the economy, market signals and affordable housing supply o 625 dwellings will not address high house prices, market signals (rising rents, under-supply etc), poor affordability, affordable housing and London’s unmet need. It will result in under-supply. Affordable housing need alone implies an overall housing target of 1,927 dwellings p.a. A 20% buffer should be added due to persistent under-delivery o Social and economic consequences of providing insufficient housing. The plan would not be positively prepared o NPPF does not cite landscape designations and the intrinsic value of the countryside as constraints o Target should reflect the needs of the local population with a more realistic number for incoming population growth o Central Government statistics should not dictate the housing target o Resisting the loss of employment land is inconsistent with the government’s proposed extension of PD rights. Planning Guidance states that care provision

counts towards overall housing targets. Should deduct this from the additional housing land o Unclear why the target moved from 6,800 to 12,500. Cannot all be down to Census figures. o If employment and housing do not match, the area will be a dormitory area for commuters. o Most of the increase is expected from migration. Should focus on current residents’ needs.

Housing target too high o Reduce housing target by 50%. Reduce the target to 4,860 dwellings. o If the 12,500 is in line with government guidance, why only provide for 10,152? o The 12,500 target is too high. An estimate which cannot be validated. Excessive compared with neighbouring boroughs. Skewed by Hatfield airfield redevelopment. The housing target and contribution of the largest settlements is too high o Lack of evidence to support 12,500. Unclear what account has been taken of macro-economic factors which could have a profound effect on the UK, o An assessed need in excess of 2012 forecasts makes no sense. Level of growth not justified or desirable. Not enough jobs in the area. o OAN is too high, confuses supply with need. Recent household forecasts would suggest 561 dwellings p.a o Need does not automatically equal supply. The NPPF states that the target can be lower than assessed need where the adverse impacts would significantly and demonstrably outweigh the benefits when assessed against the policies in the framework or the framework indicates that development should be restricted o 2012 population projections suggest an annual requirement of 580 dwellings p.a. o Insufficient account taken of the student population and international migration who live in larger than average households. The OAN should be 560-580 at most. o Reassess targets in line with brownfield site availability including unwanted offices to residential.

Dwelling type, affordable housing, affordability, built form o Refer in this chapter to the scale of affordable need (810 p.a. in the first 5 years) and an average of 578 p.a. over the plan period. o Consider if more homes could be delivered to have a greater impact on affordability o What provision will be made for affordable housing (including social rent) o Build more affordable homes provided they go to those who need it most and remain affordable. Apply eligibility criteria for affordable homes and ensure they remain affordable. o What is the policy on Lifetime Homes and Wheelchair Accessible housing o Limit development to 2 to 3 storeys high – sufficient high rise already o The plan needs a variety of sites to cater for a range of household types. Such sites could help to reinforce the character and identity of existing settlements. o Seems to ignore current and future need for affordable housing. London Boroughs are placing homeless people in the private rented sector in Hatfield, increasing housing need.

Sites and site assessment o Panshanger Aerodrome site, safeguarded for development, is the only opportunity on land outside the Green Belt. Should maximise delivery at Panshanger before releasing Green Belt sites (there are good reasons a minor Green Belt boundary revision). o Oppose scale of housing proposed at WGC4 o Carry out a more detailed appraisal of settlement edge sites with a more rigorous assessment to balance the OAN against the impact on the purposes of the Green Belt.

Technical evidence o The 2012 based SNHPs give some credence to the Council’s SHMA evidence. These largely resolve issues with 2011 based interim projections. [If] the SHMA considers the 2012 based SNHPs unreliable, it should say why. Explain and justify Headship rates o The 2012 SNHPs are not a robust starting point as they are recessionary in nature in respect of household formation o One-off development at BAe Hatfield is not acknowledged o AMR assumptions concerning the conversion rate of care beds from dwellings vacated (620:480) are over-optimistic o The SHMA needs revisiting. Assess students’ housing needs as they represent a significant element of younger person households. o Uncertainties around international migration, which the AMR indicates accounts for 67% of the borough’s population increase between 2013 and 2014 mean we could overestimate. o National and sub-national forecasts the OAN uses may be out of date and overstate need. Possible inconsistencies between authorities’ different forecasts. Review the findings of the OAN study assumptions and findings for Welwyn Hatfield HMA before proposing a target o Three studies commissioned by the Council in recent years produce divergent figures. The Edge Report suggests a base scenario of 420-450 and the Atkins Study 580, now pushed to 625 dpa. o Self fulfilling demographic projections. Unreliable economic forecasts. o Challenge underlying assumptions on population growth. Seem inordinately high, in excess of UK growth rates. o No explanation for the uplift over the 2012 based projections. o Monitoring of PD changes of use (offices to residential) identified 357 dwellings since 2013 and appears not to be taken into account in the windfall allowance o Provide more detailed evidence to support the need for housing.

Infrastructure o Infrastructure is overstretched. Health service is struggling. GPs and schools have no capacity. Police numbers have diminished. Roads and rail cannot deal with demand. Planning for infrastructure after housing is unsound. Additional housing should be conditional on adequate infrastructure provision. Limit new housing

development until improvements to infrastructure and public services can be secured. o Cumulative effect of growth in Welwyn Hatfield, North Herts and Stevenage. CIL and S106 unlikely to fund larger projects. Village facilities will be under strain o 12,500 homes and 12,000 jobs will place significant pressure on existing infrastructure. o 12,500 new homes will generate 25,000 additional cars onto already congested roads – no mention of any plans to mitigate this. o A414 seriously congested through Hertford – more development will encourage reconsideration of the Hertford bypass. o Insufficient jobs north or south so travel demands by car or train will rise dramatically.

Duty to Co-operate and unmet need o Do not suppress the housing requirement. Work with neighbouring authorities to address cross-boundary shortfalls o Adjust the OAN to take into account pressures from London o Why can’t adjacent boroughs take up the shortfall? o Why can’t land east of Welwyn Garden City in East Herts count towards the shortfall?

Consultation process / plan making process, document o The plan is well written and explains options clearly o The Housing Minister has said a wide range of people should be involved in plan preparation. o Why is local knowledge not sought? o Local elected representatives should decide the housing requirement in consultation with local people. o If ‘more favourable’ sites prove undeliverable, sites from other categories will be needed – these were not adequately consulted on, being sidelined in an appendix.

Other o Sort out employment first before building homes. o Explain how and where these people will be employed. o Plan is excessively weighted in favour of economic and housing factors. o Have no view on housing delivery figures but the historic environment is critical in the analysis of locations appropriate for development without undue harm to heritage assets. Should consider impacts to heritage assets through the SHLAA and the Sustainability Appraisal o Traveller sites should be separate from current and new housing.

How these views have been taken into account

Please see the response in the section immediately above in relation to the majority of matters raised, as noted below. Matters raised specifically under this consultation point are addressed below.

Green Belt

See above

Settlement pattern / distribution of growth

See above

OAN/Housing target

See above.

Dwelling type, built form:

The Council has revised our approach to affordable housing, Lifetime Homes and Wheelchair Accessible Housing in light of changes to national policy and local evidence.

The Plan seeks to ensure that over the plan period a range of housing options is available, in terms of price, tenure, type and size, to meet the needs and requirements of different households. LPPS 2016 Policy SP 7 Type and Mix of Housing sets out requirements for accessible, adaptable housing and housing for older people and people with disabilities. This includes, as part of the overall housing target, a proportion of new homes to be affordable housing, subject to viability and at least 20% of all new dwellings on sites involving 5 or more new dwellings to meet standards for 'accessible and adaptable dwellings'. The policy indicates how the proportion of affordable housing sought will vary depending on the site size and location.

Sites

See above

Technical evidence, SHMA

See above

Infrastructure

See above

Duty to Co-operate and unmet need

Other local planning authorities tell us that they face similar constraints and lack the capacity to address their shortfall compared with OAN. The LPPS 2016 provides for the housing target to be reviewed should insufficient land come forward for housing over the plan period.

With regard to housing land in East Herts, Policy SP 2 supports the delivery of around 1,350 dwellings and associated development to the east of Welwyn Garden City within the administrative area of Eats Herts to help meet the needs of East Herts and the Welwyn Hatfield Housing Market Area. The LPPS 2016 proposes to allocate land south east of Welwyn Garden City to create Birchall Garden Suburb. This land lies partly within East Herts and partly within Welywn Hatfield and is allocated in both areas’ Local Plans. Welwyn Hatfield Draft Local Plan Policy SP 19 states how many homes the site will provide for each local authority area.

Consultation process

Further consideration has been given to the ‘finely balanced’ and ‘less favourable sites’ since the 2015 Local Plan consultation. The consultation has been carried out in line with our Statement of Community Involvement as will future consultations.

Other

Impact on heritage assets has been considered through the SA and SHLAA (2014).

The Local Plan aims to bring about sustainable development in the borough by planning positively for growth in a way which supports economic growth, increases the supply of housing, contributes to the reduction of social and health inequalities in the borough and recognises environmental and infrastructure constraints. LPPS 2016 Policy SP 1 Delivering Sustainable Development sets out guiding principles on sustainable development which inform the rest of the Plan.

Due to the level of need for pitches and lack of sites suitable for allocation in the urban areas, the Council considers there are exceptional circumstances to justify release of Green Belt land Gypsy and Traveller pitches where there are suitable opportunities to do so.

CS2 Meeting the Needs for Growth - Figure 1 – Housing Market Area

Number of responses received: (General 0, Support 0, Object 1)

Main Issues o SHMA works from a WH perspective only and assumes the whole borough falls within a single HMA. o WH may be split across a number of different HMAs reflecting key functional linkages between places where people live and work, stronger relationships may exist elsewhere. The resulting HMA may be contrived with unlikely outcomes and make negotiations under the Duty to Cooperate harder to conclude. Our SHMA concluded that Codicote forms part of a Welwyn Garden City-based HMA but not Knebworth o Believe that Knebworth has a stronger relationship to the Stevenage HMA .

How these views have been taken into account

The Council has updated the Welwyn Hatfield Strategic Housing Market Assessment (Partial Update 2015 and Partial Update Addendum 2016). The Council note that a Joint Housing Market Area Study covering Bedfordshire and surrounding areas, including North Hertfordshire was commissioned by other LPAs and delivered following the LPCD 2015. The Council’s latest SHMA evidence takes this into consideration, along with the findings of other SHMAs in the surrounding areas, including their analysis of Housing Market Area geographies.

Housing markets in this sub-region are highly complex, influenced to greater or lesser extents by London, and there is no single right answer to defining HMAs in the sub-region.

The Council note that the Joint Housing Market Area Study covering Bedfordshire and surrounding areas concluded that that Welwyn Hatfield had no overriding strong and consistent relationship with any one wider geography or Strategic HMA, with relationships (of varying yet notable degrees) with St Albans, North Herts, Stevenage, East Herts, Broxbourne, Hertsmere and London.

On this basis, The Council feel it is justified to conclude that Welwyn Hatfield has its own housing market geography that does not neatly or definitively fit into any one wider Strategic HMA. This was the conclusion drawn in our own SHMA in 2014 and is a position which has been maintained since in light of other studies referred to above. This acknowledges relationships with many neighbouring areas in a wider geography but recognised that the most sensible HMA geography was one centred upon Welwyn Hatfield but with some overlaps into North Herts (reflecting relationships with Codicote and Knebworth), East Herts, Broxbourne, Hertsmere, Barnet and St Albans.

Policy Intention CS2a – Housing Target

Number of responses received: 333 (General 7, Support 3, Object 323)

Support o Supports proposed plan target of 68 net Gypsy and Traveller pitches within the plan period and actively seeking to meet needs within Welwyn Hatfield o Support policy CS2A Gypsy and Traveller pitches target and paragraph 3.5 which sets out pitch targets to 2016, 2026 and 2031, of 71 pitches between 2011 and 2031 o SHMA assessment of OAN (625 dwelling per annum, equating to 12,500 for the period 2011-2031). is objective and represents a robust assessment of housing need for the authority set within the wider housing market area o Agree that the Local Plan will need to allocate new development on Green Belt land o Agree with the stated objective for meeting the SHMA’s identification for a further 620 additional bed spaces for elderly person’s accommodation o The acknowledgement of the need to provide (although not the quantum) additional care home bed spaces (Class C2) for elderly persons accommodation is supported.

Main Issues o Imperative that the Council adopts 625 dwelling per annum/12,500 for the plan period as their housing target and use their evidence base to ensure that their Local Plan meets the full objectively assessed needs for market and affordable housing in the housing market area. This should ensure an adequate supply of housing to meet the needs of a changing population, including a mix of tenures and housing types that match changing demographic patterns).

Green Belt o Agree that because less than 40% of housing need can be met within urban areas, land beyond settlement boundaries will need to be identified and released. As the majority of land beyond the urban areas is within Green Belt, agree that this need constitutes “exceptional circumstances” to review the Green Belt (NPPF paragraph 83). o The approach to identifying suitable (“more favourable”) sites for release from the Green Belt and then determining the level of housing within the borough is broadly correct, provided that “finely balanced” sites are included as sites suitable for housing; and any shortfall is made up in neighbouring areas, where reasonable and consistent with achieving sustainable development. Neighbouring authorities should seek to release suitable sites as part of the review and revision of Green Belt boundaries. o Strongly oppose loss and destruction of Green Belt land. It will change the character of the area. o Should only alter Green Belt boundaries in exceptional circumstances NPPF paragraph 83. In a ministerial statement, Nick Boles MP stated that unmet housing need is unlikely to outweigh harm to the Green Belt to constitute very special circumstances

30 o Harm to wildlife, biodiversity, protected species. Wildlife sites with muntjac deer, foxes, woodpeckers, snakes, bats, great crested newts and many bird species would be affected. Fragmentation of Green Belt would isolate remaining natural populations. Increased risk of extinctions. o Rural areas with much wildlife will be desecrated, loss of trees, Alban Way will be spoiled.

OAN and Housing Target o Welcomes the fact that the Borough Council has undertaken an objective assessment of the need for housing within Welwyn Hatfield Housing Market Area (Figure 1), and the borough’s administrative area (Landowner on behalf of Cuf6) o Plan needs to state the housing target. With no target it is unclear whether there are sufficient sites to meet OAN o Development needs of the area should be met in full, in accordance with policies set out in the Framework. Pointless to objectively assess housing need and then accept need cannot be met. Positively prepared test will not be met as the Local Plan will not meet OAN. o Should meet full OAN for the district within the district or adjoining areas via the Duty to Cooperate o Disagree with CS2A “at the current time the evidence indicates that this [OAN] will be below the Objective Assessment if Need as insufficient suitable and achievable opportunities have come forward to date”. The earlier draft Local Plan presented to members 11 December presented a more balanced position, identifying a target between 10,100 – 12,500 dwellings but recognising further work was required o NPPF Para 47 requires Councils to boost the supply of housing ‘significantly’. o Approach neither positive nor proactive, will be open to challenge, as many ‘finely balanced’ sites could, if allocated, provide sufficient land o Will fail to provide for OAN without finely balanced and less favourable sites and no more than one or two years of ‘key sites’. There is already a substantial historic under-provision o Strongly recommends that Welwyn Hatfield plans to meet its own housing need in full and identify a housing target as soon as possible o Welwyn Hatfield must meet its own needs, not rely on adjoining Hertfordshire authorities who are equally constrained by Green Belt. Re-draw the Green Belt and introduce phasing to trigger the release of land on the basis of future identified need o Support intention for target be below OAN, and the statement that there are ‘insufficient suitable and achievable opportunities’ for housing. Consideration of the availability of Green Belt sites should not form part of the target setting process, but follow it, after the target is set. This the missing step required by NPPF paragraphs 14 and 47 not yet carried out. Reconsider the methodology and process for setting a housing target before determining which Green Belt sites should be developed o Target ignores the NPPF which states that targets must take into account constraints on development such as Green Belt. A reduction in housing targets would allow sites within Strategic Green Corridor to be removed from future housing plans o The scale of housing need and projected job creation is too high. The housing target grossly inflates the population projection based on expected job creation.

31 o Overstates housing need. The LEP’s projected job creation is much lower than the figure used to calculate housing need. Major employers are no longer in the area i.e. British Aerospace, ICI. o Expected windfall projection is too low based on figures from the past. o Consistent with the NPPF approach to boost housing supply, plan to meet full OAN with an additional buffer to allow for flexibility in supply o Lack of reference to the need for 5% or 20% more houses in the first five years on the plan implies Welwyn Hatfield has not been underproviding. Plan should state this o The target for care home accommodation for 620 places over a 20 year period does not reflect the steep rise in elderly people in the community. The target should be increased. o Most of the housing planned is unaffordable so unlikely to meet the needs of local young people. o Expand existing Gypsy and Traveller sites rather than creating new ones.

Settlement Strategy / distribution o A limited number of growth areas in Hatfield and Welywn Garden City is unlikely to facilitate the required range of market and affordable housing in the early stages of the plan period. o Agree that it would be a good idea to have a new town with all necessary facilities for families. o Other areas with suitable sites are failing to take a fair share. Distribute growth on a proportionate basis. o Level of growth proposed is beyond what was intended for the 'Garden City' . Welwyn Garden City, which was built and designed for a population of between 40 and 50 thousand o Growth proposed around the villages would erode their separateness and character o Only solution is to reduce the housing demand on Green Belt areas close to Greater London, and to build new towns well out of the way.

Evidence o The SHMA is flawed. Ignores economic growth aspirations set out in the Council's economic study. Fails to consider whether there is any requirement for other local authority’s housing needs to be met through additional provision in Welwyn Hatfield Borough. Only identifies a need to plan for around 48% of housing needs in the market area. o Need to evidence assumption that neighbouring authorities will meet Welwyn Hatfield's housing needs (East of Welwyn Garden City in East Herts) o Recognise the need to house the Parish's increasing population, but North Mymms Parish Council questions the projections and considers them excessive. o Approach to identifying need is too simplistic. Should base this on a socio- economic survey. o Lack of evidence and explanation for seeking to meet the housing need. o Reassess housing projections to establish a realistic figure. Take into account established Green Belt boundaries and greater use of brownfield sites and conversion of existing buildings in other use classes.

32 o The Plan should clearly state details around the calculation and/or non-inclusion of additional allowances for the underprovision of housing and older people’s accommodation

Sites and site assessment o Flawed site analysis. Should not assume there are insufficient suitable, achievable sites. o Allocate additional sites shown to be suitable, available and achievable to meet OAN o Ineffective - Not enough sites to meet OAN. Site delivery and capacity uncertain. o Reassess sites and revisit assumptions on constraints o To meet higher levels of housing need and provide flexibility allocate site at South Way, Hatfield o For sites Hat1 and Hat2 delivery will occur towards the end of the plan period. These should become NPPF Para 85 ‘safeguarded land’ o Hat4 and Hat5 should be classed as unsuitable for development, not finely balanced. There are regular floods in the fields. o Panshanger should be left as a small airfield with ancient trees, hedgerows and pleasant walks. o Evidence to the Council for Cuf5 has been assessed incorrectly. Its merits for release are not accurately reported nor given sufficient weight reflected in its “less favourable site” ranking. o Welham Green: Roads are not made for huge amounts of heavy traffic, sewers, flood plain etc. flooding issues at Marshmoor, Dixons Hill Road (WeG10), village centre. o Wrong to omit finely balanced sites. Work proactively with promoters of finely balanced sites as some, such as WGC5, can deliver land and resolve concerns. o Land at WEL1 and WEL2 can come forward as per our representations o Overestimates windfall supply since the main source, changes from B1 to C3, is time limited o Unjustified: by limiting the range of potential sites for consultation and not explaining the full range of OAN that may be required. o Smaller sites would provide a more deliverable range of sites in the shorter term and more flexibility.

Infrastructure o Sewerage and other infrastructure overstretched. Lack school facilities, GPs surgery and social centres, shops, overcrowded bus services. No longer a proper local hospital. Lost another library. o North Herts plan only includes 3,600 new jobs which means the majority of the new residents will travel outside the district for work o Lack of integrated planning of infrastructure. o More houses will add to flooding problems. Developments increase risk of flooding downstream. o Increasing frequency and number of power cuts. Planning the infrastructure needed for population growth should allow for timely delivery of the infrastructure. o Concerned by the prospect of unsuitable housing that would result from having to accommodate 12,000 homes with no supporting infrastructure, as occurred at the

airfield site west of Hatfield which has become run down, though no more than a few years old. o Local roads not capable of taking traffic generated by large scale development. o Woolmer Green: overstretched infrastructure. Lack of balance between homes and jobs.

Duty to co-operate and unmet need o Concern that the Draft Plan does not seek to meet objectively assessed need for housing and has not identified sufficient land to meet all of its identified housing need o Lack of evidence where un-met need will be provided or that WHBC has complied with the DTC. If WH’s housing target is below its OAN, need to demonstrate that site selection has exhausted all possibilities and sought to secure sites elsewhere if the OAN cannot be met within Welywn Hatfield. Such agreements will need to be transparent and secure. o Should thoroughly examine all reasonable options to accommodate unmet housing need through Sustainability Appraisal and Stage 2 Green Belt work. Any unmet need will need to be examined through the Duty to Cooperate which may place a burden on North Herts District Council, who Luton must ask for significant help in meeting its own unmet housing need o Concern that underprovision of housing in Welwyn Hatfield will place pressure on Goffs Oak in Broxbourne but within Welwyn Hatfield housing market area o Fails to demonstrate how it has met the duty to cooperate in preparing the plan, to acknowledge cross boundary housing issues and consider whether there is any requirement for neighbouring authorities’ housing needs to be met within Welwyn Hatfield o Lack of evidence that Welwyn Hatfield has worked with neighbouring authorities and other public bodies to ensure that the Local Plan takes an effective approach to strategic matters, such as housing delivery o If evidence indicates needs cannot be met locally, it will be necessary to consider how needs might be met in adjoining areas in accordance with the DtC o Welcome proactive approach to Gypsy and Traveller provision. Are reviewing potential locations to meet need in Stevenage but given constraints, may need to seek assistance from nearby authorities. o Different HMA geography to ORS areas for Stevenage, North Herts, East Herts and Central Beds. Should resolve discrepancies before submitting the Plan for Examination.

Consultation and plan preparation process o The focus on most favourable locations falls short of the housing requirement. Will need to add less favourable and finely balanced sites. These were inadequately consulted on, being sidelined in an appendix. o Policy Intention CS2A provides no clear policy on which to comment.

How these views have been taken into account

Please see the responses in sections Policy CS2 Meeting the Needs for Growth and Policy CS2 Meeting the Needs for Growth – Housing above in relation to the matters raised.

CS2 Meeting the Needs for Growth – Employment

Number of responses received: 18 (General 9, Support 3, Object 6)

Support o Support assessment of high levels of vacancy in the main part of WGC Industrial Area and Travellers Lane Employment Area, Welham Green Promoter of Pea92 o Strongly support proposals for developing the local economy and emphasis on life sciences. Wish to work with the Council and others to identify how to structure curriculum to reflect this (Stanborough School) o Some companies could benefit from being re-housed on the edge of a rejuvenated Panshanger aerodrome site

Main Issues

Green Belt o If Green Belt land is allocated for employment, in addition to aspects in paragraph 3.21, it should be reinforced that development is required to deliver a comprehensive landscape mitigation package to help compensate for loss of open land o Criteria for justifying exceptional circumstances for altering the Green Belt boundary for a strategic employment allocation are suggested as, the site should be:  Close to a railway station and easily accessible by road, including by bus  Adjacent to an existing settlement boundary and would not result in coalescence between settlements  Well related to existing local amenities  Suitable for life sciences as the site is within the A1(M) corridor and located at the heart of a cluster of existing bioscience and advanced engineering / manufacturing businesses o Object to the intention to plan for 12,000 new jobs ‘in line with the aspirations of the LEP’ and despite ‘the jobs/homes imbalance’ due to impact on Green Belt. No statutory requirement to meet LEP objectives. Must balance against NPPF paragraph 14 requirement only to do so where consistent with protection of the Green Belt. Paragraph 3.15 conflicts with the NPPF paragraph 14 by not indicating the exceptional circumstances that would justify allocating employment sites in the Green Belt o Object to criterion in paragraph 3.21 that sites suitable for life sciences should be considered for allocation for employment land if the approach of allocating sites in the Green Belt were adopted. This statement should be qualified as this alone would not constitute exceptional circumstances to warrant amendment to Green Belt boundaries o Proposed criteria for release of Green Belt sites for employment sites are biased in favour of a specific industry. Criteria should include demonstrating exceptional circumstances as a pre-requisite for their allocation/release. Site-specific criteria should reflect the full extent of stated purposes Green Belt purposes

36 o Brownfield development and regenerating previously developed employment land should be the principal objective in providing employment land, not development in the Green Belt o Object to paragraph 3.21 criterion that sites close to railway stations should be considered for allocation for employment land if the approach of allocating sites in the Green Belt were adopted. Geographical proximity does not imply good connectivity. Important to ensure infrastructure is planned or put in place to reduce car use and promote more sustainable modes. Should also assess infrastructure against Green Belt policies

Employment land and sites o Due to downward pressures on employment in the borough, loss of City Link, threat to jobs at EE, and the implications of reduction of staff at Tesco approach needs to be reviewed to ensure employment space is not granted which could be used for housing o Policy should take into account home working. o The sites chosen for employment need to have adequate public transport o The borough is perfectly located to take advantage of the Cambridge life science industry and emerging knowledge economy at Kings Cross. Identify sites to benefit from growth of the sector. o Changes over last 10 – 15 years have left much employment floorspace vacant or derelict, being no longer fit for purpose. There is no clear picture of floorspace needs for the future economy. o Paragraph 3.13 sets out the county Council’s aspiration to capture growth industries as off-spurts from the Cambridge hub. The type of “Campus” environment such industries require is incompatible with the District’s 20th century industrial areas. Not all sites in employment areas are of the quality to attract future investment. Other uses should be found, such as residential, including specialist care accommodation to meet identified needs. o Lack of balance between housing and employment as brownfield sites with potential for employment are increasingly being developed for housing. Proximity to London will ensure that demand for residential development will outstrip employment opportunities in the borough. o Look at appropriate sites within designated industrial areas to provide housing. Current proposal for housing and a care home on the edge of the industrial area next to established housing illustrates that such uses can be appropriately located in such areas o Review the distribution of housing and employment to include office to residential conversions. o Allocate site BrP4 for mixed employment / residential. It is close to a railway, next to the Royal Veterinary College, close to the University of Hertfordshire and near the A1(M).

Infrastructure o As a result of permitted development rights to convert offices to flats there should be proper planning for shops, GP surgeries, schools and open space. Otherwise there will be residential islands surrounded by industrial buildings, such as

Hunters Bridge site where the building of a distribution centre does not fit with adjoining housing developments.

Evidence o Question the 12,000 new jobs figure as the underlying evidence is unclear and, if the figure is correct, whether there is no need for additional employment land – question the logic of this if Green Belt land is needed to accommodate new housing Plan has not taken account of loss of employment land to residential as a result of permitted development rights

Other o Proposed change of use for existing designated employment areas should take into account potential impacts on the historic environment (Historic England). o Approaches in paragraph 3.21 do not fit with Hertfordshire Local Enterprise Partnership aspirations meaning that Welwyn Hatfield will miss out on this opportunity. o Employment could be 2,000 less than predicted. Plan should be clear about the types of job that will be provided for.

How these views have been taken into account

The Council has reviewed which employment areas need to be retained (noting that some employment land has been lost through the prior approval and permitted development regime) and there is a clear need to retain existing employment land to meet future needs. The Council’s evidence (Economy Study 2015 and further updates) indicate a shortfall in employment land against projected need during the plan period. The limited availability of land within urban areas for new employment areas is insufficient to meet the borough's employment needs over the plan period. In order to plan for a sustainable pattern of growth and ensure that sufficient land is available to meet the borough's employment development needs, exceptionally, Green Belt boundaries in the borough have been altered.

The LPPS 2016 proposes to allocate employment land to support employment growth in line with evidence (Economy Study 2015). This takes account of different sectors. 294.1 hectares of employment land have been identified to maintain a sufficient supply of jobs in the borough and provide for new employment floorspace between 2013 and 2032, allowing for flexibility. Provision will be made for at least 116,400 sq.m of new floorspace for industry, offices and warehousing over the plan period from designated employment areas and mixed use sites (Policy SP 2).

The LPPS 2016 proposes new employment opportunities both within existing employment areas, a employment areas and life science park at Marshmoor, Welham Green (Policy SADM 30 and Policy SP 23), and within other strategic sites coming forward elsewhere in the borough.

In planning for employment growth and developing the county’s inward investment offer the Local Plan reflects the priorities and objectives of the Hertfordshire Local Enterprise Partnership (LEP) and is in line with Government policy in seeking to

38 provide the right conditions for a balanced, resilient local economy that can be sustained.

Please also see the responses in sections Policy CS2 Meeting the Needs for Growth and Policy CS2 Meeting the Needs for Growth – Housing above in relation to the other matters raised at this consultation point.

Policy Intention CS2B Employment Land and Job Growth

Number of responses received: 31 (General 15, Support 9, Object 7)

Support o Support the provision of new jobs o Welcome proposals for providing a range of jobs for future residents and employment types which support the Local Enterprise Partnership’s Strategic Economic Plan o Support the allocation of land at Marshmoor to attract investment in life sciences and advanced engineering. It could replace less attractive existing employment land and free this up for other uses o As only 40% of the borough’s housing need can be met in urban areas, look at appropriate sites in larger designated industrial areas such as in Welwyn Garden City and Welham Green, where housing could replace existing uses o SBC anticipate being unable to provide sufficient new employment land to meet Stevenage’s requirements over the plan period. Note that WHBC is planning over provision of 12 – 13ha of employment land. On this basis WHBC might provide suitable employment opportunities to assist in meeting Stevenage’s needs o 12,000 new jobs is an overestimate, but support the policy intention in principle o Demand for residential areas in WGC will outstrip employment opportunities o Borough is in an excellent position to benefit from the growth of the life sciences sector due to its proximity to the Cambridge life science industry and the emerging knowledge economy at Kings Cross. Sites should be found to support this.

Main Issues

Green Belt o Given the surplus of employment land identified, object that Green Belt sites might be considered for allocation as employment land. This does not accord with national policy. Could lead to inappropriate development in the Green Belt where employment development should only be permitted where very special circumstances outweigh harm. Instead, should consider on a case by case basis through planning applications or amendment to Green Belt boundaries o Object to any revision of the Green Belt at New Barnfield

Jobs target, employment sectors o Jobs target does not reflect the improved economic climate since the Emerging Core Strategy consultation o Appreciate difficulty of stipulating a higher aspiration for job growth. Welwyn Hatfield is expected to remain an attractor for employment, with in-commuting from other districts to take up the jobs; having an exact balance between jobs and housing numbers would not be essential, as is the current position o Plan should identify how growth of logistics will be accommodated, or whether it is felt that existing provision is sufficient

Sites o Local industrial/commercial sites must be identified to cater for the needs of the new residents o Consider redundant employment sites which lack good access for other purposes such as housing o Releasing poor quality long term vacant employment land for other uses would stimulate change in the local market and improve the perception of local office stock There is an acute under-provision of small, high quality B1(b). o Acknowledge the role of the expansion areas such as land at Cole Green as potential areas that could provide opportunities for small scale employment uses co-located with other land uses to encourage walkable neighbourhoods and more sustainable living o Allocate Unit 2, Sterling Court, Mundells, Welwyn Garden City as a place of worship (Agent for site landowner). The church is a valuable asset to the community. If the temporary planning permission cannot be made permanent, the church would have to leave the borough. Evidence from commercial property agents shows that there is no demand for the type of accommodation. If the church were to leave, the building would be likely to lay vacant. o Allocate land at Roehyde for a science and logistics park o The Local Plan should seek to take advantage of the borough’s attributes to foster growth in life sciences/biosciences and advanced engineering industries in delivering jobs and enhancing the economy through inward investment o Support retention of employment land and floorspace, or seeking its replacement if lost. criteria for replacement land /floorspace must not be so rigid as to prevent new sites being allocated. This will need to be kept under review o There is a danger of existing employment sites with good transport links or access to railway stations being redeveloped for housing. This may encourage out-commuting rather than support local economic growth. Should retain accessible sites for employment as a priority o The Plan provides insufficient employment land suited to changes that will take place by 2031. Not all identified employment land is suitable for current and future market demand (reflected in high vacancy levels). Loss of employment land/floorspace to other uses should be replaced elsewhere. Policy should be clearer about maintaining a constant net balance of 308ha of employment land. The Plan should identify sufficient, well suited employment land to maximise the borough’s economic potential o As an alternative or in addition to residential development site Hat11 has potential to provide for up to approximately 6 ha of B1 and B8 employment development. o Vacant site at New Barnfield would be ideal for life science and would comply with paragraph 3.21 criteria. It is within easy travelling distance of the University of Hertfordshire and Royal Veterinary College. Designation in the Local Plan as a Major Developed Site would allow for redevelopment of an area of approximately 1.6ha without prejudicing the objectives of the Green Belt

41 o Consider sites in the Green Belt with good links to motorways and railway stations for appropriate employment opportunities o Review the distribution of housing and employment to include office to residential conversions.

How these views have been taken into account

LPPS 2016 Policy SP 8 Local Economy and Policy SADM 10 Employment development seeks to resist the loss of land from Class B and maintain our existing employment areas. In addition, the LPPS 2016 allocates new employment land at SDS7/WeG4b and other mixed use sites.

Please also see the response in the section immediately above.

For response on specific sites, please see the site-specific sections of the consultation statement. Sites Hat8, Hat9 and Hat10 (Land at Roehyde) and WeG8 (New Barnfield) have been assessed as unsuitable with uncertain availability and deliverability (HELAA June 2016) and therefore were not considered for allocation in the LPPS 2016.

CS3 Settlement Strategy

Number of responses received: 54 (General 4, Support 11, Object 39)

Support o Welcome the settlement hierarchy within policy CS3 (Settlement Strategy). This seeks to focus new development around settlements with better existing service provision and active infrastructure network o Strategy should promote the most effective use of existing services and infrastructure. Policy CS20 (Villages and Rural Areas) reinforces CS3 policy commitment to focus development around settlements higher in the settlement hierarchy based on their sustainability credentials o The primary focus of this policy intention seems a sensible way forward o Support additional target of 620 bed spaces for specialist care accommodation for elderly people over the plan period. o Generally supportive of the more proportionate balanced spatial strategy to meet objectively assessed housing needs. o Para 4.1: Support a more proportionate, dispersed pattern of growth and (para 4.2) that larger villages with services and facilities would take a greater share o Support approach (paragraph 4.1) to distribute development across the district and undertake a review of the Green Belt around villages o Support paragraph 4.4 that acknowledges the potential for land in East Herts (Policy EWEL1, East Herts Draft District Plan, to deliver new development east of Welwyn Garden City

Main Issues

Green Belt o Report shows proposed developments as blobs on the map, doesn’t illustrate the impact of lower housing densities, so the knee-jerk response to proposals is to minimise the area of Green Belt given up. This can lead to high density housing solutions which may not be best for the area in the long or short term o Safeguard Green Belt land. Lack of exceptional circumstances to justify developing in the Green Belt. o Object to proposals to build on the Green Belt and alter its boundary. Utilise brownfield sites first and include previous windfall sites before considering development elsewhere. Re-use buildings, such as industrial sites or offices within villages and offset these against the housing needs figure. Potential from empty units at Welham Green industrial estate could alleviate pressure to encroach on the Green Belt o Strongly object to the Local Plan proposal to build houses on Green Belt land in the Parish o Emerging Core Strategy recognised it would not be good policy to build south of Hatfield, as there would be coalescence and ribbon development from Welham Green to Potters Bar. o A disproportionate amount of Green Belt land is proposed for housing development North and West of Hatfield.

43 o Instead of proposing housing in the Green Belt and ruining our villages put houses where they are most needed: in and around towns and cities or in a new Garden City. o Green Belt land is an integral part of our community, offering many wildlife habitats and green space for recreation. Consider brownfield areas within Welwyn Hatfield before encroaching on Green Belt. o The balance between protecting the Green Belt and providing housing to achieve the number required should be proportionately distributed throughout the area. o Object to loss of Green Belt around Welham Green when three Brookmans Park sites were taken out of the "More favourable Housing Sites" list and not brought forward as part of this consultation. o Strengthen the policy by including the relevant paragraph from the NPPF and amend the policy as follows - 'In villages and other rural areas that lie within the Green Belt, development would be restricted so as to be consistent with the type of development envisaged by paragraph 89 of the National Planning Policy Framework'. o Seek to remove allocated waste sites from the Green Belt since it has not been possible to identify sufficient suitable sites on non-Green Belt land to meet requirements. Following examination, modifications were proposed to allow such sites to be removed from the Green Belt through local plans. This recognised exceptional circumstances for allocating for waste management purposes three Green Belt sites: New Barnfield, Cole Green (shared with East Herts) and RoeHyde (shared with St Albans)

OAN, housing target and level of growth o Final plan will need to identify how the full objectively assessed housing need (12,500 dwellings) will be met. Table 1 identifies sites for less than 11,000 dwellings. If some finely balanced housing sites need to be included plan policies could consider what would make these sites more suitable whether through provision of local services or improving transport o The additional target specified care accommodation for the elderly. The plan also needs to provide for other sectors of the community, not necessarily elderly, who require residential care. o The level of development should take account of factors that influence a settlement’s sustainability including population and demographic change, settlement role and function, connectivity and accessibility. Should base on an understanding of the capacity for growth in terms of infrastructure, land availability, and environmental constraints and recognise that all settlements can play a role in supporting sustainable development. o Re-consider target for increase in housing. Reduce local house building targets by 50%.

Distribution of growth

The proportionate approach to distributing housing o Does not appear to achieve stated goal of a more proportionate dispersal of growth around the borough in relation to OAN

44 o Welcome change in emphasis towards a more dispersed, proportionate distribution of development across towns and villages but needs to go further and link the strategy to achieving sustainable development, irrespective of Green Belt locations o Welwyn Garden City, Hatfield, Woolmer Green, Welham Green and Little Heath show disproportionate housing allocations in relation to the Objective Assessment of Need, whereas politically protected villages do not nearly meet OAN. Reasons cited appear inconsistent between areas o No justified reasoning for so many homes being proposed within Welwyn Garden City and Hatfield and so few in the villages. o Increasing Little Heath by over 30%, which has no employment, facilities, shops will significantly worsen congestion on local roads. The Local Plan pre-supposes Potters Bar will resolve issues but there is no evidence for this. Expanding Little Heath would give rise to coalescence issues between Potters Bar, Swanley Bar and Brookmans Park o Given the more proportionate, dispersed pattern of growth proposed, why propose a disproportionate number of Gypsy and Traveller Sites in Welham Green o Not allowing growth in the villages removes the opportunity to reinvigorate them by offering more employment, facilities and a more divergent housing stock. Some of the most sustainable sites near railway stations have been removed from the Local Plan o Policy includes excluded villages in hierarchy, but allocates no sites (aside from two with a capacity of 31 dwellings). To ensure the Plan meets soundness tests, reconsider Brookmans Park as a sustainable location for growth and the capacity of sites to contribute towards sustainable patterns of development and meeting OAN o Fewer homes should be built in various areas across the borough to spread the burden, including at Brookmans Park. Whereas Brookmans Park has no 'more favourable' site, 9 sites were proposed (potential 1032 dwellings) in the original consultation document. o The Housing Needs Assessment (October 2013), showed a need for three affordable houses in Brookmans Park compared with a need for 1,446 in Welwyn Garden City and 1,069 in Hatfield suggesting that you should build where homes are needed and there are jobs. o Welham Green is taking more than their proportion, other larger places are taking less. o Expand Brookmans Park and Cuffley. Using Hatfield once again as an easy option. o Rather than proportional approach, adopt zero-based approach to match needs and capabilities. o How has sustainable development informed the housing need distribution? Unclear why a larger village has less development than smaller villages o Para 4.3: Oaklands and Mardley Heath could provide additional housing if the Green Belt boundary is re-drawn o Table 1 indicates an OAN for Rural South of 440 and a total capacity of 54 dwellings. The Plan should recognise that land within or surrounding Green Belt villages can make a contribution to the Rural South OAN

Evidence should inform the housing distribution o Welwyn Hatfield has several distinct housing market areas each with their own housing requirement. Should base the housing distribution on evidence not a politically driven spatial strategy to build where people don’t want to live. If the spatial distribution does not reflect evidenced need/demand, housing will not be delivered and the Plan will not be implemented. o Distribute growth to key settlements with established facilities, services and infrastructure. o Should not preclude development in lower order sustainable settlements, which could help sustain existing facilities and services. o Sustainability Appraisal has not been rigorously applied, as omits some villages with good rail connections. As a result, Cuffley, Brookmans Park and Digswell will have little success in securing new housing

Take account of Garden City principles and the character of places o Welwyn Garden City is internationally regarded as a prime example of a successfully planned town designed for healthy living; limited in size to ensure success as a community. The Plan disregards the importance and significance of the Garden City, as a planning icon and key milestone in the development of town planning. Building vast extensions on the periphery of the City is inconsistent with Garden City Principles. The NPPF makes it clear that the Garden City ethos has merit for town planning in the 21st Century. This could be used to underpin the unique identify of Welwyn Garden City o The net result after 2030 will be unsustainable urban sprawl combining Welwyn Garden City and Hatfield. Reconsider proposed locations taking into account the ethos of Welwyn Garden City. o The protection of the essential character of the "village" is paramount to the English way of life. o Have not taken the opportunity to correct social imbalance to build well-balanced communities.

Build a new garden city o Given London’s significant housing shortage, one new Garden City in Welwyn Hatfield would make much more strategic sense. o Rather than build on Green Belt or agricultural land build a new Garden City south of Hatfield at the South Hatfield A1 exit or between Hatfield/Welwyn and Stevenage. o Research into a potential garden city to meet unmet housing needs for Welwyn Hatfield, N. Herts, Stevenage and possibly E. Herts. A (New Town) around the Baldock area would give good access to major roads and incorporate all the infrastructure. o Build a new Garden City in the north of Hertfordshire on non Green Belt land o Support the Council's decision to write to the government, putting the case for a new garden city on non-Green Belt land

Sites o Over-reliance on large scale strategic sites that are often slow to come forward. Should look to allocate a range of sites and over-allocate the level required to meet the full OAN. o The County Council’s adopted Waste Site Allocations document identifies sites and areas considered suitable for waste management uses. o Concern that the inability to meet identified growth needs will lead to consideration of finely balanced and less favourable sites for inclusion in WHBC Local Plan. Considerable concerns over the impact on St Albans District that may arise from Hat1 and Hat2 the possible future inclusion of HAT3, 4 and 5 in a revised WHBC Local Plan o More favourable sites are the prime focus of the consultation which gives little weight to other sites which were put in an Appendix o WGC4: Making Panshanger more favourable may make it harder for the Council to deny any developer led planning application made outside of the local plan. It is hoped the independent planning inspector gives full weight to the magnitude of what has happened regarding the site allocations. This plan does not represent the view of most Panshanger residents as previous petitions submitted to the Council prove o The Local Plan identifies more favourable sites in Oaklands and Mardley Heath and Welham Green, which would help meet a proportionate distribution of objectively assessed housing need without compromising the purposes of including, or retaining, the land in question within the Green Belt o Oaklands and Mardley Heath is a larger village with shops, a primary school and good public transport. Additional residential development, including the release of Green Belt sites on the periphery would not damage Green Belt purposes and would bolster the viability of local services o Insufficient housing allocated as all settlements (except Little Heath) fall short of their proportionate OAN. This is most pronounced in Brookmans Park, a sustainable location with a railway station and many local facilities, which raises questions about site assessments o Uncertain whether favourable sites can be delivered and their capacity). o The settlement strategy focuses on areas that adjoin existing communities and developed locations. Unclear why Bullens Green been rejected on the basis that it is "Not adjoining a town or one of the inset villages so not contiguous with an urban boundary"? It is part of Colney Heath. o Should remove the current proposal to develop the WGC4 site from the local plan. o Concern that Panshanger will not be properly integrated. o Revise criteria for site selection to reduce impact on infrastructure. o Need to be clear whether EWEL1 of EHD Plan, which identified a site for 1m700 east of WGC is meeting WH or wider HMA needs

Infrastructure and form of development o Infrastructure will be unable to cope; roads, schooling, water and sewage. There is already too much heavy traffic.

47 o Road and rail are under pressure. Extra rail capacity on existing lines is limited without major infrastructure changes. Without plans to address these issues, continued siting of new jobs in Welwyn Hatfield will exacerbate existing problems significantly. o Whilst the policy appears sound, the proposal for considerable development NW of Hatfield, (Hat1 and Hat2) conflicts with Policy CS3 which states that the focus for new development should enable access to strategic transport networks, public transport, shops, services, and other facilities. Hat1 and Hat2 are a considerable distance from Hatfield station and road infrastructure is inadequate for the scale of development proposed. They will probably do little to help rejuvenate the Town Centre due to the distance from the sites. If it is the intention, under Policy CS3, to leverage existing public transport infrastructure, it would make more sense to bring forward one or more "Finely Balanced" sites in Brookmans Park, which has one of the least used stations in the borough o Need to give consideration to areas outside towns where existing infrastructure and services may be incompatible with further development o The density of homes approved should be appropriate to the provision of community infrastructure o The Plan cites high tech life sciences and advanced engineering, using the A1 corridor to attract investment. Prospective employers would require staff to live within easy commuting distance. Little Heath is at the southern tip of Welwyn Hatfield, with increasing traffic problems and commuting times suggesting new housing should go to the north of the borough. o Plan gives no detail on the quality of housing development envisaged, and whether provision is made for infrastructure. Larger developments are more able to support infrastructure improvements (schools, shops, parks) than smaller ones. Housing density for larger schemes has a major impact on achievable development quality. o Provide information so residents can assess assumptions on design and housing density and compare with lesser housing densities which could allow better green space and infrastructure provision. o The provision and retention of employment opportunities is important for rural settlements.

Evidence o Underestimates windfalls, eg changes of use from office to residential and 480 homes from care home provision o The expected number of homes in the urban area (4,484) is too low and doesn't account for the increasing conversions of offices into flats and additional brownfield sites, school and other education sites may come forward. o Uncertainty in the population projections may mean estimated need is less and there would be less need to sacrifice Green Belt.

Duty to Co-operate o Unclear what agreements have been reached with adjoining districts on accommodating unmet needs o The Plan should explain how the Council is discharging the DtC

48 o This duty must be met before submission and supported by a robust evidence base. Will require co-operation with neighbouring authorities and perhaps further afield. Should explore all reasonable options o Note shortfall of supply compared with OAN. Doubt if East Herts is planning to meet its own OAN in full and make provision for Welwyn Hatfield’s shortfall. Would expect to see a formal agreement between the two authorities

Consultation process, document and procedure o Councillors only considered one option designed to safeguard the southern and other villages from significant development; justified by opposition from 4,000 people in the south of the borough and that it would be perverse to develop there. When challenged, agreed to review the process, however the end result is more or less the same o Removing locations deemed "finely balanced" and "less favourable" from the focus of the consultation, once again pushes the vast majority of development onto Welwyn Garden City and Hatfield. Although other sites were available to comment on in an appendix, this does not give the same weight to those sites as the more favourable sites in the main document. o Consultation focused on sites in the document, side-lining other possible sites, and ignored the many objections to the 2012 consultation, which requested a fairer share of development throughout the borough. o Policy Intention CS3 provides no clear policy on which to comment o The format of the Plan makes an objective view difficult to form and express. As in all complex consultations it is difficult to interpret and assess the facts. o Take into account the views of the local community and groups concerned about the development of the airfield. o Should not be allowed to overturn planners’ recommendation without evidence and transparent public consultation. A change agreed at the last minute at the December 11 meeting is undemocratic. Need a fair, unbiased, democratic approach.

How these views have been taken into account

Green Belt

The use of brownfield land for development remains a priority but the Council considers there are exceptional circumstances which justify releasing some land from the Green Belt for development.

Site boundaries have been drawn in such a way that, alongside detailed masterplanning and other policy requirements within LPPS 2016, the risks of coalescence and extent of encroachment into the countryside will be avoided or

49 minimised e.g. the developable extent of SDS5/Hat1 has been limited to maintain a gap between settlements.

While developing strategic sites around Welwyn Garden City and Hatfield would lead to the loss of large areas of Green Belt land, it would also provide an opportunity to create a network of connected green open spaces providing access to natural green space, enhance biodiversity and help mitigate the impact of development. The LPCD 2015 proposed a new strategic policy CS19 ‘Green Infrastructure’ to be accompanied by a detailed brief for its delivery to be incorporated into masterplanning of strategic sites and secured through S106 agreements and/or CIL. This is taken forward in the LPPS 2016 via Policy SP12.

The housing distribution in the LPCD 2015 has largely been continued in the LPPS 2016, in line with the revised CS3 of the LPCD 2015, with a more proportionate distribution across the settlements where sustainable opportunities are available

Paragraph 5.10 of the LPCD 2015 consultation document stated that “the exceptional circumstances relating to these sites, as acknowledged by the Inspector for the Waste Local Plan, relate solely to the need to provide for the treatment and transfer of local authority collected waste. With regard to the County Council’s request to remove waste sites from the Green Belt, because uncertainties remain about these sites, the Council will only review Green Belt boundaries once specific proposals and the extent of development are known.” There is considerable uncertainty over the need and distribution of waste management facilities for local authority collected waste in the county, and with regard to the specific scale, nature and extent of proposals at New Barnfield and Roehyde. Therefore, exceptional circumstances are not deemed to exist to remove these two sites from the Green Belt. With regard to Cole Green, which is a site with an extant waste permission for waste operations, the wider area of land in which it resides has been removed from the Green Belt for residential-led mixed use development (SDS2/WGC5 and Land in East Herts). The LPPS 2016 notes that where considered necessary, when planning for the strategic growth locations identified in the Local Plan, The Council will work with the County Council to explore opportunities for the provision of waste management facilities in order to help achieve greater self sufficiency in Hertfordshire (Chapter 13 Infrastructure). The LPPS 2016 shows allocated waste sites on the policies map.

OAN, housing target and level of growth

Please see response within section CS2 Meeting the Needs for Growth above

Distribution of development

The LPCD 2015 set out a more proportionate approach to the distribution of housing growth than was presented in the ECS 2012, in response to comments made on the ECS 2012 and recommendations of the Sustainability Appraisal of the ECS 2012.

The LPPS 2016 largely continues this approach, subject to changes in the make-up of sites that are allocated compared to the more favourable sites set out in the LPCD 2015 as a result of further site and infrastructure assessments. As such, there

50 remains a significant focus upon Welwyn Garden City and Hatfield to take a the majority of growth but with significant provision for excluded villages where sustainable opportunities exist. Whilst a more proportionate approach has been pursued, a mathematically proportionate approach is not feasible and does not necessarily equate to the most sustainable strategy or result in the most sustainable sites being allocated.

The 2015 Local Plan consultation document figures for employment floorspace provision and jobs targets take into account more up to date evidence, including an updated economy study. Figures have been further revised in the LPPS 2016.

Garden City principles and the character of places

The Council has substantially revised and added new text in the LPPS 2016 to acknowledge the importance of Welwyn Garden City’s iconic heritage and its relevance for shaping new development of the future. The LPPS 2016 notes the NPPF point that the supply of new homes can sometimes be best achieved through planning for large scale developments that follow garden city principles and will require all strategic sites to be masterplanned according to Garden City Principles.

There aren’t any opportunities in Welwyn Hatfield for a new garden city of a similar scale to Welwyn Garden City to its equivalents elsewhere; however, the LPPS 2016 identifies a potential new garden village at Symondshyde, north-west of Hatfield. A garden city outside the Borough lies beyond the scope of Welwyn Hatfield Local Plan.

Sites

For specific sites, please see the responses within the site-specific sections of this statement

Infrastructure and form of development

The Emerging Core Strategy Policy CS9 set out an approach to design advising that density should be mostly between 30 and 50 dph to balances the efficient use of land with delivering high quality, functional design that respects distinctive local character and encouraging higher density development in accessible locations, such as town and neighbourhood centres. LPPS 2016 Policy SP 9 sets out broadly the same approach as follows: “Proposals are of an appropriate density (typically between 30 - 50 net dph) that combines the efficient use of land with high quality design that respects character and context. Higher density development will be encouraged in accessible locations, such as around transport hubs or town and neighbourhood centres, where this is appropriate.”

The LPPS 2016 will require development to be of a high quality design. Requirements are as set out in site specific policies and policies covering generic design issues. Strategic sites are to be masterplanned involving key stakeholders and would be required to secure the necessary infrastructure. This approach should ensure the broad principles set out in the Local Plan translate into more detailed

51 design and site specific considerations which schemes would be expected to address.

Evidence

The LPCD 2015 was based upon on a robust, comprehensive and proportionate evidence base for that stage of consultation. This evidence base has been further updated, expanded and strengthen to inform the LPPS 2016, using the latest information available that could be used in a reasonable and timely way to inform its preparation.

The LPCD 2015 contained revised estimates for urban capacity and land supply, including projected windfall, as a result of comments made during the ECS 2012 and further analysis. These are further updated and revised in the LPPS 2016 using up to date evidence.

Duty to Co-operate

The Council has held further discussions with neighbouring authorities, infrastructure providers and agencies, on cross boundary matters since the LPCD 2015.

Housing numbers in adjoining areas are not expected to count towards Welwyn Hatfield’s requirements. However, development next to Welwyn Garden City in East Herts will contribute to meeting needs in Welwyn Hatfield housing market area – the LPPS 2016 makes this clear. Policy SP 19 in the LPPS 2016 sets out a strategy for bringing forward this strategic site (Birchall Garden Suburb). Delivery will require the two authorities to produce a joint masterplan and achieve a consistent approach across their respective Local Plans.

Consultation process

Policy Intention CS3 set out an approach on which the Council sought views as part of the 2015 consultation. LPPS 2016 policy SP 3 “Settlement Strategy and Green Belt boundaries” brings together elements of Policy Intentions CS3 and CS4 and the settlement hierarchy within a single policy. Consultation has been carried out in line with the Council’s Statement of Community Involvement. The Council has tried to strike the right balance between providing necessary detail and accessible material. As with previous local plan consultations, the Council will produce a booklet/leaflet summarising key elements of the LPPS 2016 and provide guidance. As the Council are approaching a formal stage of consultation, responses will need to be made in a prescribed format; however the Council will provide guidance on how to respond.

Table 1 – Potential distribution of housing growth

Number of responses received: 276 (General 5, Support 3, Object 268)

Support o The potential distribution of housing set out in Table 1 appears fair. o Table 1 shows a lack of capacity to meet objectively assessed need in Welham Green without some housing development of site WeG4b o There is a demand for more homes.

Main Issues

Green Belt o Until the potential capacity of previously developed land and permitted development have been reassessed, and housing and employment targets set in accordance with the NPPF, the scale or location of Green Belt development set out in table 1 is not justified o Loss of Green Belt to housing would destroy the character of settlements. o Usage of Green Belt land on the scale proposed would be a great loss to our wildlife. o The settlement strategy ignores the effect of other types of development such as waste management on residential amenity and the character of the countryside. Should take into account Green Belt land in this Parish used for waste management and other permitted developments before allocating further Green Belt for housing. Loss of Green Belt is much greater than shown on the consultation map.

Settlement strategy and the proportionate approach o Needs to take into account the wider area in terms of housing need, demography, economic base, connectivity and social impacts. 500 units allocated to Cuffley is inappropriate - should be 193 at most. Road congestion. Lack of infrastructure o Support approach to allocating land for at Little Heath. Should allocate additional land at Brookmans Park in view of the OAN versus the urban capacity shown in Table 1 and potential for sustainable development o New housing around villages and existing settlements would help sustain community facilities to ensure there is less reliance on major settlements such as Welwyn Garden City and Hatfield o The villages and small towns should play their part. o Although paragraph 4.1 states the Council now proposes a more proportionate and more dispersed pattern of growth, approach heavily biased towards sites around Hatfield and Welwyn Garden City as the Table only shows ‘more favourable’ sites which are mostly at these towns. o Approach is not proportionate as the majority of growth is proposed for Welwyn Garden City and Hatfield. o Development at Little Heath would result in 30% expansion.

53 o West Hatfield has already endured a huge amount of development with thousands of homes built over the past decade, while places like Brookmans Park and Digswell remain largely unchanged. o Alarmed by the prospect of East Herts adding a settlement of a further 1,700 dwellings onto the boundary of Welwyn Garden City. This, along with the other proposed increases would increase the town’s population by 25% - too much within the proposed timeframe. o Omits some of the most sustainable sites in the borough near railway stations. o Lack of transparency. Total potential capacity stated in second column drastically reduces capacity in some areas (Brookmans Park), but not others (Welham Green). Reasons for potential capacity decisions should be made public. o A new Garden City does not appear to be proposed in another location with another authority. o Build a new garden village somewhere else in the borough. o Investigate land around and on the edges of each community. About 500 houses could be allocated to each community. Would cause minimal disruption overall and to communities and avoid the large scale cost and disruption to the environment and infrastructure. o Revert to a more balanced distribution of housing, which allows for moderate development of a wider number of communities at a reasonable pace. o Identify smaller, less valuable areas of land marginal for farming so that the impact upon any community is much less. The impact on traffic flow would be less, infrastructure required would be minimal and the Green Belt preserved better. The planning department could have more control with smaller developments

OAN o Plan identifies insufficient sites to meet OA. Even if all favourable sites came forward there would remain a shortfall of land amounting to 2,348 dwellings or 18.7 percent of the OAN

Sites o We commend the Council on finding brownfield sites for up to 5,000 new dwellings. Should build on these before anywhere else whilst reassessing the target figures. We cannot see any brownfield sites identified in Brookmans Park. o A new policy should support an allocation for a new village at Symondshyde (around 56 ha) provides an opportunity to plan new housing and supporting infrastructure. Sustainable location. Potential connections to Hatfield, close to Welwyn Garden City. o Table 1 has failed to identify Cuffley’s true potential capacity by excluding Cuf5 site which would realise the settlement’s objectively assessed needs o Table 1 shows a lack of capacity to meet objectively assessed need in Welham Green without housing development at site WeG4b o Reappraise major sites such as Stanborough to meet the housing target o Allocate additional land at Brookmans Park in view of the level of Objectively Assessed Need versus urban capacity and potential for sustainable development in this location

54 o Amend potential capacity in Welwyn Garden City in table 1 to include 1,200 homes at WGC5. This would help meet objectively assessed housing needs). o Bulls Lane is not suited for any more traffic which extra housing will bring.

Table 1 figures o Potential distribution of housing as set out in Table 1 appears fair, based on the number of households currently in the area, Cuffley could accommodate 193 new dwellings as set out on page 19. Sites chosen are favourable and would not greatly change the area. o It is unclear where the Rural South and Rural North figures come from. o Could expand Table 1 to indicate where the urban capacity can be accommodated. For example, does this only take into account more favourable sites? o Overestimates capacity of some sites. Uncertainty whether all are deliverable. o Reassess the scale/density of development for settlements beyond Welwyn Garden City and Hatfield to ensure that higher densities are achieved on other sites around the borough to ensure a more even distribution of dwellings). o Figures are overestimated and should be recalculated to obtain a more realistic target.

Evidence o Hard to tell if the approach is proportionate as no indication given of current number of households per settlement. o There needs to be a careful review of the need for growth and population forecasts for the area. o Analysis of demand is flawed. o Re-evaluate growth forecasts for areas which do not match their predicted development needs. o Insufficient analysis of the balance of housing over the whole planning area. o The promotion of land for housing from developers has had far too much effect. o Houses are needed, but use a number of second homes. o Windfall figures too low: Changes of use of offices to residential have generated 357 since June 2013. Table 1 shows 532 windfall dwellings (38 per annum). Should add on to permissions and windfalls, not subtract, 480 dwellings released as a result of care home provision o Defer housing capacity decision until after public consultation, then review based on all consultation material.

Other o Mineral extraction will not be completed by the end of the plan period so Plan is undeliverable. o Lack of infrastructure. Villages cannot cope with extra traffic. Hatfield has outgrown the town infrastructure due to the University’s growth and new housing. Lack of parking. o Children need open spaces, fields etc for their mental health which declines in enclosed spaces. o Building will add to air pollution levels which are already high.

How these views have been taken into account

Green Belt

The use of brownfield land for development remains a priority but the Council considers there are exceptional circumstances which justify releasing some land from the Green Belt for development.

Allocated waste sites are shown on the LPPS 2016 policies map.

Settlement Strategy, proportionate approach and OAN

Please see the response within the section immediately above and in CS2 Meeting the Needs for Growth.

Sites

For specific sites, please see the site-specific responses elsewhere in this statement.

Evidence / Table 1 content

Please see the response within the section immediately above and in CS2 Meeting the Needs for Growth.

The sources of supply within Table 1 of the LPCd 2015 have been updated, as reflected in Tablle 2 of the LPPS 2016, to account for comments made during the LPCD 2015 (e.g. in relation to the Frythe) and completions and permissions that have occurred since the LPCD 2015.

Windfall

The Council has updated the housing distribution figures (LPPS 2016 Table 2) to take into account an expected increase in the number of windfalls over the plan period supported by the analysis set out in the HELAA 2016.

Other

Protecting and enhancing the Borough’s open spaces is a key theme of the Plan. Partnerships with Hertfordshire County Council, adjoining local authorities and landowners will deliver new and improved strategic green infrastructure, to improve access and biodiversity and reinforce the role of the Green Belt between Hatfield and Welwyn Garden City and surrounding towns. To compensate for the loss of green field land for developments the Council will seek improvements and additions to the network of green infrastructure. For the larger strategic allocations, new areas of open land will be created to serve existing and new communities.

The Council has taken into account proposals in Hertfordshire Minerals Local Plan 2007 in the assessment and selection of sites, and within the relevant policies guiding the development of sites where the presence of minerals has or could be identified.

Policy SADM 18 Environmental Pollution of the LPPS 2016 sets out the approach the Council will adopt to ensure that pollution will not have an unacceptable impact on human health, general amenity, critical environmental assets or the wider natural environment. The LPPS 2016 seeks to encourage alternatives to the use of the private car, promoting sustainable modes of travel (Policy SP 4 Transport and Travel).

Infrastructure issues, including Green Infrastructure, have been considered as part of the Infrastructure Delivery Plan (IDP) which has informed the preparation of the LPPS 2016 and site allocations. Please see Council’s Consultation Statement on the Draft IDP 2015 Consultation for further information. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development and Policy SP 14 sets out the approach for the delivery of a new secondary school to serve growth in the borough and particularly Hatfield, Welwyn Garden City and the northern villages.

Policy Intention CS3

Number of responses received: 27 (General 3, Support 7, Object 17).

Support o Proposed Policy and approach to a more proportionate, dispersed pattern of growth is supported o Support proposed dispersal strategy. Agree that development in larger villages inset from the Green Belt that have access to good quality public transport constitutes sustainable development o Whilst generally support the principles of sustainable development in settlements, policy needs to be more flexible and informed with regards to their historical status and potential for growth o Welcome review of emerging strategy for distributing housing and more proportionate and dispersed pattern of growth proposed. Support recognition that excluded villages, including Cuffley, have an important role to play in meeting the need for new homes within the Borough o Support Policy Intention CS3 that there will be no Green Belt boundary changes proposed around villages [and rural areas in the Green Belt]. This allows for a better transition ecologically between open countryside and the edges of smaller settlements, enabling wildlife to use Green Infrastructure assets within the villages themselves o Support broad principles set out in Policy Intention CS3 and paragraph 4.1 to distribute development across the district and undertake a review of the Green Belt around villages. Current strategy more consistent with NPPF aims to deliver a wider choice of homes, in particular paragraph 55 where it is acknowledged that housing should be located where it will enhance or maintain the vitality of rural communities

Main Issues

Green Belt o Having shown that there are exceptional circumstances for a review of the Green Belt to meet the objectively assessed need for housing, the application of the proportionate approach to the distribution of housing provides the exceptional circumstances for a review of the Green Belt around the principal towns and villages. Agree that full account needs to be taken of the assessment of sites’ availability, suitability (including the impact of development on the openness of the Green Belt) and achievability within and adjoining settlements. Where sites do not meet these criteria, agree that it is unlikely to be appropriate to release them from the Green Belt, purely to meet the full housing requirement o Plan inconsistent with stated intention to prioritise the use of previously developed land over greenfield. Examples are the minimal contribution from windfall development, and the intention to allocate Green Belt sites for preferred industries, despite having an adequate supply of employment land o Concentrating housing development within Welwyn Garden City and Hatfield and extending these towns further will turn them into a large conurbation, erode the Green Belt and diminish their separate identities.

Settlement Pattern o Given the more proportionate, dispersed pattern of growth sought, CS3’s hierarchical approach is flawed and inconsistent with CS2. Emphasis should be on achieving sustainable development irrespective of whether a site is in Green Belt. Assessment should consider the NPPF’s three dimensions of sustainable development. Wording does not reflect the Council’s acceptance that exceptional circumstances exist to review Green Belt boundaries and that less than 40% of housing need could be met within urban areas. Development in villages and other rural areas, may be appropriate subject to a rigorous review o It is acknowledged that the primary focus for new development should continue to be Welwyn Garden City and Hatfield. Consider a more proportionate approach based on number of dwellings in the settlement, to ensure a fair, equitable distribution o Strategic growth will be delayed to later in the Local Plan period. Given the shortfall of housing land supply, should look to the borough’s villages which offer sustainable development with existing facilities, railway station and infrastructure that can support increased housing. Welwyn village is a sustainable location o Settlement Strategy fails to take into account the geography of Hatfield, and/or the selection of sites fails to meet the strategy. Should not focus on Hatfield. Consider sustainable sites, regardless of whether are a town or village o None of the major Hatfield sites leverages existing infrastructure, being distant from the town centre and railway station. The idea of creating new neighbourhoods is attractive, but the history of development at Hatfield and failure to deliver promised infrastructure, eg at Hatfield Aerodrome, gives no confidence as to the likely success. o Unfairly biased against Welwyn Garden City and Hatfield whilst other areas are allowed to duck out of their share of the developments such as Brookmans Park, Little Heath and Cuffley. o Should explain why the primary focus for development is in and around WGC and Hatfield. This is not national policy and not in keeping with a Garden City to go on adding more suburbs on the periphery. Why hasn't the special nature of a Garden City been given any weight in this policy? o The correct application of Policy CS3 makes development in village locations which are not ideal a necessity. Proposed level of growth in Welwyn Garden City and Hatfield is not ideal either but development should be spread more fairly. o Many of the Borough’s existing villages remain more sensitive to large allocations of development o The dispersed, proportionate approach has not been achieved. o Welcome the idea of proportionality, however, the way sites have been assessed and Councillors’ decision to not consult on most sites around villages prevent this from being realised. o In addition to undertaking a structured and basic "means test" for each settlement, consider less "mechanical" factors, such as community aspirations for growth in their neighbourhood; achieving a more diverse range of housing to meet local need and retaining and attracting essential services and facilities. Without homes in the right locations to support future growth, in commuting will increase and economic benefits from retail, leisure, educational uses / investment will be lost. A neighbourhood must also be viable and make best use of its assets

and resources, including redundant "land fill" sites. Need. One way to achieve a balance between homes, employment and other community benefits is through sustainable urban extensions which provide employment and ancillary uses to support a wide range of market and affordable housing o Development in excluded villages will sustain the viability of their services. Government policy considers the allocation of housing to rural settlements essential to ensure the viable use of local facilities o Understand the need for further housing, but would welcome a more balanced approach. Appears to be little development centred around other villages such as Cuffley, Brookmans Park. o Excluded villages do not have more limited range of facilities, but have sites adjacent to mainline stations and attractive shopping areas which would benefit from the additional custom new housing would provide. Their long term development would be more straightforward because higher values would allow a higher proportion of affordable housing and the areas are likely to attract families looking to make a long term home o Would be better to build 6/8 houses on the edge or within a village/hamlet throughout the County rather than 300 plus featureless houses on an estate. o If this settlement strategy applied to all sites equally Policy CS3 would not deem WGC4 a more favourable location. Should expand this policy intention to spell out how it will be implemented and what the process will be if sites are brought forward for development o No employment sites are envisaged for the area meaning more car journeys.

Sites o The housing trajectory relies on a large number of small urban sites that would have a cumulative effect on residential amenity and place demands on infrastructure without the opportunities strategic sites offer to improve and/or provide new facilities. Adopt a phasing of sites that reflects a mix of urban and Green Belt sites early in the plan period. WGC5 would help with this. Its release in the first 5 years of the plan would provide a stream of housing supply (approximately 1,200 new homes) o Would not support the removal of Mill Green from the Green Belt but should allow limited infilling, where appropriate, subject to appropriate safeguards over design and build quality o A new village at Symondshyde (56 ha, 1,100 new homes) provides a unique opportunity to comprehensively plan new housing and supporting infrastructure and create a sustainable development o Include some finely balanced sites around larger villages in case some more favourable sites are not achievable or set aside as safeguarded land. That might help achieve policy CS3. o Change the boundary of Welwyn to include the Frythe for the statistics of the schemes in the village, as clearly they will use and impact on the village infrastructure. o Woolmer Green’s convenience shop has closed and a key community aim is to secure its replacement. Proposals include a farm shop, which could incorporate day to day convenience retail, alongside small scale business units as part of a diversified farm business. Allocating WGr1 would lead to the provision of a local service and premises for small businesses, supporting community vitality

60 o Several other sites far closer to the rail network than Panshanger have been classified less favourable and are not promoted in the Plan o Does not maximise accessibility to job opportunities. Lack of employment at Panshanger means people would have to travel elsewhere for work.

Phasing o Disagree with policy intention to prioritise previously developed before allocated greenfield land. This would place the Council under even more pressure to meet the 5 year housing land supply commitments. o The housing trajectory should reflect the new housing target based on OAN of 625 dwelling per annum o Remove reference to phasing o Object to the Plan’s phasing strategy and artificially constraining sites. This is inconsistent with the NPPF para 14 and 15. The NPPF para 47 requires plans to show a 5-year supply of deliverable housing land to ensure housing targets can be met and sites to deliver a significant step change in housing delivery and meet objectively assessed housing needs. Any undersupply should be dealt with within the Plan’s first 5 years (NPPG Paragraph 3-035). Applying the minimum 5% buffer as the NPPF requires, gives a five year requirement of 4,648 dwellings. Whilst the Council should identify a trajectory for likely timescales for housing delivery through the plan period, it should not seek to stall sustainable, deliverable sites from coming forward o The housing trajectory requires the new Local Plan to be adopted by the end of next year – delays increase the risk of a gap in the housing land supply

Evidence o The SHMA has substantially underestimated the level of housing required, and so the under-provision in the emerging Local Plan proposals is even greater than 2,350 dwellings. o The Sustainability Appraisal ranking for each site has not been used in site selection. o The comparison of the effects of the larger sites on the landscape has not been given equal weighting to the impact of smaller sites. o The population and job projections on which the housing target is based are too high. The Local Economic Partnership forecasts 19,000 jobs in the A1 (M) growth area by 2030, mostly in Stevenage, yet the Local Plan predicts 12,000 in Welwyn Hatfield. o The windfall and elderly persons housing allowance has been overestimated which affects the calculation of the shortfall and OAN. Accurately assessing these allowances gives an OAN for Welwyn of 517 dwellings

Infrastructure o Need to expand infrastructure, currently under severe stress, to meet the increase of 1,000 people flowing from the schemes already under construction. Concern there will be a shortfall and that the plan does not fully provide for the key infrastructure required.

61 o Does not appear to take into account the significant number of borough residents who commute by rail to London for employment o This plan would have a serious negative impact on the lives of existing Panshanger residents dependent on local services. Rail transport is sustainable but driving to the town centre and parking near the station are not. Lack of assurances that supporting infrastructure would be provided for this site. No new local infrastructure was put in place following the last major extension to Panshanger in the 1980s o A rigid assessment, based on arbitrary criteria is not a sound basis for meeting a settlement’s development needs. To support sustainable development, must address the need for community infrastructure, education, environmental improvements, attracting and maintaining employment and providing a choice of market and affordable homes

Duty to co-operate o Need to ensure that site selection has exhausted all possible opportunities in terms of new development sites o With regard to the proposed new neighbourhood east of Welwyn Garden City (in EHDC), should clarify, before submission, whose housing supply these 1,700 homes (paragraph 4.4) will count towards (EHDC or WHBC) o Clarify how the borough’s unmet need is to be met

Consultation process and procedure o Policy Intention CS3 Settlement Strategy provides no clear policy on which to comment (this applies to other Policy Intentions within the consultation document). This raises procedural issues as this stage in the plan-making process should be the main opportunity for consulting on Draft Local Plan policies and content, before the plan is published in advance of submission to the Secretary of State for Examination o Ignores responses to the Emerging Core Strategy with regard to WGC4 and previous reports and petitions other than reporting some objections. Local attempts to have the area designated an Asset of Community Value have been dismissed. Consultation should include not just listening to the community’s views but taking them into account and acting on them.

Other o New housing should be affordable, aimed at young families and a few small bungalows for older people to downsize. Planning applications from those with large gardens who wish to build a house for children or grandparents should be looked at reasonably.

How these views have been taken into account

Please see the response with the CS3 Settlement Strategy and Table 1 sections above. Responses to further matters are set out below.

Phasing

The Council has revised our approach to phasing and revised the housing trajectory, including the plan period, which now runs from 2013-2032. While the Plan seeks to prioritise and maximise the use of brownfield land (Strategic Objective 2 and Policy SP 1 Delivering Sustainable Development), and this informs the location of new development, because there is insufficient previously developed land to meet the borough’s development requirements proposed allocations comprise a mix of sites, urban/previously developed and greenfield. The Council expect the proportion of development on brownfield land to fall in future to an estimated 45% over the plan period.

The Council intends to split the housing target into two rates over the plan period (LPPS 2016 Policy SP 2 Growth) with 4,455 dwellings (average 495 dwellings per annum) delivered between 2013 and 2021, and 7,650 dwellings (765 dwellings per annum) delivered between 2022 and 2032. This is not a restrictive phased policy and will not prevent the release of any allocated housing site or early development if circumstances allow - the target is for the purposes of calculating and monitoring Welwyn Hatfield's 5 year housing land supply. If insufficient land comes forward for housing within the plan period, then the strategy to meet the overall housing target will be reviewed. Phasing for strategic sites is to be addressed through a delivery strategy.

CS4 Green Belt Boundaries and Safeguarded Land – CS4 and Policy Intention CS4

Number of responses received: 630 (General 10, Support 18, Object 602).

Support o Welcome CS4 which seeks to promote Green Belt restraint in the borough o Welcome the pragmatic approach being taken in respect of the Green Belt and the need to ensure that the current boundaries remain fit for purpose. Agree with paragraph 5.2 that the pressing need for housing and limited land availability amounts to exceptional circumstances to prompt a review o Welcome the Council’s recognition that the objectively assessed need for housing within the Borough provides the exceptional circumstances for a review of the Green Belt o Welcome the proposals that ‘ larger strategic housing sites (500+ dwellings ) released from the Green Belt will need to be subject of a masterplan [which] may involve the provision of significant areas of open space ’ (Para 5.13) o Para 5.12 – The proposed approach with regard to the possible re-drawing of Green Belt boundaries is sensible. Welcomes the decision to review the Green Belt in the context of meeting the borough’s housing needs. o NPPF encourages planning positively for the beneficial use of the Green Belt to retain and enhance landscapes, visual amenity and biodiversity. A high proportion of the Borough (79%) currently lies within Green Belt, which should help to sustain much of the Borough’s open character and associated ecology and ecosystem services. This is very dependent upon management and a consideration when comparing the relative quality and contribution of sites o Welcome in-principle support for development on land east of Welwyn Garden City within East Herts detailed in Policy CS4 and commitment to continued joint working. However, there are some uncertainties over this site and how it forms part of the wider submitted option which includes land at WGC5. It may be prudent to be less specific about how the site will be managed in policy terms, for example whether delivery will be through a the masterplan, Supplementary Planning Document (SPD), Area Action Plan or other method o The general approach set out in this policy is acceptable, but any re-drawing of Green Belt boundaries should be carefully assessed against future needs beyond the current plan period, so the potential for land phasing should be considered o Support proposed Policy in the context that changes to the Green Belt boundary are necessary and justified and the policy intention that the Council will consider the need to release land from the Green Belt for housing and employment needs o Support the dispersed approach to development o Support the Council’s view that Green Belt Boundaries need to be reviewed and that Exceptional Circumstances exists to provide land for 12,500 homes. o Welcome acknowledgement of the need to consider release of suitable land from the Green Belt for employment purposes o As an exception to this general restraint (in the Green Belt), the identification of a broad location of growth area to the east of Welwyn Garden City within East Herts district is justified and therefore supported o Support the need for change to policy CS4 in order to reflect the approach set out by policy CS3

Main Issues

Green Belt: overarching issues o CS4 promotes the amendment of the Green Belt boundary east of Welwyn Hatfield to safeguard housing land for future provision. Should consider the variety of ecosystem services which Green Belts offer along with the opportunity to promote public access to nature o Para 5.1 to 5.13. Green Belt can help conserve the significance of heritage assets through the control of development within their setting. Need to consider the impact on the historic environment of redrawing Green Belt boundaries and safeguarded land o The allocation of 'more favourable sites' will leave 77% of land still designated as Green Belt. Should base the decision whether or not to release all the land required on robust, up-to-date evidence o Given that 60% of housing need cannot be met (paragraph 5.5), Green Belt land must be released to provide for homes and a comprehensive Green Belt review undertaken. Only 1% of Green Belt would be lost o A reduction in the amount of Green Belt land from 79 to 76 percent is insignificant and could reduce further without loss of amenity for the majority of Borough residents by the use of appropriate densities in settlements, eg 40dph instead of 30dph. This would reduce the land required to be sourced from the Green Belt by 25% o The amount of space to be taken from the Green Belt - 2% of the borough - is not insignificant to residents of Panshanger, Welwyn Garden City or Hatfield which will be significantly adversely affected. o Para 5.5 notes that if need is to be met, there will be some harm to the Green Belt. Why the shortfall as per table 1? Agree that an individual site might have relatively small impact on gaps between settlements (Para. 5.6) o Not a statutory requirement to achieve Local Enterprise Partnership requirements. Must balance against the NPPF (section 14) only where consistent with protecting the Green Belt. The plan is silent on the use of Green Belt for employment land o Object to the proposal to develop any Green Belt land. Government has stated that 'Councils must protect our precious Green Belt land' (6 October 2014). Oppose any development of Green Belt o Reclassify all Green Belt as safeguarded. o Object to the assumption that any housing shortfall from brownfield and existing sites should be made up by building on Green Belt. Should not build on Green Belt o Exhaust all brownfield and windfall sites before releasing Green Belt land, and then only in exceptional circumstances. Use all urban brownfield, derelict and infill sites to preserve the communities and surrounding areas. WGC has plenty of brownfield sites with potential to create housing and further amenities without affecting the Green Belt. o Greater emphasis needs to put on locating suitable sites for smaller developments before encroaching on to the Green Belt. o Misleading assertion that removing large areas of Green Belt land will enable better communication within the Borough and facilitate access to the Green Belt (page 7 Summary and Guide to the LPCD 2015).

65 o Withdraw proposals to declassify Green Belt within the Strategic Green Corridor (SGC) defined as: the land corridor east of A1; north of A414; south of Welwyn Garden City, both west and east; around Panshanger Park and west of Hertford. o Note affirmation that one purpose of the Green Belt is to ‘assist in safeguarding the countryside from encroachment’. Where countryside is ecologically valuable, this will also safeguard associated biodiversity interest although requires management to sustain o Concerned by the effect loss of Green Belt will have on wildlife habitats, protected species and open spaces. Urbanisation of Green Belt areas would disproportionately harm wildlife and biodiversity by restricting the movement of animals and dispersal of plants. Fragmentation of Green Belt land would isolate remaining natural populations and increase the risk of extinctions. o Loss of Green Belt will increase flooding on local lanes. o Paragraph 5.9 states, “Where land is removed from the Green Belt, it should be specifically allocated in the Local Plan as a waste management facility site only”. This was a requirement in the Companion Guide to PPS10 but no similar requirement in the Planning Practice Guidance for Waste or National Planning Policy for Waste

Exceptional Circumstances o Provide evidence of exceptional circumstances and how redefining Green Belt boundaries will promote sustainable patterns of development together with 'safeguarded land' to meet longer-term development needs beyond the plan period, rather than the piecemeal approach proposed. o Policy or supporting text should acknowledge there may be circumstances where exceptional development can be permitted in the Green Belt o Exceptional circumstances may warrant the review of existing Green Belt boundaries to accommodate land for employment in life sciences. o Fails to demonstrate exceptional circumstances exist to outweigh harm to Green Belt land o Object to the release of Green Belt land for development. Contrary to original ethos of protecting the countryside from urban sprawl, safeguarding agricultural land and rural character. Altering the Green Belt boundary would be contrary to Government Policy and ministerial statements. The Secretary of State has said need alone is not the only factor to consider when drawing up a Local Plan,” and that “Green Belt boundaries should only be altered in exceptional circumstances o Revised wording should refer to paragraph 89 of the NPPF to provide clarity on the acceptability of development sites within the Green Belt. o Inconsistent with the NPPF, paragraphs 14, footnote 9 and NPPG paragraphs 44 and 45 that the Plan should seek to meet full assessed need for housing within the ‘market area’ unless constraints, including Green Belt, indicate a lower target is appropriate. NPPF paragraph 14 states that ‘needs’ should not necessarily be met if Green Belt and other constraints indicate development should be restricted. Fails to follow national policy by not identifying a target that avoids significant harm to the Green Belt. Para 5.8 - General need alone is not an “exceptional circumstance “sufficient to justify development

Coalescence

66 o Protecting the Green Belt should be a primary objective of the Local Plan. Green Belt is essential to prevent coalescence of settlements and provide local residents with access to countryside. It must be preserved for future generations o Concern that Green Belt is disappearing at an increasing rate and will cause all Hertfordshire’s towns and villages to merge into one. Specific areas that should no longer be designated Green Belt - perhaps because they already have a major road going through them, should be discussed, consulted on and decided separately. o Erosion of the Green Belt will lead to coalescence of settlements. Hatfield/Welham Green/ Brookmans Park, Little Heath/Potters Bar/London Borough of Barnet. Development will reduce gaps between communities and access to countryside, to the detriment of everyone. o Green Belt between Brookmans Park and Little Heath, and Brookmans Park and Welham Green, is very narrow. Should be preserved if the villages are not to coalesce. Some of it is agricultural land and should be maintained as such o Green Belt should not be built on; it was created for a purpose and is a finite resource. The purpose of setting land aside as Green Belt was to prevent the creation of urban sprawl around London. Impact of overdevelopment of South Herts villages on rural/semi-rural fabric that separates London from the larger towns in the area.

Green Belt and methodology for site selection o Should base the decision to release Green Belt land on the findings of a robust, justified methodology and accurate assessment of the extent to which sustainable sites contribute to Green Belt purposes o Including a ‘local purpose’ in the Green Belt Review methodology goes beyond NPPF criteria and purposes and may have led to discounting potential sites which could assist the borough to meet its OAN. Vital that Green Belt reviews are consistent to inform a strategic vision for the future of the Metropolitan Green Belt. o National Green Belt policy addresses the merging of towns with towns, not villages. The ‘local purpose’ stated in Part 1 of the review for the purpose of ‘preventing villages merging with each other or with towns’ changed in Part 2 of the review ‘to maintain the existing settlement pattern’. Unclear whether this change of wording has changed the approach to site selection o The rationale/process behind how site recommendations from the Green Belt Review were categorised “more favourable”, “finely balanced” and “less favourable”, and included in the Local Plan Consultation is unclear o Because of the above (local purpose) and need to ensure all possible sites have been considered (see response to CS2A), additional Green Belt releases may be appropriate and/or required o Coalescence in national Green Belt policy, is concerned with towns, not villages. On this basis, land around larger villages in the Green Belt may have potential if general impact on openness could be mitigated (eg. compensatory landscaping) o Considering the Green Belt only in terms of its designated purposes, fails to acknowledge that Green Belts can have a positive social and environmental land use function. When assessing harm to the Green Belt consider: degree of public access; national or local biodiversity designations, landscape conservation areas within the land or setting; whether the land parcel provides attractive views of the

countryside; potential for enhancement other than through development that would be inappropriate within the Green Belt

Options for managing open spaces within strategic sites which require a revision to Green Belt boundaries o For larger strategic housing sites released from the Green Belt, large areas of open space that form part of the overall masterplan should remain in the Green Belt, as the designation provides greater clarity over the function and appearance of land (see NPPF paragraph 81). At Panshanger Aerodrome this approach would help provide a clearly defined buffer for heritage assets, particularly Panshanger Registered Park and Garden o Ecological interests are considered best served by large areas of open space remaining in the Green Belt, where they can also serve to set clear development boundaries. Management of such areas remains an essential, though largely outside the scope of planning unless linked to major development o Whilst the need for a consistent approach is acknowledged, it may be that a ‘site- specific’ approach may be required o Para 5.13, whilst desirable to give open land the level of protection Green Belt designation would offer, allowing flexibility within the masterplan layout can be important, for example, for the delivery of SuDS. Ensuring that open space is ‘multifunctional,’ providing flood protection and ecosystem services, can increase the value of open space and justify its protection o Paragraph 5.13 notes that larger strategic housing sites released from the Green Belt will need a masterplan which will set out where different uses would be located on a site. Should include this within a Local Plan policy. As a service provider, favour the approach whereby a whole masterplanned area is removed from the Green Belt. Tightly drawn Green Belt boundaries inhibit development potential, particularly for schools. o Prefer the Urban Open Land option. Would expect new open space within strategic sites to include outdoor sports facilities, especially playing pitches. If retained in the Green Belt, such proposals may be deemed inappropriate. Retaining such open space in the Green Belt, reduces the flexibility of the masterplan and usually results in outdoor sport and other open space types going on the periphery of the development separated from communities they serve by roads, railways and rivers in order to provide a strong defensible Green Belt boundary o At Birchall Garden Suburb a comprehensive, holistic approach should be taken to masterplanning. The Council’s concern regarding its second option is that the open space function might be lost by taking it out of Green Belt. At WGC5 the landfill nature helps structure and retain the use of the new park as public open space. Therefore feel the appropriate strategy here is to designate open space Urban Open Land. Recognise this may not be so in all cases and recommend a site by site approach o Support the retention of large areas of open space in the Green Belt. The area west of the A1, and north - east of the proposed built development on site, should be formalised as green space. o Regarding whether large areas of open space within strategic sites and masterplan areas should retain Green Belt status or be excluded and designated Urban Open land, there should be no need for any designation. If a masterplan

area is to be removed from the Green Belt, it should be removed in full and how the open space is then controlled within them becomes a matter for Development Management

Green Belt boundary Brookmans Park o On the Green Belt maps, Brookmans Park appears to be surrounded by more Green Belt than is the case. Much of it is already developed o Exceptional circumstances do not exist to warrant a review particularly in North Mymms. o Concerns about impact of loss of Green Belt and population increase on the rural infrastructure, roads and agricultural land.

Green Belt boundary Ellenbrook o The Green Belt is a natural buffer between Hatfield and St Albans and must be kept. o HAT 2, 3, 4 and 5 must not be built on. o Impact of loss of Green Belt and development on local and main roads, pollution, congestion, overcrowded trains and buses, lack of school facilities, GPs surgery and social centres, flooding made worse. 3000 dwellings have been built already in the area. o Question the need for so many houses. Ellenbrook Fields would be more suitable for such a vast number of houses. Unnecessary to spoil Ellenbrook area. o Access is poor, Alban Way will be spoiled, flooding made worse.

Green Belt boundary Hatfield o The proposal to remove so much land from the Green Belt for housing along Coopers Green Lane would result in coalescence with St Albans (also planning an increase of housing towards that boundary). This land is currently a buffer between the two settlements and preserves biodiversity. o Impact of loss of Green Belt on mental health, traffic issues along the A1000 and infrastructure, schools, sewerage, housing mix, increasing buy to let and parking.

Green Belt boundary Welwyn Garden City o By no longer protecting Green Belt the unique character of Welwyn Garden City will be irreparably damaged. After the building of Knightsfield, Haldens and Panshanger promises were made that the Green Belt would remain untouched. o WHBC’s Green Belt reviews show flexibility to revise boundaries at WGC5. The first stage assesses WGC5 as contributing least towards Green Belt purposes; the second stage also demonstrates the benefits for redefining Green Belt boundaries for this area against NPPF purposes, concluding that the site contributes significantly against only one national Green Belt purpose (assisting in safeguarding the countryside from encroachment) and performs weakly against the others

Green Belt boundary Welham Green o Object to proposed use of Green Belt land around villages and to providing 300+ homes on Green Belt sites at Welham Green. We are a village not a town. o Proposed expansion will greatly exceed the 3.7 per cent figure for incursion to the Green Belt. o Question why sites around Brookmans Park have been removed when Welham Green has exactly the same issues but less to offer residents.

Green Belt and WGC4 o A review of the Green Belt boundary at this location is necessary. The current boundary appears arbitrary, does not reflect land ownership, physical features or NPPF guidance, lacks strength, clarity and permanence. Amend to accord with the boundary shown in our Masterplan Scenario Document scenario 2. Regarding feasibility of providing the aerodrome on site, land in the Green Belt would be needed. If the aerodrome scenario is not feasible, the existing boundary makes it harder for the site to be properly masterplanned and unduly constrains site capacity. Excluding a larger area from the Green Belt would soften the impact of development along the northern edge whilst maximising the potential for housing. The extent of built development could be agreed having regard to more detailed visual impact analysis and discussion with stakeholders. o Question the relevance of the Phase1 Green Belt assessment to site allocations. East and North East of WGC assessed as making a significant contribution to several Green Belt purposes but no problems with building on WGC4. o Have regard to all relevant NPPF guidelines. o By removing Panshanger Aerodrome have given too much weight to NPPF policy to retain the Green Belt instead of NPPF guidance on retaining leisure and air transport facilities. o If WGC 4 were not developed could return ASR area to Green Belt resulting in no net loss of Green Belt in the borough.

Green Belt boundary New Barnfield area / New Barnfield site o Retain New Barnfield in the Green Belt. o Object to reviewing/altering the Green Belt in this area. The New Barnfield site makes a significant contribution to the four Green Belt purposes identified by WHBC in the current review, contributes to the existing settlement patterns of Hatfield and Welham Green and the setting of Hatfield House. The Green Belt in this area is a ‘green lung’ contributing to environmental and social sustainability o The NPPF Paragraph 89 allows for development in the Green Belt under certain circumstances. o South Way currently provides a strong defensible Green Belt boundary. Redefining the boundary would result in an irregular shaped boundary with no strong features o Object to alteration of the Green Belt boundary which would lead to the coalescence of Welham Green and Hatfield. Development north/south of each built up area would cause coalescence and be unacceptable. Loss of Green Belt would be detrimental to the parish, borough and 'green lung' around London.

Should only occur as a final resort. Use Brownfield sites and reclassified use buildings first o Contrary to Government policy and ministerial statements. o The site helps maintain the gap between Hatfield and Welham Green. The site not only contributes significantly to the fragile gap between Hatfield and Welham Green, it is the gap. o When considering Green Belt boundary changes, consider existing nearby development in the Green Belt and present information about this to people asked to comment on Council plans. o Maps show Green Belt areas as "green", whereas many are developed, including Angerland park-and-ride car park. The Green Belt is more fragile here than maps suggest. o Impact of loss of Green Belt and proposed development on the link road at South Hatfield, schools and parking. o WHBC’s duty to cooperate with HCC [as waste planning authority and original ‘approver’ of a waste management facility at New Barnfield] is not a duty to agree o Object to proposed incinerator which is harmful to children, shouldn’t build next to Southway Cemetery. o Misleading to state that New Barnfield proposals are not defined. Each allocated waste site including NB has a site brief listing potential waste management related uses and potential scale of development. A proposed Recycling Energy Recovery Facility (RERF) at New Barnfield had been resolved for approval by the Waste Planning Authority and considered by the Secretary of State whose decision to refuse was subsequently quashed. Proposed policy CS4 gives no robust reason for not removing the NB site from the Green Belt. The extent of NB site proposals are well known, defined and accepted as not being prejudicial to any other proposals coming forward on the other sites. An important consequence of the WSALP allocation, disregarded by the WHBC policy intention, is the expectation by the WSALP Inspector and court that New Barnfield would be removed from the Green Belt in the next local plan review of boundaries o Re. building houses or flats where garages are suggest re-think as roads and paths are being blocked with parked cars and vans.

Welham Green & Marshmoor Green Belt issues o WeG4b Marshmoor is the last remaining piece of Green Belt contributing to the perceived gap between Welham Green and Hatfield when entering or exiting the village. o WeG10-WeG3-WeG6 will encroach on our precious Green Belt land, cause access problems and should be rejected. o Concern about changes to the Green Belt resulting in loss of wildlife habitat, increased risk of flooding e.g at Marshmoor, the Moat, Watersplash, Waterend and Swallow holes and where land floods and becomes boggy and roads also flood after heavy rain, impact on fragile infrastructure.

BRP7 / Little Heath Green Belt issues o Strongly object to the building on Green Belt as proposed. Lack of exceptional circumstances to review and change Green Belt boundaries so significantly.

71 o Green Belt boundaries should be sustainable and defensible. Some sites, BrP7 for instance, have significantly weaker boundaries than at present. o Concern that changes to the Green Belt will affect sites allocated in North Mymms that are susceptible to surface water flooding or are within or very near designated flood zones. o Concern that sites selected, if developed, will lead to ribbon development contrary to national Green Belt purposes. o At WHBC Little Heath Consultation meeting only “a or b” options or a new garden city were available. There is a great void south of Welwyn Garden City, east of the A1000. This represents 20-25% of Welwyn & Hatfield yet there is no proposal for this area. o Little Heath does not benefit from transport links and services yet it is still being proposed.

Oaklands and Mardley Heath Green Belt issues o Given that the southern Green Belt boundary will be altered to incorporate sites OMH5 and OMH8. Should follow the boundary from the southern end of the proposed boundary northwards of the A1M on the eastern side of the motorway up to The Avenue, then up The Avenue to Danesbury Park Road and along D.P.R. to the North Herts and W.H. Borough boundary. This would then incorporate OMH 7 for another 12 units as a More Favourable site. o The Green Belt Review Stage 2 states ‘Nearly half of all the sites assessed also make a significant contribution to the third national Green Belt purpose of protecting the countryside from encroachment. This is a probable reflection of the fact that, when they were originally defined, Green Belt boundaries were chosen carefully and that, since their definition, the local planning authority has been rigorous in preventing inappropriate development in the Green Belt.’

Gypsy and Traveller development in the Green Belt o Para 5.7 fails to point out the same requirement to demonstrate exceptional circumstances for any site allocation applies to Gypsy and Traveller sites o Incongruous to propose a Gypsy and Traveller site within WGC4 as this community lives in “rural or edge of rural locations” and the NPPF makes allowance for land to be removed from the Green Belt to meet Gypsy and Traveller housing need. o In WHBC’s consultation report the majority of Gypsies and Travellers said they prefer to have additional pitches “on the edge of existing settlements”, not “alongside new housing“.

Alternatives o Build a new settlement in a less crowded area. o Build a new garden city on land not in the Green Belt with neighbouring Local Authorities in North Hertfordshire to address the shortfall between the OAN and the housing target

Sites o Schools within the Green Belt: the removal of Green Belt designation from sites on the periphery of settlements where additional demand for education provision is likely can help the delivery of extended or new schools. Would ask that consideration be given to: a) removing Green Belt designation from school sites; b) identifying MDS status for schools currently washed over by the Green Belt; c) for school sites with MDS status, review whether site boundaries site enable the growth required to meet any increase in needs as a result of further development in those areas o Have not identified sites for release from the Green Belt on the basis of sustainable patterns of development. Subjective, inconsistent assessments of sites classed as favourable, finely balanced and unfavourable; only included favourable sites. Contrary to the NPPF paragraph 84. Does not demonstrate all opportunities have been sought to meet objectively assessed housing need. Not positively prepared. Reassess Green Belt sites within sustainable settlements like Brookmans Park, classed as finely balanced or unfavourable, on a consistent basis in terms of their potential to contribute towards sustainable patterns of development and provide an opportunity to further consider sites excluded from the main body of the LPCD 2015 o In light of the Council's evidence that Brookmans Park is a sustainable location, lack of sites here means the plan will be unjustified and inconsistent with the NPPF aim for sustainable patterns of development o Remove allocated waste sites New Barnfield, Cole Green and RoeHyde from the Green Belt. Object to Policy CS4 supporting text: ‘Because there is so much uncertainty relating to all these sites, the Council will only review Green Belt boundaries once specific proposals and the extent of development are known.’ Demonstrated at examination that all allocated sites are needed to provide adequate waste management facilities for the County and should be removed from the Green Belt via the local plan process. Such an amendment would reflect the County Council’s long term strategic aspirations to ensure sustainable waste management as set out in the Waste Local Plan o Development of OMH 7 has always been supported by the local residents. o Release housing sites from the Green Belt in suitable village locations including Welwyn village. Exceptional circumstances exist to review the Green Belt boundary at sites WEL1 and WEL2. Whilst these sites have ‘red marks’ the Local Plan consultation notes that the issue to consider is the cumulative impact. o Seek the allocation of land for a science and logistics park at Roehyde as an exceptional circumstance that justifies its release from the Green Belt o Against development of the Green Belt and hitherto not suggested a preferred site in our campaign against BrP4, but now feel we have no option other than to promote BrP6 as "least worst" to highlight shortcomings in your assessment of BrP4. The Council’s response regarding BrP4 is misguided, politically motivated and socially engineered to place the ‘affordable housing’ apart from Brookmans Park o Paragraph 5.3 recognises the need to consider the extent of harm to the Green Belt against social and economic benefits. Should release sites such as Cuf 5 where benefits considerably outweigh harm to the Green Belt. The stage two Green Belt Study does not apply a sufficiently fine grain analysis to the Cuf5 site

or place appropriate weight upon the unique opportunity to provide a ‘zero carbon development because of the site’s proposed connection with the nearby Anaerobic Digestion Plant, within the same ownership o Assess and review the purpose and availability of land west of Welham Green. Given nearby station this could be a sustainable location. Together with site WeG4a, traveller sites LTALA03 and GTLAA01 and brownfield sites fronting the A1001, including the Rookery site, there is potential for a new Green Belt boundary in line with South Way. The A1001 and Millward’s Park would provide a permanent, defensible boundary. o Whilst generally support the principles of the Green Belt policies a prejudicial stance is taken on sites at the edge of urban areas considered too small to justify release from the Green Belt. Smaller sites may be considered sustainable by these communities to meet a local need, like affordable housing. A range of different sized sites on the edge of settlements will help support a more sustainable neighbourhood o Exceptional circumstances exist to review the Green Belt boundary for housing land at site WGr3 south of Knebworth village

Hat1 and Hat2 o Clarify how Hat2 was considered in SKM’s Green Belt work. This joint study identified the “Strategic Gap” between St Albans and Hatfield at this point as vulnerable concluding the gap has a significant role in preventing neighbouring towns from merging and assisting in safeguarding the countryside o Agree that exceptional circumstances justify altering the Green Belt boundary around Hatfield. Lack of evidence to justify a reduction of 650 dwellings to 1,350 dwellings. Land for Housing Outside Urban Areas concluded the site could accommodate up to 2,000 dwellings provided the Masterplan was carefully designed to avoid coalescence with Stanborough. Should remove more land from the Green Belt at Hat1 and redraw the new boundary further east along the New Salisbury Line to allow for a suitable scale of development. A revised Hat 1 northern boundary, together with a permanent Green Infrastructure Corridor would safeguard Green Belt purposes, allow the eastern side of the site to remain open land and would continue to contribute to the green gap between Welwyn Garden City and Hatfield. o Para 5.6 ignores the impact on Hatfield and Welwyn Garden City of potential coalescence and that developing some conjoined sites or parts of sites, acknowledged as having less impact. Assumes all conjoined sites would be developed, therefore causing coalescence. o Huge amount of housing proposed north and west of Hatfield to the detriment of the Green Belt. o Proximity of this land so near the university would inevitably lead to the development in time becoming student let dwellings.

OAN and growth targets o The Council acknowledges the need for a Green Belt Review but demonstrates no commitment to releasing sites that would make a real difference to meeting housing need. o Approach fails to meet OAN and longer term needs

74 o WHBC Planning has identified 4860 dwellings that can be met from urban areas and safeguarded land not in the Green Belt. This should be the housing target. o The Local Enterprise Partnership Strategic Employment Plan seeks ambitious growth in the A1(M) corridor. The Local Plan consultation provides insufficient land suited to employment changes that will take place by 2031. Plan not positively prepared, justified, effective and consistent with national policy Need also to account for historic losses of circa 75,000 sqm of employment floorspace to other uses o Reduce the 5,000 homes Green Belt figure to a more manageable total which would have very little effect on the Green Belt and help preserve the character of our towns and villages. o Revised housing figures should take into account these constraints. o Target of 12,500 homes means 50% will be on Green Belt land. Inflates projections of housing need and jobs. Housing Projection is excessively high compared with neighbouring boroughs.

Infrastructure o A conurbation of Welwyn, Hatfield and St Albans is being created without planning of services. o Hatfield’s infrastructure is already strained and roads are inadequate to take extra usage. Infrastructure promises are never kept as in the case of Hatfield Business Park. o Impact of loss of Green Belt and increase in developments on roads and transport links, schools and other family orientated needs.

Duty to co-operate o The delivery of new dwellings East of Welwyn Garden City would meet the needs of the wider housing market area. The two authorities need to accurately reflect this in trajectories and targets. In order to allocate a strategic scale site such as this incorporating or independent of the land at WGC5, there is an onus on the local planning authority to demonstrate the site can be delivered. This approach would be better achieved through a detailed masterplan at an earlier stage and formal collaborative working supported by a jointly prepared policy and allocation in respective local plans. This would help overcome uncertainty with regard to the scale of development and phasing and delivery of essential infrastructure to support the allocation o Should the Council decide not to release the land required to meet its OAN it must demonstrate that it has met the Duty to Cooperate o WHBC’s duty to cooperate with HCC [as waste planning authority and original ‘approver’ of a waste management facility at New Barnfield] is not a duty to agree o Recommend that Green Belt boundaries for this quadrant of Welwyn Garden City are defined in a joint policy in both Local Plans

Other o Recognise the aim of ‘channelling development towards towns and villages ’. Whilst this seeks to retain open land resource, where appropriate should also

recognise and where possible conserve valuable urban ecological resources so as not to degrade the biodiversity of the built environment o There is no clear policy on which to comment. Policy intention is vague and non- committal o Prioritise social / low cost housing in any new development. o Direct efforts and resources into making existing houses more accessible to those who need it and redevelop areas in decline. Target abandoned and derelict areas for compulsory purchase and redevelopment. o Build 4-5 storey apartment blocks for young, low-paid people; rather than industrial developments to promote employment in this region, where housing is already under severe pressure.

How these views have been taken into account

For specific sites, the Green Belt purposes and boundaries assessments have been incorporated into the overarching selection work and considered a range of other benefits and harm that would arise from development of each site.

This is noted in the site-specific responses elsewhere in the consultation document, and is more fully explained in the Housing/Employment Sites Selection Background Papers 2016 prepared by the Council to inform the site allocation decision in the LPPS 2016.

As requested by Hertfordshire County Council, the Council has considered whether there is a need to review Green Belt boundaries around schools and concluded no there are no exceptional circumstances that would warrant their removal from the Green Belt given the proposals for development in the Local Plan and the existence of Major Developed Sites.

Green Belt

The ECS stated the Council’s intention to review Green Belt boundaries, citing the pressing need for housing and limited availability of suitable land within the borough’s existing urban areas. A Stage 1 Green Belt review was undertaken jointly by Dacorum, St Albans and Welwyn Hatfield Councils. The Welwyn Hatfield Stage 2 Green Belt review (plus a later addendum) assessed Green Belt sites in terms of their contribution to these purposes, considered the strength of each site boundary of each site its overall contribution to the openness of the Green Belt. The Green Belt review has informed the preparation of the Plan. Land around excluded villages has been considered as part of this review.

The 2016 Draft Local Plan explains that having taken into account the supply of housing through completions, urban capacity, sites with planning permissions and a windfall allowance, the Council concluded that a strategy that would constrain housing growth to sites within the borough's urban areas would mean that there would be a significant shortfall of housing when considered against the Objectively Assessed Need. Therefore, achieving sustainable development within the borough without impinging on the Green Belt has been unavoidable and Green Belt

76 boundaries have been amended, where exceptional circumstances existed, in order to achieve sustainable development in the borough (paragraph 5.7).

Our approach to site allocation has sought to avoid coalescence between settlements. At strategic sites the Council will require green infrastructure to address issues such as provision of accessible green space, wildlife habitat and landscaping. Masterplans are required by the relevant policies to guide the development of strategic sites.

Hat2 is no longer being proposed for allocation as an outcome of the site assessment and selection work that has been undertaken. Please see the site- specific section for further information.

Green Belt Review and site selection – methodology

The methodology for assessing harm to the Green Belt is set out in the Green Belt Review. It is considered a robust and proportionate methodology, and the results of the Stage 1 and Stage 2 reviews are considered valid. The Local Purpose is considered justified in the Welwyn Hatfield context. While the local purpose has been given some weight, this has been less than that given to the national purpose.

Further work has been undertaken regarding the selection of sites since the LPCD 2015 to more clearly set out how the Council has decided on site allocations. This site selection methodology is set out in the Housing/Employment Sites Selection Background Papers 2016 and is supported by associated committee reports and minutes of the Cabinet Housing and Planning Panel where members deliberated the recommendations of the site selection work and the resolutions passed.

Options for managing open spaces within strategic sites which require a revision to Green Belt boundaries

The consultation document sought views on whether large areas of open space within strategic sits should remain within the Green Belt be designated Urban Open Land. Respondents’ answers varied. In general, the LPPS 2016 proposes that where large open areas exist in conjunction with strategic sites released from the Green Belt these will be designated as urban open land where they meet the criteria for designation. The large area of open space between SDS2/WGC5 and the site within East Herts has been designated as Urban Open Land on the Policies Map for the LPPS 2016. The northern area of SDS5/Hat1, which will most likely be used for playing fields associated with a new secondary school, has not been released from the Green Belt in order to avoid reducing the gap between the Green Belt boundaries of Hatfield and Welwyn Garden City.

LPPS 2016 Policy SP 12 Strategic Green Infrastructure states that “Development proposals within the borough should plan positively for, and contribute to, the creation and management of high quality, multifunctional green spaces that are linked to the surrounding green infrastructure network” (2016 LPPS 2016) and sets out criteria for designating Urban Open Land (Chapter 12). LPPS 2016 Policy SP 11 Protection and enhancement of critical environmental assets and Policy SADM17 Urban Open Land provide for the protection and maintenance of new areas of Urban

Open Land created through development of the sites allocated during the plan period. Areas of Urban Open Land (UOL) are designated on the Policies Map. New areas of UOL which meet Local Plan criteria will be treated as designated UOLs despite not being shown on the Policies Map and protected in the same way as those designated on the Policies Maps.

Green Belt boundaries

The approach taken to amending Green Belt boundaries follows national guidance using physical features apart from where the gap between settlements is fragile. Proposed changes to the Green Belt boundary are considered sustainable and defensible. Green Belt boundaries are shown on the Policies Map. They will be maintained throughout the plan period and only reviewed through a review of the plan.

The Council has considered the impact on heritage assets as part of the assessment of sites and proposed Green Belt boundary amendments. Policies require development to incorporate mitigation where necessary to avoid harm to heritage assets, for example, through the use of buffers and green infrastructure.

Gypsy and Traveller development in the Green Belt

The Plan aims to deliver mixed, sustainable communities which are inclusive, accessible and fair for everyone (Strategic Objective 3). Due to the level of need for pitches and lack of sites suitable for allocation in the urban areas, the Council considers there are exceptional circumstances to justify release of Green Belt land Gypsy and Traveller pitches where there are suitable opportunities to do so.

Waste sites

Paragraph 5.10 of the LPCD 2015 consultation document stated that “the exceptional circumstances relating to these sites, as acknowledged by the Inspector for the Waste Local Plan, relate solely to the need to provide for the treatment and transfer of local authority collected waste. With regard to the County Council’s request to remove waste sites from the Green Belt, because uncertainties remain about these sites, the Council will only consider the need to review Green Belt boundaries once specific proposals and the extent of development are known. There is still uncertainty over the need and distribution of waste management facilities for local authority collected waste with regard to the specific scale, nature and extent of proposals at New Barnfield and Roehyde. With regard to Cole Green, which is a site with an extant waste permission for waste operations, the wider area of land in which it resides has been removed from the Green Belt for residential-led mixed use development (SDS2/WGC2 and Land in East Herts). The LPPS 2016 notes that where considered necessary, when planning for the strategic growth locations identified in the Local Plan, the Council will work with the County Council to explore opportunities for the provision of waste management facilities in order to help achieve greater self sufficiency in Hertfordshire (Chapter 13 Infrastructure). The LPPS 2016 shows allocated waste sites on the Policies Map.

Duty to co-operate

The Council has held further discussions with neighbouring authorities, infrastructure providers and agencies, on cross boundary matters since the LPCD 2015.

Other

Policy Intention CS3 set out an approach on which the Council sought views as part of the 2015 consultation.

The plan proposes to encourage higher densities in accessible locations (Policy SP), such as transport hubs and town and neighbourhood centres Policy SP9 Place Making and High Quality Design.

Developments, depending on their size, type and location, will be required to provide affordable housing in line with Plan policies

Movement Strategy and New Policy Intention Movement

Number of responses received: 32 (General 9, Support 8, Object 15).

Support o Welcome the Plan’s acknowledgement of A1(M) capacity issues and WHBC commitment to continue lobbying the Highways Agency for investment to improve traffic flow and capacity, as part of the A1(M) Consortium. Request this issue continue to be given due consideration within future iterations of the Local Plan o Fully support this strategy o Support the proposed intentions of the new movement policy, in particular the approach advocated in paragraphs 6.1 to 6.4 o Supports WHBC's intention to provide improved opportunities for travelling by public transport, walking and cycling through the location and development of sites and new infrastructure o Supports aim to promote the use of alternative modes of transport with the aim of reducing dependence on the motor car and to promote the use of rail and bus services, improvement to cycle ways, walking routes and journey to work, school , shopping and community facilities and proposals to improve traffic flows created by new development o Promoting walking and cycling, public transport is supported. At present pedestrian & cycle access to some of the borough's smaller stations is terrible, eg at Welwyn North station from North WGC for example. o Welcome the forward-thinking Movement Strategy which has the potential to reduce the need for private vehicle use, while promoting more sustainable transport options (e.g. walking and cycling) o Support the Local Plan growth strategy promoting the use of rail and bus where appropriate and providing for new or improved cycling and walking routes. Welcome recognition of the link between the movement strategy, sustainable development and delivery of strategic sites.

Main Issues o Agree that ' alternatives to the use of the private car continue to be encouraged'. This is essential to make best use of limited space on the road network and for environmental sustainability, health and well-being o Movement strategy needs to take account of the Borough’s already overstretched transport. o There must be a guaranteed increase in local buses to serve the new and existing community. If we are to use it the bus network it needs to be reliable, nearby, frequent and serve all surrounding destinations without the need to change buses. o The Borough is served by Thameslink/Great Northern services rather than East Coast Mainline rail services. Limited parking at smaller stations o Support reference to enhancing the natural, built and historic environment. Should refer to Green Infrastructure as integral to the delivery of sustainable transport, and a key concept for increasing connectivity for more sustainable transport modes, cycling and walking

80 o Could supplement this strategy by the addition of public health principles (linked to Public Health Outcomes Framework)

Cycling and footpaths o Encouraging alternatives to cars should include cycle routes suitable for all year commuting. At present this is possible between Welwyn GC and Hatfield but not to Hertford, St Albans, Potters Bar or Stevenage which are also within cycling distances. Converted railways like Alban Way or Cole Green Way cannot be used for all year commuting as they are unlit and isolated. Therefore routes along main roads are vital. o The emphasis always seems to be traffic flow, but should put pedestrians before traffic, especially in residential areas and routes to the town centre. More pedestrian routes should be at grade rather than involving slopes, steps or tunnels and emphasis placed on making traffic obey speed limits in residential areas and stop parking on grass verges. o Support the need for identifying walking and cycling routes. This should include a commitment to long term maintenance of routes to allow safe use. Policy needs to address securing reliable, affordable bus services in the long term o Recognise the need to provide safe links between existing footpaths through the creation of off-road linking FPs or linking pavements on existing roads where an off-road solution is not practicable. o Welcome Local Plan aims to improve public footpaths and cycleways by providing new connections to existing footpaths and cycleways. There is no mention of the need to provide safe access/links to and between existing Rights of Way and the road network. Many public footpaths in the area have no safe access onto the road system. The local plan needs to reflect a requirement for more comprehensive, safer links connecting the FP network to provide a safe access strategy for all. o Hatfield is missing a vital cycling link from the business park to the station. No cycle path means no cycling as Queensway is too hazardous to cross o All local secondary schools should be on cycle routes to minimise traffic on the school run. These should be safe for an 11 year old child to use (the age at which pavement cycling becomes illegal). A plan for such routes should be a compulsory part of the Local Plan to avoid the health consequences of children being driven to school. The kids cycling to Stanborough School are a model of good practice others could easily follow.

Sites o The location of sites raises issues for the strategic road network which is likely to require mitigation. It is unclear whether development in the full range of proposed Green Belt locations will be permitted. Depending on which locations go forward after examination, this could have significant implications for the impact of the local plan on the SRN o WGC4, WGC5, Hat1 and Hat2 have major highway issues. A considerable distance between site centres and nearest railway stations. WGC4 is too far from the nearest railway station o Little Heath has very little employment. More commuting will increase congestion and emissions, not improve them, as the SA report suggests

81 o The plans make no allowance for the amount of traffic generated o Spread development more widely around the borough. o For housing sites Hat1 and Hat2, road infrastructure will need very serious improvement.

Road network, congestion, highways issues o The transport model focuses on Welwyn Garden City and Hatfield area so allows no assessment of local highway impacts from developments in southern villages outside this area. Discrepancies between site capacities tested and numbers for ‘more favourable ” sites means modelling is likely to have overestimated traffic from development in the Hatfield area, though highway locations coming under pressure are likely to be the same. Development in East Herts has been included (1700 dwellings east of WGC) whereas consultation documents indicate only 450 dwellings likely to have been developed by end of plan period hence less traffic on A414 than forecast by 2031 o Lack of infrastructure to support housing growth proposed and Highway authority credibility, partly due to the long time it is taking to complete the adoption of roads on the former aerospace site. Given that road infrastructure will lag behind development, it makes more sense to spread development more widely around the borough. o The A414 already suffers from congestion at peak times. Additional development will add pressure on the local and strategic road network.. Whilst each development site needs to ensure its local impacts are minimised and mitigated an assessment of the cumulative impacts from development along the A414 corridor as a whole is currently being undertaken. East Herts Council will support its neighbours, working with the County Council to achieve improvements in the strategic road network o The B156 is unfit for purpose and will deteriorate further if the local plan proposed developments proceed. Need a traffic management strategy for the B156 and road infrastructure improvements to precede any further significant housing development at Cuffley and Goffs Oak. o Concern that the B656 and B197, Welwyn’s principal roads, are not mentioned and that development will increase congestion. o The Movement Strategy does not mention the B156, a rat run for the M25 and relief road for the A10. An incident on the M25 causes gridlock which blocks access for residents and emergency vehicles to Cuffley and Goffs Oak o Lack of A1(M) capacity. Highways Agency response to the 2013 consultation noted the lack of any scheme or funding would be a key obstacle. WH development proposals likely to significantly impact upon remaining capacity, and other authorities’ ability to demonstrate the deliverability of credible plans o Note intention for Green Travel Plans and transport assessments for smaller schemes that have an impact on the highway network. Must also take into account the effect of development in surrounding districts, eg the effect of plans for significant expansion at Codicote and Knebworth on traffic flows on the B656 and B197 o Safety improvements should be made at the junctions of Travellers Lane and Swanland Road with Dixons Hill Road

Duty to Co-operate o Discrepancy between the Plan’s stated intention to encourage bus usage and current reduction in subsidy and local bus services. Need a coordinated policy between Boroughs, Districts and the County Council to address o Lack of "joined up" thinking between the local and county Councils on the traffic impact at the Clock roundabout of thousands of new residents from schemes on the Codicote/Kimpton Roads, Woolmer Green and Stevenage, seeking to avoid A1M jams morning and evening. A traffic light controlled junction is needed.

How these views have been taken into account

The LPPS 2016 settlement strategy and hierarchy direct growth to the most sustainable locations which make best use of existing infrastructure and the potential for improvements or changes to it. The LPPS 2016 is clear about locations where land is proposed to be released from the Green Belt. This should provide certainty with regard to road infrastructure and mitigation that may be required.

The Plan recognises highway network and public transport improvements will be important to facilitating development the Local Plan identifies, in particular the delivery of the strategic growth locations. These works need to take place alongside the promotion of sustainable means of travel, minimising congestion and emissions. This will support the local economy whilst protecting quality of life and air quality and improving accessibility and road safety.

A key theme which runs throughout the plan is improving opportunities for travel by public transport, walking and cycling and creating walkable neighbourhoods. This is reflected in LPPS 2016 spatial vision and policies. Policy SADM 3 Sustainable Travel for All requires developments at or above the thresholds set in Hertfordshire County Council’s Travel Plan Guidance to submit a Travel Plan as part of a planning application. The policy includes requirements for provision for cyclists, pedestrians, safeguarding existing Public Rights of Way and promoting enhancements to the network; public transport (measures to provide new or improved routes); community transport; servicing and emergency vehicles; and facilities for charging plug- in and other ultra-low emission vehicles.

The LPPS 2016 requires strategic sites to be developed via a masterplanning process. A key element of these masterplans will be considering any highway impacts and the mitigation measures required to facilitate development without adversely impacting on the network. They will also set out how sustainable transport measures including improving pedestrian links, cycle paths, passenger transport and community transport initiatives, suitable access arrangements and any necessary wider strategic and local highway mitigation measures will be delivered. Development at SDS5/Hat1 would be required to address impacts on Coopers Green Lane, Green Lanes, the A1001 and locations at or around Junction 4 of the A1(M) (Policy SP 22 North West of Hatfield) and development at SDS2/WGC5 will be required to address impacts to the A414 in Hertford, the B195 and A1(M).

Site Hat2 is not proposed for allocation.

Hertfordshire County Council plans to improve the bus station arrangements in Welwyn Garden City Town Centre. Part replacement and/or enhancement of the pedestrian bridge over the railway at Welwyn Garden City Station is an objective in the Broadwater Road West Supplementary Planning Document. The Council is aware that passenger capacity issues on East Coast Main Line may need addressing to support planned development. Hertfordshire County Council is updating its Local Transport Plan and associated documents to accommodate growth arising from Local Plan in Hertfordshire.

The LPPS 2016 recognises the need to provide infrastructure to support walking and cycling across the borough to ensure that new development is delivered in a sustainable way. The LPPS 2016 notes that the Council will work with developers and/or landowners and its partners to ensure that new development is well supported by pedestrian footpaths and cycleways, and that where appropriate existing infrastructure is enhanced to meet the level of demand. Policy SP 12 Infrastructure aims to ensure suitable provision is made for new or improved infrastructure, required to meet the levels of growth identified in the Local Plan.

The Council’s Infrastructure Delivery Plan (IDP) supports the delivery of the LPPS 2016 objectives. It is based on a detailed assessment of Welwyn Hatfield’s infrastructure needs and indicates specific requirements for different types of infrastructure. The Council will continue to work with infrastructure providers in refining and developing the IDP and its associated infrastructure delivery schedule to ensure that necessary infrastructure of all types is in place to support planned growth.

LPPS 2016 Policy SP 4 Transport and Travel commits the Council to working with the County Council as the local highway authority, Highways England, public transport operators, developers and other relevant bodies to design and fund improvements to transport infrastructure necessary to support growth or to improve accessibility to existing centres, employment areas and community facilities.

The Council has undertaken extensive transport modelling work since 2010 (Highways Agency ‘Diamond' model and subsequently a bespoke strategic model - the Welwyn Hatfield and Stevenage Hitchin (WHaSH) model) to test the impact of planned housing and employment growth identified in the Local Plan on the highways network in and around the borough to 2031. This work has shown that, planned growth around Hatfield and Welwyn Garden City would increase pressure on Junction 4 of the A1(M) and adjoining Jack Oldings roundabout and would lead to significant traffic growth at Junction 3 of the motorway. More detailed modelling work has looked at component parts of this traffic growth and potential queuing locations, and informed the consideration of possible junction and link improvements to reduce congestion.

The planned section of 'smart motorway' between junctions 6 and 8 (Welwyn to North Stevenage), which is intended to mitigate against the effects of congestion between Welwyn and Stevenage, has been allocated funding and is due to be implemented in 2020.

The WHaSH model shows that a number of key local roads, especially around the strategic growth locations, become close to or over capacity. Alongside the modelling work, initial studies identifying possible mitigation measures and producing broad costs of such measures have been undertaken. Further work on mitigation designs and alternatives will be required, to develop a range of measures to ameliorate the impact of growth on the highways network. This would take place at the planning application stage.

The LPPS 2016 acknowledges that the B156 is a heavily trafficked route (footnote 50, Policy SADM 18 Environmental Pollution).

The Council has further assessed potential sites and site capacities and taken this assessment into account in LPPS 2016 allocations. Hertfordshire County Council has carried out work to consider the highways impact on villages. Subsequent transport modelling has been done on the basis of the LPPS 2016 proposed growth scenario. These further pieces of work update our evidence on transport and highways impacts and should help avoid any potential discrepancy in the figures.

The LPPS 2016 acknowledges that to achieve the level of housing growth proposed additional peak stresses on north/south routes will need to be addressed with measures to improve traffic flow and investment in sustainable transport. Hertfordshire County Council will be preparing a Growth and Transport Plan which will support the delivery of the Local Plan. As noted above, masterplanning of strategic sites will need to take account of the wider impact of the development of those sites on the transport network.

LPPS 2016 Policy SADM 2 Highway Network and Safety aims to manage the growth in traffic on the highway network resulting from development in the interests of highway safety and maintaining highway capacity.

As a local authority member of the A1(M) Consortium the Council will continue to lobby Highways England and Government for investment to improve traffic flow and capacity at key locations on the motorway. The Council will work with HCC and other Hertfordshire authorities to address congestion issues on the A414 and seek opportunities for transport improvements to ease east-west movement across the borough and in the county generally.

CS19 Strategic Green Infrastructure and Policy Intention CS19

Number of responses received: 28 (General 6, Support 10, Object 11).

Support o Support this approach and welcome further discussions and co-operation. o Support approach and delivery mechanism o Support approach set out in Figure 2 o Support this proposal as it would compensate for loss of greenbelt land o Support approach to secure delivery through S106 and CIL, given the importance of land management in securing ecological enhancements o GI provision has an important role in improving health and wellbeing o Agree with the above statement from ) o Support the proposals. o Welcomes the broadening of policy CS19 to focus on strategic green infrastructure provision between Hatfield and WGC Proposals provide an opportunity to create a network of connected green open spaces providing access to natural green space, enhance biodiversity and help to mitigate the impacts of development. The Estate are proposing a new, extended Salisbury Line which will build upon the original agreement between the Gascoyne Cecil Estates company and Welwyn Garden City Ltd in 1946 that sought to maintain a strategic gap between Welwyn Garden City and Hatfield [more detail in response] o The masterplan for Birchall Garden Suburb comprises a series of green fingers that form a new multi-functional green network. This network would integrate existing areas whilst also creating new links and enable an extension to the Commonswood Local Nature Reserve. As the Master Plan progresses David Lock Associates will seek to inform the delineation and scale of the strategic green infrastructure links and the key diagram to be included in the local plan o Support proposals for a green chain. STL1 will provide additional open land if taken forward.

Main Issues o This proposal should be delivered regardless of housing growth. o Refer to the Council’s local Green Infrastructure Plan o Policy should address historic environment issues relating to GI. Heritage assets can benefit from GI proposals and can be GI assets. Green Chain proposals connect heritage assets such as Hatfield House and Panshanger Park o Unclear how proposals will be delivered. Major landowners along the green chain would need to be involved. More detail required to support this policy. o The rationale and context for the Green Infrastructure belt is poorly expressed. Does not reflect the existing, principle feature of this corridor, the River Lea. The strategic function of Ellenbrook Fields is unclear o S106 and CIL funding will not be sufficient to deliver this project. o The nature and management of greenspace is critical if it is to genuinely compensate for loss of open land and biodiversity enhancements. Hertfordshire’s Ecological Networks Mapping should be used. Ecological networks mapping should determine the location and character of new green infrastructure.

Provision of green infrastructure should coordinate with existing assets to maximize value to biodiversity. o Housing densities should be lower in areas the green chain passes through or borders. Proposals should form part of the masterplans for growth locations. o The current green corridor between WGC and Hatfield prevents coalescence between Hertford, Welwyn Garden City & Hatfield, protects existing green space, delivers community benefits, increases public access to open countryside, protects the River Mimram and River Lea valleys, forms an important wildlife site and corridor, preserves the setting of heritage assets, provides a vital role in the function of Welwyn Garden City as a Garden City. o Acknowledge that the green chain will compensate for the loss of Green Belt land around the two towns. Just providing amenity aspects of greenspace is insufficient, as these presume high quality greenspace is present to begin with and can be maintained – which may be beyond the role of planning o Sites forming the proposed green chain will block an important wildlife corridor between Stanborough and Hertford. Lack of evidence that the potential loss and protection needed for sites across the green chain has been assessed. Should protect wildlife sites o Land must be safeguarded throughout the green chain to create routes wide enough to encourage wildlife migration. Narrow corridors through housing estates will not be appropriate. o Acknowledge that large strategic sites, whilst resulting in the loss of open space, would provide an opportunity to create a network of connected spaces. o Amend links on Figure 2 to reflect residential and recreational opportunities along the Green Chain. o GI should be shown on the key diagram o Proposals do not go far enough. Policy should encourage development proposals to link to strategic GI throughout the district not just in WGC and Hatfield. o GI resources should build on existing provision in districts and relate to wider GI networks in neighbouring areas, especially where open land resources are vulnerable to coalescence (Hertfordshire County Council Environment). o Whilst only a very limited green corridor could be identified through masterplanning credible GI still needs to be provided to support the proposed growth locations o The link is compromised by the A1M and will be further compromised by WGC5. o Proposals do not compensate for the release of Green Belt land around the towns, which already serves this function. Should protect existing green spaces. Concern about loss of a significant part of Ellenbrook Fields Country Park. Development will increase pressure on remaining Park resources. Ecological impact on Home Covert woodlands and adjacent grassland. Remaining area likely to be dug for gravel, changing the area permanently to a largely wetland environment unless extraction pits are filled in. Loss of a valuable grassland habitat of considerable local bird interest – albeit modified due to future gravel workings and recreation pressure. Need to consider the net impact and provide habitat compensation

Duty to co-operate o Would welcome the opportunity to work with the Council at the borough boundary to evolve the policy. Development east of WGC will need to address GI provision and connections to East Herts through the masterplan and supporting policy

How these views have been taken into account

LPPS 2016 Policy SP 12 Strategic Green Infrastructure takes forward the intention set out in the LPCD 2015 and provides further detail on the requirements and provisions that will need to be made in associated with development. This has been informed by further informal consultation, including a workshop, with stakeholders within and beyond the borough.

This policy is wide-ranging in scope and commits the Council to working with partners to actively support the creation and enhancement of strategic green infrastructure across the borough. It seeks to ensure that proposals plan positively for and contribute to, the creation and management of high quality, multifunctional green spaces that link to the surrounding green infrastructure network. The policy requires (where appropriate) Hertfordshire’s Ecological Networks Mapping to inform the location and nature of green infrastructure provision. New development will be required to have regard to open space standards. Developer contributions will be sought to support the implementation of Hertfordshire Rights of Way Improvement Plan and Welwyn Hatfield Green Corridor project; improvements to the River Mimram and Lea corridors; and greening of the urban environment in Welwyn Garden City and Hatfield.

The policy states that Welywn Hatfield Green Corridor project will provide new strategic connections to Ellenbrook Country Park, Symondshyde Great Wood and Heartwood Forest in the West, and Stanborough Park, the Commons Wood Nature Reserve, and Moneyhole Lane Park to connect to Panshanger Park, the River Mimram and Lea Valley in the east. Provision of GI is also dealt with under other policies for example, strategic sites policies which will require masterplanning to show how GI requirements will be met. Policy SADM 16 Ecology and Landscape deals with the protection of ecological networks.

With regard to the development/creation of Welwyn Hatfield Green Corridor, LPPS 2016 Policy SP 12 states: “Proposals for the development / creation of the Green Corridor will be detailed in the emerging Green Corridor Supplementary Planning Document and will be incorporated into the masterplanning of strategic sites. Proposals for development within or adjacent to the Green Corridor must have regard to the aims, objectives and projects identified in this document and avoid any negative impact upon existing ecological assets, valuable areas of green or blue infrastructure and public rights of way. Development that would jeopardise implementation of the Green Corridor project will not be permitted.”

Policy SP 12 supporting text acknowledges that “Open space can sometimes be of historic significance, perhaps as part of a conservation area or simply contribute to visual amenity by providing views and vistas or simply through its beauty.” The supporting text describes the role of Welwyn Hatfield Green Infrastructure Plan 2011 in providing an overview of existing green infrastructure assets within the Borough and assessing its functions. Following further consideration of the evidence, Hat2 is not proposed for allocation.

Duty to co-operate

The Council has held further discussions with neighbouring authorities, infrastructure providers and agencies, on cross boundary matters since the LPCD 2015.

Development next to Welwyn Garden City in East Herts will contribute to meeting needs in Welwyn Hatfield housing market area and will be required to be in line with general green infrastructure requirements but also support delivery of the Green Corridor concept which stretches from St Albans through the borough to East Herts. Delivery of of development at SDS5 and on adjacent land in East Herts will require the two authorities to produce a joint masterplan which will respond to general green infrastructure issues and the specific Green Corridor concept.

Spatial Policies and Spatial Policies Intention

Number of responses received: 12 (General 5, Support 0, Object 7).

Support

Main Issues

Green Belt o Building on Green Belt is unacceptable, against government policy (Little Heath Action Group). o Should not build on Green Belt land.

Vision and objectives o The statement (paragraph 8.4) that the vision and objectives for Hatfield were generally supported in the Emerging Core Strategy consultation is a misrepresentation as generally people objected to the location and number of dwellings proposed o The vision for Welwyn Garden City is bland and should include an airfield and other diversified attractions important to the community. o Hatfield always seems to get the rough end of the deal – losing more Green Belt and open space and traffic is increasing. o Garden City principles should apply to Hatfield as well as Welwyn Garden City. o Vision for Hatfield should appreciate that sites west of the A1(M) are not near the town centre or railway station, cut off from Hatfield by busy roads and will never contribute to its regeneration. It should recognise that there are two Hatfields. Need a vision allowing the town centre to shrink and addressing the transient nature of much of Hatfield’s population and a separate vision for the new community west of the A1(M) o Disagree that “there are more opportunities for growth” in Hatfield. This reflects supply, not demand. Best opportunities for sustainable growth and establishing stable communities, which will fund more affordable housing, are not in Hatfield which is blighted by its town centre.

Sites o Previous comments on visions and objectives for Hatfield and Welwyn Garden City should be taken into account. Note intention to include site specific policies for strategic locations of 500 or more dwellings. Should not exclude smaller sites from site specific policies. They often have specific issues that need addressing, including heritage assets. An appropriate level of detail should be set out in accordance with the NPPF paragraph 157 and Planning Practice Guidance o Hat1 and Hat2 will do nothing for Hatfield town centre as residents will head to Welwyn Garden City. Document does not acknowledge the huge scale of development will change the settlement pattern of the borough. o Major housing sites identified are too far from the town centre, on the wrong side of the motorway, to represent an opportunity to secure much needed investment

90 o Panshanger Aerodrome has been closed for 6 months, North London Flying School has relocated to Elstree Aerodrome. All owners have made alternative arrangements to park their planes. Development would not therefore result in the loss of an existing facility. There is currently no compelling evidence that there is demand or need for an aerodrome in this location. o The majority of people are against the development of Panshanger Aerodrome and Hilly Fields and this would have a negative impact on the vision and objectives. o Ignores the fact that Panshanger aerodrome and surrounding areas have high historical and environmental value in terms of recreational green space and natural wildlife habitat. o Mill Green is not of a scale that warrants it being considered as a strategic housing allocation. Other policies, e.g. CS20, should allow for limited infilling where appropriate and subject to appropriate safeguards over design and build quality o Welcomes Core Strategy policy CS7 recognition that sites within or adjoining the borough’s Green Belt villages can provide housing to meet the local community’s identified needs. Policy is more restrictive than the NPPF paragraph 54 which states; 'Local planning authorities should in particular consider whether allowing some market housing would facilitate the provision of significant additional affordable housing to meet local needs". Should this be the intent, should justify this. Concerned the approach may render provision of affordable housing within rural areas unviable o Clarify the long term approach to Ellenbrook Park, given the significantly reduced park resource that will then be dug for gravel which presents restoration expectations and management requirements. Implications for recreation and future ecology

Other o Local Plan should allow limited infilling in villages o The wishes and views of the borough residents needs to be better reflected.

How these views have been taken into account

Welwyn Garden City and Hatfield

With regard to the visions and objectives for Hatfield and Welwyn Garden City a mix of views was received, but overall support was shown. For the vision for Welwyn Garden City the Council has added text to support this in the LPPS 2016, including a new section “Garden City Principles for masterplanning strategic developments” which sets out principles which strategic development should follow.

The Council has revised the vision for Hatfield in the LPPS 2016 to make this more positive. Replacing the second sentence with “The town's strengths as a sub regional destination for employment and higher education will be complimented with investment in its town centre and neighbourhood centres, alongside new housing, and excellent community and leisure facilities” and referring to the provision of new green infrastructure to provide habitat for wildlife and access to open space. The Council has revised the ending as follows: “Together these actions will have created

91 a well designed, well connected, well balanced, distinctive and multi centred town which retains its 'New Town' pioneering and entrepreneurial spirit.” Reflecting our work as part of Hatfield Town Centre Partnership, the LPPS 2016 also includes a vision for Hatfield Town Centre and a strategy to deliver that vision.

The Council has substantially revised and expanded the objectives for Hatfield in the LPPS 2016 as result of comments made on the LPCD and the Hatfield Visioning exercise which took place after the LPCD 2015.

The LPPS 2016 notes the NPPF point that the supply of new homes can sometimes be best achieved through planning for large scale developments that follow garden city principles. The LPPS 2016 envisages all strategic sites across the Borough to be masterplanned according to Garden City Principles.

In addition, Policy SP 9 requires all development of a high quality design that respects the character and context of the site.

Hat2 is no longer proposed to be allocated.

Excluded villages

Considering the responses to the LPCD 2015, the more proportionate distribution of growth and greater growth in the excluded villages, news sections for each excluded village have been incorporated into the LPPS 2016. These sections set out a number of objectives for each settlement. Development proposals in those settlements will be required to respond to and support those objectives. Similarly, all allocated sites within the excluded villages set out with the respective SADM policy are accompanied by table outlining the basic site-specific provisions that development proposals for those sites will be required to respond to.

Green Belt

Please see responses in the CS2, CS3 and CS4 sections above.

Infill development

The LPPS 2016 recognises the role of infill and indicates the circumstances where this may be appropriate under policies SADM 1Windfall Development, SP 25 Rural Areas and SADM 36 Development within the Green Belt.

Part 2 Sites

Section 10 Welwyn Garden City, Welwyn Garden City Housing and Table 4

Number of responses received: 39 (General 12, Support 2, Object 25)

Support o We need more homes, particularly 1 and 2 bed flats/maisonettes for young, single and older people and affordable homes to buy and rent. o Will continue to work with both Welwyn Hatfield and Hertfordshire County Council and relevant landowners and stakeholders to ensure the sites are comprehensively masterplanned with the necessary infrastructure

Main Issues

Green Belt o Recognise the purposes of the Green Belt around Welwyn Garden City which seeks to prevent coalescence of settlements. The only land available outside the settlement not part of the Green Belt is at Panshanger Aerodrome. It would seem there is no other option than to consider this if land of this extent needs to be identified without impacting upon the Green Belt o It is important that WGC and Hertford remain separate and Green Belt is protected. WGC will become a conurbation and lose its identity. o Do not build on Green Belt, use brownfield sites such as garages and old industrial units. o Don’t destroy countryside around WGC. Access to and through surrounding open countryside and Green Belt and the restraint on growth ensures the continuing function of the Garden City for residents and business.

Open space / countryside / ecology o More housing will infringe on open spaces which are important for our health and wellbeing. o Proposals will create noise and air pollution, endangering wildlife and affecting quality of life. o Some proposals are close to nature reserves. Development will disrupt the wildlife corridor from Panshanger Park to Stanborough Park.

Settlement Pattern o The proposed housing distribution goes against everything Welwyn Garden City stands for. Welwyn Garden City was the world’s second Garden City built on the principle of healthy living. The proposed WHBC Local Plan fails to consider Garden City principles, which do not include building vast extensions on the periphery of the town. A sprawling Welwyn Garden City impacts severely on the function of one of Hertfordshire’s internationally-recognised towns. o Recent development to the east has unbalanced the town. Further development here would compromise attempts at sustainable transport and destroy

opportunities for creating a viable green link between The Commons and Panshanger Park. o New roads should be wide enough for bin lorries to get past parked cars. Suggest grass verges next to the house frontage, as with South Ley. o Development will not assist regeneration and is unsustainable. o Withdraw support for development within East Herts. Neighbouring authorities are already appending their own developments to Welwyn Garden City’s borders. o Panshanger has not properly integrated into WGC. o Build up not out. o Build where it will have least impact on existing residents. o Spread housing across the borough in a fairer way so that all communities take a fair share of new housing and Gypsy and Traveller sites and no single area is swamped. o As 42% of the borough population already lives in Welwyn Garden City, it would be more sustainable to plan a different approach to housing distribution. o A new Garden City / New Town with the necessary infrastructure would be a better solution to solve the housing issue.

OAN shortfall / scale of growth o No evidence of exceptional need to justify 1700 homes on land around Panshanger Park. o We cannot keep building until the land is exhausted. o Table 4 shows significant shortfall compared with OAN

Design, local character and Identity o New homes diverge from traditional WGC housing layout and don’t fit in. Adopt NPPF principles to underpin the identity of Welwyn Garden City and recognise the important planning status of this Garden City, its unique history and potential as a future model for planning. WGC as originally designed cannot cope with the demand placed on it by motor traffic (narrow roads, verges being cut up and parked on). o Developers should be made to adhere to higher environment standards

Wellbeing o Clarify how proposed growth will address/reduce health inequalities in Peartree Ward and not exacerbate deprivation. Regeneration to reduce existing health inequalities should be a priority of future development schemes which should promote physical activity, health and wellbeing in a community experiencing high levels of obesity and premature mortality o Proportion of affordable and social housing has implications for existing health inequalities. o How21/WGC1/WGC5 deliver over 1100 homes in or adjacent to Howlands ward where obesity is above the England average. Proposed developments should promote physical activity through green infrastructure, open space, play areas, neighbourhood centres and active travel

Sites

o Assess WGC4 and WGC5 as “not favourable”. Do not build east of WGC. o Potential for Broadwater Road development to be isolated from the wider Peartree ward and to promote a social divide. Need to consider community integration and access to services and facilities for existing and future communities o Hertfordshire Fire and Rescue Service seek an alternative site(s) for Welwyn Garden City and Hatfield Fire Stations. The County Council requests that the Welwyn Garden City Fire Station, Woodfield Road and Bridge Road East be allocated for housing within the Local Plan. o Requests that the former weighbridge site, A1001 Comet Way be allocated as a site for a combined Fire and Rescue Centre

Proposals in the vicinity of Panshanger registered park and garden, including WGC4 and WGC5/EWEL1 o Development will affect the setting of Panshanger Park and its importance as a heritage asset o Future iterations of the Local Plans for Welwyn Hatfield and East Herts should not be taken forward until the evidence base to assess the sensitivity of this area for development has been fully considered. Request a study be prepared defining the significance of Panshanger to determine the sensitivity and capacity of this area for development. The study should be carried out with the co operation of the two local authorities, relevant landowners and English Heritage, and should help inform Local Plans and any subsequent masterplanning o East Herts have a legal requirement to provide a country park in relation to development around Panshanger. o Object to any access roads down Holwell Hyde Lane or Thistle Grove.

Site Pea94 Bridge Road East o On the information available, no wastewater capacity issues are expected o Development will not adversely affect any heritage assets o No fundamental ecologic issues, low ecological opportunities and sensitivity, site unlikely to be home to protected species. There are no recognised ecology sites nearby

Gosling site o Broadly support the idea of developing Gosling it if eases pressure on the Green Belt. o Stanborough school leases adjacent land for playing fields, including a strip of land that enables access to the playing fields. Development should take account of the lease, rights of access and use of playing fields by the school o Access to the playing fields for school pupils should not be compromised. o Do not build on Gosling as it is the only leisure centre in Welwyn Garden City. o Disposal of part of the Sports Park would result in the loss of sports facilities - may be contrary to national and local planning policies relating to community sports facilities

Pea96 Former Argos site, Bessemer Road o Reclassify former Argos site as suitable for residential led mixed use. Such redevelopment would generate similar or greater employment to the present B8 classification. Could help address the shortfall of quality flatted development close to the town centre and transport network. A sustainable town centre location

Sh91 o Allocate 15 Digswell Park Road as it is outside the Green Belt

Cuf5 o Reserve our position in commenting in detail on potential housing that have been identified at WGC and throughout the borough generally

East Welwyn Garden City o Figure 5 does not show the full extent of land submitted by landowners and gives the impression that a decision has been made regarding the extent of this site. Figure 5 - caveat that this is indicative until such time as East Herts, working with Welwyn Hatfield Council determines the preferred site outline

Gypsy and Traveller Sites o Put new Gypsy and Traveller sites next to existing sites.

Infrastructure o Welwyn Garden City cannot take much more development. We do not have the infrastructure to cope within this plan. Schools, doctors, hospitals, railway and roads water, sewerage are overstretched, with no proposals for new and improved facilities. Road, railways and parking cannot cope. o Proposal for more jobs takes no account of infrastructure. o WGC and Hatfield would have to support the development in East Herts, through schools, transport, retail, even though it is in East Herts. o Reinstate hospital facilities before developing sites.

Duty to Co-operate o Need to consider the cumulative effect of Welwyn-Hatfield and East Herts proposals, as they cannot be considered in isolation. There is a lack of discussion between the two authorities. o Will continue to work with Welwyn Hatfield and Hertfordshire County Council, relevant landowners and stakeholders to ensure sites are comprehensively masterplanned with the necessary infrastructure o Paragraph 10.25 refers to development east of Welwyn Garden City meeting the needs of the housing market area. This encompasses parts of East Herts around

the A414 into Hertford. The delivery of new dwellings needs to be accounted for accurately in each authority’s housing trajectories. East Herts District Council would welcome the opportunity to discuss this further. o Strategic sites may be required to meet the needs of Gypsies and Travellers within East Herts. would welcome the opportunity to engage with Welwyn Hatfield Council on this, particularly given the potential provision within the Panshanger site at WGC4

Consultation process/materials o Format of the local plan makes it difficult to read and form an objective view. A poor, subjective document. The result of political intervention

How these views have been taken into account

Green Belt

Please see the Council’s response in section CS4 above.

Open space / ecology

The process of appraising and selecting sites has sought to avoid impacts on designated natural assets and open space, and avoid impacts on ecology and wildlife. The LPPS 2016 contains policies that seek to safeguard environmental assets including open space and wildlife, in particular SADM 16 Ecology and Landscape.

Settlement Patter/ OAN shortfall / scale of growth

Welwyn Garden City, the largest settlement in the borough, is the primary focus for new development. New development will reinforce its role as the borough’s principal centre for economic activity and support the delivery of economic growth (LPPS 2016 Policy SP 3 Settlement Strategy and Green Belt boundaries).

In line with the Settlement Strategy, the LPPS 2016 allocates sites to deliver around 2,140 new dwellings in and around Welwyn Garden City. Total housing growth, now set out in the LPPS 2016, will be 4,923 dwellings which is above the 3,963 total potential capacity identified in the LPCD 2015, but below the mathematical proportionate OAN of 5,600 dwellings noted in the LPCD 2015. A purely mathematically proportionate approach does not necessarily equate to the most sustainable strategy or result in the most sustainable sites being allocated.

Please see the Council’s response to section CS3 Settlement Strategy above for further information on this matter.

Design, local character and identity

For the vision for Welwyn Garden City the Council has added text to support this in the LPPS 2016, including a new section “Garden City Principles for masterplanning

98 strategic developments” which outlines principles strategic development in the borough must follow.

Wellbeing

The Local Plan seeks to bring about sustainable development in the borough by applying the following principles: The need to plan positively for growth in a form which supports economic growth, increases the supply of housing and contributes to the reduction of social and health inequalities in the borough and which recognises environmental and infrastructure constraints (Policy SP 1 Delivering Sustainable Development). Plan objectives (Strategic Objective 3) and other Local Plan policies, including strategic site policies, and policies on Community Services and Facilities, Design, Open Space, Green Infrastructure, Transport and Travel, Sustainable Travel for All and Environmental Pollution also address health and wellbeing.

Duty to Co-operate

The Council has held further discussions with neighbouring authorities, infrastructure providers and agencies, on cross boundary matters since the LPCD 2015.

Site allocations/issued related to WGC4, WGC5 and Land in East Herts

See Welwyn Garden City site specific sections further below

10 Welwyn Garden City Site Pea94 Bridge Road East

Number of responses received 3 (General 3, Support 0, Object 0)

Main issues o No wastewater capacity issues expected o Development will not adversely affect any heritage issues o No fundamental ecological issues

How these views have been taken into account

This site received planning permission for 23 dwellings on 30/09/2014.

100

10 Welwyn Garden City Site WGC1, Creswick

Number of responses received 19 (General 6, Support 1, Object 12)

Support o Subject to further masterplanning in consultation with Welwyn Hatfield Borough Council, Hertfordshire County Council and local stakeholders, recommend allocating within the emerging local plan for up to 300 dwellings

Main Issues

Ecology o Impact of development on wildlife sites, Commons Local Nature Reserve, local wildlife and hedgerows. Creswick Plantation Local Wildlife Site affected along northern edge - buffer if possible. Majority of wildlife site unaffected. Unlikely to prevent WGC1 from coming forward as long as other linkages are not broken. Protected species unlikely. May be potential to retain hedgerow, compensate for loss of trees and create new habitat or green infrastructure. Ecological sensitivity low except at hedgerows where it is moderate. No apparent ecological constraints. May need reptiles survey

Heritage o Would not adversely impact on designated heritage assets. Southern edge of site needs careful consideration, as it will form the new boundary of Welwyn Garden City

Infrastructure o Increased pressure on overstretched facilities – schools, GP surgeries, hospitals (no local A&E). Resolve infrastructure issues before developing. o Constraints on water supply. o Site size means it will not provide same amenities as some of the larger sites. o Wastewater treatment capacity unlikely to be able to support the development. Likely to require infrastructure upgrades. Would welcome working with planning authority and developer to address. Upgrades can take 18 months to 3 years to deliver. If no improvements are programmed by Thames Water, will require a condition to secure infrastructure before occupation o May increase local road traffic (Howlands and Chequers) that will require mitigation. WHaSH model predicts no A414/ A1000 Junction capacity issues o Cumulative impact on the A1 (M), with site How24 may be significant o Concern about capacity of local transport network to cope. o Improve pedestrian / cycling accessibility and access to bus services on Howlands

Green Infrastructure / Open space

101 o WGC1, How21 and WGC5 would deliver more than 1100 homes in or adjacent to Howlands ward which has high levels of child obesity and premature mortality. Developments should seek to promote physical activity – through green infrastructure, open space, play areas, neighbourhood centres and active travel o Reduce number of proposed dwellings to preserve recreational green space.

Green Belt o Loss of Green Belt, used for recreation. o Remove requirement for housing at WGC1 or reduce capacity by implementing existing permissions to convert officers near Bessemer Road/converting offices in Welwyn Garden City. o A better alternative than losing Green Belt, build on brownfield sites first.

Impact of development on the wider area o Recent infill development in this area has adversely affected services and residents. o Use alternative site with less impact. o To reduce impact on existing properties, only develop southern part of the site. Maintain a gap between new and existing dwellings and ensure new dwellings are no higher than 2 storey. o Development on Green Belt would change ethos of the ‘Garden City’ and ruin the countryside.

Site specific issues o Site within mineral consultation area. May have economically viable material to extract. Need to demonstrate requirements of the Adopted Minerals Plan are being met. o Concern about drainage issues because Ascot Lane floods. o Disproportionate impact on existing residents, compared with other sites. Will diminish privacy, light and property values of adjoining houses and damage views from existing properties. o Potential to increase pollution of the river Mimram. o Damage to oak trees along the boundary of the site. o Covenants on the land prevent it from being built on. o Pylons are a development constraint.

Sustainable development issues o Unsustainable location away from existing infrastructure, jobs and railway stations. o No indication that new development will be affordable.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical

102 studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the ECS 2012/LFHOUA 2012 and LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report of the CHPP June 13 meeting for further information).

In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development and Policy SP 14 sets out the approach for the delivery of a new secondary school to serve growth in the borough and particularly Hatfield, Welwyn Garden City and the northern villages.

103

10 Welwyn Garden City Site WGC4, Panshanger Aerodrome

Number of responses received: 225 (General 9, Support 10, Object 206)

Support o Support the allocation of WGC4 for housing (including Gypsy and Traveller pitches), employment, retail and urban open land o Support WGC4 as more favourable for housing. Policy should confirm entire site is suitable for housing should the aerodrome not be feasible. Support principle of delivering appropriate infrastructure across Welwyn Hatfield. Need more clarity on requirements o Support proposed allocation of the airfield for 700 new homes. The site can contribute significantly to housing in Welwyn Garden City, provide opportunities to develop strategic green infrastructure links between WGC and Panshanger Park o Appropriate to consider for release this longstanding safeguarded site given the borough’s objectively assessed housing need. Need to consider in relation to other potential sites east of the town o WGC4 has been continuously under consideration for development and should be developed. o Panshanger is best suited for development – many people who have not commented would support development here. o Housing is desperately needed. Support a scheme that would provide homes for young people. o The houses should be reasonably priced with gardens and open spaces. o Development here would have no effect on traffic or infrastructure o Oppose the continued use by aircraft of Panshanger Aerodrome. Would not encourage the use of this strip of land next to houses. Noise from aircraft was disturbing and there were accidents.

Main Issues

Loss of aviation / sports facility o Sport England strongly object to Panshanger Aerodrome being more favourable. Reasons include . proposal contrary Sport England's Planning for Sport Aims and Objectives (2014) guide which seeks to prevent loss of sports facilities and access to natural resources used for sport. . removal of air sports facility of regional importance, without proposing how it could be replaced contrary to the NPPF.. If allocated for housing, will breach government guidance which requires the DCLG to be consulted before planning to build on an airfield . site is of strategic (or regional ) importance for air sports. Considered to be of significant regional importance by the Light Aircraft Association and General Aviation Awareness Council (GAAC). . as other aerodromes in the region are at capacity, its permanent loss would reduce opportunities for participation in air sports in the Welwyn Hatfield area and wider region.

104 o WGC4 is an allocated ASR excluded from the Green Belt so should be considered as a possible development site. It is understood that Sport England has a ‘Power of Direction’. Their interest presumably includes regard to the historic role of the airfield o Strongly object. Panshanger is a unique local asset, one of only three aerodromes suitable for sport and leisure aviation north of London. The aerodrome’s closure does not alter its planning status; should safeguard the site for meeting current and future GA needs. o Loss of aerodrome would result in a loss of opportunities for participation in air sports. Negative impact on sport flying and transportation in the region. Loss of the airfield diminishes the General Aviation network without which this sector would die o Aerodrome is a high quality, easily accessible, well-drained facility which should be reinstated. o Sport England is working with GAAC and other organisations to identify key airfields for air sports. Initial assessment suggests that the aerodrome offers strong potential to be identified as a Significant Areas for Sport (SASP). o It has not been demonstrated that the site could not be brought back into viable aviation (GAAC). o An educational link with the University of Hertfordshire, potential for apprenticeships and ability to train pilots would be lost o The Plan should require a realigned runway o Subject to a feasibility study, Sport England would not object in principle to some land within WGC4 being allocated for housing if the runway could be satisfactorily realigned. It would be essential to engage the GAAC, LAA and Sport England in preparing any feasibility study. This must be undertaken first as it will affect the amount of land available for housing. The GAAC have indicated that the runway could in principle be realigned. o Retain aviation, if necessary by reconfiguring the runway, and make space for mixed use/ affordable housing/light industry o If the airfield is lost, could use currently built-up areas for craft workshops or light engineering. o Lack of evidence to show a demand/need for an aerodrome here.

Loss of green open space o The aerodrome provides an important area of open space in an area otherwise over-developed area. A resource for leisure such as walking, cycling, nature activities and community events. o Object to loss of Hilly Fields Meadow as a playing space for local children important for community health and well-being. Should replace this recreational facility. The loss of Hilly Fields Meadow will affect the habitat of ground-nesting birds and other wildlife.

Loss of aerodrome - economic implications o Loss of potentially vibrant business on the site. The airfield is a valuable resource for bringing business and money to the local economy. o The aerodrome has a significant economic role in terms of employment, economic value, community and business benefits. GAAC have advised that the

105

Aerodrome is potentially economically viable to reopen in the future and that strong demand would exist for aviation businesses similar to North London Flying School to continue to operate from the site. Aviation operations ceased in 2014 because North London Flying School’s lease was not renewed rather than because the site was not viable o Network of GA (general aviation) aerodromes around the UK provides connectivity for business travellers and is an important part of national infrastructure - recognised in the National Planning Policy Framework and Planning Practice Guidance o Failure to consider the airfield’s economic and environmental roles contrary to the National Planning Policy Framework o Impact on General Aviation business sector. Aviation Policy Framework notes the importance of aviation to the UK economy. Until September 2014 the aerodrome supported 33 full time equivalent jobs. York Aviation estimate a gross value added of £2.02 million. Local businesses have endorsed Panshanger aerodrome. The members’ club had 12,000 members.

Green Belt o The only piece of non-Green Belt land in the borough outside urban areas, the site has been safeguarded to meet future development needs since 1993 o Erosion of Green Belt gap between Welwyn Garden City and Hertford o Housing need does not justify the exceptional circumstances to build on Green Belt land. o Once Green Belt is “unprotected” it leaves the way open to other undesirable land use changes o The area of the site which is unimproved grassland should be designated as Green Belt.

Historic environment and landscape o Policy CS15 and proposed masterplan will need to contain adequate references to the historic environment and landscape o Surviving structures on site may be of local significance. The LPA will need to assess their value and local significance to determine whether some or all should be retained. Negative effects on the historic environment will need to be addressed and mitigated. Careful consideration would need to be given to the scale of buildings and boundary treatment at the eastern end of the site near Panshanger Park Historic Park & Garden and to the siting of houses in relation to the northwest edge of the plateau and views up from the Mimram valley o The decoy site control room retains has some interest. Would expect its significance to be properly understood and addressed by any development proposals o Object to the loss of Panshanger aerodrome because it is the only surviving World War 2 3D Star Fish decoy aerodrome of its type in the UK o “Historic” claim for the airfield is unfounded. The decoy airfield buildings from WWII were not on the site, but where Moneyhole Park is now. o Development would spoil views across the ancient Mimram valley and be within 110m of Panshanger Park, potentially destroy its setting

106 o Panshanger Park is the largest, most significant, nearest to population centres and richest in wildlife Grade II* Historic Park in Herts. Need to consider the impact of developing WGC4 on the Park’s setting and on significant heritage assets and their setting o Development would harm the setting of the Grade II* Registered landscape at Panshanger park, a unique landscape incorporating the work of Capability Brown and Humphry Repton. Should consider in accordance with NPPF guidance on conserving and enhancing the historic environment and in conjunction with East Herts Local Plan which proposes further development close to Panshanger Park boundary. The site’s relative tranquillity is a very important element of the park o The Landscape Sensitivity and Capacity Study contains errors relating to habitat, so landscape is more sensitive to change than stated. Omits to mention the impact of the site on heritage including Marden Hill House, Panshanger Park and buildings and the rare Capability Brown and Repton landscape o The new housing would be prominent on the landscape due to its elevation. o Development at WGC4 will compromise the character of the town. o The proposed development would compromise Garden City principles due to a housing density and the addition of suburbs. Adopt NPPF principles to underpin WGC’s unique identity.

Green Infrastructure, ecology o Ecological resources on site. Value in neglected, undisturbed areas around periphery. Consider and pursue potential for habitat compensation o The statement that development provides opportunities to develop strategic green infrastructure links between Welwyn Garden City and Panshanger Park is compromised if half of the site is developed as in its undeveloped state it provides that role currently. Support the ‘green infrastructure provision and…..structural landscape belt ’ that will be needed as part of the masterplanning. Will need to consider the site’s developing ecological interest when developing future plans for the site. o Should define ‘structural landscape belt’ o Moving the runway to the north may leave some undisturbed land to replace areas lost to development, given that access to functional airfield areas would be restricted. Remaining open grasslands could be managed with biodiversity as a major consideration o There are no recognised ecology sites within, adjacent or close to the site. Other features include rough grassland with scattered trees. Ecological sensitivity: low to locally moderate. Protected species: Bird records available; potential for reptiles. Fundamental ecological constraint: Phase 1 survey to assess habitat value. May require reptile surveys if habitat is suitable. Potential for habitat management / creation due to size of site o Developing the site for housing would have major impact on the landscape and local wildlife. o Airfield is a rich natural habitat, flora and fauna and part of the ethos of the town. It should not be lost. WGC4 is an area of biodiversity with habitats for a range of wildlife. The airfield site allows wildlife to access Panshanger Park. The area is rich in wildlife - including foxes, hedgehogs, skylarks, red kites, barn owls, bats, bees, grass snakes, partridges, sparrowhawks and deer.

107 o The plan should protect biodiversity. An independent biodiversity assessment of the area should be undertaken before the Council make any decisions. o Reinstate the airfield or retain open areas for wildlife use. o If development here cannot conserve and enhance biodiversity it should not come forward. Dwelling capacity may depend on the site’s ecological value. Plan should state that the ecological value of all major development sites will be assessed using BS4020 and Biodiversity Impact Assessment Calculator. Development must result in an increase in ecological units to ensure biodiversity is conserved and enhanced o Development at WGC4 would be too close to Tewinbury Site of Special Scientific Interest and Mimram River. Potential flooding downstream and contamination of groundwater near the SSSI and Panshanger Park stretches of the Mimram River. Site susceptible to groundwater pollution draining into Mimram River valley, because of chalk substrate. o Run-off from the WGC4 development could potentially increase flood risk and pollution. o Development here will increase water abstraction leading to even lower flows in the Mimram o Environmental value of WGC4 has not been assessed, despite many objections to this loss, contrary to Natural England’s national recommendations. Fails to give due weight to ecology and the environment in site selection. Need a clear, evidenced vision for biodiversity. The unimproved grassland is a rare habitat, well used by residents. o To protect wildlife and views, the park needs a buffer o Development would destroy existing green infrastructure. Site already a resource for wildlife and leisure, so hard to see how 700 new homes would provide opportunities for new green infrastructure between WGC and Panshanger Park. o Development of site contrary to the aspiration for the Mimram Valley Greenspace strategic green infrastructure set out in the Draft Infrastructure Delivery Plan.

Sustainability o Due to the distance to local facilities, town centre and station car journeys will increase. The planning inspector for the District Plan did not think the site sustainable (2004 report). Development would contravene Hertfordshire County Council policies to shift away from the car. o Building 700 houses on one site is unsustainable. o The Sustainability Appraisal incorrectly assumes the airfield is previously developed land and gives insufficient weight to the biodiversity, historic environment and distinctiveness of the site. Were these errors corrected, WGC4 would be one of the Borough’s least sustainable locations. o The south east suffers from serious water stress and Welwyn Hatfield has some of the highest use in the country, so this is an unsustainable location for development o The water table is low. Development at WGC4 would make this worse. Lack of water to sustain enlarged population. Consider areas in the borough less constrained by water supply.

Settlement pattern and site selection

108 o Panshanger Aerodrome should not be used as a housing site. o Site selection is not proportional (as per Policy CS3). 700 homes is unfair on top of 1,700 homes in East Herts and development at Bericot Way and adjacent to Sir Frederic Osborn School. o As 42% of the borough’s population lives in WGC, it would be logical to look at a different distribution, especially in light of neighbouring authorities’ developments on WGC borders. o Panshanger is out of character with the rest of WGC. The proposed development will alter the community feel of the Panshanger area. o WGC4’s change from ‘finely balanced’ to ‘more favourable’ and Councillors’ decision only to consult on more favourable sites was against officers’ advice and ignores information from the General Aviation Awareness Council, the Light Aviation Association and Panshanger People. Councillors promoting this change were from areas least impacted by development. Removing sites deemed “finely balanced” and “less favourable” from the focus of the consultation, pushes the majority of the development onto Welwyn Garden City and Hatfield (Panshanger Airfield Preservation Association and others). o Other sites previously considered ‘more favourable’ but changed to ‘finely balanced’ were well-located in relation to public transport and should be considered ‘more favourable’ than this site. o WGC4 has been assessed differently to BrP9. Inconsistent use of points relating to historic parks and distance to railway stations to show BrP9 as less favourable and WGC4 as more favourable. o Claim that development at WGC4 would create the opportunity to provide a green infrastructure link yet BrP9 declared less favourable due to proximity to Gobions Park (Panshanger People). o Fails to consider the impact developing Panshanger would have on the town or how residents would relate to the town centre (Welwyn Garden City Society). o The Plan should take into consideration housing planned in East Herts Local Plan south-east of Panshanger that will all use Welwyn Garden City as their local town. o Chalk sinkholes are a well known feature of Panshanger - expensive to avoid / remedy. Chalk mine workings may also be present. Given these risks, should consider other more suitable sites o Work with other local Councils to consider/establish a new town or settlement.

Scale of growth o 700 houses on one site creates imbalance of the town, would lead to urban sprawl. Scale down the plans and for WGC4 in favour of a more proportionate distribution throughout the area. o Build across the town and borough instead of just on two main sites. o Build housing using garden city principles, providing less than the 700 houses. o The density of housing would impact on the environment and the Mimram chalk stream. o Increase the development area to enable a scheme of neighbourhood size to be constructed. Extend built area of WGC4 up to the borough boundary along its northern edge with landscaping provided beyond, in East Herts o Landowner owns the land in East Herts. WGC4 should extend to the east into East Herts as part of the duty to co-operate

109 o Careful design and layout could allow greater density

Gypsy and Traveller accommodation o A Gypsy and Traveller community here will be unsatisfactory for Travellers and new residents. Gypsies and Travellers prefer to live on the edge of settlements rather than alongside new housing. Other proposed Gypsy and Traveller sites are preferable. o Distribution of Gypsy and Traveller sites is unfair. Should located these in the south of the borough as well as the north o Expand the Travellers’ site on the A414. o Allocate a smaller proportion of land at WGC4 to Gypsy and Traveller sites.

Transport and Infrastructure o The site lacks the infrastructure and services to support development so should not be used. o Insufficient infrastructure and amenities for current residents. Facilities, such as healthcare, shops, schools, community halls, parking already overstretched o Site too small to create a critical mass to support new services. o Ensure sites selected are not undeliverable due to infrastructure demands or constraints . o Need to explain fully the consideration given, in approving development, to its impact on infrastructure, how and where it is to be provided and to what timetable o There is no school provision on site. Sir Frederic Osborn School will need further school places. o Local hospital facilities are limited. Unacceptable distance to Lister Hospital. To support any new development, need to upgrade the QEII hospital. o One shop is inadequate. The development would need a shopping area and doctor’s surgery. o Include additional dedicated green spaces, community centres, local shops and cycle paths. o Significant distance from the site to the town centre, bus station and railway station could discourage residents from using non-car modes of transport o WGC4 and 5 may increase congestion on approaches to the Mundells Gyratory and Birchall Lane / A414 Roundabout. Capacity improvements may be necessary and micro-simulation modelling o New access routes to the sites could damage the environment. The only strategic access point is via the A414. New roads should be routed from the B1000 and Panshanger Lane. o Development will increase congestion on the B195. o The dangerous B1000 will need to be improved for development at WGC4 to take place. o Important to design out potential community isolation by linking to existing communities, offering shared benefits with existing and new communities and access for pedestrians and cyclists rather than car-dependent o Concern that the wastewater network will be unable to cope with development of this site. Upgrades to infrastructure likely to be necessary. Should require the developer to provide a detailed drainage strategy setting out improvements

110

required and how they will be funded and bear in mind upgrades take from 18 months to 3 years to deliver o Developing in the south of the borough, served by different Waste Water Treatment Works, would be more sustainable.

Duty to co-operate o Potential relationship with new housing proposed by East Herts District Council does not appear to have been taken into account o Historic England expects to be actively involved in ongoing duty to co-operate discussions.

Consultation process o Ignores comments and objections to previous consultations. Significant number of objections to WGC4 in 2012 have not influenced the current consultation, contrary to the Localism Act 2011 and NPPF. Despite objections to the 2012 Emerging Core Strategy, the approach is unchanged. The Council’s initial reactions to objections seem dismissive. The majority of development would previously have been in Welwyn Garden City and Hatfield – despite overwhelming objection this remains the case. o All local residents need to be directly contacted by the Council to find out their opinions. The Council should have sought ideas and sites from local residents, as South Bucks Council did. o Lack of collective vision for Panshanger drawing on comments from the last consultation or priorities agreed with the community. Lack of public debates or focus groups during the formation of this plan. o Consultation event poorly advertised, poorly organised and poorly attended as a result. o The public meeting of Cabinet Housing and Planning Panel shows the level of public dissatisfaction. o At the 9 October 2012 meeting, Councillors overrode officers’ recommendations to promote a village-and-town distribution of housing growth over a towns-only distribution due to “substantial objection from the local community”. Rejecting planning experts’ recommendations and only to recognise residents’ objections from the large villages has the appearance of rubberstamping a pre-determined position adopted by the majority party. o The change from ‘not preferred’ to ‘preferred’ appears to be political. Councillors who approved this have interests to keep housing out of wards they represent. o Attempts to designate the area as an Asset of Community Value were rejected on spurious grounds

Other o Note in the supporting text the possibility for on-site use of minerals should be fully explored. o Should design of houses to a higher quality than recently developed sites in Panshanger. o Houses here will be too expensive for local people.

111 o We have worked with adjoining landowners to promote this site and are keen to develop a masterplan

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the ECS 2012/LFHOUA 2012 and LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

With regard to WGC4 (and WGC5 and Land in East Herts), the Council jointly commissioned with East Herts an independent Heritage Impact Assessment to assess the potential harm to heritage assets within the area that could arise from development of those sites. The conclusions of this assessment indicated that development could come forward on those sites without substantial harm to the heritage assets. The potential harm that could arise was capable of mitigation through a number of measures. These measures have influenced how the site boundaries for WGC4 have been drawn and have been incorporated into the requirements and provisions set out in Policy SP 18.

The Council also commissioned an independent assessment of the significance of the historic environment at Panshanger Airfield and its component buildings and structures. The Assessment concluded that Panshanger Airfield does not retain sufficient historic interest to meet the criteria for either designation as a Scheduled Ancient Monument or for Listing under the register of Buildings of Special Architectural and Historic Interest as a group, or designation as a Conservation Area. A number of important buildings were identified; these were submitted to English Heritage for further investigation on an individual basis. English Heritage concluded that neither building met the criteria for listing. The Local Enterprise Partnership has indicated that Panshanger Airfield did not play a significant role in the local economy.

As an outcome of this process, the site has been allocated in the LPPS 2016 for 650 new homes in Policy SP 18 North East Welwyn Garden City – SDS1 (WGC4). However, the capacity (650) reflects the requirement in Policy SP 18 that the masterplan allows the opportunity for a realigned runway on land to the north of the Green Belt boundary. This is primarily in response to Sport England’s concerns over the loss of a strategic sporting asset in this location (further information is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated

112 committee report and minutes of the CHPP 13 June meeting and the 20 July meeting for further information).

Green Infrastructure/ ecology:

The Council has taken into account ecological considerations which would be addressed in a number of ways. For example, the developable area of the site has been reduced to reflect landscape, ecology and heritage mitigation measures required to make it suitable. An area of ecological enhancement is to be provided in the north west of the site. The Council would require open spaces to contribute to wider ecological networks including the strategic Green Corridor from St Albans to Hertford, providing provide safe routes for wildlife, protecting and enhancing wildlife assets, balancing the needs of recreation and nature, providing animal infrastructure and undisturbed areas.

The supporting text to SADM16 Ecology and Landscape specifies the use of BS42020 and BS5837 when analysing and preparing proposals so that biodiversity and trees are properly accounted for and protected from adverse impacts. The Council has not required the use of a specific Biodiversity Impact Assessment Calculator, one which quantifies biodiversity into units for offsetting purposes. Decisions upon compensation and offsetting of biodiversity will be informed by the information and analysis available and requested at the time of a planning application, which could include the use of such calculators.

Use of sustainable drainage and flood mitigation will manage run-off and flood risk in line with Policy SADM14.

Gypsy and Traveller accommodation

Due to the level of need for pitches and lack of sites suitable for allocation in the urban areas, the Council considers there are exceptional circumstances to justify release of Green Belt land for Gypsy and Traveller pitches where there are suitable opportunities to do so.

Green Belt

Please also see the Councils response under section CS4 Green Belt Boundaries above.

Settlement pattern/strategy

Please see the Council’s response under section CS3 Settlement Strategy above

113

Site WGC5 and Appendix A finely balanced site

Number of responses received: 90 (General 17, Support 5, Object 42, Object that southern portion is not More Favourable 1)

Support o Welcome inclusion of the northern part of WGC5 as “more favourable” and making a significant contribution towards affordable housing o Support residential-led mixed-use development at site WGC5 and the consideration of the southern part of WGC5 as ‘finely balanced’ until such time as evidence on contamination is resolved. Site is less well-connected to the existing built-up area so may conflict with wider ambitions for strategic green infrastructure. However, since the Plan does not meet identified housing needs, this may override some issues o East Herts Council will continue to work with Welwyn Hatfield and Hertfordshire County Council and relevant landowners and stakeholders to ensure sites in Welwyn Hatfield and East Herts are comprehensively masterplanned with the necessary infrastructure. It may be necessary to consider alternative policy approaches to planning and delivering these sites. o Compared with WGC4, site is more integrated within the built up framework of the settlement and equally or better situated to existing services and facilities. Constraints do not appear insurmountable and appropriate mitigation could be undertaken to ensure the site was capable of development as a neighbourhood centre o More housing is needed, particularly smaller homes for young, single and older people who want to downsize, affordable homes and homes to rent. o Support development of WGC5 in conjunction with the land proposed within East Herts. o The benefits afforded this location and proposal for a Garden Suburb make future development at WGC5 and Birchall Farm an ideal prospect for WHBC to build sustainable communities.

Main Issues

Environmental constraints o Significant environmental constraints require careful consideration before allocating the site. Need to leave a large naturalised buffer to watercourses. Hatfield Hyde Brook currently at poor ecological status. To comply with the Water Framework Directive WHBC should require development on this site to take account of and look to improve this o There is an active waste site south west of the site. Should set development back as far as possible to prevent future residential complaints o If following the Sequential Test and flood risk assessment sites are allocated in flood zones 2/3 ensure design principles and Development Management Policies reflect Level 2 SFRA recommendations o Watercourses in culvert should be deculverted wherever possible and re- naturalised as part of a development to re-establish river and bankside habitat

114

and the continuity of the river corridor. Herts County Council as Lead Local Flood Authority (LLFA) will have requirements for the ordinary watercourse on this site

Transport & Infrastructure o Scale of growth would place additional burden on overstretched infrastructure. Need to plan additional facilities - schools, doctors’ surgeries, hospitals, railway stations and shops. o WGC4 and 5 may increase congestion on approaches to Mundells Gyratory and Birchall Lane / A414 Roundabout. May need additional capacity improvements and micro-simulation modelling o A material impact could occur at A1(M) Junction 4. Lack detail on sustainable transport options o A new access road from the A414 to Holwell Hyde Lane would increase air and noise pollution. o Holwell Hyde Lane would be turned into a major road, increasing noise and pollution. It would be preferable to build a new spur road from the A414 or B195. o There are no mineral issues on this site. The reduced area of WGC5 does not cover impact on Burnside, Cole Green HWRC or Birchall Lane waste sites. Were a reassessed area to include these, the County Council would seek to safeguard their provision. Could address through masterplanning o Wastewater treatment capacity unlikely to be able to support the demand anticipated from development and upgrades likely to be required. These can take 18 months to 3 years to design and deliver. Should require developer to produce a detailed drainage strategy o Howlands ward has above average levels of child obesity and premature mortality. Proposed developments should promote physical activity – through open space, play areas, neighbourhood centres and active travel o Important to design out potential community isolation through links to existing communities and offering shared benefits

Ecology o Recognised ecology sites within Site: Ecosite: Old Filter Beds S. of Holwell Hyde Farm. Recognised sites adjacent / close to Site: Adjacent to The Commons, a Local Nature Reserve and Local Wildlife Site. Potential for habitat creation. Need buffer adjacent to Local Wildlife Site / LNR. Low ecological sensitivity. No fundamental ecological constraint o Would cut off Commons Local Nature Reserve (LNR) from open land to the east. Additional land to the south promoted for housing would further isolate the LNR . Proposal conflicts with proposed east-west Green Infrastructure corridors. Measures will be required to enhance management and ecological corridors in order to retain the LNR ‘s condition and quality before Herts Ecology would support development here o Northern part of site too close to Commonswood Nature Reserve. Need a buffer of at least 400m to protect wildlife. o Need an open corridor to retain a direct link to open countryside to the east and south ensure a link to open land is retained for The Commons woodlands. Retaining a robust link for more mobile species with Hatfield Park to the south is also important

115 o Design of current housing in The Commons and south from Black Fan Road and Hyde Valley allows movement of wildlife into countryside. Birchall Garden Suburb proposal would block. o Site is an important wildlife corridor. Welwyn Hatfield Council has a statutory duty to protect the Commons Local Nature Reserve. Development of WGC5 would damage the nature reserve because wildlife travel through this area to the former landfill site. o WGC4 and WGC5 are habitat to a wide range of endangered species. The Council has a duty of care to protect wildlife in the area under UK/EU law. o Proximity of proposed housing to the wildlife site will ruin its beauty and impact on wildlife. o Lack of detail about the effect on the ancient woodland at Holwell Hyde Lane. o Woodland trees will have to be felled in order to build a new road. This will affect the welfare of the local wildlife as well as the surroundings of the existing local residents. o Loss of farmland. Fen, woodland, grassland and arable land would be affected. Arable farmland provides habitat for owls and bats which would be lost by building on this land. o New open spaces will be ineffective in replacing lost habitats were the site developed. o The peat layer underneath the Commons Local Nature Reserve is linked hydrologically to the surrounding area. Peat is protected under European law. o The proposed access routes Holwell Hyde Lane and Thistle Grove would endanger local wildlife and alter biodiversity, running counter to the objectives of the Local Nature Partnership. o To minimise damage to woodland, use the disused railway line to access WGC5.

Heritage o Consider protecting the setting of Holwellhyde Farmhouse, through a site boundary revision or requirement for public open space to form a buffer between the farmhouse and new housing. Policy and masterplan should cover heritage issues o Adverse impact on the historic character and setting of the registered Hatfield Park. Development should not proceed given the park’s historic significance and landscape importance. A View Management Framework for Hatfield House identifies critical views including protecting the setting to Hatfield House and its historic parkland grounds. Development here would be prejudicial to achieving this objective. Propose that a supplementary planning document and local plan policy be developed o Development will be very visible from the south and would break the green corridor between Hertford and St Albans incorporating Panshanger Park, Hatfield Park, Stanborough Park and Ellenbrook.

Green Belt o Loss of Green Belt contrary to Government policy. Would erode the Green Belt between WGC and Hertford and between WGC and Hatfield. o Site forms awkward protrusion into Green Belt. Development would increase the sense of coalescence between WGC and Hertford, undermine the Strategic

116

Green Infrastructure Corridor south east of Welwyn Garden City and erode countryside between Welwyn Garden City and Hertford. Due to the slope running up from A414 development will be intrusive – adverse visual impact viewed from Essendon, West End and Hatfield Park. Unlikely the site would be adequately screened by 2031. Tree planting would be ineffective because of the topography. o Destruction of Green Belt land and access to wildlife. o If both WGC5 and East Herts are developed, would lose Green Belt all the way along the A414. o Should prioritise brownfield sites – including vacant office blocks –before Green Belt land is used.

Settlement Pattern o Garden Cities need to retain green space and open areas. o Proposed development too large. Would prefer small additions to several smaller villages – or to create additional hamlets – instead of a single development on one site. o The South and East areas of the town are unfairly targeted for excessive development. o Distribute developments around the borough. o Build new Garden Cities away from the Green Belt. o Build houses at New Barnfield instead. o Create new high-rise housing instead of building outwards. o Alongside WGC4 and East Herts proposals, development would exacerbate the unbalanced nature of Welwyn Garden City where the eastern boundary of the town is already considerably further from the town centre than the northern, southern and western boundaries. o Development should conform to the standard and layout of a garden city development. The town should be maintained as something special.

Sustainability o Require developers to consider use of grey water and recycled building materials. o Connections to the town less good than other possible sites being 4km from WGC town centre. o 500 houses would distort the rural nature of Essendon. Adverse impact on the local school and community. Development would be isolated, lack infrastructure. Site does not adjoin WGC or an inset village so does not merit the “finely- balanced” rating. Unsustainable. o New development will reduce access to countryside and health benefits from this. o For this site to deliver sustainable development add additional land adjoining the northeast boundary to create a comprehensive scheme, providing open space / wildlife area as part of phased residential development to meet local housing need

Impact of Development on the wider area o Impact of WGC4, WGC5 and East Herts proposals on SE Welwyn Garden City ethos/character.

117 o Proximity of dwellings to Windmill Hill would spoil the human experience of the nature reserve. o Concerned about the impact of access to the development via Thistle Grove.

Site Specific issues o To facilitate Birchall Garden Suburb align EHDC District Plan and WHBC Local Plan policies, and use tools at appropriate planning application stages, rather than SPD which would cause delay. Define the Green Belt boundary in a joint Welwyn Hatfield-East Herts policy o Gas Distribution High Pressure gas pipeline crosses site o Proposed development too large. Reduce the scale by 80-90%. o Too far from local shops, the town centre and other facilities. o Build a small number of affordable homes to meet village needs (Essendon Parish Council). o Require small affordable homes. o This is an open area of beauty that should remain so. Do not build here. o Site was not in the Emerging Core Strategy consultation so should not consider ‘more favourable’. o If there has to be development at the more favourable part of WGC5, reduce the number of houses proposed on this site and build instead on the part currently rated as “finely balanced”. o Proximity of new homes beside potentially hazardous land, recycling centre, noisy processing plant. o Consult with the in-house conservation officer to advise on how best to preserve this area.

Comments on development in the southern part of site WGC5, rated as “finely balanced” o Excluding the southern part of the site would create an isolated housing estate with fewer services. Disagree it is “finely balanced”. Should consider all of WGC5 “more favourable” as the site is deliverable and available to develop in the first five years of the plan period. There are no technical constraints to delivering the whole of WGC5 as part of the wider Birchall Garden Suburb scheme. No abnormal infrastructure requirements that would delay delivery o Should consider the southern part of the site “more favourable”. Potentially easy access to the A1 and A10. An extension to the nearby Gypsy and Traveller site could easily be achieved. o Presence of the Historic landfill raises issues. Need to locate development in areas which minimise any potential risk o Object for same reasons as the “more favourable” part of the site. Should determine extent of development thorough Green Belt and topographical analysis. Adverse impact on Commonswood Local Nature Reserve o The village should not be dominated by a development with no connection to it. Should transfer WGC5 from Essendon to Welwyn Garden City should development be necessary o Alongside East Herts development, would create urban sprawl along the A414 towards Hertford.

118

Ecology o Area strategically valuable, provides an ecological resource to link with the Commons LNR. Secure appropriate management for biodiversity if possible to enhance the remaining development and reduce the ecological isolation of the LNR from open countryside to the north-east o No recognised ecology sites within site. Adjacent to Ecosite: Land SW of Birchall Lane, Cole Green Pits and part of Local Wildlife Site: The Commons. Close to Ecosite Gypsy Lane Golf Course. Potential for birds in trees; opportunities for potential habitat creation. Buffer adjacent to sites of ecological interest. Low Ecological sensitivity. No apparent fundamental ecological constraint o Comments on the more favourable part of WGC5 also apply here

Objections to development of land East of Welwyn Garden City in East Hertfordshire (not part of consultation) o WHBC should not look favourably upon East Herts’s proposal east of Welwyn Garden City. Houses will not count towards Welwyn Hatfield’s housing, but further strain the town’s infrastructure and erode the gap between Hertford and WGC, destroying countryside that people enjoy. o Development would exacerbate problems caused by the development of Panshanger aerodrome. o Would cut off the green corridor that stretches from Hertford to Hatfield Park via Panshanger. o This proposal would be detrimental to the countryside, local services and infrastructure. o Sustainability issues mentioned in connection with WGC5 would become more acute. o Such a large-scale extension of the Garden City should be decided by those representing the Garden City residents, not its neighbours. To do otherwise would run counter to local democracy.

Duty to Co-operate o Paragraph 10.25 refers to development east of Welwyn Garden City meeting the needs of the housing market area. This encompasses parts of East Herts around the A414 into Hertford. The delivery of new dwellings needs to be accounted for accurately in each authority’s housing trajectories. East Herts District Council would welcome the opportunity to discuss this further. o Lack of discussion with East Herts Council about proposed development east of WGC. These two developments will significantly harm this corridor (important for the movement of wildlife), which includes Commonswood Nature Reserve

How these views were taken into account

119 advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

With regard to WGC5 (and WGC4 and Land in East Herts), the Council jointly commissioned with East Herts an independent Heritage Impact Assessment to assess the potential harm to heritage assets within the area that could arise from development of those sites. The conclusions of this assessment indicated that development could come forward on those sites without substantial harm to the heritage assets. The potential harm that could arise was capable of mitigation through a number of measures. These measures have influenced how the site boundaries for WGC4 have been drawn and have been incorporated into the requirements and provisions set out in Policy SP 18

Duty to co-operate

The Council has held further discussions with neighbouring authorities, infrastructure providers and agencies, on cross boundary matters since the LPCD 2015.

Green Infrastructure/ ecology:

120

Hertford, providing provide safe routes for wildlife, protecting and enhancing wildlife assets, balancing the needs of recreation and nature, providing animal infrastructure and undisturbed areas.

Use of sustainable drainage and flood mitigation will manage run-off and flood risk in line with Policy SADM14.

Green Belt

Please also see the Councils response under section CS4 Green Belt Boundaries above.

Settlement pattern/strategy

Please see the Council’s response under section CS3 Settlement Strategy above

121

Appendix B Less Favourable Sites – Welwyn Garden City – Site WGC3, The Holdings, Cole Green Lane

Number of responses received: 4 (General 2, Support 1, Object should be more favourable 1, Object should not be considered 0)

Support o Too near a busy road. o Would impact on tranquillity and ability to experience the countryside in this area, which benefits health and wellbeing. o Need to retain the ‘Garden’ aspect of Welwyn Garden City.

Main issues o Development would not adversely impact on any designated heritage asset o No recognised ecology sites within, adjacent or close to the site. Adjacent to Ecosite: Land SW of Birchall Lane, Cole Green Pits. Great crested newts recorded in the area but current terrain not particularly favourable for them. Opportunities for grassland creation

Object should be more favourable o Extant planning permission for equestrian centre; appropriate for residential development. Part of future growth area for Welwyn Garden City; available to meet local housing need in the short term. Bringing spoilt land on the edge of the urban area into use for residential development would improve the area’s attractiveness. Change WGC3 to a preferred site to enable flexible land supply around Welwyn Garden City to meet local needs

How these views were taken into account

WGC3 is adjacent to an allocated waste site and it is not considered that the impacts of this can be adequately mitigated. Therefore the site is considered unsuitable for residential development (HELAA 2016).

The site has since received planning permission for employment related development

122

Appendix B Less Favourable Sites – Welwyn Garden City – Site WGC6, East of Digswell Hill

Number of responses received: 4 (General 1, Support 2, Object should be more favourable 1, Object should not be considered 0)

Support o Support no development here as it would increase the fragmentation of Local Wildlife Sites and the isolation of Sherrardspark Wood SSSI. No recognized ecology sites within the site but adjacent Local Wildlife Sites: Malm’s Wood (57/017) and Sandybottom Wood (43/003). Badgers are in the area and probably birds in trees. Phase 1 habitat survey and badger survey required. Opportunities for grassland and woodland creation due to surrounding habitats o Part of the landscape laid down by Lancelot Capability Brown. Relic planting can still be identified

Main Issues o Development unlikely to have an adverse impact on any designated heritage asset

Object should be more favourable o Site is the only opportunity to expand to the west of town. Closer and better related to the town centre and services than other sites, which relate poorly to infrastructure. Can make a major contribution to meeting OAN and providing affordable housing Landowner on behalf of WGC6 o Refute the need for wildlife site buffers as existing gardens already adjoin the same woodland and SSSI. The development would take full advantage of its surroundings and features, including improvements to the existing woodland that would benefit landscape and residents. o The site is below the A1M giving it protection from noise and air pollution, plus further measures would be incorporated into any development (e.g. layout, sound barriers). o The site does not impact on national GB purposes ‘countryside’ and ‘merging’ and the local purpose yet Wel4 and other sites which pose a greater risk of coalescence have been deemed ‘More Favourable’. o WGC’s character is least affected by this site, and a revised site boundary to the previous elongated boundary would relate well to the form of WGC. o Would not result in the loss of agricultural land. o Existing use of the land (equestrian) is not sustainable and risks becoming redundant.. o Change WGC6 to a preferred site to enable flexible land supply around Welwyn Garden City to meet local needs (Landowner on behalf of WGC6).

How these views were taken into account

This site was assessed as unsuitable (HELAA 2016) and therefore has not been considered for allocation in the LPPS 2016.

123

10 Welwyn Garden City - Gypsy and Traveller Sites

Number of responses received: 3 (General 0, Support 0, Object 3)

Main issues o Object to Gypsy and Traveller sites on any Green Belt land. o The NPPF gives tacit acknowledgement to issues relating to Traveller Sites, giving dispensation for Green Belt use where alternatives are unavailable or undesirable. o Apply the approach to the whole borough and not just Welwyn Garden City and Hatfield. No sites promoted for Woolmer Green, Welwyn, Digswell, Brookmans Park, Little Heath or Cuffley. o The approach should be consistent and not focussed on Welwyn Garden City (and Hatfield). o Inappropriate to provide additional Gypsy and Traveller sites at WGC4, Hat1 and Hat2. o Locate additional sites at Finely Balanced and Less Favourable sites away from the two main towns. o Should not provide Gypsy and Traveller sites at locations envisaged for major housing growth. Would lead to poor relations between communities. Use other sites that avoid housing growth. o Consider increasing the size of existing traveller sites in the area. o Relocate sites to the south of the borough as per the concept of proportional development.

How these views were taken into account

The Council has reviewed (2016) the accommodation needs of Gypsies and Travellers and Travelling Showpeople and the evidence indicates that there is a need for additional pitch provision to be made. Table 6 on page 73 of the LPPS 2016 sets out how provision will be made over the plan period on various sites across the borough.

In accordance with national Planning Policy for Traveller Sites, the Council has developed a fair and effective strategy to meet the need through the identification of land for sites. Sites are planned over a reasonable time scale with the opportunity to review the need during the plan period. The plan is positively prepared with the objective of achieving sustainable development. The national policy confirms that traveller sites are inappropriate development in the Green Belt but a planning authority may (in exceptional circumstances) make a limited alteration to the defined Green Belt to meet a specific identified need, which might be to accommodate a site inset within the Green Belt. It may only do this through the plan making process. If land is removed, it should be specifically allocated in the development plan.

A rural isolated site would not be located in a sustainable location; being remote from services and facilities. Wherever possible, sites have been selected which would allow households to access services and facilities.

124

Responses were received at the ECS stage from residents living on an established site and at the Issues and Options stage in 2009. At the Issues and Options Stage, the Council discussed options with residents on two of the borough’s existing sites. Residents agreed that there was a need for more pitches and that existing sites were generally unsuitable for expansion. Respondents considered that sites should be capable of living alongside the settled community, near to public transport, have safe access, not be contaminated or affected by pollution, be in areas at low risk of flooding and be large enough to accommodate landscaping. The “Consultation with the borough’s Gypsy and Traveller community on the provision of additional pitches Report of consultation” is available at http://www.welhat.gov.uk/CHttpHandler.ashx?id=4228&p=0

(For clarification: the term settled community is used by the government in national Planning Policy for Traveller sites. It means the general community living in towns and villages. In this context, it does not mean a settled gypsy and traveller site – which is how some responses to the consultation appear to have interpreted its meaning).

At the ECS stage, a number of residents living on existing established Gypsy and Traveller sites in the borough supported the identification of the need for, and the provision of more pitches. Responses considered that there are many families that have nowhere to live, that additional pitches are required for families and those families’ children when they become adult households.

125

10 Welwyn Garden City Gypsy and Traveller Sites and Site GTLAA06, Panshanger Aerodrome

Number of responses received: 25 (General 2, Support 1, Object 23)

Support o Support the allocation of WGC4 for housing – including Gypsy and Traveller pitches, other land uses and a mix of housing tenures. Only piece of non-Green Belt land Safeguarded to meet future development needs. Will work with other landowners to develop a master-plan and co-operate with the Council to meet housing needs

Main issues

Green Belt and environmental constraints o Loss of Green Belt. Green Belt boundaries should only be moved in exceptional circumstances o No wildlife survey has been carried out – impact on natural environment ignored. o Insufficient infrastructure and local services in area. o National policy protects places of employment, training and education. o Should not be located in the Mimram Valley – a rare chalk river flows through the area. o Will not integrate with a new housing estate or settled residents. Maintaining activities such as stabling of horses and cart racing could be difficult.

Approach o Other strategic sites such as WGC5 appear not to include provision for a Gypsy and Traveller site. o Disproportionate concentration of sites in WGC (and at Hatfield) o No sites defined in southern part of borough. Why have villages there been protected from such development? Distribute Gypsy and Traveller sites evenly and equitably across the borough to prevent clustering and an unbalanced concentration. o Put GTLAA06 next to the Essendon site [Holwell]. Next to A414 is preferable for travelling. o Locate sites where better infrastructure exists. o Locate away from built up areas. o Move to a location with more suitable access. o Placing GTLAA06 within housing development at WGC4 is not desirable for the local or traveller community. Previous consultation with the borough’s Gypsy and Traveller community revealed one third in favour of living alongside new housing. 93% wanted to be near public transport, which WGC4 will not have. Were Gypsies and Travellers consulted on the plan? o Allocate GTLAA06 within WGC5. o Liaise with East Herts regarding traveller provision in this area.

Site specific

126

o Remove GTLAA06 from WGC4. o No clear, safe access out of the site. Would require a complex route through a housing estate. o Distance to A414/A1 would present a problem. o Allocation of a Gypsy and Traveller site at WGC4 may affect the viability of housing development and stated priorities for housing mix and infrastructure provision. o No recognised ecology sites within the site or adjacent to recognised site. Protected species: unlikely. Low ecological sensitivity, no apparent fundamental ecological constraints. o Heritage assets may be of local significance (note proximity to a Grade II Registered Park and Garden – Panshanger). This is for the LPA to consider

Evidence o Provide more evidence on why WGC4 is a preferred option for a traveller site, on the need for sites and for making provision in the middle of housing, next to existing housing. o The Local Plan projects beyond the evidence base to 2031. The formula is poorly explained. Numbers presented do not add up in the context of the 29 pitches required between 2016 and 2026 (Panshanger People).

Consultation o The Council has ignored previous consultation responses. o Consult with the traveller community to find out what they want. o Take local residents’ views into account.

How these views have been taken into account

Please see response to WGC4 above for site specific issues.

127

The LPPS 2016 proposes that site WGC4, Panhanger (which incorporate Site GTLAA06) should make provision for 6 pitches for Gypsy and Travellers. Development of the site as a whole would be subject to a masterplan and required to meet criteria set out in Policy SP 18 North East of Welwyn Garden City (SDS1) and other policies in the plan. This should ensure that planning considerations such as matters relating to ecology, heritage, housing mix, access, infrastructure, and viability are fully addressed.

128

10 Welwyn Garden City Table 5 - Sources of housing supply for WGC

Number of responses received: 14 (General 12, Support 1, Object 1)

Main Issues

Site Hal02 (Land at Waterside) o Development will not adversely affect heritage assets

Site Han15 (Windsor House & Denmark House, Howardsgate) o Although within Welwyn Garden City Conservation Area, an appropriately-scaled, well-designed development would not be harmful to it (Historic England). o Based on information available envisage no issues with wastewater capacity (Thames Water).

Site Hol100 (Dairycrest Depot, Homestead Lane) o Development will not adversely affect any heritage assets Historic England. o Based on information available envisage no issues with wastewater capacity (Thames Water).

Site How24 (QEII Hospital) o Site relatively close to Beehive Conservation Area, but unlikely to be harmed. Careful consideration should be given to the design of the southern edge of the site given that it will be the new southern boundary of Welwyn Garden City (Historic England). o Wastewater network will be unable to cope with the demand from development of this site. Upgrades to infrastructure likely to be necessary. Should require developer to provide a detailed drainage strategy setting out improvements required and how they will be funded and bear in mind that upgrades can take 18 months to 3 years to deliver (Thames Water). o Development on this site may have no significant effect on the A1(M) in isolation, but could have a significant cumulative impact alongside other sites (Highways England).

Site Pea02 (Broadwater Road West SPD Site) o Support development at Pea02. It should come forward as soon as possible. o Should retain most historic elements of the site and bring back into suitable use. Possible negative effects on the historic environment identified in the Sustainability Appraisal will need to be mitigated (Historic England). o Wastewater network unable to cope with the demand from development of this site. Upgrades to infrastructure likely to be necessary (Thames Water). o Development on this site relatively sustainable given proximity to facilities and public transport. Possible impact on strategic road network due to proximity to the A1(M) (Highways England).

129 o Although Proximity to facilities and the town centre is positive, the scale of development is of concern as it is one of the Borough’s most deprived areas. To alleviate issues, consider housing mix (and proportion of affordable housing), the need to regenerate the existing area, potential for isolation by having the bulk of development along Broadwater Road, and the need to promote physical activity, health and wellbeing (Hertfordshire County Council Public Health).

WGC4 Panshanger Aerodrome o Object that Table 5 shows site WGC4 as a Green Belt site. Should be shown as a ‘large urban site’ in the first half of the table (landowner of site).

How these views have been taken into account

Han15, Hol100, How24, part of Pan01 (Pan01a) and either have permission, are under construction, have been completed or have been withdrawn by the land owner. Pan02 is too small for an allocation and has been counted towards the windfall projection.

The other sites within Table 5 of the LPCD 2015 were subject to further site assessment work. Please see the responses within the site-specific sections of this statement.

Regarding Pea02(b and c) this was subject to further site assessment work also, although a Supplementary Planning Document already exists for the site. As an outcome of this further work, which addressed a wide range of matters including infrastrcture (both site-specific and cumulative), this site has been allocated as Pea02b and Pea02c (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

Policy SADM 21 and Table 19 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development and Policy SP 14 sets out the approach for the delivery of a new secondary school to serve growth in the borough and particularly Hatfield, Welwyn Garden City and the northern villages

130

10 Welwyn Garden City – Employment

Number of responses received 6 (General 3, Support 0, Object 1)

Main Issues o Include employment land released for housing in the Council’s calculation of windfalls to reduce the amount of land allocated in the plan for housing. o Former Argos site, Bessemer Road, Welwyn Garden City: opportunity to redevelop a mixed use scheme to act as a buffer between proposed redevelopment of former Shredded Wheat site and employment zones to the north and east. Opportunity to make a significant contribution to housing supply within a sustainable town centre location. Classify site as suitable for residential led mixed use developments on the basis re-development would generate similar or greater employment to the present B8 classification o Retaining Panshanger airfield and re-establishing suitable smaller companies on a rejuvenated site could free up central WGC land for housing in a more sustainable location, without the need for Green Belt land. o Use of Green Belt land for employment is no better than using it for housing. o Plan for employment land needs to account of recent losses. o Transport links to jobs outside the borough are overstretched. o Employ all existing and future inhabitants in the area in line with the Garden City concept as this is more sustainable, reduces the need to travel and strengthens communities.

How these views have been taken into account

Windfalls

The Council has increased our estimate for windfalls, taking into account evidence on the increased number of windfalls expected to result from conversion of offices to residential.

Panshanger

Please see response under the WGC4 consultation point above.

Green Belt

Our evidence (Economy Study Update) predicts that there will be a shortfall of about 5.4 hectares of employment land by 2032. The limited availability of land within urban areas for new employment areas is insufficient to meet the borough's employment needs over the plan period. In order to plan for a sustainable pattern of growth and ensure that sufficient land is available to meet the borough's employment development needs, exceptionally, Green Belt boundaries in the borough have been altered.

Former Argos site (Pea96)

131

This site has subsequently been withdrawn (HELAA June 2016, Appendix E Sites withdrawn from the HELAA).

Welwyn Hatfield has a good balance between those living and working here. LPPS 2016 policies and proposals aim to promote a shift towards more sustainable modes of transport.

132

10 Welwyn Garden City Town Centre Strategy, Figure 7 (Town Centre Boundary Map), Retail Frontages, Development sites in the Primary Retail Core, Welwyn Garden City Town Centre North

Number of responses received 6 (General 3, Support 0, Object 3)

Main Issues o Previously commented on Policy CS14 Welwyn Garden City Town Centre and hope that references to the historic environment are enhanced. o Wastewater network unable to cope with the demand from development of this site. Upgrades to infrastructure likely to be necessary. Upgrades can take 18 months to 3 years to deliver o Have been monitoring town centre opportunity sites identified within the Local Plan document. Although sites have been suggested for some time no schemes have progressed. Policy should avoid being so prescriptive that schemes will not come forward or sites will remain vacant and should comply with the NPPF para 173 o Despite being an excellent shopping area in many ways Welwyn Garden City town centre is not thriving and requires active and urgent attention. o Building flats in the town centre will spoil the Garden City layout, upset the balance of the town centre and harm the south side of town which already suffers due to the level of charity shops. o Assess alternative sites which would allow more flexibility for future retail development. o Make better use of brownfield sites and change to a shared usage policy to increase the number of local (walking distance) residents who will benefit from the shops and transport links. o Build up not out and ensure villages take their full amount of housing and Gypsy/Traveller sites.

Town Centre North development site o An appropriately scaled, well-designed development would be capable of meeting the requirement to preserve or enhance the character or appearance of the Conservation Area o An opportunity for a significant civic space linking John Lewis to Stonehills and the Howard Centre. Whilst a pavilion type retail building of high architectural quality within a hard/soft landscaped area could be acceptable, a dense mixed use retail/residential building would not. o Town Centre North should not be developed due to loss of open space, impact on the character of Welwyn Garden City town centre and traffic impact. Question the need for further retail.

How these views have been taken into account

The LPPS 2016 contains town centre strategy for Welwyn Garden City prepared in consultation with the Welwyn Garden City Town Centre Partnership. This strategy takes into account the findings of the Welwyn Hatfield Retail and Centre Needs Assessment, May 2016 and allocates land to meet the scale and type of retail

133 development Welwyn Garden City town centre needs. The strategy sets core objectives which development in the town centre should address if it is to make a positive contribution to improving its vitality and viability. Policy SADM 19 Town Centre North Development Site (MUS1 (Han 40) sets out criteria development would need to meet. To ensure that development of this site meets high standards of design and the needs of the market and customers, the Council has prepared a planning brief to guide the future development of the site. The Town Centre North Supplementary Planning Document, adopted in 2015, provides detailed information on the type of development, design and layout constraints that need to be considered whilst also seeking to highlight how development of this site can help to address the wider objectives of the town centre strategy.

134

10 Welwyn Garden City - Urban Open Land

Number of responses received 3 (General 0, Support 1, Object 2)

Main issues o Seek the review of the designation of The Woodside Centre (UOL99), as an area of Urban Open Land in line with the NPPF paragraph 77 and allocation of the site for residential development. Existing use surplus to requirements as site no longer appropriate for service use or use as a school (Hertfordshire County Council). o Housing site HAL02a should be designated as an area of Urban Open Land. o Support urban open spaces and any green infrastructure that they can provide (Herts Ecology). o Proposed Housing Site HAL02a should be designated as an area of UOL by extending the existing UOL27 Sloansway as it meets the criteria for designation.

How these views have been taken into account

The Local Plan aims to reinforce the designation of urban open land sites within the borough’s main towns and settlements and to recognise their importance. The Council has carried out an updated open spaces survey (June 2016) to ensure that potentially valuable open spaces are identified and not lost to development and that open space is preserved and enhanced where possible and incorporated into the design of towns and villages to enhance the built environment, in addition to any recreational, ecological, landscape or any other amenity that they provide. UOL99 helps strengthen and define the Green Belt boundary and provides a visual link with The Commons Wood a popular area for passive recreation.

Woodside Centre: while development could potentially be suitable if restricted to the northern half, there are uncertainties with regard to whether the site is available and achievable (HELAA 2016). Therefore the site was not considered for allocation within the LPPS 2016.

The LPPS 2016 proposes to allocate site HAL02a. Although the site is informally used as open space, it is not covered by any designations and is therefore considered suitable in principle for a residential use (HELAA 2016).

135

10 Welwyn Garden City – Site Hal02, Land at Waterside

Number of responses received 6 (General 3, Support 0, Objections 3).

Main Issues o On the information available, no wastewater capacity issues are expected o Development will not adversely affect any heritage assets (English Heritage). o Site has no fundamental ecological value; low ecological opportunities, low ecological sensitivity and unlikely to have protected species. There are no recognised ecology sites within the site. Within 10m of Blackfan Valley Local Wildlife Site (beyond the B1000) o Support development on Hol19 because it would redevelop an existing housing site. o Concern at the principle of housing on the site o 21 new houses do not justify the loss of an open space. o 21 houses would harm residential amenity – would require dense or high rise buildings. o Unsuitable for housing as the site provides a valuable amenity area for local residents, a safe area for ball games and dog walking without needing to cross roads. Used informally since the estate was built. o Remove Hal02 from the plan. o Designed to form a pleasant outlook for surrounding houses, an integral part of the ‘garden city’ ethos of the surrounding area. Infilling is contrary to this. o Site forms a pleasant transition from countryside to the urban area along the B1000. o Site was removed from the Local Plan in 2002 following objections. Should be removed again. o Part of an area of archaeological interest. o Access to the site from Waterside or Mundells would not be practical or safe. o Parking congestion at the end of Sloansway would be increased. o Designate the whole of the open space around Waterside/Mundells as Urban Open Land.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

136

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

Policy SADM 21 and Table 9 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development and Policy SP 14 sets out the approach for the delivery of a new secondary school to serve growth in the borough and particularly Hatfield, Welwyn Garden City and the northern villages

137

10 Welwyn Garden City – Site Hal03, Ratcliff Tail Lift Site

Number of responses received 3 (General 3, Support 0, Objections 0).

Main Issues o The wastewater network around the site is unlikely to be able to cope with the extra demand of this development, and will need upgrading o Development will not adversely affect any heritage assets o Site has no fundamental ecological value; low ecological opportunities and sensitivity, and unlikely to have protected species. No recognised ecology sites within the site, nor nearby

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

138

10 Welwyn Garden City – Site Hol19, Hyde Valley House & First House

Number of responses received 4 (General 3, Support 1, Objections 0).

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

139

10 Welwyn Garden City – Site Pan01, Land between Bericot Way and Waterbeach

Number of responses received 12 (General 3, Support 0, Objections 9).

Main Issues o The wastewater network around the site is unlikely to be able to cope with the extra demand of this development, and will need upgrading o Development will not adversely affect any heritage assets o Site has no fundamental ecological value; limited ecological opportunities (boundary trees and shrubs should be retained or compensated for if lost), although may have some protected bird species in nearby trees. No recognised ecology sites within the site, nor nearby

Respondents object to development on site Pan01 for a number of reasons o This land has always been set aside for a school – with overcrowding in existing schools and new development proposed, it should be used for that purpose. o Part of the ethos of Welwyn Garden City is green space. This is one of Panshanger’s few green areas. Allow some green space to remain, in accordance with garden city principles. o Site currently used for recreation, including for children’s play and dog walking. o New dwellings will lead to parking issues. o Lack of new infrastructure planned for the high dependency needs of care home residents, will put further strain on health infrastructure. o Panshanger already has a lot of care homes – 26% of all those in Welwyn Garden City. Put new care homes in another part of the borough to spread the load on doctor’s surgeries. o A 3 storey care home and 35 houses are unsuitable for the site’s size and out of character. o Whilst a care home is a reasonable alternative to the school originally proposed, 35 homes in addition are inappropriate. Reduce the number of dwellings to make development more sympathetic to its surroundings. o If Hertfordshire County Council do not intend to develop the site for a school, should gift the land to Panshanger residents to use as amenity land or for a community hall. o If development goes ahead], build another school elsewhere.

How these views have been taken into account

The southern part of this site (Pan01a) has been granted permission for a 75 bed care home. The LPPS 2016 proposes to allocate the remainder (Pan01b) for 17 dwellings. Policy SADM 21 and Table 9 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development and Policy SP 14 sets out the approach for the delivery of a new secondary school to serve growth in the borough and particularly Hatfield, Welwyn Garden City and the northern villages

140

10 Welwyn Garden City – Site Pan02, Land behind 1-17 The Poplars

Number of responses received 13 (General 3, Support 0, Objections 10).

Main Issues o On the information available, no wastewater capacity issues are expected o Development will not adversely affect any heritage assets o Site has no fundamental ecological value; low ecological opportunities and sensitivity, and no protected species. No recognised ecology sites within the site, nor nearby o The ethos of Welwyn Garden City is to have green space – filling in this piece of land will take away from this. Land deliberately left undeveloped when housing was built. o The site is used for recreation by children and dog walkers. o Don’t lose green areas such as these for the sake of a relatively small number of homes. o Site is a grass verge next to a roundabout. Unsuitable for housing. Access would be dangerous. o Development will place additional strain on busy local roads and shops at Moors Walk. o Proposed density is too high and would repeat past mistakes. o Suggest bigger site by the roundabout at the football club further along Moors Walk.

How these views have been taken into account

HELAA assesses the capacity of this site as 8 dwellings which is below the minimum threshold for allocating in the Local Plan.

141

10 Welwyn Garden City Site Pea08, Land adjacent to Ravenfield Road

Number of responses received 3 (General 3, Support 0, Objections 0).

Main issues o On the information available, no wastewater capacity issues are expected o Development will not adversely affect any heritage assets o Site has no fundamental ecological value; low ecological opportunities and sensitivity, unlikely to be home to any protected species. No recognised ecology sites within the site, nor nearby

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

142

10 Welwyn Garden City Site Pea24, St Michaels House and Day Centre, Holwell Road

Number of responses received: 3 (General 3, Support 0, Object:0)

Main issues o On the information available, no wastewater capacity issues are expected o Development will not adversely affect any heritage assets o The site has low ecological opportunities and sensitivity, and is unlikely to be home to protected species. There are no recognised ecology sites within the site, nor nearby. However, given that a building is to be demolished, a bat assessment may be required beforehand

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

143

Section 11 - Hatfield

Number of responses received 7 (General 2, Support 0, Objections 5).

Main Issues

Green Belt, Ecology, Environmental impact o Green Belt e.g. objections to the loss of Green Belt and to our evidence. o Wildlife and the environment within Green Belt land will be threatened. o Use brownfield sites for development instead of Green Belt. o Green Belt provides a valuable recreation resource around Hatfield and Hatfield Garden Village o Risk of coalescence between WGC, Hatfield and St Albans. o Should clarify the long term approach to Ellenbrook Country park. Given the significantly reduced park that will be dug for gravel, the vision must include restoration expectations and management requirements that give the concept of a park credibility. Future habitat and ecology from restoration should be developed into a valuable wildlife resource which acknowledges the high recreational pressures placed on it. This should be part of the vision for Hatfield (Hertfordshire County Council Environment and Herts Ecology). o ‘More favourable’ assessment of Hat1 and Hat2 is at odds with the environmental impacts they would cause: traffic stress on the A1(M); loss of Country Park (Ellenbrook Fields) and its designation as a preferred minerals site, complex delivery (Landowner(s) on behalf of Cuf5).

Settlement pattern/distribution of housing and proportionate approach o Protect Hatfield Garden Village and the surrounding Green Belt/countryside o Hatfield would experience a disproportionate amount of additional housing compared to the rest of the Borough. o Protect the integrity of Hatfield, WGC and St Albans as separate settlements.

Infrastructure o Infrastructure inadequate. Doctors, hospitals and schools cannot cope. There are only two primary schools, no senior schools and lack of public transport in the area. Sewage system at capacity. o Hatfield Garden Village’s roads, already congested, could not cope with more traffic. The three new developments would result in an estimated 5000 additional cars in the area. o Existing roads and access would need upgrading which would damage the local environment. o Hatfield has poor shopping facilities and amenities. o The QEII Hospital has been downgraded with no A&E and reliance on Lister Hospital, Stevenage.

Sustainable development

144 o Proposed sites some distance from the train station, town centre. The Strategic Transport Network Policy required development to be near a train station and the town centre. o Unclear where residents will work. o Developing the area lead to the loss of the highest quality agricultural land in the Borough. o Loss of green open space will be detrimental to the environment and the standard of living.

Impact of the Development on the wider area o Impact on New Barnfield area which separates the settlements of Hatfield and Welham Green. o The area would experience a fall in house prices. o Impact on Hatfield Garden Village, currently a rural area surrounded by countryside and wildlife.

Site specific issues o The houses built would butt up to A1(M) motorway. o Ellenbrook Country Park could be developed into a nature and wildlife area. o Strongly object to the development of the Veolia incinerator on Green Belt land. o Use brownfield sites and protect the Green Belt, environment and wildlife.

How these views have been taken into account

Green Belt

Please see the Council’s response in section CS4 above.

Ecology, Environmental impact

The Council has reassessed sites and considered further sites (HELAA June 2016). Sustainability Appraisals and Appropriate Assessments carried out while preparing the Local Plan have informed the selection of sites proposed for allocation in LPPS 2016. The Sustainability Appraisal has considered the social, environmental and economic effects of the Local Plan and meets requirements for Strategic Environmental Assessment. It has tested the overall strategy and Local Plan policies, and reasonable alternatives, against agreed sustainability objectives.

Hertfordshire Minerals Local Plan 2002-2016 (2007) allocates land at Hatfield Aerodrome as a Preferred Area for future mineral working, sets out the approach to minerals sterilisation and has taken into account in site selection and Local Plan policies for Strategic Development Sites.

A key Local Plan objective for Hatfield is to maintain appropriate access to Ellenbrook Country Park during mineral extraction as part of the Green Corridor, and work in partnership with St. Albans District Council and Hertfordshire County Council to restore full access to the Park once mineral extraction is complete, to support healthy living (LPPS 2016, Objective HAT5).

145

The LPPS 2016 does not propose HAT 2 for allocation. Hat1 would be subject to requirements set out in Policy SP 22 and other Local Plan policies to address environmental impacts.

Settlement pattern/proportionate approach

Hatfield, the second largest settlement in the borough and large town, is the primary focus for new development alongside Welwyn Garden City. New development will help bring about investment and regeneration and deliver economic growth (LPPS 2016 Policy SP 3 Settlement Strategy and Green Belt boundaries).

In line with the Settlement Strategy, the LPPS 2016 allocates sites to deliver around 1,770 new dwellings in and around Hatfield. Total housing growth, now set out in the LPPS 2016, will be 2,936 dwellings which is below the 3,774 total potential capacity identified in the LPCD 2015, and below the mathematical proportionate OAN of 3,820 dwellings noted in the LPCD 2015. A purely mathematically proportionate approach does not necessarily equate to the most sustainable strategy or result in the most sustainable sites being allocated.

Please see the Council’s response to section CS3 Settlement Strategy above for further information on this matter.

Infrastructure

The Council will require supporting infrastructure to be provided in advance of, or alongside, development, unless there is sufficient existing capacity (LPPS 2016 Policy SP 13 Infrastructure Delivery).

Please see the Council’s Consultation Statement on the draft Infrastructure Delivery Plan 2015 for further explanation on infrastructure matters.

Sustainable development

The Sustainability Appraisal has tested the overall strategy and Local Plan policies, and reasonable alternatives, against agreed sustainability objectives. To compensate for the loss of greenfield land the Council will seek improvements and additions to the network of green infrastructure, multi functional areas of open space, including a new Green Corridor between Welwyn Garden City and Hatfield (LPPS 2016 Policy SP 12 Strategic Green Infrastructure).

Impact upon the wider area

Proposals would be subject to requirements set out in Local Plan policies to address site specific issues (summarised in relevant allocations policies or in connection with these) and wider policies. This should help ensure impacts in the wider area and site specific issues are addressed.

146

11 Hatfield - Housing

Number of responses received 22 (General 4, Support 0, Object 18)

Main Issues

Green Belt o Risks WGC and Hatfield coalescing into one town, losing their identity. Protect the integrity of Hatfield, WGC and St Albans as separate settlements. o Risk of coalescence with St Albans, considering proposals in St Albans District. o Protect Hatfield Garden Village and surrounding Green Belt/countryside. o Use brownfield sites and protect the Green Belt, environment and wildlife.

Settlement pattern o Welcome reduction from 3,430 to 2,450 for NW Hatfield is but still disproportionate. o Housing, and affordable housing, is needed and Green Belt may need to be used, but proposals would result in a massive expansion of Hatfield. Too many houses to be built in one area. o Hatfield has reached capacity and now needs regeneration. o Hatfield would experience a disproportionate amount of additional housing compared to the rest of the Borough as it has done over the last decade. Spread housing more fairly, with more in Brookmans Park, a sustainable location supported by good infrastructure and facilities, Mill Green, and Welham Green. o Hatfield is overpopulated. Hatfield’s population increased by 9,434 between 2001-2011 (33.7%) has increased by a further 1000 since 2011. With more students Hatfield’s population has grown by over 10,000 but without appropriate increase in supporting infrastructure compared to WGC. o Develop a new Garden City on non-Green Belt land further up the A1M.

Infrastructure o Development on this scale would place too much pressure on roads, schools, doctors and health care. Infrastructure would not cope. Existing community facilities and shops are poor. There are only two primary schools and no senior schools in the area. o If development is needed, then essential infrastructure should be provided. o Insufficient parking being provided with new development. o The Council has a poor track record on infrastructure management. o Hatfield Garden Village roads are very busy. Three new developments would bring 5000 additional cars in the area. Coopers Green Lane is heavily congested and the A1M could not sustain the volume of extra traffic. o Existing roads are in poor condition. Roads on Campion Way are still unadopted. o Upgrades to Roads and access ways are likely to damage nature and the local environment. o Hatfield train station is already at capacity, with Welham Green and Brookmans Park being much quieter and underused. o Lack of public transport options in the area. Bus services would need improving.

147 o The local QEII Hospital has been downgraded and has no A&E. Increased traffic on the A1M from additional housing the journey to Lister hospital will take longer. o Concern about drainage, the sewerage system and very low water pressure. o Water Cycle Scoping Study (April 2010) demonstrates sewerage infrastructure as a constraint/ possible showstopper and the need for extensive upgrades to support growth

Sustainable development o Plans are against the long term sustainability of the area by building on Green Belt and the highest quality agricultural land in the Borough. o A number of Hatfield wards experience levels of deprivation and associated health inequalities above the England average. Hatfield Central experiences higher levels of obesity and premature mortality

Impact of development on the wider area o Detrimental impact on wildlife and quality life through loss of green space for walking and enjoying nature. o Reduction in house prices in the area.

Site specific issues o Sites for Hatfield have not been considered well. o Houses built would butt up to A1(M) motorway. This should not be allowed. o Develop Ellenbrook Country Park into a nature and wildlife area, and for housing. o Citroen Garage on Great North Road, Hatfield, considered suitable in the Old Hatfield Charette in 2008, will be available within the plan period. Allocate for mixed-use development including up to 50 dwellings. Would assist in the rejuvenation of Old Hatfield o Reduce the number of houses proposed for the Hatfield sites. o Hertfordshire Fire and Rescue Service are to undertake search for alternative site(s) for Welwyn Garden City and Hatfield Fire Stations. Request that Hatfield Fire Station and associated housing on Wellfield Road be allocated for housing. HCC are undertaking a feasibility study to identify if the Weighbridge site, A1001 Comet Way is suitable for a combined Fire and Rescue Centre. Request site be allocated for this purpose

How these views have been taken into account

Green Belt

Please see the Council’s response in section CS4 above.

Proportionate approach

148

Please see the Council’s response to section CS3 Settlement Strategy above for further information on this matter.

Sustainable development

Impact upon the wider area

Site specific issues

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

Certain sites have been allocated as an outcome of this process. Detailed justifications are provided in the Employment/Housing Sites Selection Background Paper 2016, associated committee report or, for Hat11, the consultation point within this document. Hatfield Fire Station has not been allocated as there is significant uncertainty around reprovision of the fire station.

149

11 Hatfield – Employment

Number of responses received 1 (General 1, Support 0 Object 0)

Main Issues o Lack of new employment areas in Hatfield and loss of some existing employment land to housing, may leave a shortfall, particularly for logistics. To maintain a supply of employment sites further land needs to be released from the Green Belt. The draft Local Plan states that exceptional circumstances for altering the Green Belt would exist where proposals perform well against criteria in paragraph 3.21 o Allocate land at Roehyde for a science and logistics park

How these views have been taken into account

Sites Hat8, Hat9 and Hat10 have been assessed as unsuitable (HELAA June 2016) and therefore were not considered for allocation in the LPPS 2016.

150

11 Hatfield Town Centre Strategy, Definition of Town Centre Boundary and Sub Areas, Figure 21 (Hatfield Town Centre Boundary Map), Retail Frontages, Development Sites in the Primary Retail Core

Number of responses received 3 (General 2, Support 1 Object 0)

Support o The town centre is in desperate need of regeneration and so any measures need supporting.

Main Issues o Have been monitoring developments on town centre opportunity sites identified within the Local Plan document. Although sites have been suggested for some time no schemes have progressed. Policy should avoid being so prescriptive that schemes will not come forward or sites will remain vacant and should comply with the NPPF para 173 o Query whether Hatfield town centre needs to be so big. A smaller centre might be more viable. o Assess alternative sites which would allow for more flexibility to deliver future retail o Imaginative use of land in the town centre, for example White Lion Square, could provide alternative housing. Proceeds could fund a modern centre in the Market Square area. o Future redevelopment should include the completion of the east-west cycle link to encourage trade, active travel, improve cycle access and ensure that Hatfield in not dominated by the car.

How these views have been taken into account

The Council has reviewed and updated the town centre strategy in light of Welwyn Hatfield Retail and Leisure Needs Assessment (2016) and to allocate land to meet the scale and type of retail development Hatfield town centre needs. The strategy sets objectives that development in the town centre will need to make a positive contribution to improving its vitality and viability. Consultation highlights that residents feel strongly that the town centre should remain a focal point for the community. Following detailed analysis of challenges, in terms of the town centre’s physical characteristics and commercial factors affecting the retail market, it is considered that whilst retail will remain important for the centre, in the medium term, opportunities should be taken to add new uses and improve linkages to the wider town - thereby adding to the centre’s attractiveness and vibrancy.

151

11 Hatfield – Large Neighbourhood Centres and Small Neighbourhood Centres

Number of responses received 4 (General 2, Support 2, Object 0)

Support o Support designating and protecting neighbourhood and village centres, including reference to the sustainability benefits of residents not always needing to travel to a town centre for day-to-day needs.

Main Issues o Limit the number of shops within each centre able to sell alcohol, to reduce street drinking. o Repair broken cycle stands at neighbourhood centres Crawford Road and Birchwood.

How these views have been taken into account

LPPS 2016 Policy SP 5 Quantity and location of retail development sets out a retail hierarchy which defines the borough’s neighbourhood centres and identifies broadly the level and type of retail needed to support sustainable communities. The Plan envisages a network of neighbourhood centres working together. Investment in neighbourhood centres is part of the vision for Hatfield; regeneration of High View neighbourhood centre a Plan objective. A new neighbourhood centre is proposed to be delivered as part of the strategic site Hat1 North West of Hatfield.

152

11 Hatfield– Urban Open Land

Number of responses received 5 (General 0, Support 2, Object 3)

Support o Welcome proposed designation of UOL 218 along Mosquito Way, a key part of the approach to the Grade II* listed buildings. UOL designation is important to safeguard the setting of important heritage assets o Support the intention of providing Urban Open Land

Main Issues o Request allocation Woods Avenue site for educational use UOL169 and amendment to remove the area of the school buildings designated as Urban Open Land o UOL220 is within the Green Belt and should remain so. It is not Urban Open Land. o Policy lacks measures sufficient or specific enough to ensure the protection of urban open land in light of the significant amounts of lost urban land. o Retain UOL220 as Green Belt rather than classify Urban Open Land o Amend Policy to prohibit development in areas designated as Urban Open Land unless replacement land is provided to compensate for the loss. Hatfield

How these views have been taken into account

LPPS 2016 Policy SP12 and approach and Policy SADM17 continues the Council's approach of protecting areas of Urban Open Land. The Open Spaces Survey (2016) notes that Ellenbrook Lane: UOL 220 is a well landscaped, large recreation area off Ellenbrook Lane, Hatfield which provides excellent opportunities for both passive and active recreation and formal and informal children’s play.

153

11 Site HE23, Factory adjacent to Wellfield Road Depot

Number of responses received 8 (General 6, Support 2, Object 0).

Support o An isolated pocket of industry at present, redeveloping the site for housing would be logical.

Main Issues o Concern that wastewater network will be unable to cope with development of this site. Upgrades to infrastructure likely to be necessary. Should require the developer to provide a detailed drainage strategy setting out improvements required and how they will be funded and bear in mind upgrades can take 18 months to 3 years to deliver o Development will not adversely affect any heritage assets o Site has no fundamental ecological value; low ecological opportunities and sensitivity, and no protected species. No recognised ecology sites within the site, nor nearby o A transport assessment and travel plan will be required because of the number of dwellings proposed Hertfordshire County Council o The site’s developer should contribute to completing the cycle path from Wellfield Road to Hatfield Railway Station, which is incomplete through the town centre. o Given the site’s good accessibility to the town centre, active travel links should be supported. There may even be potential for the site to become a car-free development. o Given that Wellfield Road is a main route into Hatfield, attention needs to be given to the poor state of the road and pavement, speeding traffic and poor management of undergrowth beside the Alban Way before development can take place.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

154

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

Policy SADM 26 and Table 10 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development and Policy SP 14 sets out the approach for the delivery of a new secondary school to serve growth in the borough and particularly Hatfield, Welwyn Garden City and the northern villages

155

11 Hatfield – Site HS12, Garages off Garden Avenue

Number of responses received 4 (General 4, Support 0, Object 0).

How these views have been taken into account

Site was granted planning permission for 22 flats (S6/2014/2179/MA).

156

11 Hatfield – Site HS31, Garages off Hollyfield

Number of responses received 4 (General 4, Support 0, Object 0).

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

157

11 Site HW12 Land North of Toms Field

Number of responses received 5 (General 3, Support 0, Object 2)

Main Issues o Concern that wastewater network will be unable to cope with development of this site. Upgrades to infrastructure likely to be necessary o Prior to development a Phase 1 survey will be needed to understand fundamental ecological constraint. A reptile survey may be needed. Site has moderate ecological sensitivity. Moderate opportunities for the creation of an orchard or green infrastructure link. Retain hedgerows and trees, or compensate if lost. Potential for protected bird species on site. No designated ecology sites within the site or nearby o New bus infrastructure would be required in proximity to the site o Development would have a dramatic impact on what was once a country lane. o Landowner seeks designation of the site for university uses rather than housing

How these views have been taken into account

Site has been withdrawn by the landowner and has not been considered for allocation within the LPPS 2016.

158

11 Site Hat1 North West Hatfield

Number of responses received 143 (General 8, Support 1, Object 134)

Support o Support allocation. It will be essential to provide safe cycle routes, link to Stanborough School, WGC Town Centre, Hatfield Town Centre, Onslow School and Hatfield Station.

Main Issues

Green Belt/Countryside Heritage / Ecology o Oppose building on this site or adjacent area marked “land promoted for housing” due to risk of coalescence between Hatfield and Welwyn Garden City o Would lead to coalescence with WGC/Stanborough. o Hat 1 (1,100 houses) and Hat 2 (1,350 houses) would cause significant harm to the Green Belt (encroachment), transport infrastructure and quality of life. Risk of coalescence between Welwyn Garden City and Hatfield and St Albans o Hatfield has had its fair share of greenbelt development already in the last decade, the new plans are disproportionate compared to other areas in the borough o Green Belt should not be built on, particularly at this scale.

Settlement pattern/strategy o Note reduced capacity from 2,000 dwellings in the Emerging Core Strategy to 1,350 in this consultation. Still some concerns about large scale development in this location o Disproportionate burden of housing growth falling on Hatfield. Hatfield will accept proportionate development but will not be the Borough's dumping ground o Support proportionate approach, however the contribution of the largest settlements is too high. o Would be a major overdevelopment. Would lose ‘village feel’. Have no sense of community. o Housing should be more spread out more across the borough and recommend Brookmans Park due to its ‘underused’ railway station with parking, and little recent history of housing expansion. o Hat1 too far from station. All areas should accept a proportionate level of development in Welwyn Hatfield with greater emphasis placed on areas with rail links. Build where there are under-used rail links - Welham Green & Brookmans Park o Remove the ‘more favourable’ designation from Hat1. o Consider other areas; WGC5 - excellent road connections, Welwyn has capacity to take more; Little Heath could take 500 houses between Swanley Bar Lane and Hawkshead Road. o Build in all villages so generations of families can remain in their village. o Housing should be limited to that needed for local employees. o Develop land west of Stanborough instead.

159 o Look at building land already available, and develop new Garden Cities instead. o No need for more Gypsy and Traveller accommodation here. o Would not help town centre regeneration as most new residents would go to WGC or St Albans. Adverse effect on health and safety of residents. o The Council’s concerns regarding the potential to cause coalescence of Hatfield and Welwyn Garden City do not merit the proposed reduction from 2,000 dwellings to 1,350 dwellings. Advocate a compromise, which provides greater green separation from Stanborough and provides for about 1,650 dwellings to help meet housing need o Amend Figure 19 to include ‘Hat1 Land Promoted for Housing’ within the proposed development. Amend Hat1 site boundary in accordance with drawing no. 1357/203

Environmental issues o Would lead to flooding. o Unsuitable location due to problems of noise (from A1(M)). o Worsening of air quality due to increased traffic. o Disturbance from construction traffic over long period. o Increased light pollution – already bad from A1(M) and Business Park. o Loss of the area’s best Grade 2 agricultural land which should be conserved for food production. o Countryside and views will be spoilt. o Development should take account of the setting of the Grade II listed Old Cottage; harm to setting more likely if the ‘finely balanced’ part of Hat1 comes forward. Include mitigation measures in the masterplan for the site o A severe indirect impact from development, affecting Ellenbrook Park through isolation. Low sensitivity overall as land is intensively farmed. No designated ecological sites or fundamental ecological constraints. Protected species unlikely o Wildlife will be adversely affected.

Highways and Transport o Due to significant number of dwellings proposed and proximity of the site to two SRN junctions (Junction 4 and 3 of the A1(M)) there could be a material impact on both Junctions. Transport model shows additional stress on the A1(M) during peak times o Likely to significantly increase pressure on the local road network.. Additional modelling required to assess whether the proposed mitigation measures are appropriate and whether further mitigation is required o Further development close to the A1(M) junction 4 would exacerbate existing traffic issues on the A1(M) and roads in St Albans. The consultation document acknowledges that additional stress would be placed on the A1(M) and nearby junctions which would need to be addressed with little indication of appropriate solutions o Should not develop Hat1 for housing. Local infrastructure cannot support more housing. Current traffic flows suggest an alleviation scheme is required now, o Additional traffic will worsen existing congestion; on Coopers Green Lane, Green Lanes, Hatfield Avenue, Comet Way, A1(M) junctions. o Roads from previous new development still not adopted.

160 o Bus services inadequate. Train services from Hatfield overloaded. o Isolated from rail services. Would need significant improvements to walking and cycling facilities around Hat1. The size of the proposed site is likely to warrant new / enhanced passenger transport provision (local buses) and improved access / links to key destinations such as employment / leisure in Hatfield o Unsustainable. Too far from town centre and railway station, especially for walking. o Site developer should contribute to completing the cycle path from Wellfield Road to Hatfield o Railway Station, which is incomplete through the town centre. o Active travel links should be supported and there may be potential for car-free development. o Given that Wellfield Road is a main route into Hatfield, attention needs to be given to the poor state of the road and pavement, frequent speeding traffic and poor management of undergrowth beside the Alban Way before development can take place

Other infrastructure and services o Huge gaps across all types of infrastructure. Lack community facilities and shops in area. Schools overcrowded; healthcare facilities overstretched and not easily accessed. Travel to Lister Hospital via A1(M) lengthy and potentially hazardous. Howe Dell community hall too small. o Unreliable electricity supply. o Should design out potential for community isolation, consider how development will link into existing communities, offer shared benefits (services and infrastructure), be accessible by pedestrians and cyclists rather than being car- dependent, promote active travel using the strategic green corridor proposed for Hat1, improve existing active travel links o Wastewater treatment capacity unlikely to be able to support the demand anticipated from this development. Likely to require infrastructure upgrades to ensure sufficient capacity to serve development. Upgrades can take 18 months to 3 years to design and build. Seek to work with the Local Planning Authority and developer to plan for the sewage treatment infrastructure needed. o Would exacerbate water supply shortage. o Problems for waste management, refuse collection and emergency services. o There is an ordinary watercourse on this site. Herts County Council as Lead Local Flood Authority (LLFA) will have requirements similar to our requirements for Main Rivers

Minerals o Would object to development on the site without the full consideration of prior mineral extraction. Given the close proximity to Hat 2 any proposal to extract mineral would need to take into account possible cumulative impacts. The timing of delivery would be crucial. Issues could be detailed as part of the suggested master planning process. The presence of mineral and possibility of prior extraction would need to be fully explored within the local plan. Add to the supporting text for sites Hat 1, Hat2, and WGC4: “In order to prevent the

161

sterilisation of minerals, consideration should be given to the need to extract any underlying sand and gravel, prior to future development taking place.”

How these views have been taken into account

This site (both the more favourable and finely balanced parts) has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report of the CHPP June 13 meeting for further information).

The northern extent of the site (northern area of the finely balanced part) will remain within the Green Belt so that the northern Green Belt boundary of Hatfield will not be any closer to the Welwyn Garden City as a result of taking the site out of the Green Belt. Policy SADM 26, Policy SP 22 and Figure 14 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. Development of this site would be guided by a masterplan which would require contributions to the Green Corridor and investment in significant green infrastructure, in line with Policy SP 12, to further mitigate against the risk and perception of coalescence.

Policy SP 22 also includes the requirement for development proposals to demonstrate the extent of the mineral that may be present and the likelihood that prior extraction can take place in an environmentally acceptable way has been fully considered. As a minimum, an assessment of the depth and quality of mineral, together with an appraisal of the consequential viability for prior extraction without prejudicing the delivery of housing within the plan period should be provided.

Green Belt

162

Please also see the Councils response under section CS4 Green Belt Boundaries above.

Settlement pattern/strategy

Please see the Council’s response under section CS3 Settlement Strategy above.

163

Appendix A - Finely balanced sites – remainder of Hat1, North West Hatfield

Number of responses received 4 (General 0, Support 1 Object 3)

Support o Understandable that fields along Coopers Green Lane, in Salisbury Village and Stanborough, may be 'ripe for development': subject to infrastructure being provided, including schools and local NHS provision

Main Issues o Disagree that this site should be considered for future development, especially if the remainder of HAT 1 (land suitable for development) and HAT 2 are developed. Major over-development joining Hatfield to Welwyn Garden City at Stanborough, proximity to Hatfield Garden Village, amount of Green Belt land used, and location too distant from rail stations and town centres. o Reject due to coalescence with Welwyn Garden City. o The site suffers excessive road traffic noise which is surely above statutory limits for housing. o Welcome that a portion of Hat1 and Hat2 are no longer classified as "More Favourable". However, reasons for reclassification fundamental. (E.g. coalescence with WGC, overwhelming scale, road infrastructure issues). For consistency with other sites assessed, reclassify the "Finely Balanced" portions of Hat1 and Hat2 as "Less Favourable". Partly this is to reflect the fact that were they to be considered again for inclusion the cumulative Green Belt impact would require all of Hat1 and Hat2 to be rejected. o Consider that Hat1 Remainder and Hat2 Remainder sites should be “less favourable” rather than “finely balanced” and not be taken forward

How these views have been taken into account

See response to Hat1 consultation point immediately above.

164

11 Site Hat 2 West of Hatfield

Number of comments received 73 (General 8, Support 3, Object 62)

Support o Support general principles set out in the plan, with particular reference to proposed housing allocation Hat2. Support its allocation. Seek the inclusion of the part of Hat2 classified as a finely balanced site as a safeguarded site o Support the proposed allocation of Hat2 o Seems a sensible location for more housing, so long as good cycling links and public transport are provided, for example there is no all year commutable cycle route west to St Albans. The Alban Way is unlit and isolated, so not suitable for cycling at night, so preventing safe winter cycle commuting. A cycle route along the A1057 is therefore essential.

Main Issues

Heritage/Ecology/Green Belt/Countryside o The western site boundary is not clearly defined by a recognisable, permanent, physical feature, as the NPPF paragraph 85 requires. o The strategic Green Infrastructure belt in Fig 2 is poorly expressed, lacks rationale, Borough or County context. Does not reflect key GI link, the River Lea, and is severely compromised by the A1. The strategic function of key sites such as Ellenbrook Fields is unclear. In this context, the function of Ellenbrook Country Park will largely cease to exist. Recent management has created a general grassland habitat of local bird interest which future gravel workings and recreation pressure would modify. Need to consider the net impact and provide habitat compensation elsewhere to offset the loss of at least some of this resource o Expanding towards St Albans through Hat 1 and Hat 2 would risk coalescence with St Albans, negating the role of the Green Belt to prevent urban sprawl o Green Belt should not be built on, particularly at this scale. Would lead to loss of natural gap between Hatfield and St Albans. o Use brownfield sites first; close to other housing areas and facilities. o Hatfield has had its fair share of greenbelt development already in the last decade, the new plans are disproportionate compared to other areas in the borough

Settlement pattern/size/community o Would be a major overdevelopment. Have no sense of community. o Housing target of 12,500 is too high. Support the proportionate approach to development, however the contribution made by the largest settlements is too high, encroachments into Green Belt from Hat 1 and Hat 2 would significantly harm the Green Belt, transport infrastructure and quality of life o Housing numbers too great. Unjustified. Disproportionate burden of growth falling on Hatfield.

165 o Would not help town centre regeneration as most new residents would go to WGC or St Albans. o Disruption of existing community at HGV and Salisbury Village. o Not enough local jobs to match housing growth. o Previous new housing largely ‘buy to let’ for students; should not be repeated. o Breaches promise to Hatfield residents to deliver the country park to compensate for Hatfield Aerodrome redevelopment. o Cumulative development with Hat1 would lead to loss of Hatfield Garden Village identity. o Hat2 has no local train station. Build where there are under-used rail links - Welham Green & Brookmans Park. Place greater emphasis on areas with rail links o Use land SW of Welham Green – has access to choice of villages and stations. o Build large numbers of flats around shops and key transport locations. o Build in ALL villages so that there are properties for generations of families to remain in their village o Reduce target for housing in borough to 4860. o Consider the New Barnfield site for housing development rather than an incinerator. o Consider a well laid-out retirement village here as an alternative; would help retain village feel. o Gypsy and traveller accommodation does not mix with ordinary housing. o Should design out potential for community isolation by considering how development will link existing communities/the wider community, offer shared benefits and be accessible by pedestrians and cyclists rather than car-dependent o Concentrate on providing social and low-cost housing for local need.

Environmental issues o Site contains significant, ecological value. To come forward it should demonstrate development does not have a negative effect on the site’s ecological interest and that it conserves and enhances biodiversity. Should require the site and all major sites to be assessed using BS42020 and the Biodiversity Impact Assessment Calculator o Ellenbrook Fields has substantial wildlife and historic value – should not be built on. Rich biodiversity - newts, wide range of birds and flora – would be lost or very badly affected. o Countryside and views will be spoilt. o Recognised ecology sites within Site: Ecosite: Ellenbrook Fields; Adjacent to Local Wildlife Site: Home Covert & Round Wood. Protected species: potential for reptiles. High potential for habitat creation and GI as site is large. Habitat for Small Heath butterfly (a NERC species). Buffer with adjacent Local Wildlife Site. Ecological sensitivity: locally moderate. Fundamental ecological constraint: within Ecosite. Phase 1 survey may be required to assess habitat value and reptiles survey if habitat is suitable o Concern about the ‘loss of a significant part of Ellenbrook Fields Country Park.’ Serious outstanding issues with the proposed approach. Development will be highly damaging to the developing ecological interest of this part of the Park; increase pressure on remaining resources; degrade the ecological setting of Home Covert; and disturb the Home Covert woodland. Management of remaining

166

parkland is outside planning control unless subject to S106 agreement. Remaining area likely to be dug for gravel (7.4), changing the area permanently in the longer term to a largely wetland environment unless extraction pits are filed in. Although unlikely to occur over all the area at once it is not conducive to a functional Country Park environment o Need to assess impacts on the setting of The Grade II listed Astwick Manor west of the site and provide for mitigation measures through the master plan process if required o Development will cause substantial harm to the setting of Astwick Manor Grounds, a listed park and garden o Give more consideration to history of the town (including conserving aircraft heritage). o Worsening of air quality due to increased traffic. o Disturbance from construction traffic over long period. o Increased light pollution – already bad from A1(M) and Business Park. o There is an ordinary watercourse on site. Herts County Council as Lead Local Flood Authority (LLFA)will have requirements similar to our requirements for Main Rivers o Would exacerbate water supply shortage. o North-east part of site adjoins commercial depots – unsuitable for residential or community use. Would lead to flooding from ground water. o Keep 100m of grassland/countryside around perimeter of the houses (to improve look and feel).

Highways and Transport o Due to significant number of dwellings proposed and proximity of the site to two SRN junctions (Junction 4 and 3 of the A1(M)) there could be a material impact on both Junctions. Transport model shows additional stress on the A1(M) during peak times o The main access to the A1(M) from Hat2 is via Junction 3 and already significantly congested. The WHaSH Model indicates the proposed mitigation would not significantly improve this. Further investigation required before the impact of Hat2 on the local road network can be adequately assessed. o Hat2 should not be considered for Housing development. Local infrastructure, including roads surrounding HAT, cannot support more housing. Current traffic flows suggest an alleviation scheme is required now o Additional traffic will make congestion worse on Coopers Green Lane, Green Lanes, Hatfield Avenue, Comet Way, A1(M) junctions, A414, A1057 etc. o Car use will not reduce on new development due to outlying location and cuts to bus services. o Roads from previous new development still not adopted. o Bus services inadequate. o Demand for car parking would overflow the boundaries of the site. o Use land at Brookmans Park due to railway station location and lack of previous growth there. o Unsustainable, as too far from town centre and railway station, especially for walking. o The developer should contribute to completing the cycle path from Wellfield Road to Hatfield Railway Station.

167 o Hat1 and Hat2 are isolated from rail services. Would need significant improvements to walking and cycling facilities around Hat1 and Hat2, new / enhanced passenger transport provision (local buses) and improved access / links to key destinations such as employment / leisure in Hatfield o Given the site’s good accessibility to the town centre, active travel links should be supported and there may be potential for the site to become a car-free development. o Given that Wellfield Road is a main route into Hatfield, attention needs to be given to the poor state of the road and pavement, frequent speeding traffic and poor management of undergrowth beside the Alban Way before development can take place. o Hat1 and Hat2 are isolated from rail services at Hatfield Station. Would need significant improvements to walking and cycling facilities around Hat1 and Hat2, new / enhanced passenger transport provision (local buses) and improved access / links to key destinations such as employment / leisure in Hatfield

Other infrastructure o Significant concerns. Ellenbrook Fields Country Park is an important piece of strategic green infrastructure, part of a S106 agreement for the Hatfield Aerodrome redevelopment. Given significant issues WHBC previously raised in assessing the site’s suitability, unclear why it is being taken forward now. o Lack of infrastructure: schools overcrowded; healthcare facilities stretched and not easily accessed. Travel to Lister Hospital via A1(M) is lengthy and potentially hazardous. o The local plan states that the landowners will be encouraged to work together and with the Council to develop a shared vision for development and a joint approach to the provision of infrastructure and community facilities – welcomes this approach o Wastewater treatment capacity unlikely to be able to support the demand anticipated from this development. Likely to require upgrades to ensure sufficient treatment capacity to serve this development. Upgrades can take 18 months to 3 years to design and deliver o Area lacks community facilities. Lack of shops in vicinity and town centre. o Problems for waste management, refuse collection service and emergency services.

Minerals o The County Council’s Minerals Policy 3: Sites for Sand and Gravel Extraction and the Working of Preferred Areas identifies land at the former British Aerospace site as a preferred area for mineral working. Potential for large areas of the preferred area to be sterilised through proximity of housing on Hat2. Phased approach possible but HCC would seek a legal agreement to guard against sterilisation. Until such a time that viable sand and gravel has been extracted from Hat2, the County Council will object to proposals that may prejudice its extraction. Will reassess existing preferred areas as part of the review of the adopted Minerals Local Plan. Add to supporting text for sites Hat 1, Hat2, and WGC4: “In order to prevent the sterilisation of minerals, consideration should be given to the need to extract any underlying sand and gravel, prior to future development taking place.”

168 o Discount this site from the plan period due to the need to extract minerals, fill and restore first. o Deliverability is unclear given substantial mineral reserves and time required to extract these

Other comments o Existing S106 contains covenants to keep Ellenbrook Fields open; will not be easily rescinded. o Remove Hat2 from category of ‘more favourable’ sites. o A complete re-think of the whole plan is required.

How these views have been taken into account

As a result of this process the site has not been allocated (reference: Housing Sites Selection Background Paper 2016 and associated committee report and minutes of the CHPP 13 June 2016 meeting). In summary, whilst it was concluded that the site could form a sustainable extension to Hatfield of a size that would enable the provision of new facilities and supporting infrastructure, development of the site would lead to the loss of a substantial area of publicly-accessible green infrastructure. Mineral extraction will result in large parts of the remaining country park being largely inaccessible to the public for the plan period, and delivery of the site could also be delayed by the need to vary the existing S106 agreement and there is uncertainty as to whether all parties will agree to such a variation. Given the uncertainty around securing a variation to the legal agreement, how long it would take for minerals to be extracted – Hat2 falls within a Preferred Area in the Hertfordshire Minerals Plan) and other concerns, the Council has agreed not to allocate the site – either for within the plan period, or as Safeguarded Land for beyond it.

Green Belt

Please also see the Councils response under section CS4 Green Belt Boundaries above.

169

Settlement pattern/strategy

Please see the Council’s response under section CS3 Settlement Strategy above.

Biodiversity

170

Appendix A Finely balanced sites – remainder of Hat2, West of Hatfield

Number of responses Received 12 (General 2, Support 0 Object 10)

Main Issues o Welcome that a portion of Hat1 and Hat2 are no longer classified "More Favourable". The reasons for the reclassification were fundamental e.g. coalescence with WGC, overwhelming scale, road infrastructure issues, etc. For consistency with other sites reclassify the "Finely Balanced" portions of Hat1 and Hat2 as "Less Favourable". o Based on evidence and concerns raised above, Hat1 Remainder and Hat2 Remainder sites should be categorised “less favourable” and not taken forward. o Excluding the southern section would secure more of the park and reduce impacts on the Local Wildlife Site. Potential mineral extraction could destroy this area of open grassland. Retention of this area will have limited impacts due to its size and increased recreational pressure. Within Ecosite: Ellenbrook Fields. Adjacent to part of Local Wildlife Site: Home Covert & Round Wood. Potential for reptiles and Great crested newts. Potential for habitat management / creation. Buffer with Local Wildlife Site. Ecological sensitivity: moderate. Fundamental ecological constraint: within Ecosite - Phase 1 survey to assess habitat interest. Reptile and Great crested newt surveys may be required and mitigation for if present o Site of high amenity and ecological value. Its loss would be irreplaceable and to the detriment of the local environment and the many local users of the area for leisure and recreation. o The development is not suitable. Would breach former planning agreements. Development is possible on the Ellenbrook Fields area provided for as part of the planning permission and section 106 agreement for the surrounding former DeHavilland site. o Seek the inclusion of that part of Hat2 classified as a finely balanced site as a safeguarded site for 250 homes to assist in meeting objectively assessed needs in the event that other sites identified are not able to deliver the number of homes envisaged

How these views have been taken into account

Please see response to consultation point Hat 2 immediately above.

171

Appendix B Less Favourable Sites – Hatfield – Site Hat3, West of Ellenbrook

Number of responses Received 1 (General 1, Support 7 Object 1)

Support o Support the ‘less favourable’ classification. Development would shorten a vulnerable Green Belt gap and impact on the distinctive nature of rural settlements such as Smallford and Colney Heath o Agree that development site would further degrade gaps between Hatfield and St Albans and is likely to have negative ecological impacts on old or rough grasslands o Site unfavourable for development; open space is too narrow to be reduced further. o As part of the site is in St Albans and unavailable, question the identification of Hat3 in the plan. o Site within important Green Belt Gap between St Albans and Hatfield, need to prevent coalescence. o Loss of Grade 2 agricultural land. o Distance from infrastructure and proximity to a congested road network. o Location in Watling Chase Forest o Risk of mineral sterilisation. o Ruin an area of high biodiversity value. o Unlikely to contribute to Hatfield town centre regeneration.

Main Issues

Heritage Impact o The Sustainability Appraisal correctly identifies potential for significant negative harm to the historic environment. Designated heritage assets in the vicinity of this site, include Torilla (grade II* listed modern movement house), Great Nast Hyde (grade II 17th century manor house), Nast Hyde farmhouse and barns (grade II) and the granary, barn and farmhouse at Popefield farm (all grade II). Recommend site is not brought forward and that consideration be given to designating a small conservation area in this locality jointly with St Albans City and District Council

Object - this site should have not been considered o Would increase coalescence between St Albans/Hatfield/ Welwyn Garden City; Damage the rural character of Smallford and Colney Heath; unclear what infrastructure would support development; lack of joint-working between neighbouring authorities and parishes; should prioritise development of brownfield and under-used land; should not build on the Green Belt. It's a natural buffer between Hatfield and St Albans

Object site should be more favourable

172 o Masterplan proposals demonstrate the site could be developed in a way that does not undermine Green Belt purposes. Site is suitable, available and deliverable, therefore the Council cannot justify the under provision of housing in the borough. Site capable of being subdivided into two distinct parcels and the Council should assess parcels separately. Hat3 should be allocated for residential development

How these views have been taken into account

The site has since been assessed as unsuitable due to heritage impacts (HELAA June 2016) and was not considered for allocation within the LPPS 2016.

In response to the LCPD 2015, the landowners asked for a smaller part of the site adjacent to Bramble Road to be assessed on its merits. This smaller site (referred to as Hat19) underwent assessment in the HELAA and other technical studies and was considered for allocation in the Housing Sites Selection Background Document 2016. However, it was recommended that Hat19 should not be allocated on Green Belt grounds. Please refer to the Housing Sites Selection Background Document and associated committee report and minutes of the CHPP June 13 meeting for further information.

173

Appendix A Finely Balanced Sites – Hatfield Site Hat4 Land south of Ellenbrook

Number of responses received 156 (General 5, Support 0, Object should be more favourable 0, Object should be less favourable 0, Object should not be considered 151)

Main Issues o The Ellenbrook area is a sustainable location close to employment centres, the railway and bus stations with easy access to facilities. The site may provide an opportunity to provide some convenience shopping facilities. Decisions on whether the site should be developed have been based on a flawed Green Belt Review, which misinterprets Green Belt purposes and does not comply with national policy. The site makes no significant contribution to Green Belt purposes. Development would be carefully masterplanned to reduce impact and minimise harm to the Green Belt. The 2014 SHLAA concluded that as long as development does not extend west of the existing urban area, it would be suitable. To prevent the westward spread of development, propose an area of Urban Open Land. Landscape impact less than stated since assessment was based on the site being Grade 2 agricultural land – this is not a landscape matter. o Access to the site would be from Ellenbrook Lane, minimising impacts. No development would take place within the parts of the site within a flood zone, other than highway access. Provision to boost surface water drainage through swales and balancing ponds, would improve the current situation and reduce flood risk elsewhere. There are no undue utilities constraints

Settlement pattern o There is a perception of Hatfield as being a ‘dumping ground’ for unwanted growth elsewhere due to vast number of homes built in Hatfield in recent years, construction of a new university campus and a large business park. Should not expect Hatfield to take a large share of growth again – the distribution of sites is unfair. o Several respondents advocate a more proportional approach to development, with less development around Hatfield, suggesting alternative locations for housing such as around Welwyn Garden City, the site of the former proposed incinerator at New Barnfield and the borough’s villages, citing issues around the need for affordable housing and rail accessibility

174

Sustainability o An unsustainable location for development. Site a long way from facilities, the town centre and railway station. The Community Facilities Study gives the Ellenbrook area one of the lowest ratings in the borough for proximity to facilities. Residents will need to rely on a car, with resultant impacts on infrastructure, pollution and energy use. o The site is important Grade 2 agricultural land and should be protected.

Impact upon the wider area o The Sustainability Appraisal correctly identifies potential detrimental impacts on the historic environment. Development would impact on the distinct character and quality of Wilkins Green Lane, the setting of Torilla, Grade II* listed and other Grade II listed buildings including Great Nast Hyde manor house and Nast Hyde Farm. Recommend the site is not brought forward for development, and its ‘finely balanced’ status downgraded o Sites should be chosen so as to ensure Hatfield town centre regeneration. Due to the distance from Hatfield Town Centre, and proximity to St Albans, development will not support this. o Development will not benefit residents of the Ellenbrook area. o Ellenbrook’s tightly-knit community will be disrupted by development on the site. o Development will result in noise and disruption to local residents during construction. o Development will result in Selwyn Drive and Selwyn Avenue becoming ‘rat-runs’. o Development will impact upon the character of Wilkins Green Lane and historic buildings. o Pollution from additional traffic will affect the health of children using the play area within Ellenbrook Open Space. o Site within Watling Chase Community Forest area, and would impact upon its openness.

Site specific o No recognised ecology sites within the site or close by. Not home to protected species. Few ecological opportunities, low ecological sensitivity. No fundamental ecological constraint o Should direct site allocations away from areas of high flood risk – or where development is necessary, ensure that flood risk elsewhere is not worsened. If sites in flood zones are considered for allocation, a Strategic Flood Risk Assessment will be required and if sites then are allocated, recommendations from the Assessment must be followed o Support intention not to take the site forward for development in the plan. Unclear why it is now assessed as ‘finely balanced’. This is at odds with the narrative of the consultation document, and previous findings in the 2012 Land for Housing Outside Urban Areas. Site is in a fragile and vulnerable Green Belt gap between St Albans and Hatfield, which would be compromised by development. Access to the site across land in Flood Zones 2 and 3 will necessitate a Strategic Flood Risk Assessment.

175 o Previous reasons for assessing the site as unsuitable in the Council’s 2012 Strategic Housing Land Availability Assessment still stand. The site is too far from Hatfield town centre, the railway station and other facilities; There is no safe means of access; The site floods, part of the narrow, fragile Green Belt gap between St Albans and Hatfield, adjacent or close to six listed buildings, limited capacity of the sewerage network. Development could alter the semi-rural nature of the Ellenbrook area –mature trees and hedgerows provide a safe habitat for animals, and the area (including the Alban Way) is enjoyed by people from the local area and visitors. This semi-rural green corner of Hatfield should be preserved o The majority of respondents consider the site unsuitable and/or should not be considered. o Site was previously progressed for development in the 1970s, and dismissed at a public enquiry. Since previously rejected as unsuitable– difficult to see what has changed. o Ellenbrook Lane and Wilkins Green Lane are too narrow to be used as access points for the development. Widening would change the lane’s character which would be unacceptable. o Development will increase traffic levels at Ellenbrook Lane beyond what the lane can cope with Ellenbrook Lane was cut-off at its southern end several decades ago because of excessive traffic. Opening up access to Comet Way at the south end once again would be unacceptable. o Because the Alban Way footpath/cycle route runs between Hat4 and Hat5, there could be no safe means of access between them. o The number of homes proposed will leave insufficient space for parking and open space. o Houses built here will do nothing to resolve the need for more affordable housing. o The location of the site will mean that the majority of new homes become buy-to- let or student properties, with resultant issues around refuse collection, noise, littering and poor maintenance. o Residents will experience noise and air pollution due to the site’s proximity to the A1 and A1001 o One of the few areas in Hatfield with a less urban character which should be preserved. o Development will spoil the character of the Alban Way, which is well used by locals and visitors. This will put people off using it for exercise, when people need to be encouraged to exercise. o Development will affect the peace and quiet of the site relative to its surroundings provides an environment where wildlife thrives –and adjacent Wildlife Site WS022 Copse at Nast Hyde. o Development will destroy mature trees and hedgerows around and between the two sites. Overshadowing from development will inhibit the growth of trees and plants on the Alban Way. o The site should be allocated for development

Flood risk o Concern that site in Flood Zone 3 is being considered. Site regularly floods. Development would increase the likelihood of flooding on site and further downstream, particularly in Colney Heath and London Colney.

176 o Existing flood defences in the Ellenbrook area are inadequate and have come close to breaching.

Infrastructure o The Ellenbrook area lacks facilities. To reach facilities residents will need a car worsening existing traffic congestion on St Albans Road in Hatfield and Hatfield Road in St Albans o Road and rail overstretched - cannot accommodate more users. o Healthcare facilities in the area overstretched and cannot accommodate more patients. o Schools in the area are overstretched and cannot accommodate more students. o Utilities in the area overstretched and cannot accommodate more users. o Cumulative impacts, as a result of development on other sites (specifically Hat1 and Hat2 north and west of Hatfield, as well as development within St Albans District) will worsen the above.

Other o Do not trust the Council and developers to plan and build responsibly, given the experience of Salisbury Village and Hatfield Garden Village with roads still unadopted years after being built. o Concern that planning decisions are being taken irrespective of the wishes of local people. o Fewer homes need to be built given the University of Hertfordshire is building more student accommodation on its own land, freeing up ‘conventional’ housing occupied by students.

How these views have been taken into account

Site Hat4 is considered unsuitable due to likely substantial harm to heritage assets (HELAA June 2016) and has not been considered for allocation in the LPPS 2016.

177

Appendix A Finely Balanced Sites – Hatfield – Site Hat5, North of Roehyde

Number of responses received 157 (General 5, Support 0, Object should be more favourable 0, Object should be less favourable 0, Object should not be considered 152)

Main Issues o The Ellenbrook area is a sustainable location close to employment centres, railway and bus stations with easy access to facilities. site may provide an opportunity to provide some convenience shopping facilities. Decisions on whether the site is suitable based on a flawed Green Belt Review. The site makes no significant contribution to Green Belt purposes. Development would be carefully masterplanned to reduce impact and minimise harm to the Green Belt. The 2014 SHLAA concluded that as long as development does not extend west of the existing urban area, it would be suitable. To prevent the westward spread of development, propose an area of Urban Open Land. Landscape impact less than stated since assessment was based on the site being Grade 2 agricultural land – this is not a landscape matter. Does not constrain developability o Access to the site would be from Ellenbrook Lane, minimising impacts. No development would take place within the parts of the site within a flood zone, other than highway access. Provision to boost surface water drainage through swales and balancing ponds, would improve the current situation and reduce flood risk elsewhere. There are no undue utilities constraints

Green Belt o The site is Green Belt, and should not be developed. Government policy makes this clear. o Development of the site will lead to coalescence between Hatfield and St Albans/Smallford – it is in the narrowest and most fragile gap between the two settlements. o The site forms naturally beautiful and unspoilt countryside and should be protected. o Decisions on whether the site should be developed were based on a flawed Green Belt Review, which misinterprets Green Belt purposes and does not comply with national policy. The site makes no significant contribution to Green Belt purposes, and the impact would depend on the eventual form of development

Settlement pattern o There is a perception of Hatfield as being a ‘dumping ground’ for unwanted growth elsewhere due to vast number of homes built in Hatfield in recent years. Should not expect Hatfield to take a large share of growth again – the distribution of sites is unfair. o Several respondents advocate a more proportional approach to development, with less development around Hatfield, suggesting alternative locations for housing such as around Welwyn Garden City, the site of the former proposed

178

incinerator at New Barnfield and the borough’s villages, citing issues around the need for affordable housing and rail accessibility.

Impact upon wider area o Sites should be chosen so as to ensure Hatfield town centre regeneration. Due to the distance from Hatfield Town Centre, and proximity to St Albans, development will not support this. o Ellenbrook’s tightly-knit community will be disrupted by development on the site. o Development will result in noise and disruption to local residents during construction. o Development will not benefit residents of the Ellenbrook area. o Development will result in Selwyn Drive and Selwyn Avenue becoming ‘rat-runs’. o Pollution from additional traffic will affect the health of children using the play area within Ellenbrook Open Space o Site within the Watling Chase Community Forest area, and would impact upon its openness. o Development will impact upon the setting of listed buildings along Wilkins Green Lane. o Development at Hat5 will not have the same level of impact on listed buildings along Wilkins Green Lane as Hat4 would, but may still have implications for the lane’s character. Agree with the site’s designation as ‘finely balanced’ (Historic England).

Site specific o No recognised ecology sites within the site. Adjacent to Wildlife Site 022 (Copse at Nast Hyde). Not home to protected species. Few ecological opportunities, except a buffer to the wildlife site, low ecological sensitivity. No fundamental ecological constraint o Site allocations should be directed away from areas of high flood risk – or where development is necessary, ensure that flood risk elsewhere is not worsened. If sites in flood zones are considered for allocation, a Strategic Flood Risk Assessment will be required and if sites are allocated, recommendations from the Assessment must be followed o Support intention not to take the site forward. ‘Finely balanced’ category is at odds with the narrative of the consultation document, and 2012 Land for Housing Outside Urban Areas consultation. Site in a fragile, vulnerable Green Belt gap between St Albans and Hatfield, which development would compromise. Access is across land in Flood Zones 2 and 3 will necessitate a Strategic Flood Risk Assessment

179 o No need for additional light industry floorspace as Hatfield Business Park has a significant vacant employment land. Light industry out of keeping with the area. o The majority of respondents considered the site unsuitable and/or should not be considered. o Previous reasons for assessing the site as unsuitable in the Council’s 2012 Strategic Housing Land Availability Assessment still stand. Site too far from Hatfield town centre, the railway station and other facilities; no safe means of access; The site floods, part of narrow, fragile Green Belt gap between St Albans and Hatfield, adjacent or close to six listed buildings, limited sewerage network capacity. Development could alter the semi-rural nature of the Ellenbrook area – mature trees and hedgerows provide a safe habitat for animals, and the area (including the Alban Way) is enjoyed by local people and visitors. Should preserve o Ellenbrook Lane and Wilkins Green Lane are too narrow to be used as access points for the development. Widening would change the lane’s character which would be unacceptable. o Development will increase traffic at Ellenbrook Lane beyond what the lane can cope with. Opening up access to Comet Way at the south end once again would be unacceptable. o Because Alban Way footpath/cycle route runs between Hat4 and Hat5, there could be no safe means of access between them. o The number of homes proposed will leave insufficient space for parking and open space. o Houses built here will do nothing to resolve the need for more affordable housing. o The location of the site will mean that the majority of new homes become buy-to- let or student properties, with resultant issues around refuse collection, noise, littering and poor maintenance. o Residents will experience noise and air pollution due to the site’s proximity to the A1 and A1001. o One of the few areas in Hatfield with a less urban character which should be preserved. o Development will spoil the character of the Alban Way, which is well used by locals and visitors. This will put people off using it for exercise, when people need to be encouraged to exercise. o Development will destroy mature trees and hedgerows around and between the two sites. Overshadowing from development will inhibit the growth of trees and plants on the Alban Way o Development will affect the peace and quiet of the site relative to its surroundings provides an environment where wildlife thrives –and adjacent Wildlife Site WS022 Copse at Nast Hyde. o The site was previously dismissed at a public enquiry. Difficult to see what has changed. o Seek the removal Hat5 from the Green Belt and its designation as an Area of Special Restraint prior to its allocation for development in the future

Flood risk o Concern that site in Flood Zone 3 is being considered for development. Site regularly floods. Development would increase the likelihood of flooding on site and further downstream, particularly in Colney Heath and London Colney.

180 o Existing flood defences in the Ellenbrook area are inadequate and have come close to breaching.

Infrastructure o The Ellenbrook area lacks facilities. To reach facilities residents will need a car worsening existing traffic congestion on St Albans Road in Hatfield and Hatfield Road in St Albans. o Healthcare facilities, schools, transport and utilities in the area overstretched. Lack capacity to support housing growth. o Cumulative impacts, as a result of development on other sites (specifically Hat1 and Hat2 north and west of Hatfield, as well as development within St Albans District) will worsen the above.

Miscellaneous o Do not trust the Council and developers to plan and build responsibly, given the experience of Salisbury Village and Hatfield Garden Village with roads still unadopted years after being built. o Concern that planning decisions are being taken irrespective of the wishes of local people. o Fewer homes need to be built given the University of Hertfordshire is building more student accommodation on its own land, freeing up ‘conventional’ housing occupied by students.

How these views have been taken into account

This site has not been allocated as an outcome of this process (a detailed justification is provided in the Housing Sites Selection Background Paper 2016 and associated committee report and minutes of the CHPP 13 June 2016 meeting)

Green Belt

181

Please also see the Councils response under section CS4 Green Belt Boundaries above.

Settlement pattern/strategy

Please see the Council’s response under section CS3 Settlement Strategy above.

182

Appendix B Less Favourable Sites – Hatfield – Site Hat11, South of Hatfield

Number of responses received 157 (General 5, Support 0, Object should be more favourable 0, Object should not be considered 152)

Support less favourable assessment o If developed dwellings on this site should count towards Welham Green’s housing numbers. Development would close the gap between Hatfield and Welham Green, so the less favourable allocation is supported

Main Issues o No recognised ecology sites in or adjacent to Hat 11. Western hedgerow boundary is ecologically sensitive. Site grassland and mixed hedgerows. Potential for protected species: birds in trees. Opportunity to retain hedgerows and create grassland. Phase 1 habitat required o Low rise residential development unlikely to have an adverse impact on any designated heritage assets (including longer views from Hatfield House and Grade 1 Registered Park and Garden) o Close proximity to existing housing. Site is enclosed, there is an existing tree belt on either side of South Way and with some simple landscaping both sides of the road site would not be visible.

Object should be more favourable o Review new evidence and assess Hat11 as more favourable. Development would not be visible. Ridge line would create a new defensible Green Belt boundary. Will enhance opportunities for recreational access to the Green Belt. Design, mitigation and enhancement measures will protect wildlife sites. No access concerns. Site complies with national policy, will ensure Local Plan is positively prepared and justified. Could deliver B1 and B8 employment uses as an alternative, or as well as residential uses o Fail to see why site is less favourable. Road network and links very strong. Could ease the burden of student accommodation in South Hatfield and encourage families back into the area.

Object should not be considered o Site makes a significant contribution to Green Belt purposes, including preventing coalescence between Hatfield and Welham Green. o Would weaken current defensible Green Belt boundary (South Way). o Provides a wildlife corridor and habitat, including for Great Crested Newts. o Green space and plants provide drainage and mitigation from air pollution. o Serves as a sympathetic background to key heritage asset Hatfield House. o Valued recreation space so contributes to local environmental and social sustainability. o Contrary to ministerial statements and Government policy.

183 o The Council’s duty to cooperate is not a duty to agree with Hertfordshire County Council.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site (Scenario 1) has been allocated as an outcome of this process. A summary of the issues is set out in the Housing Sites Selection Background Paper 2016, where it was recommended that the site not be allocated. However, members of the Cabinet Housing and Planning Panel decided that the site (Scenario 1 Housing) offered the strategic advantage of extra cemetery space and the benefit of contributing toward meeting housing need whilst also allowing enough land for a substantial landscape belt to the south. Further information is provided in the CHPP 13 June meeting minutes.

184

Appendix B Less Favourable Sites – Hatfield – Site Hat12, Nast Hyde Farm

Number of responses received 157 (General 3, Support 0, Object should be more favourable 1, Object should not be considered 1)

Support/should not be considered o Important Green Belt gap between Hatfield and St Albans o Loss of Grade 2 agricultural land o Impact on local Grade II listed buildings o Impact on congestion on the A1057 o Distance from infrastructure, site is likely to be car dependent o Location within Watling Chase Forest.

Main Issues o No recognised ecology sites within the site. Adjacent to wildlife site (69/046) and two Ecosites: Traveller's Lane Grassland and Ponds and New Barnfield Plantation. Site is rough grassland and hedgerows. Potential for grassland management / creation. Protected species unlikely. Low ecological sensitivity and no ecological constraints o The Sustainability Appraisal correctly identifies the potential for significant negative harm to the historic environment, although incorrectly states there are no heritage assets adjacent to site Hat12. Designated heritage assets in the vicinity of this site, include Torilla (a grade II* modern movement house), Great Nast Hyde (grade II 17th century manor house), Nast Hyde farmhouse and barns (grade II) and the granary, barn and farmhouse at Popefield farm (all grade II listed. Recommend the site is not brought forward o Recommend consideration be given to a small conservation area in this locality, to be designated jointly with St Albans City and District Council o Unclear if this is a new site since the last consultation. Support designation as less favourable because it would shorten a vulnerable strategic Green Belt gap between Hatfield and St Albans. do not support the suggestion that were Hat4 to come forward, this site could potentially come forward it combination with it

Object should not be considered o Strongly object to any housing or mixed use proposals due to impact on the Green Belt and Watling Chase Forest. How will the schools cope?

How these views have been taken into account

This site has been assessed as unsuitable for development (HELAA 2016) and has not be considered for allocation in the LPPS 2016.

185

11 Hatfield - Gypsy and Traveller Sites

Number of responses received 3 (General 0, Support 0 Object 3)

Main issues o No Gypsy and Traveller sites have been promoted in Hatfield, Woolmer Green, Welwyn, Digswell, Brookmans Park, Little Heath and Cuffley. o Combining Gypsy and Traveller sites with significant housing growth is flawed. o Why have no sites been allocated for Woolmer Green, Welwyn, Digswell, Brookmans Park etc? o Cannot expect Hat1 and Hat2 to have all the housing and Gypsy and Traveller development. o Co-locating housing and Gypsy and Traveller sites does not work. o If the Council goes beyond what has been promoted, then the approach to providing sites must apply to the whole borough. o Provide Gypsy and Traveller sites where large scale housing growth is not envisaged – look at Finely Balanced and Less Favourable sites not Hat1, Hat2 and WGC4.

How these views have been taken into account

LPPS 2016 Policy SP 22 North West Hatfield (SDS5) proposes Gypsy and Traveller provision sufficient to accommodate a total of 15 pitches (with 4 of these pitches off- site at HS33). 12 pitches are proposed at Welham Green (Policy SADM 32). The development plan should include fair, realistic and inclusive policies which help create sustainable, inclusive, mixed communities in both urban and rural areas. The Plan seeks to ensure that over the plan period a range of housing options to meet the needs and requirements of different households such as families with children, couples, single person households, older people, students, Gypsies and Travellers and Travelling Showpeople will be provided.

186

11 Hatfield – Table 7 – Sources of housing supply for Hatfield

Number of responses received 5 (General 5, Support 0, Object 0)

Main Issues

The following comments were received on sites listed in Table 7 which were not subject to consultation because the principle of development has already been established (through a planning permission or Supplementary Planning Document) o Development on site HC100b (Hatfield Town Centre Redevelopment Area) likely to have a significant positive effect on public health within one of the most deprived areas of the borough. Residents will be able to walk to shops and services Hertfordshire County Council o Based on the information available do not envisage any issues with wastewater capacity at sites HC100b (Hatfield Town Centre Redevelopment Area), HE09 (Car park north of Salisbury Square), HS32 (City Church, The Wades), and HW100 (Highview SPD Site)

How these views have been taken into account

HC100b, HE09, HS12, HS32 and HW12 either have permission, are under construction, have been completed or have been withdrawn by the land owner. Pan02 is too small for an allocation and has been counted towards the windfall projection.

The other sites within Table 7 of the LPCD 2015 were subject to further site assessment work. Please see the responses within the site-specific sections of this statement.

187

12 Woolmer Green

Number of responses received 17 (General 3, Support: 0, Object 14)

Main Issues o Redevelop the two remaining employment areas. Marshalls is an eyesore. If this land became available it would ideal for a village centre and low-density housing. As long as the landscape frontage remains, would support housing or a mix of housing and employment on the Entec site. o Good design is very important to enhance village character. o Require village shop in high street location, not on WGr1. Two public houses should be protected. o Village hall and grounds, the playground and village pond must all be protected.

Protect the Green Belt o Development would lead to coalescence between Oaklands and Mardley Heath, Woolmer Green and Knebworth. o Green Belt already under threat due to proposed solar farm

Settlement Pattern o Basis for deriving the numbers is unclear. Lack of details on the demographics of the community. o A more co-ordinated approach between local Councils would produce a more balanced plan.

Infrastructure Issues o Excessive scale of development proposed: school full, Knebworth surgery under strain, road congestion, development out of character unless sensitively designed; surface water drainage problems on WGr1; village lacks basic amenities. o Local infrastructure may be unable to cope: Knebworth and Welwyn GP surgeries, primary and secondary schools, train services at capacity; no local shops. Development will be car dependent adding to congestion; safety issues from lorries visiting employment areas; parking inadequate. o Need assessment and consultation to identify new school places to support the new housing. o Not against new housing at Woolmer Green. Concern that consequences not fully considered: infrastructure and services at capacity, won’t support future growth. Knebworth Village has no functioning village centre and is increasingly car dependent. o Local country lanes increasingly dangerous for pedestrians and cyclists. o Improvements are needed to Knebworth High Street to make the traffic two-way. o New houses are needed. Every town and village should take a share. Can’t support without guarantee that local infrastructure will be enhanced. o Sewage system must be upgraded before any new houses are built. o A new convenience shop is needed.

188 o Broadband capacity in the village is inadequate. o Should reject housing demands until plans for public transport, road infrastructure, and local broadband provision and Green Belt protection have been produced.

Impact on development on the wider area o WGr1 appears to be the only site adjacent to an industrial area. Residential and industrial uses are incompatible. As a growing business, concerned with conflicts that a new housing site would bring with business uses, such as activity during unsociable hours and lorry deliveries.

Sustainability o Develop on brownfield land not greenfield sites. o Do not believe that new housing in Woolmer Green will be affordable for future generations.

How these views have been taken into account

Following the completion of site assessment work and consideration of the benefits and adverse impacts, the LPPS 2016 sets out the following local planning objectives for Woolmer Green which the Council will take into account when considering development proposals in Woolmer Green, alongside borough-wide objectives:

 Ensure sufficient infrastructure capacity, including primary school provision and wastewater capacity, in parallel with the development process to support sustainable growth.  Protect playgrounds, the community and village halls, allotments, ponds, playing fields and woodlands.  Maintain the provision of employment land to protect and enhance the vitality and viability of Woolmer Green as a working village.  Maintain housing choice.  Maintain and, where possible, enhance the character of Woolmer Green ensuring all development is well-designed and sympathetic to its local setting.  Support the provision of a community orchard.

Woolmer Green is a small excluded village. Consistent with the proposed settlement strategy and hierarchy (LPPS 2016 Policy SP3), provision is made for a limited amount of development compatible with the settlement's place within the hierarchy. The LPPS 2016 makes provision for 150 dwellings at Woolmer Green over the plan period which is considered compatible with the village’s character and scale, as well as infrastructure constraints relating to primary school infrastructure. Green Belt purposes assessments have been undertaken and have informed the overall consideration of site allocations in Woolmer Green and the wider borough. Exceptional circumstances are considered to exist to justify the release of certain sites from the Green Belt around Woolmer Green. Further explanation is set out in responses relating to CS2 Meeting the Needs for Growth, CS3 Settlement Strategy and CS4 Green Belt Boundaries and Safeguarded Land of this statement

189

Infrastructure issues, including Green Infrastructure, have been considered as part of the Infrastructure Delivery Plan (IDP) which has informed the preparation of the LPPS and site allocations. Please see Council’s Consultation Statement on the Draft IDP 2015 Consultation for further information.

The Council has worked closely with neighbouring local planning authorities and other relevant bodies to ensure that the Local Plan addresses cross boundary issues adequately and that the necessary infrastructure can be provided. Effective and ongoing co-operation has taken place with relevant bodies and neighbouring local planning authorities on the production of this plan. This includes the commissioning and sharing of evidence and identifying infrastructure requirements.

190

12 Woolmer Green – Housing

Number of responses received 3 (General 0, Support 0, Object 3)

Main Issues

Green Belt o Develop brownfield land and protect Green Belt land.

Settlement pattern o Lacks detailed, meaningful assessment of housing and employment needs in Woolmer Green. o Prevent further housing in Woolmer Green. o Identify two areas for redevelopment within the village boundary - Woolmer Green village hall playing field and the village pond.

Infrastructure o Local schools are full and there is no expansion potential at the primary school. o Sewage and water drainage is overstretched. o London Road is congested. Knebworth Station parking an issue. Village bus service under threat.

Sustainable development o Woolmer Green has lost most of its employment land and convenience shops in the last 25 years. Further housing development here is unsustainable. o Planning should promote sustainable patterns of development, addressing opportunities for sustainable transport and school planning.

Duty to Co-operate o Would like evidence of cooperative working across boundaries.

How these views have been taken into account

See section immediately above.

191

12 Woolmer Green Site WGr1, East of Great North Road

Number of responses received 48 (General 6, Support 3, Object 39)

Support o Will help solve local problems by creating a garden village, providing a farm shop and business units and delivering public space.  Traffic and transport appraisal show site capable of handling its own traffic.  Have designed an access structure that would calm the B197.  Flood risk study shows no flood risk, surface water issues can be managed  Historic Assessment identifies no substantive archaeological factors.  Site has very limited ecological value.  Landscaping provided north of the site will provide enclosure and stop coalescence.  No utilities constraints anticipated. o Will provide more facilities and will not disrupt the settlement pattern too badly. o Suitable site to meet requirements for Woolmer Green.

Main Issues

Green Belt o Loss of Green Belt land, reducing openness, damaging the rural character and increasing potential for coalescence with Knebworth. Building should never be allowed on Green Belt o Build on brownfield sites, rather than Green Belt. o Find sites elsewhere in Hertfordshire, protect Green Belt boundaries. o Already a solar farm potentially coming forward on Green Belt land near Woolmer Green. o Site within fragile Green Belt gap between Knebworth and Datchworth

Settlement pattern o No further housing in Woolmer Green. With developments in the 1990s, has Woolmer Green not fulfilled its quota? o Deliver housing in a new town with supporting facilities and infrastructure. o Reject site WGr1 for housing and consider other sites.

Infrastructure o Wastewater network capacity in this area unlikely to support the demand from this development. Upgrades to existing capacity are likely to be required o Due to the relatively small size of the proposed development limited impact on A1(M) junctions. A cumulative impact may occur if considered with other sites o The scale of development at WGr1 will be significant. Increased commuting will put pressure on the B197 and Clock Roundabout. Mitigation will be needed to ensure safe vehicular access. Sustainable transport options should be implemented

192 o Infrastructure issues will be exacerbated by the growth at Knebworth and Welwyn. o Adverse impact of 300 more vehicles on the congested B197. Traffic turning right at Woolmer Green will create a bottleneck. Knebworth surgery and local schools are at capacity. New school site suggested at Knebworth is not ideal o Impact on local services: primary and secondary school provision, GP surgeries, policing, train services and Lister hospital. New shops or amenities should be provided in the village centre. o Sewerage, drainage, communications and water infrastructure is already overstretched. o Impact on the road network - will increase congestion on the B197, make it more dangerous and difficult to access. Inadequate parking in Knebworth. Congestion at ‘the Clock’ roundabout. o Exacerbate difficulties on New Road caused by change of use at Pipers Farm in East Herts. o Allow development only if sufficient new infrastructure and facilities are delivered.

Impact upon the wider area o Woolmer Green has limited facilities and employment. Scale of development out of keeping with the scale and character of Woolmer Green, contrary to the Local Plan strategy objectives. o Will turn our small village into a housing estate destroying it for future generations. o The mix of industrial and residential land needs to be carefully considered to mitigate conflicts. o Adjacent to Grade II listed Payne’s Farmhouse. Should be possible to develop site without causing unacceptable harm to the significance of the farmhouse. No other impact on designated heritage assets

Site Specific Issues o Loss of view and concern about overlooking; o Damage to wildlife habitats (badgers, foxes, barn owls), loss of good agricultural land and concern about flooding. o Scale of development excessive. Proximity to industrial land and a care home. Noise from Cawdor Stone. Visual impact of development would need mitigation. Drainage issues. Remaining part of field between Knebworth and Woolmer Green could be vulnerable to encroachment. Would welcome landscaped area to create a natural boundary. If solar farm is permitted the openness of Green Belt around the village will be compromised (Woolmer Green Parish Council). o Arable site. No recognised ecology sites within or adjacent to WGr1. Protected species unlikely. No ecological sensitivity or ecological constraint on record

Sustainable development issues o Unsustainable due to limited amenities and cuts to village bus service - will increase car use. o Too close to industrial land, residential and industrial uses are incompatible. o 150 dwellings is unsustainable

193

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

Policy SADM 27 and Table 11 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development and Policy SP 14 sets out the approach for the delivery of a new secondary school to serve growth in the borough and particularly Hatfield, Welwyn Garden City and the northern villages

194

Appendix B Less Favourable Sites – Woolmer Green – Site WGr3, Land adjacent to 52 London Road

Number of responses received 48 (General 2, Support 3, Object should be more favourable 1, Object should not be considered 2)

Support o Would lead to coalescence and should be discounted o Support decision not to develop WGr3 to protect the gap between Woolmer Green and Knebworth, prevent coalescence and ensure they remain separate communities. o Outside settlement boundary would cause coalescence.

Main Issues o No ecology sites within site, ecological sensitivity low. Potential for reptiles and birds. Phase 1 habitat survey required. Opportunity to retain and plant more trees o Unlikely to have an adverse impact on any designated heritage assets o WGr3 should be allocated as a housing site

Object should be more favourable o Agent on behalf of landowner of WGr3: site should be developed for a number of reasons: . Whether the site acts as an extension to Knebworth is immaterial in terms of the need to meet OAN. . Site’s removal from the Green Belt would not affect the character of the village or landscape given the site is surrounded on three sides by built development. . Development would not conflict with national Green Belt purposes: it is a gap between two villages not towns. . Closer to local amenities and services in Knebworth than WGr1. . Could deliver affordable housing, self-build housing and a community facility. . Could help address shortfall of provision at Oaklands and Mardley Heath

Object should not be considered o Site outside settlement area. Would join Woolmer Green to Knebworth o Oppose any development, would cause coalescence with Knebworth.

Settlement pattern o Unsure if this should be reclassified to prevent this being pursued further. o Object to further housing in Woolmer Green.

How these views have been taken into account

195

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has not been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

196

Appendix B Less Favourable Sites – Woolmer Green – Site WGr4, Land in front of 17 Twin Foxes

Number of responses received 48 (General 2, Support 1, Object should be more favourable 0, Object should not be considered 5)

Support o Open land/green space prevents coalescence with Oaklands and Mardley Heath. o Object to further housing in Woolmer Green.

Main Issues o No ecology sites within the site and no ecological constraint. Low ecological sensitivity but possibly protected species (birds) and opportunity to retain trees o Unlikely to have an adverse impact on any designated heritage assets

Object should not be considered o This land prevents coalescence and creates an attractive feature and rural character at entrance to village. It should be protected o Development would lead to coalescence with Oaklands and Mardley Heath

Site specific o Site should not list as a less favourable site, should be completely discounted and removed from document. o Would result in over development of Twin Foxes and have a detrimental visual impact. o Covenant on land preventing development. Land donated to Welwyn Hatfield Borough Council by developers to prevent coalescence with Oaklands and Mardley Heath. Already an electricity sub-station on site and insufficient area to build on. o Important community play space for children.

How these views have been taken into account

This site has been assessed as undeliverable (HELAA 2016) and has not be considered for allocation in the LPPS 2016.

197

Appendix B Less Favourable Sites – Woolmer Green – Site WGr5, Land in front of 9 Twin Foxes

Number of responses received 48 (General 1, Support 1, Object should be more favourable 0, Object should not be considered 5)

Support o Open land/green space prevents coalescence with Oaklands and Mardley Heath. o Object to further housing in Woolmer Green. o Do not include WGr5 in the document, even in the appendix.

Main Issues o No ecology sites within the site and no ecological constraint. Site has low ecological sensitivity but there are possibly protected species (birds) and opportunity to retain trees o Unlikely to have an adverse impact on any designated heritage assets

Object should not be considered o Protect this land as it prevents coalescence and creates an attractive feature and rural character at entrance to village Woolmer Green Parish Council o Welwyn Parish Council and Welwyn Parish Plan Group o Oppose development as would lead to coalescence with Oaklands and Mardley Heath.

Site specific o The site should be completely discounted and removed from the document rather than listed as less favourable. o Would result in over development of Twin Foxes and have a detrimental visual impact. o Covenant on land preventing development. Land donated to Welwyn Hatfield Borough Council by developers to prevent coalescence with Oaklands and Mardley Heath. o Already an electricity sub-station on site and insufficient area to build on. o Important community play space for children.

How these views have been taken into account

This site has been assessed as undeliverable (HELAA 2016) and has not be considered for allocation in the LPPS 2016.

198

12 Woolmer Green – Employment

Number of responses received 6 (General 1, Support 1, Object 4).

Main Issues o Woolmer Green needs a shop. If land at Marshall’s is made available, should redevelop to build a small parade of shops. o Large commercial business not suitable in a small village, unless attractively screened. o Site has potential as a mixed residential and commercial site. As a brownfield site in the village it is preferable to Green Belt development. Other sites in the village could continue to provide employment

Green Belt o The plan only identifies existing employment areas. Should designate a new employment site on the green field between Entec House and Monread Lodge. This would not cause coalescence between Knebworth and Woolmer Green. o Prefer to see this employment land developed for housing and the Green Belt preserved. o Entec house could provide over 60% of the village’s potential housing target. It is vital the Green Belt is protected. o Support the intention to allocate this area as employment land. Identified in the adopted Waste Local Plan as an Employment Land Area of Search Hertfordshire County Council

How these views have been taken into account

The LPPS 2016 designates two new employment areas in the Borough for B class employment uses. One of these is at Woolmer Green. LPPS 2016 Policy SADM 10 Employment development designates land at London Road for B1, B2 and B8 uses (EA10).

Entec House (site WE90) is partially or wholly located within a designated or proposed Employment Area and is therefore considered unsuitable for housing (HELAA 2016).

199

13 Oaklands & Mardley Heath - Housing and Table 10 - Summary Table – Oaklands & Mardley Heath Capacity

Number of responses received 8 (General 2, Support 3, Object 3).

Support o OMH5 will make a positive contribution to housing need. Court Homes have confirmed they support the development and access can be taken across a strip of verge along The Avenue, in their ownership o Support land allocation and are a willing party to the development o Support the proportionate requirement for 320 new dwellings in Oaklands and Mardley Heath.

Main Issues o Direct, cumulative impact of more favourable sites unlikely to be significant. Likely to require contributions towards improved sustainable transport to mitigate potential impact on the Clock roundabout. Highway and sustainable works will be established as part of the transportation studies of the potential impact of development o 340 dwellings in a location with limited facilities. Could be a material impact on A1(M) Junction 6 o Not possible to satisfy the OAN of 340 units. Settlement constrained by borders with North Herts and Woolmer Green o If housing is to be distributed proportionately, a shortfall of 247 dwellings is unsatisfactory.

Green Belt o Development would lead to coalescence between Knebworth, Woolmer Green and Oaklands and Mardley Heath.

Infrastructure issues o Inadequate school and health provision. Road network in Knebworth cannot accommodate additional traffic, shortage of parking in Knebworth.

How these views have been taken into account

Following the completion of site assessment work and consideration of the benefits and adverse impacts, the LPPS 2016 sets out the following local planning objectives for Oaklands and Mardley Heath which the Council will take into account when considering development proposals in the village, alongside borough-wide objectives:

 Protect and maintain the character of Oaklands & Mardley Heath.

200

 Identify and secure solutions to deliver necessary infrastructure improvements, in parallel with the development process to support sustainable growth.  Protect facilities and services which provide an important community function and support the adaptation of existing facilities where community benefits can be enhanced.  Widen housing choice, delivering a range of housing types, sizes and tenures to help meet housing needs and demand.  Work with the Parish Council to help implement priorities identified in any  Neighbourhood Plan.

Oaklands and Mardley Heath is a small excluded village. Consistent with the proposed settlement strategy and hierarchy (LPPS 2016 Policy SP3), provision is made for a limited amount of development compatible with the settlement's place within the hierarchy. The LPPS 2016 makes provision for 31 dwellings (including 6 Gypsy and Traveller pitches) at Oaklands and Mardley Heath over the plan period which is considered compatible with the village’s character and scale, as well as infrastructure constraints. Green Belt purposes assessments have been undertaken and have informed the overall consideration of site allocations in Oaklands and Mardley Heath and the wider borough. Exceptional circumstances are considered to exist to justify the release of certain sites from the Green Belt around Oaklands and Mardley Heath. Further explanation is set out in responses relating to CS2 Meeting the Needs for Growth, CS3 Settlement Strategy and CS4 Green Belt Boundaries and Safeguarded Land of this statement

201

13 Oaklands & Mardley Heath– Site WE01, 52 Great North Road

Number of responses received 4 (General 3, Support 0, Object 1).

Main Issues o On the information available, no wastewater capacity issues are expected Development will not adversely affect any heritage assets o Site has minimal fundamental ecological constraints –buildings to be demolished may need assessing for bats. Trees on site may be home to protected bird species. Low ecological opportunities and sensitivity. No recognised ecology sites within site or nearby o Canonsfield Road forms a cohesive residential area - denser development would be detrimental to its look and feel. o Object to the development of large detached dwellings as they are an inefficient use of land and do not resolve local housing pressures. o Object due to increased pressure on roads, schools and parking.

How these views have been taken into account

The HELAA (June 2016) assesses the site capacity as 3 dwellings gross (2 net), which is below the size threshold for allocating in the Plan.

202

13 Oaklands & Mardley Heath – Site WN11, 17 Canonsfield Road

Number of responses received 4 (General 3, Support 0, Object 1).

Main Issues o On the information available, no wastewater capacity issues are expected o Development will not adversely affect any heritage assets o Site has minimal fundamental ecological constraints –buildings to be demolished may need assessing for bats. Trees on site may be home to protected bird species. Low ecological opportunities and sensitivity. No recognised ecology sites within site or nearby o Canonsfield Road forms a cohesive residential area - denser development would be detrimental to its look and feel. o Object due to increased pressure on roads, schools and parking.

How these views have been taken into account

The HELAA (June 2016) assesses the site capacity as 2 dwellings gross (1 net), which is below the size threshold for allocating in the Plan.

203

13 Oaklands and Mardley Heath – Site OMH5, Land rear of 1-12 Great North Rd and Site OMH8, Great North Rd

Number of responses received 10 (General 2, Support 4, Object 4).

Support o Development would not adversely impact on any designated heritage asset o Strongly support removal of this land from the Green Belt, as it serves no purpose. A1(M) would provide a strong new Green Belt boundary o Agree with assessment of OMH5 and OMH8

Main Issues o Targets exclude ‘Wiltshire Park’ properties, appears odd, as they will become part of Welwyn. o Object to term ‘settlement’ instead of ‘village’. Confirm the status of Oaklands and Mardley Heath as a village.

Green Belt o Object to loss of Green Belt land.

Site specific issues o No ecology sites within or adjacent to the site. Danesbury Park Local Nature Reserve 60m to the west, separated by the A1(M). May be potential for protected bird species and roosting bats in trees. Retain native trees or compensate for loss. High potential for woody habitat creation / management. Requires Phase 1 habitat survey, assessment of trees and bats o Loss of woodland on the site and natural habitat. Trees screen noise and pollution of the A1(M). Experts should inspect trees to ensure all trees of significant environmental value are protected o Development will overlook properties 3, 4, 5, 6 and 9 The Avenue. Design development with adequate parking and ensure existing properties are not overlooked. o Limit the number of dwellings. o Access should be via B197, not the Avenue.

Impact upon wider area o Concerned that Council may seek higher densities, which will impact on design and parking.

Infrastructure issues o Short sighted not to set out the additional infrastructure required to support development.

204 o Concerned about additional traffic on The Avenue, a minor, private road. Access to Great North Road already difficult. No alternatives as The Avenue is a single- track road leading to a rural lane. o Clarify the status of Wiltshire Park and its need for additional infrastructure and services. o Envisage no concerns regarding wastewater network capability. Essential that developers demonstrate adequate capacity on and off the site to serve the proposed development and that it would not lead to additional capacity constraints for new and/or existing user o Concern about additional traffic on The Avenue. Access to Great North Road is already difficult. Additional vehicles would overload the junction

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

These two sites have been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

Policy SADM 28 and Table 12 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development and Policy SP 14 sets out the approach for the delivery of a new secondary school to serve growth in the borough and particularly Hatfield, Welwyn Garden City and the northern villages

205

Appendix B Less Favourable Sites – Oaklands and Mardley Heath – Site OMH7, Land at 22 The Avenue

Number of responses received 3 (General 2, Support 0, Object 1).

Main issues o Development would not adversely impact on any designated heritage asset o No ecology sites within/adjacent to site. May be potential for protected bird species in trees, otherwise unlikely. Opportunities for woodland / planting. Low ecological sensitivity and constraint

Object should be more favourable o Small alteration will provide a definitive Green Belt boundary and incorporate OMH7 into the more favourable category. Supported by locals o Change OMH7 to a more favourable site and provide a further 12 units

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has not been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

206

13 Oaklands and Mardley Heath – Gypsy and Traveller Sites and GTLAA04, Four Oaks

Number of responses received 13 (General 1, Support 2, Object 10).

Support o Development would not adversely impact on any designated heritage assets o There is a great need for more traveller sites and GTLAA04 is a good use of land.

Main Issues o No recognised ecology sites within site; adjacent to Local Wildlife Site Old North Road & Central Reservation, Lockleys. Protected species unlikely, ecology sensitivity low. Limited opportunity to provide buffer with adjacent Wildlife Site. No apparent fundamental ecological constraint o The Housing Act requires housing authorities to assess Gypsies and Travellers’ accommodation needs. o Expansion does not accord with the Emerging Core Strategy and the core principles in the vision. Site has expanded over the last 2 years with mobile homes, heavy trucks, plant and machinery present. Further expansion would ghettoise the site. o Proposal for site expansion should be withdrawn. Site already overcrowded. Further expansion would create undue concentration out of balance with the area o Site is already at full capacity – do not support exceeding the existing 5 pitch limit / Do not support increase from 5 to 11 pitches. o Restrict number of pitches to 6 (as permitted). o Site detracts from the visual amenities of the residential area. Tops of lorries/trucks are visible. o Commercial operations present on site with vehicles loaded with rubbish, builders, construction vehicles, plant and machinery. Should curtail commercial operations. o Growth of Gypsy and Traveller pitches is disproportionate for such a small ethnic group. o Government policy seeks to protect the Green Belt and is clear that temporary and permanent sites are inappropriate development in the Green Belt. o Site does not integrate with the rest of Oaklands and Mardley Heath. o Local Plan has not made a case to substantiate proposed allocation of land for Gypsies and Travellers, how land would be for those pursuing a nomadic lifestyle or how it will promote the integration of the Gypsy community into the larger community and neighbourhood. o Site in breach of current permission (maximum number of caravans and limit on occupation). o Proposal contradicts policy for the site. Conditions state the site must be occupied by named residents and their dependants only and the use shall cease when those named are no longer occupying the site o Proposed increased in pitch and caravan numbers would exceed that already permitted. o Proposals for Gypsy and Traveller sites elsewhere in the borough do not state number of pitches

207 o Reduce overall provision of pitches for the borough.

How these views have been taken into account

208

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

Policy SADM 28 and Table 12 of the LPPS 2016 set out specific provisions and requirements for this site. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development and Policy SP 14 sets out the approach for the delivery of a new secondary school to serve growth in the borough and particularly Hatfield, Welwyn Garden City and the northern villages

209

13 Oaklands & Mardley Heath – Village Centre

Number of responses received 4 (General 3, Support 1, Object 10).

Support o Support the exclusion of a small wooded area from the proposed village centre boundary for Oaklands & Mardley Heath

Main Issues o If the small wooded area excluded from the village centre boundary remains as such should designate as urban open land and use to provide a playground, given the village lacks such facilities o The small excluded wooded area should not be developed.

How these views have been taken into account

The land in question is now included with the village centre boundary (the two parcels have now been joined). The land was included because it is part of the North Star Public House grounds. On that basis, the land was not designated as Urban Open Land.

210

13 Oaklands & Mardley Heath – Urban Open Land

Number of responses received 2 (General 1, Support 1, Object 0).

Support

No comments made

Main Issues o The small wooded area between The North Star PH and the retail units excluded from the village centre designation has recently been cleared of trees. Request that it is included in the Village Centre or designated as Urban Open Land. This area could be used for recreational purposes, such as a playground, a facility that is lacking in the settlement (Welwyn Parish Council).

How these views have been taken into account

211

Section 14 Welwyn

Number of responses received 4 (General 2, Support 0, Object 2).

Main Issues o More favourable sites are in close proximity to the A1(M) Junction 6. Individual sites unlikely to have a significant impact on the operation of the Strategic Road Network, however could be a cumulative impact. For finely balanced sites, proximity to Junction 6, lack of alternative access to the SRN and lack of significant public transport opportunities could result in an increase in trips using the junction o More favourable sites may increase pressure on the A1(M) junction 6, including the Clock roundabout. Further modelling is required to provide a greater understanding of flows and conflicts of movement that affect the performance of the junctions. Improved highway access and measures to encourage the use of sustainable transport will be required o Community Involvement in Planning decisions is still not being applied correctly and has ignored the wishes of the community, resulting in the Clock House Gardens which resembles a cliff face of flats at the entry to our heritage village. Residents of the village were not allowed to speak their objections and the Clock House Gardens plan was voted through by District Council members who had no knowledge of Welwyn. o It is essential to retain the village character of Welwyn

How these views have been taken into account

Following the completion of site assessment work and consideration of the benefits and adverse impacts, the LPPS 2016 sets out the following local planning objectives for Welwyn which the Council will take into account when considering development proposals in Welwyn, alongside borough-wide objectives:

 Conserve and enhance the historic environment, ensuring that development is well designed, affording appropriate weight to the importance of designated heritage assets.  Ensure sufficient infrastructure capacity, including primary school provision, in parallel with the development process to support sustainable growth.  Ensure that development does not have a significant adverse effect on the operation of Junction 6 of the A1(M).  Work with the Parish Council to help take forward priorities identified in Neighbourhood Plans.  Deliver a range of housing types, sizes and tenures to help meet housing needs and demand.  Maintain the vitality and viability of the village centre.  Retain off-street parking facilities in the village centre and support the provision of bus services and cycleways between villages to maintain and enhance accessibility to the village.

212

Welwyn is a large excluded village and is considered to be a sustainable location for growth due to its range of facilities and services available. This has been reflected in Policy SP 3 of the LPPS 2016 which regards Welwyn as being suitable for limited growth that is compatible the scale and character of the village. The LPPS 2016 makes provision for 353 dwellings at Welwyn over the plan period, the bulk of which has already been completed or is permitted, which is considered compatible with the village’s character and scale, as well as infrastructure constraints relating to primary school infrastructure. Green Belt purposes assessments have been undertaken and have informed the overall consideration of site allocations in Welwyn and the wider borough. Exceptional circumstances are considered to exist to justify the release of certain sites from the Green Belt around Welwyn. Further explanation is set out in responses relating to CS2 Meeting the Needs for Growth, CS3 Settlement Strategy and CS4 Green Belt Boundaries and Safeguarded Land of this statement

Infrastructure issues, including matters relating to the A1(M), have been considered as part of the Infrastructure Delivery Plan (IDP) which has informed the preparation of the LPPS and site allocations. Please see Council’s Consultation Statement on the Draft IDP 2015 Consultation for further information.

The LPPS 2016 includes policies on movement and quality of development which mean that any adverse impacts of development in Welwyn will be avoided or mitigated to an acceptable level, and development would need to respond to and complement the character and context of its surroundings.

213

14 Welwyn – Table 12 - Summary Table – Welwyn Capacity

Number of responses received 5 (General 1, Support 0, Object 4).

Main Issues o New homes at the Frythe have not been included in the total homes under construction in the village, given the reliance the site will have on Welwyn, and also considered that those at the Clock roundabout had not either. The ‘to find’ figure for Welwyn was therefore much higher than it should be.

How these views have been taken into account

The new dwellings provided at the Frythe during and since 2013 have now been added to the sources of supply for Welwyn in ‘Table 3 Distribution of housing growth’ in the LPPS 2016.

The provision of dwellings at The Clock development were included in Table 12 and Table 13 of the LPCD 2015 and were counted towards the sources of supply at that time.

214

14 Welwyn – Site Wel3, School Lane

Number of responses received 8 (General 3, Support 2, Object 3).

Support o Site surplus to requirements (apart from retention of pumping station at the centre of the site) Potential to redevelop for housing, deliverable and developable within next 5 years. Support release of the site from the Green Belt o The site should accommodate 100 houses as they have close access to A1 and would encourage growth of services within the area.

Main Issues o Do not envisage wastewater network infrastructure concerns in relation to this site o Development/redevelopment of this site for residential use would not adversely impact on any designated heritage assets o No recognised ecology sites within, adjacent or close to the site. There may be protected birds species. Phase 1 habitat survey would be needed. Low ecological sensitivity. Few opportunities for improvement. Should compensate for loss of any trees o Encroaches on Green Belt land along a designated ‘quiet lane’ o No logic to the proposed Green Belt boundary o Amend Green Belt boundary to facilitate the site’s redevelopment for housing o The site should accommodate 100 houses, not 10.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

Policy SADM 29 and Table 13 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. In addition, Policy SP

215

13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development and Policy SP 14 sets out the approach for the delivery of a new secondary school to serve growth in the borough and particularly Hatfield, Welwyn Garden City and the northern villages

216

14 Welwyn – Site Wel4, Sandyhurst

Number of responses received 8 (General 3, Support 4, Object 1).

Support o Site already spoilt by roads on either side. o Site is reasonable, subject to substantial contributions to extend the cycle route between Welwyn and Welwyn Garden City (schools and town centre) to address traffic congestion, and impact on local services.

Main Issues o Do not envisage wastewater infrastructure concerns for this site o Development/redevelopment of this site for residential use would not adversely impact on any designated heritage assets o Sandybottom Wood Local Wildlife Site 60m to the east, separated by A1M. Large Ecosite 50m to the south-west (The Frythe, Horseshoes Plantation Cook’s Wood). May be protected birds species and reptiles. Need Phase 1 habitat survey and potentially a reptile survey. Locally moderate ecological sensitivity. Opportunities to retain trees or compensate for their loss o It would change the design of the area. o Loss of countryside endangering wildlife. o Increased road congestion.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

Policy SADM 29 and Table 13 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development and Policy SP 14 sets out the approach for the

217 delivery of a new secondary school to serve growth in the borough and particularly Hatfield, Welwyn Garden City and the northern villages

218

14 Welwyn – Site Wel11, The Vineyards, Codicote Road

Number of responses received 5 (General 6, Support 1, Object 19).

Support o The site should be developed for 300 houses rather than 30 as it has close access to the A1 and would encourage growth of shops and services in the area.

Main Issues o Do not envisage wastewater infrastructure concerns o Development/redevelopment of this site for residential use would not adversely impact on any designated heritage assets o Adjacent to Danesbury Park Local Nature Reserve and Local Wildlife Site (43/016) - should buffer. Potential for protected birds species and reptiles. Phase 1 habitat survey would be needed and potentially a reptile survey. Moderate ecological sensitivity due to possible loss of trees; opportunities to retain trees or compensate for their loss, and create/manage grassland habitat o Represents an increase in ribbon development along Codicote Road, with Royton Express site. o Access from Codicote Road unacceptable for safety reasons. Potential access issues from the Danesbury estate. Housing density an issue. With successful resolution of these issues, we do not oppose this proposal o Do not object to this site per se but concern that access/egress to the B656 Codicote Road, would be dangerous and would add to appearance of ribbon development

Green Belt o Object to building on Green Belt land o Site performs a local purpose and development would risk coalescence with Codicote. o Proposed boundary is illogical. Village needs a strong boundary. Development would increase pressure to develop land between this site and Blake’s Way to square off a new boundary.

Site specific o Access to Codicote Road would be dangerous due to speed and volume of vehicles. o Access via Carlton Rise would impact on the amenity and safety of Carlton Rise residents and increase pressure on the two existing junctions exiting Danesbury Estate, already dangerous for drivers and pedestrians due to limited visibility and speed/volume of traffic using Link Road. o Vehicle traffic arising from this site and cumulatively with other sites in Welwyn, Codicote and Oaklands & Mardley Heath would exacerbate existing traffic and congestion problems within Welwyn, the Clock Roundabout and Junction 6 of the A1M.

219

Infrastructure o School and GP surgeries are already full and under immense pressure. o Access via mini roundabout on Codicote Road with speed controls, rather than Carlton Rise. o Access via Carlton Rise rather than Codicote Road. o Part time traffic signals on Clock Roundabout at rush hour.

Impact on the wide area o Proposed high density would harm the character of the area and be out of keeping with the low density Danesbury Estate. Reduce the density and ensure it is in keeping with Danesbury Estate and the transition from urban to rural surroundings (e.g. ten or fewer detached houses). o The rising site would lead to overlooking of residents of the Vineyards. o Adverse landscape and visual impact viewed from Kimpton Road/Oakhill Drive. o The site serves as a green lung to Danesbury Park Local Nature Reserve which provide health and well-being benefits for residents of Welwyn. o 300 houses not 30. o Change the rating to Finely Balanced. o Ensure there is adequate parking, 3 spaces per unit (not including garage space).

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

220

Appendix A Finely Balanced Sites – Welwyn – Site Wel1, Land at Kimpton Road

Number of responses received 11 (General 2, Support 3, Object should be more favourable 2, Object should be less favourable 0, Object should not be considered 4).

Support o Development would severely compromise the Green Belt landscape and gap between Welwyn and Codicote. o Singlers Bridge would need to be widened which would encroach on the Local Nature Reserve and a rare chalk river, designated a BAP.

Main Issues o Account should be taken of potential adverse impact on views out from the nearby Welwyn Conservation Area o Buffer adjacent Ecosite (Cemetery 43/053). Low ecological sensitivity, with opportunities for habitat creation given the size of the site o Create new settlements and garden villages rather than expand already overstretched villages. o Should preserve the gap between Welwyn and Codicote permanently, for example by expanding the cemetery.

Object should be More Favourable o Should release Wel2 from the Green Belt. The Council’s Green Belt and landscape assessments are incorrect: the gap between Welwyn and Codicote is substantial , not fragile, with no risk of coalescence; would be infill not ribbon development; impact from encroachment of the countryside westward would be no greater than existing housing estates to the north and south. Site scored the same (red) for Green Belt purposes as Wel11, a preferred site o Site capacity for 238 dwellings can help meet the Council’s objectively assessed housing need, including part of the shortfall within Oaklands and Mardley Heath and rectify the distribution of housing to conform to policies. A sustainable village location, development would support the viability of existing services . The site can be delivered between 18 months and 3.5 years from adoption of the local plan. . Development would not affect the character of Welwyn or landscape character. Site visible from Kimpton Road which is little used, with limited views from Codicote Road and close neighbours and it is proposed to heavily landscape the periphery. . Herts Highways has No objection in principle to new access scheme improving highway safety and existing junctions. Development proposal would retain and preserve Singlers Bridge as a footpath/cycleway and make the Singlers Marsh area more accessible.

221

. Planning obligations will be made for off-site highway improvements, including the A1M Clock Roundabout. Improvements to Welwyn’s bus services would be made. . Along with Wel2, site can financially contribute to the expansion of St Mary’s School by 1FE . Bridge Cottage Surgery already has a good ratio of doctors to patients, but a S106 contribution would be made. Further contributions could be made to secondary health care. . Development can assist in Green Infrastructure by improving Mimram Valley greenspace. . Would provide church car park extension. o Site should come forward with Wel2 and Wel6 to assist the Council in meeting its objectively assessed housing need

Object should not be considered o Contribute to ribbon development with Codicote, visually open and good quality agricultural land; Access problematic o Difficult access through narrow, congested roads: Kimpton Road, a narrow lane, inadequacy of Fulling Mill Lane Bridge onto Codicote Road. o Disproportionate increase in housing next to Welwyn village o Village centre, High Street, approach roads and car park cannot support expansion. o Would increase ribbon development between Welwyn and Codicote and encroach on Green Belt. o Stress on services within Welwyn - shops, surgery, library, schools, parking = from 220 houses.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has not been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

222

Appendix A Finely Balanced – Welwyn Consultation Point – Site Wel2, Land east of Welwyn Cemetery

Number of responses received 11 (General 2, Support 3, Object should be more favourable 2, Object should be less favourable 0, Object should not be considered 4).

Support o Development would severely compromise the Green Belt landscape and the gap between Welwyn and Codicote. o Singlers Bridge would need to be widened which would encroach on the Local Nature Reserve and a rare chalk river which is a BAP.

Main Issues o Account should be taken of potential adverse impact on views out from the nearby Welwyn Conservation Area o Buffer adjacent Ecosite (Cemetery 43/053). Low ecological sensitivity o Create new settlements and garden villages rather than expand already overstretched villages. o Should preserve the gap between Welwyn and Codicote permanently, for example by expanding the cemetery.

Object should be more favourable o Site Wel2 can rectify distribution of housing to conform to policies. Site capacity, 60 dwellings, can help meet OAN, including part of the shortfall at Oaklands and Mardley Heath. A sustainable village location, site within 530m of town centre, bus and rail o The Council’s Green Belt and landscape assessments are incorrect: the gap between Welwyn and Codicote is substantial, not fragile, with no risk of coalescence; would be infill not ribbon development; impact from encroachment of the countryside westward no greater than existing housing estates to the north and south. This site scored the same (red) for Green Belt purposes as Wel11, a preferred site . The site can be delivered within 18 months of adoption of the local plan, . Development would not affect the character of Welwyn or landscape character. Site visible from Kimpton Road, little used, with only limited views from Codicote Road and close neighbours, and it is proposed to heavily landscape the periphery. . Herts Highways has no objection in principle to a new access scheme improving highway safety and existing junctions. . Would preserve Singlers Bridge as a footpath/cycleway and make the Singlers Marsh area more accessible. . Planning obligations will be made for off-site highway improvements, including the A1M Clock Roundabout. Improvements to Welwyn’s bus services would be made.

223

. Along with Wel1, site can contribute to the expansion of St Mary’s School by 1FE and to Bridge Cottage Surgery. Further contributions could be made to secondary health care. . Development can assist in Green Infrastructure by improving Mimram Valley greenspace. . Would provide church car park extension. o Site should come forward with Wel6 to assist in meeting OAN

Object should not be considered o Not contiguous with village boundary. Would enclose Singlers Marsh LNR and informal recreational area. Access problematic o Disproportionate increase in housing. Village centre, High Street, approach roads and car park not capable of expansion to accommodate a major increase in housing, residents and vehicles o Would increase ribbon development between Welwyn and Codicote; encroach on Green Belt. o Difficult access through narrow, congested roads.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has not been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

224

14 Welwyn – Village Centre

Number of responses received 2 (General 0, Support 2, Object 0).

Main Issues o General support, including for the 60% retail threshold for large centres (Welwyn Parish Council and the Welwyn Parish Plan Group) o General support (Welwyn Planning & Amenity Group) o Extend Welwyn’s village centre boundary further along Prospect Place to include commercial properties in that area

How these views have been taken into account

The village centre and retail boundaries set out in the LPCD 2015 have been maintained with the LPPS 2016. The offices along Prospect Place have received prior approval for conversion to residential use under the extended permitted development regime. As such, the boundaries were not extended as the approach taken by the Council is to exclude any areas that include residential uses.

225

14 Welwyn – Urban Open Land

Number of responses received 3 (General 1, Support 2, Object 0).

Main Issues o Amenity grassland. There are no recognised ecology sites within or adjacent to the UOL, unlikely to be any protected species present. No ecological sensitivity or ecological constraint on record o Support the designation of new UOL225 at Nodeway Gardens, Welwyn. Should a similar type of development be proposed for Sandyhurst (Wel 4) we suggest the same designation for the open areas of that site (Welwyn Parish Council). o Support Welwyn Parish Council’s recommendation that the centre of Nodeway Gardens is designated as an UOL

How these views have been taken into account

Node Way has been designated as Urban Open Land on the LPPS 2016 policies maps.

226

Section 15 Digswell – Housing

Number of responses received 4 (General 1, Support 1, Object 2)

Support o Remarks and policies in paras 15.1 to 15.13 are well-considered and should be adopted.

Main Issues o Should build more houses in Digswell to provide diversity of housing and to support policy CS3. o Cannot satisfy the OAN for Digswell. Constrained by border with East Herts and by the Mimram valley. There are no” More Favourable” or “Finely Balanced” sites o Exceptional circumstances justify release of site Dig 1 to meet OAN. Should be assessed as more favourable and released from the Green Belt.

How these views have been taken into account

Whilst the village of Digswell is excluded from the Green Belt, no suitable opportunities have been identified for housing or other growth. No sites have therefore been allocated for development in Digswell (see next section for Dig1 response). Completions and permissions for 15 dwellings are accounted for within the plan period (LPPS 2016 Table 30).

LPPS 2016 Policy SP 3 Settlement Strategy and Green Belt boundaries provides for a limited new development where compatible with the scale and character of the village and the maintenance of Green Belt boundaries. When considering development proposals in Digswell, the Plan states that the Council will take the following local objectives into account, alongside the borough-wide objectives:

 Review and continue to use the Digswell Character Appraisal in decision making.  Maintain the character and widen the choice of housing available in Digswell.  Preserve the setting of the Grade II* listed Digswell Viaduct.

227

Appendix B Less Favourable Sites –Digswell - Site Dig1, Land behind 2 New Road

Number of responses received 29 (General 5, Support 6, Object should be more favourable 2, Object should not be considered 16).

Support o Part of the Tewin Water parkland laid out by Humphry Repton, site adjacent to Grade II Registered landscape o Due to the topography of the area development would have an adverse impact on the setting of the Tewin (Grade II) Registered Park and Garden. The significance of the Registered landscape would be substantially harmed by development of Dig1 o Agree with the analysis that this site is Less Favourable (Welwyn Parish Council). o Dig1 is very visible from several points. o It is good agricultural land and protects the countryside from incursion. o Urbanising this land would increase the risk of overland flow of water. o Loss of valuable Green Belt land that divides Digswell from Welwyn Garden City. Green Belt land even more relevant with major extensive developments planned at Panshanger.

Site specific o New properties would have foundations higher than the roofs of adjacent/lower housing that has been in place for 50-100 years. Major notable views from existing across field footpaths would be destroyed. Topography would lead to overbearing, highly visible new housing dominating the village and all views to the east. o Loss of privacy - new housing would have direct sight towards rear reception rooms and bedrooms of existing properties. o The Digswell Character Appraisal identifies this area and the open ridgeline as a defining feature of Digswell to the east and also when viewed from Tewin Water areas. o Topography likely to create water runoff due to steep slopes. Major flooding already on roads at the junction of Harmer Green Lane/New Road and Hertford Road. o The Landscape Sensitivity Analysis should rate Dig1 as high and not categorise as an urban area. o The SHLAA 2012 deemed DIG1 unsuitable at Stage two. Nothing has changed. o Three extensively used footpaths run directly through the land. o Site has an abundance of wildlife including some protected species. Infrastructure o Lacks infrastructure and facilities, eg shopping, to support growth at DigIG1. Local primary school is over-subscribed. There is no room to expand. o Proposed site access poor. Potential for flooding of storm water drains would exacerbate the regular road flooding of the Harmer Green Lane/Herford Rd junction. Road network not suitable for the additional volume of traffic that would be generated

228

Main Issues o Digswell Residents Association has carried out a survey in relation to sites Dig1 and Dig4. Not rated as “favourable” in the consultation document, they should be removed from future plans. Concerns: traffic congestion, the character of the village, use of brownfield sites, flooding, schools, topography, loss of amenity and identity, surface water run-off, the Mimram floodplain, over development. Conversely, development may prompt shops/restaurants to establish in the village and improve rail services. o No recognised ecology sites within/adjacent/close to site. No protected species Opportunities: low. Ecological sensitivity: low. Fundamental ecological constraint: low o Consideration must be given to the density and style of the new buildings. Avoid high density. o An unnamed landowner appears to have proposed DIG 1. Care must be taken not to allow undue pressure from any party whose self-interest may exceed concern for the local environment. o The Council's assessment of sites around the borough is inconsistent and unreliable. o Development is far more sustainable at sites BrP6 and BrP12 found "suitable and available”, in Brookmans Park than in Digswell. Decision to exclude Brookmans Park, one of the borough’s most sustainable locations, from any significant share of development is potentially unlawful. o Remove Dig1 from list of potential developments even if classified as "less favourable". The construction of housing on this land is totally inappropriate o Solution is building on brownfield sites or developing a new garden city. o Development of this site will mean that policy CS3 will be more achievable.

Object should be more favourable o Exceptional circumstances justify release of site Dig 1 to meet OAN. Should assess as more favourable. Lower proportion of site could come forward with minimal impact on the Green Belt. Visual openness overstated. Sustainable location. Available now o More houses should be built in Digswell. o Dig 1 and Dig4 have no significant detractions - the” Less favourable” category seems wrong. o Site within easy walking distance of train station and therefore sustainable. Does not cause sprawl, but rounds out the natural shape of the community, so is inobtrusive. o Disagree that the site makes a significant contribution to protecting the countryside and landscape any more than site WGC4. Inconsistent arguments for Dig 1 compared with WGC4. o Site cannot be seen from the two roads. Visual impact overstated. o Logical and defendable greenbelt boundaries can be created after the development when the edge of the development becomes the Green Belt boundary. o The risk of water runoff is no worse than that at WGC4, which can be mitigated with SUDs.

229 o More housing will improve the diversity of the housing stock in Digswell and ensure the continued viability of the village. o Reconsider the status of Dig 1 site as at least finely balanced, if not more favourable. o Building on the Green Belt is going to be necessary to achieve the assessed housing numbers and this site scored well as a sustainable site for development (as did Dig4).

Object should not be considered

Green Belt o Proposal would have a severe detrimental effect upon the Green Belt land adjacent to Digswell village and would harm its setting and character. Detrimental visual aspect. Would set precedent. o This site is not suitable for development and should be removed completely from the plan. National Policy Planning Framework states that inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. o Sites put forward should be on a sequential basis. Dig1 would rank very low in a sequential test, based on objective tests of sustainability, suitability, land character, and Green Belt/countryside. o Green Belt evidence takes no account of sustainability criteria or the sites elevation relative to its surroundings and the resultant impacts on views. o The 2014 Stage 2 Green Belt Review was undertaken partly by Council officers with a lack of experience so concern with findings. Site pro-forma for Dig1 does not identify major Green Belt constraints, Should refer to height AOD (Above Ordnance Datum). The site is highly visible and development on it would be very visible as well.

Settlement Pattern o Digswell has reached its maximum size. Consider other more sustainable sites. o Digswell has insufficient facilities for new housing. Should not consider for new development until more sustainable sites in other larger villages and within WGC have been developed first.

Impact upon wider area o Tewin Water proposal (130 dwellings) takes no account of the lack of services or increased traffic that would ensue from this project. o Development would have a significant detrimental effect upon the setting of the Grade II* listed Digswell Viaduct, o Development likely to interfere with the views across the valley and Digswell to west and east. The delicate, unique ecological ecosystem of the Mimram River (chalk stream) needs to be protected and studies made available to fully understand the implications and possible solutions o Level of housing growth will destroy the character of the village and compromise facilities.

230

Site Specific o The Council's Digswell Character Study states that the distinctive topographical setting is integral to its character: The existing planning proposal will obliterate the ridge lines (identified in the Character Appraisal) that are integral to maintain this character. o Development will alter the skyline to and from this site that create this unique local character. o Development would be out of character with surrounding housing, and at a significantly higher level than neighbouring housing. o The site, location, access route and its rising nature will lead to car dependency. Development would destroy a footpath and bridleway regularly used by residents adjacent to the site. o Further houses behind properties on the east side of New Road and the traffic generated would aggravate the problem of disturbance from the bridleway. o Building would severely compromise residents’ privacy. o The field proposed at the site of Dig1 is part of the food chain. o Dig1 was rejected as a housing site in the 2012 SHLAA, because of access issues and Digswell's lack of facilities. Should dismiss on the basis of site characteristics and environmental issues. o The 2012 Landscape Sensitivity and Capacity Study incorrectly states that the site's level of openness is limited. The Council has stated that impact on land sensitivity could be mitigated, inconsistently with other sites where it has stated that there is no scope for mitigation. As a result the landscape visual score is too low, and we recommend it should be higher. Ecological score should be higher; Site has a greater ecological value than assessed in the study.

Topography o The site has a high degree of visual and physical openness, with clear long views across the valley. The proposed new development will unacceptably eliminate a landscape asset that offers a degree of elevation, views and openness that is exceptional and rare within the County. o Close proximity to existing homes with a level differential of 20-30m higher makes it unsuitable. The large difference in level changes has not been properly considered, therefore, assessment on feasible density and types of the 130 dwellings has not been adequately assessed. Would compromise the open, rising nature of this area and views to and from it. o Potential loss of sunlight, open views. Without the usual acoustic baffling that occurs on flatter sites there is potential for increased noise pollution to existing properties. o The Total Landscape Sensitivity score and Landscape Visual Score should be much higher. o The unique topographical value of the site as a visual, recreational and tranquil asset has been correctly assessed by Council in designating this site as less favourable.

Infrastructure

231 o Area does not meet "sustainability" criteria as limited local facilities. Services and transport infrastructure must be improved to cope with the extra population. Limited or lack of local primary schools, doctors dentists, shops, pubs and restaurants, community centres, sporting facilities, car parking. New residents will depend on a car. o Access to this land will lead to an increase in traffic on roads that are unsuitable o Proposed site access far too narrow. o Shortage of nursery and primary school provision in the Digswell area with no plans for improvement. New residents will drive their children elsewhere to school, adding to traffic. o Development would be car dependent exacerbated by inadequate public transport. o The station would not cope with more commuters. Peak time trains into London are always full.

Drainage o Developing on the hillside would cause drainage and sewerage problems, exacerbate flooding at the bottom of the hill at Harmer Green Lane J/W Hertford Road, which is prone to flooding. o Building on the land would cause runoff, increasing the risk of flooding. Could overwhelm drains.

How these views have been taken into account

This site has been assessed as unsuitable (HELAA 2016) and has not been considered for allocation in the LPPS 2016.

232

Appendix B Less Favourable Sites – Site Dig4, Land at Digswell Road and Bessemer Road

Number of responses received 29 (General 5, Support 6, Object should be more favourable 2, Object should not be considered 16).

Main Issues o Not rated “favourable” in the consultation document, sites should be removed from future plans. Concerns: traffic congestion, village character, use of brownfield sites, flooding, schools, topography, loss of amenity and identity, surface water run-off, the Mimram floodplain, over development. Conversely, development may prompt shops/restaurants to establish in the village and improve rail services o No recognised ecology sites within/adjacent or close to site: none. Protected species: probably birds in trees. Opportunities: potential for grassland and planting. Ecological sensitivity: low. Fundamental ecological constraint: Phase 1 survey needed to assess value of habitats. Reptile survey may be necessary depending on habitat suitability.

OBJECT to our assessment that it is not identified as a preferred site (more favourable) o Should build more houses in Digswell to provide diversity of housing. support the community and fulfil policy CS3. o Dig 1 and Dig4 appear to have no significant detractions. The Less favourable category seems wrong. Reconsider the status of Dig4 site as finely balanced, if not more favourable. o Inconsistent arguments put forward for Dig 1 compared with the WGC4 site. o Would provide housing within easy walking distance of a train station, therefore sustainable. Does not cause sprawl, but rounds out the natural shape of the community so is unobtrusive.

OBJECT - this site should have not been considered o Proposed building sites in Digswell Lane (20 dwellings) take no account of the lack of infrastructure and increased traffic which Digswell Lane could not cope with. 2 cars is the norm.

SUPPORT the assessment that the site is less favourable o Site part of open land surrounding Digswell Lake. Area an important relic of the Regency Park laid out by Nathaniel Kent and Humphry Repton and part of designed parkland along the river Mimram (to include Tewin Water and Panshanger). Development here would be a significant loss of local and national heritage o Site within the setting of the Grade II* listed railway viaduct. Development would erode the dramatic landscape setting of the viaduct, resulting in harm to its significance

233 o Agree site should be classified as Less Favourable. Dig4 would compromise the separation of Digswell from Welwyn Garden City (Welwyn Parish Council) . o Support decision to designate land less favourable. Strategic Green Belt Review Purposes Assessment found the land contributed significantly to three of the five Green Belt purposes. o To allow development on this site would contravene national and local Green Belt policy.

How these views have been taken into account

This site has been assessed as unsuitable (HELAA 2016) and has not been considered for allocation in the LPPS 2016.

234

15 Digswell – Village Centre

Number of responses received 3 (General 0, Support 1, Object 2)

Support o Remarks and policies in paras 15.1 to 15.13 are well-considered and should be adopted.

Main Issues o The proposed village centre boundary does not reflect the actual extent of the centre. o Extend Digswell village centre boundary extend east along Station Road to Harmer Green Lane to include the Cowper Arms public house, Welwyn North Railway Station (and associated businesses), Welwyn North Stores and Digswell Village Hall.

How these views have been taken into account

The LPPS 2016 and associated policies maps designate three areas as the village centre, which include the original proposal plus land taking in the Cowper Arms Public House and Welwyn North Stores. Land taking in the village hall were not designated as this is protected under Policy SP6 and Policy SADM 7, and the railway station has not been designated as it would have required designating large areas of car park which would not be consistent with the intent and purpose of village centre designations.

235

Section 16 Welham Green

Number of responses received 23 (General 1, Support 0, Object 22)

Main Issues o The East Coast Main Line limits vehicle access to Welham Green via Dixons Hill Road and the A1000. The WHaSH model indicated significant delays in peak hours. Proposed measures in the Draft IDP do not mitigate delays as predicted traffic flow is beyond the road capacity. Further investigation and analysis is required to confirm the impact that the More Favourable sites would have on the A1000 and Dixon Hill Road roundabout. The cumulative scale of the sites means that improved access for sustainable modes and improved facilities for Welham Green station are likely to be required

Object

Green Belt o Retain Green Belt. New Green Belt boundary would be weaker than existing one. o Exceptional circumstances for taking land around Welham Green out of the Green Belt not demonstrated. o Green Belt around Welham Green and between the towns retains character and identities. o Proposals would result in coalescence with Hatfield and Brookmans Park. o There is enough brownfield land nationwide to accommodate housing needs. o Use the New Barnfield Incinerator site for housing rather than Green Belt around Welham Green.

Settlement pattern o Welham Green has already had substantial development and pressures associated with a village having a large industrial estate. o Proposed scale of development would overwhelm Welham Green which would lose its character and cease to be a village. o Proposals for Welham Green seem excessive compared with Brookmans Park which only has 21 dwellings, despite being one of the most sustainable locations in the borough.

Infrastructure issues o Primary school at capacity with no scope for expansion. Lack proposal / site for new school. o Traffic congestion will be intolerable. Concerns over road safety. o Proposed development would overwhelm facilities and services e.g. healthcare, power, water, drainage, public transport, post office.

Impact on the wider area

236 o Loss of unspoilt, picturesque and pleasant space for leisure, recreation and experiencing wildlife. Impact on residents; existing quality of life. o Loss of habitat for wildlife. o Sites prone to flooding.

Other matters o Landscape Sensitivity and Capacity Study inconsistent, unreliable assessment of Welham Green sites (More Favourable) compared to three Brookmans Park sites which have been discarded. o Promote a garden city on non-Green Belt in North Herts. o Reclassify Green Belt sites to Finely Balanced/Less Favourable. o Use existing school capacity to cater for brownfield infill within the village, not Green Belt sites. o Stop stating that housing development in the village has only been ‘modest’.

How these views have been taken into account

Following the completion of site assessment work and consideration of the benefits and adverse impacts, the LPPS 2016 sets out the following local planning objectives for Welham Green which the Council will take into account when considering development proposals in Welham Green, alongside borough-wide objectives:

Welham Green is a large excluded village and is considered to be a sustainable location for growth due to its range of facilities and services available. This has been reflected in Policy SP 3 of the LPPS 2016 which regards Welham Green as being suitable for limited growth that is compatible the scale and character of the village. However, there are notable constraints relating to primary school capacity which restricts the amount of growth which can occur within the village. The LPPS 2016, reflecting this, makes provision for 121 dwellings at Welham Green over the plan period which is considered compatible with the village’s character and scale, as well as infrastructure constraints relating to primary school infrastructure. Green Belt purposes assessments have been undertaken and have informed the overall

237 consideration of site allocations in Welham Green and the wider borough. Exceptional circumstances are considered to exist to justify the release of certain sites from the Green Belt around Welham Green. Further explanation is set out in responses relating to CS2 Meeting the Needs for Growth, CS3 Settlement Strategy and CS4 Green Belt Boundaries and Safeguarded Land of this statement

The Council’s Landscape Sensitivity and Capacity Studies have adopted and consistently applied a methodology when appraising sites across the borough. Any inaccuracies or errors within the report have been corrected with updated conclusions then factored into the Sustainability Appraisal of August 2016.

238

16 Welham Green – Housing and Table 16 points

Number of responses received 107 (General 1, Support 2, Object 104)

Support o Support approach to identifying new housing sites in Welham Green (Landowner on behalf of WeG12). o Support the 360 dwelling objectively assessed need for the village, based on the principle of distributing housing growth proportionally around the borough and called for further development to support and maintain local services. o

Main Issues

Green Belt, countryside o None of the Welham Green sites have defensible Green Belt boundaries. o The proposed development will exceed the 3.7% figure for incursion on to the Green Belt –against Government policy. All development should take place on brownfield sites. CPRE have stated that there is ample brown field land to accommodate housing. o Proposed housing in Welham Green will cause disruption and damage to wildlife, biodiversity and the countryside as a result of the reduction of Green Belt land. o Proposed development sites in Welham Green are an encroachment on the Green Belt. Further development will lead to further coalescence with neighbouring towns. o Redefining boundaries and reducing the Green Belt for additional housing is very worrying. o Green Belt land and green areas in and around the village would be spoilt. o The New Barnfield site should not be removed from the Green Belt as it makes a significant contribution to the four Green Belt purposes identified by WHB Council. o Green Belt loss would increase the frequency of water shortages. o Any development on Green Belt land could lead to further ribbon development o Scale of growth would have a detriment impact on surrounding countryside which should be protected for future generations.

Settlement pattern o Object to scale of development proposed in Welham Green. Emerging core strategy identifies the village as having a “limited range of local employment opportunities, services and facilities” and advocates development compatible with the scale and character of the village. 288 new dwellings not in keeping with the scale or character of this small village (Landowner on behalf of Hat3). o 250 extra houses at Welham Green is unfair compared with Brookmans Park. Should spread housing development equally through all the villages. o Welham Green should remain a village and not be overdeveloped. 400 additional houses would be disproportionate and change the character of the area. Welham

239

Green will merge with Hatfield and Brookmans Park to become a suburb rather than a village. o The incinerator plans and the Local Plan will destroy the green and quiet village lifestyle. o A new town or Garden City would be a better option with the necessary infrastructure o Object to the wording below Table 16, considering it too vague in whether or not the plan commits to a proportional distribution of housing growth.

Infrastructure issues o Welham Green Residents Association: concern about the scale of growth, lack of infrastructure: . Welham Green has around 1500 houses. Growth of 20-26% is a major increase for a small village which has been seen as a dumping ground for new housing. . Insufficient account taken of local needs or existing pressures on infrastructure. Welham Green has grown significantly. In recent years many small developments have taken place, which residents generally consider as positive. Infrastructure or facilities in the villages have seen no major development. Lack of reference to the need/ability of the local medical centre and dentists to expand. The now-local hospital in Stevenage is under immense pressure without further new patients from Welwyn Hatfield. Lack of plans to expand or relocate Welham Green JMI school. . Object to development at Pooleys Lane for the reasons outlined above. o The Local Plan Document does not address lack of infrastructure in potential development sites, including at schools. Failure to assess the impact of new housing on community infrastructure. o Would need a new school for the additional children. There is no room for expansion. Local shops will not be able to cope with the increased demand created by the new housing. o Recent flooding and power cuts in the village prove that the infrastructure is not adequate. o The local area has no Accident & Emergency. Will require expanded local medical facilities o Sewage infrastructure is inadequate and cannot cope at present. Will require a sewage upgrade. o Roads to proposed Welham Green sites have difficult access. o Welham Green shops are accessible via one road which may cause an increase in congestion. o The combined impact of WeG10, WeG3 and WeG1 would cause heavy road congestion. o Inadequate bus service will not cope with increased demand of residents. o Proposals will give rise to significant issues in capacity of footpaths. o There is insufficient policing in the area. o There are not enough leisure facilities. Recreation and open areas would need to be expanded.

240

Site specific issues o Unclear yet whether the five ‘more favourable’ sites (equating to 250 dwellings) would have a material impact on SARN junctions o WeG4b is an area where natural water features highly with marshes, swallow holes and flooding. The new housing would affect the natural drainage area available. This is significant due to the poor drainage and high water tables in the village. o The Marshmoor area and Skimpans frequently flood. Proposed sites suffer from significant surface water. The Skimpans site (WeG6) is adjacent to a flood plain - new housing would eradicate the flood plain and push the water table higher. This could lead to homes flooding. o If Welham Green has to take a share of housing, the WeG4b site may be the best option. o Develop housing on the site of the proposed incinerator /The New Barnfield site could now be used for housing development. o Develop housing on the site of the stables opposite Potterells Medical Centre. o Lack of consideration given to brownfield sites in the Green Belt and sustainable sites closer to the station. Assess sites between Dixons Hill Road west of the railway and towards the A1001, including the Rookery. The A1001 and Millwards Park provide an opportunity for a new Green Belt boundary and housing linked to the railway station o The proposed developments should not go ahead. o Allocate Land at Pooleys Lane as a more favourable housing site

Impact on the wider area o The additional housing would add 300 cars to the roads. The A1000, Dixons Hill Road, Whites Corner and other roads around proposed sites are already busy; further traffic would worsen congestion and raise road safety concerns. Proposed plans would exacerbate village parking issues and give rise to traffic and safety issues from cars parked on the road. o Lack of assessment taking into account climate change, flood risk arising from the development of individual and cumulative sites and sites in neighbouring boroughs. This particularly relates to Water End, within Flood Zones 2 and 3 and downstream of Brookmans Park sites. o Some identified housing sites could exacerbate surface water flooding problems. o Scale of housing growth will have an adverse effect on residential amenity.

Sustainable development issues o Affinity Water is to reduce water extraction from the Mimram River, but an increase in housing will negate this. o Recreation areas in the village are highly valued. o Social housing is necessary for every 14 houses built –this is not suitable for Welham Green. o Pollution would rise and other costs would rise in Council tax.

241

Gypsy and Traveller sites o There is currently unauthorised encampment(s) in the area - the current Skimpans Bridge site is an eye-sore. Welham Green is being unjustly targeted in the Local Plan Document with three Gypsy & Travellers sites - there is no justification to authorise a legal site.

Other matters o Consider the views of the whole community, not just the select few. Lack of thought given to the residents’ futures. o

How these views have been taken into account

Please see the response in the section immediately above in relation to the majority of matters raised, and responses within sections CS2 Meeting the Needs for Growth, CS3 Settlement Strategy and CS4 Green Belt Boundaries and Safeguarded Land of this statement. Other matters are addressed below

Flood risk

A Strategic Flood Risk Assessment was undertaken in 2015 (updated in 2016) which fully appraises flood risk and accounts for climate change. The conclusions of this work have informed the LPPS 2016 strategy and site allocations, and supporting site assessment work.

Gypsy and Traveller development

242

Site allocations

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

The issues and outcomes for each Welham Green site in the LPCD 2015 are set out below.

243

16 Welham Green – Employment – Site WeG4b – Marshmoor

Number of responses received 55 (General 5, Support 2, Object 48).

Support o Lack of capacity in existing urban areas to meet OAN provide very special circumstances to review Green Belt boundaries. Site represents a sustainable form of mixed use development: adjoins village; the A1000 can provide a strong defensible boundary; development would not be isolated or encroach into open countryside; site is partly PDL; allocation would consistent with policy intention CS4; meets para 3.21 criteria - has very good access to serves and facilities, including the railway station and buses; is of a scale consistent with the size of Welham Green; would not result in coalescence with other settlements; is a suitable location for life sciences. Development would not prejudice provision of gypsy and traveller site GTLAA01 It is the larger more strategic site out of only 2 new employment sites proposed in the local plan. Site is suitable, available and deliverable o The need for employment development provides exceptional circumstances to justify the land's removal from the Green Belt. The employment land review underestimates future employment potential in the borough. There is a significant need for new high quality employment premises, on well connected greenfield land within Welwyn Hatfield such as this. Marshmoor is well placed to meet this need, due to its location adjacent to a mainline railway station, proximity to the strategic highway network and the potential that it offers for a high quality landscaped environment. We have previously assisted the Council in identifying potential locations for Gypsy and Traveller accommodation, and they would be happy to discuss this matter further with the Council as required o Stage 2 Green Belt Review is flawed as it misinterprets national Green Belt purposes, and introduces a 'local test' which it gives the same weight as national policy. Land at Marshmoor makes at most a partial contribution to the purposes of including land in the Green Belt as follows: . limited/no contribution to checking the unrestricted sprawl of large built-up areas . partial contribution to preventing neighbouring towns from merging (in a visual sense);- . partial contribution to protecting the countryside - the site's character is mixed and not generally 'open' . no contribution to protecting the setting and character of historic towns . no contribution to assisting in urban regeneration . a partial contribution to the local purpose of maintaining the existing settlement pattern (in a visual sense) o Site makes no positive contribution to the landscape. Development would allow mature trees and hedgerows to be retained, provide consistent landscaping along the eastern boundary with significant new planting and opportunities to restore the ecological value of the area. Development will offer an opportunity to resolve surface water flooding and provide suitable surface water drainage. Investigations show no undue utilities constraints. Most habitats on site are common and have only a local value. Major habitats such as trees would be

244

retained as part of the masterplan allowing them to remain largely undisturbed. Allocate site for mixed employment/residential development

Main Issues

Green Belt o Should remain as Green Belt to ensure a visual barrier between Hatfield and Welham Green, and prevent dangerous traffic conditions in the surrounding area. o Do not need an employment site in the Green Belt - could be built on a brownfield site. o A new Green Belt boundary around the site would be weaker than the existing one and lead to continuous development along the A1000 Site assessed as significant for the national Green Belt purpose on encroachment. Development would narrow the gap between Welham Green and South Hatfield. o Green Belt boundary and land should be retained. New Green Belt boundary would be weaker than existing one. o Exceptional circumstances for taking land around Welham Green out of the Green Belt not demonstrated. o Development of WeG4b creates "Ribbon Development" along the A1000. Would cause coalescence between Welham Green and Hatfield. Application for large development on Marshmoor refused several times in the past. o Would lead to continuous development along the A1000. o Would narrow the gap between Welham Green and South Hatfield, risking coalescence. Green Belt around Welham Green and between the towns retains character and identities. Coalescence could be further risked by uncertainty surrounding the New Barnfield site. o Change assessment of the site’s Green Belt purpose of maintaining the existing settlement pattern from partial to significant. Site makes a significant contribution to secondary local gap. Virtually the only visual perception of gap along A100 between Welham Green and Hatfield. o Assessed as Significant for Green Belt National Purpose – Encroachment. (Displays typical rural and countryside characteristics and high levels of visual openness). o Proposal contrary to national Green Belt policy and Ministerial Statement March 16th. o SHLAA assessment of WeG4b as suitable is inconsistent compared with BrP2 assessment (unsuitable) despite the same issues. o There is enough brownfield land nationwide to meet housing needs without using Green Belt. o Safeguard for employment use beyond the plan period. o WeG4a would be a better option with a smaller development within the middle of the site with green edges and ends to it, as per previous options. o Housing projections are too high. Job creation-led scenarios are substantially lower than the projections used in the Local Plan. Windfall housing projections are too low. o There is vacant employment land in and around the towns and villages, including Traveller Lanes Industrial Estate, and more jobs than working age residents so no need for Green Belt land for employment.

245

Site specific o Least worst option for development around Welham Green. Could develop on northern portion of site to avoid over-built up entrance to Welham Green. Visual impact – must use tree belts; access, increased traffic – must not exacerbate current problems; additional commercial provision unjustified – Travellers Lane North industrial estate has empty units. o Everywhere needs to take some development. WeGb4 a better option for Welham Green as it is directly adjacent to the village and has access to a major road unlike other sites in the village. o Should be More Favourable to help meet need for 322 houses in Welham Green. o Whilst having a scruffy appearance, part of land that buffers Hatfield House Grade I Registered Park and Garden from Welham Green. Potentially significant negative effect. Recommend further development is not brought forward for this area. Enhancement of the landscape would enhance the significance and setting of the Grade I Registered Park and Garden o Inconsistent assessments within the Sustainability Appraisal of potential impact on the historic environment posed by sites in the Marshmoor area - GTLAA01 assessed as potentially significant negative impact, but GTLAA03 and WeG4b assessed as minor negative o Wastewater network capacity unlikely to be able to support the demand anticipated from this development. Likely to require upgrades to drainage infrastructure. Where no improvements are programmed, the developer should provide a detailed drainage strategy on infrastructure required and how it will be funded. A planning condition is highly likely to be required to ensure strategy recommendations are implemented ahead of occupation. Infrastructure delivery is likely to take 18 months to 3 years to deliver o Area floods and has poor drainage. Development would exacerbate flooding on Station Road. The A1000 also floods in parts. o Would destroy wildlife, including rare species of reeds which grow here, through loss of habitat. o Pylons and power lines would preclude or affect development. o Access from Marshmoor Lane would be dangerous due to narrow blind access near the bridge. o Remove this site from the plan. o Use other brownfield sites instead of Green Belt. o Reuse Travellers Lane Industrial Estate for housing instead of this site. o Flooding issues. o The only entrance to Marshmoor is Marshmoor Lane - access here would be a major traffic hazard, to exit to the A1000 would need major work to ensure safety. o Health risk of living under electricity cables (has National Grid been consulted?). o When previously considered for housing found species of plant exclusive to marshlands.

Infrastructure issues o Housing would be isolated, with inadequate facilities provided within the site.

246 o Primary school is at capacity with no scope for expansion and no proposals for any new or replacement school site acceptable to HCC. o Limited recreational facilities within the village for younger people.

Impact on the wider area o Traffic and congestion on the A1000 and Dixons Hill Road will be made worse. Road safety concerns along the A1000 there have been accidents and fatalities due to speeding and dangerous access. Additional entrances on the A1000 would not make sense. o Impact on residential amenity - the area is pleasant to live in. o Impact on the ancient woodland at Millward Park. o Site lacks facilities, giving rise to more car trips to the village where parking and congestion are poor. o Impact on station parking from commuters and users of the industrial estate. o Area characterised by residential properties in a rural setting. Should surround with commercial, housing and traveller sites. o Polluted run-off would impact on wildlife and Water End SSSI.

Settlement pattern o Promote a garden city on non-Green Belt in North Herts with supporting infrastructure. o Equal distribution of housing per settlement based on existing number of houses.

How these views have been taken into account

Our evidence suggests there is insufficient brownfield land to meet employment requirements. The Economy Study Update (hybrid scenario) predicts a shortfall of about 5.4 hectares of employment land by 2032. There are no other sites in urban areas that could be allocated for new employment land. As the Council has to plan proactively to meet the development needs of business, this constitutes exceptional circumstances to release land from the Green Belt so that this shortfall can be met.

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

247

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report), principally because it offers a strategic advantage of assisting in meeting the shortfall of employment land, alongside other sites, during the plan period.

Policy SADM 30, Policy SP 23 and Figure 15 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development.

248

16 Welham Green – Site WeG1, Welham Manor House

Number of responses received 33 (General 5, Support 1, Object 27)

Support o Support proposed allocation. The site is PDL and is therefore an exception in Green Belt terms within the NPPF. Both owners are supportive of bringing the site forward for development o If WeG2 and WeG3 sites are also allocated overall layout and landscaping could form a cohesive development and a fitting edge to the settlement to establish a new Green Belt boundary

Main Issues o Wastewater network capacity unlikely to be able to support the demand anticipated from this development. Likely to require upgrades to drainage infrastructure. Where no improvements are programmed, the developer should provide a detailed drainage strategy on infrastructure required and how it will be funded. A planning condition is highly likely to be required to ensure strategy recommendations are implemented ahead of occupation. Infrastructure delivery is likely to take 18 months to 3 years to deliver o No recognised ecology sites, protected species or opportunities. Low ecological sensitivity. o Local opinion not in favour of this site due to access and flooding, however it is PDL in the Green Belt o WeG1 less visually intrusive than WeG3 if hedges are retained, but difficult access as the road is narrow. Further traffic will cause significant impact for residents’, refuse and emergency vehicles. o Unclear where Welham Manor sites are. Lack viable access. Welham Manor has a narrow road width. Potential traffic issues on Dixons Hill Road and around the surrounding area. 140 extra cars would make residents’ lives intolerable. Residents already suffer extensive flooding in their back gardens, as well as regular sewage problems

Green Belt o Green Belt boundary and land should be retained. WeG3 is assessed as having a significant role in protecting the Green Belt from encroachment – it has high visual openness and typical countryside characteristics. Proposals would have a detrimental impact on these purposes. o There is enough brownfield land elsewhere to accommodate housing needs without building on this site.

Settlement pattern o Other areas in the borough are better suited for development.

249

Infrastructure issues o Existing problems with drainage in Welham Manor and Welham Green. Infrastructure will not be able to cope with the proposed development. o There is not enough capacity in the primary school and doctors for the proposed development.

Site specific o Increased traffic along Welham Manor will pose significant road safety issues for drivers, pedestrians and cyclists accessing from Dixons Hill Road and travelling along Welham Manor. o Insufficient off-street parking in Welham Manor currently results in on on-street parking which blocks footpaths causing safety concerns for pedestrians. o Welham Manor road is not wide enough for emergency and refuse vehicles and two-way traffic due to width of the road and on-street parking. o Construction vehicles using Welham Manor during the construction phase will have a significant adverse impact on the amenity and health and wellbeing of existing residents. o Adverse impact upon amenity, health and wellbeing of existing residents due to noise and air pollution arising from increased traffic and domestic activity of new residents. o There are extensive flooding problems in Welham Manor and other sites within Welham Green. o Trees behind Welham Manor are protected by a Tree Preservation Order.

Impact on the wider area o Cumulatively with other sites, the proposed development would lead to significant traffic and congestion on Dixons Hill Road and surrounding roads. o Adverse impact on wildlife and habitats through loss of trees and woodland. o Adverse impact on landscape.

Other matters o Development here would affect the value of existing properties in Welham Manor. o Retain as business premises. o Build a new garden village or city in North Herts where encroachment on the Green Belt is less likely. o Leave existing villages alone that don’t need new development. o Use another site that does not encroach on the safety and wellbeing of existing residents. o Find more suitable brownfield sites.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical

250 studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has not been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report) principally due to primary school capacity constraints.

251

16 Welham Green – Site WeG2 – Welham Manor Grounds

Number of responses received 51 (General 5, Support 3, Object 43)

Support o Site could be utilised for development as it is not currently used for Green Belt purposes.

Main Issues o Wastewater network capacity in this area unlikely to be able to support the demand anticipated from this development. Likely to require upgrades to drainage infrastructure. Where no capacity improvements are programmed, developer should provide a detailed drainage strategy informing what infrastructure is required and how it will be funded. A planning condition is highly likely to be required to ensure recommendations of the strategy are implemented ahead of occupation. Upgrades can take 18 months to 3 years to deliver o Potential for protected bird species (in hedgerows, trees) and reptiles. Opportunity for habitat management or creation of woodland/compensation for loss of trees. High ecological sensitivity if woodland would be lost. Phase 1 habitat survey and reptile survey needed and compensation if justified o Local opinion opposes this site, but there is some indication that development of this site would be possible o WeG2 would be less visually intrusive than WeG3 if hedges are retained, but access will be a challenge as the road is narrow and constrained. Further vehicle movements will cause significant impact for residents’, refuse and emergency vehicles. o Unclear where the Welham Manor sites are. o Lack of viable traffic access to all these sites. Would create further traffic issues on Dixons Hill Road and around the surrounding area. o Welham Manor has a narrow road width - 140 extra cars would make residents’ lives intolerable. o Residents already suffer extensive flooding in back gardens and regular sewage problems. o Cumulatively, sites WeG2 and WeG3 would have an adverse effect on Green Belt openness because they jut out from the current boundary.

Green Belt o Proposal contrary to national Green Belt policy and Ministerial Statements March 16th. o Green Belt boundary and land should be retained. o Cumulatively this site would have an adverse impact on openness of the Green Belt. o Green Belt should be enforced to protect wildlife.

Settlement pattern o Other areas in the borough are better suited for development.

252 o Western and Southern aspects of Welham Green provide a green lung as an essential counter to the heavily industrialised eastern side of the village.

Infrastructure issues o Infrastructure unable to cope with the proposed development. Existing drainage problems in Welham Manor and Welham Green. o Lack of capacity in the primary school and doctors for the proposed development

Site specific o Possible highway access issues. o Construction will have a significant adverse impact existing residents’ amenity and well being. o Adverse impact upon amenity and health and wellbeing of existing residents due to noise and air pollution arising from increased traffic and domestic activity of new residents. o Site appears to be allotments. Should not develop unless an assessment has been undertaken showing them to surplus, under the Small Holdings and Allotments Act 1908. o Trees behind Welham Manor are protected by a Tree Preservation Order. o Unclear where site boundaries are. o Remove this site from the plan.

Impact on the wider area o Adverse impact on wildlife and habitats through loss of trees and hedgerows. o Cumulatively with other sites, the proposed development would lead to significant traffic and congestion on Dixons Hill Road and surrounding roads which will pose road safety issues. o Extensive flooding problems around Welham Manor and other sites within Welham Green.

Other matters o Build a new garden village or city in North Herts where encroachment on the Green Belt is less likely.

How these views have been taken into account

Site Weg2 has been assessed as unsuitable and undeliverable (HELAA June 2016) and has not been considered for allocation in the LPPS 2016.

253

16 Welham Green – Site WeG3 – South of Welham Manor

Number of responses received 64 (General 4, Support 2, Object 58)

Support o Support site assessment and proposed allocation. Do not object to restricted site capacity (due to the Council’s transport assessment) at this time provided policy wording is flexible to enable future changes subject to detailed technical assessments o Extend site area and capacity to double proposed numbers to encourage growth of Alpha Business Park and local shops and greater use of the train station.

Main Issues o Local opinion opposes this site because of access and flooding issues, it being Green Belt land with a high degree of visual openness, and concerns about creating a new defensible Green Belt boundary o Unclear where the Welham Manor sites are. o Lack of viable traffic access to all these sites. Would create further traffic issues on Dixons Hill Road and around the surrounding area. o Welham Manor has a narrow road width - 140 extra cars would make residents’ lives intolerable. o Residents already suffer extensive flooding in back gardens and regular sewage problems. o Cumulatively, sites WeG2 and WeG3 would have an adverse effect on Green Belt openness because they jut out from the current boundary.

Green Belt o Green Belt boundary and land should be retained. Proposal contrary to national Green Belt policy and Ministerial Statements March 16th. o WeG3 is assessed as having a significant role in protecting the Green Belt from encroachment – it has high visual openness and typical countryside characteristics. Proposals would have a detrimental impact on these purposes. o Narrowing of gap between Welham Green and Brookmans Park. o Green Belt should be enforced to protect wildlife. o There is enough brownfield land elsewhere to accommodate housing needs without this site. o Windfall housing projections are too low, as Welham Green has seen a large number of such developments historically. o Find more suitable brownfield sites that do no encroach on Green Belt.

Settlement pattern o Distribute growth on a proportionate basis, community by community. Adopt a proportionate approach based on number of existing dwellings in each settlement. o Proportion of housing proposed excessive compared with Brookmans Park proposals which have similar adverse effects.

254 o Other areas in the borough are better suited for development. o Build a new garden village or city in North Herts where encroachment on Green Belt is less likely. o Leave existing villages alone that don’t need new development.

Infrastructure issues o Existing drainage problems in Welham Manor and Welham Green - infrastructure will not be able to cope with the proposed development. o Not enough capacity in the primary school and doctors for the proposed development. o Need to account and plan for infrastructure impacts upfront, rather than after development, which may make the site undeliverable.

Site specific o Wastewater network capacity unlikely to be able to support the demand anticipated from this development. Likely to require upgrades to drainage infrastructure. Where no improvements are programmed, the developer should provide a detailed drainage strategy informing what infrastructure is required and how it will be funded. A planning condition is highly likely to be required to ensure strategy recommendations are implemented ahead of occupation. Infrastructure delivery is likely to take 18 months to 3 years to deliver o Extensive flooding problems in Welham Manor and other sites within Welham Green. o Site relatively close to Grade II listed Hope and Anchor public house. Should be possible to develop without adversely impacting on the setting of the building o Potential for protected bird species in hedgerow trees, and reptiles. Opportunity for grassland creation, retain trees and hedgerows or compensate for loss. Low ecological sensitivity but phase 1 habitat survey needed to assess interest. Reptile survey needed and compensation and if justified o Would result in the loss of one of the last remaining natural meadows in Welham Green. o Significant adverse impact on existing residents’ amenity/health from construction vehicles. o Adverse impact upon amenity, health and wellbeing of existing residents due to noise and air pollution arising from increased traffic and domestic activity of new residents. Use another site that does not encroach on the safety and wellbeing of existing residents. o Unclear where the site boundaries are. o WeG1 and WeG2 would be less visually intrusive than WeG3 if hedges are retained. o Reassign existing industrial areas along Travellers Lane for housing instead. o Increase site size and capacity to encourage growth and viability of services.

Impact on the wider area o Increased traffic along Welham Manor will pose significant road safety issues for drivers, pedestrians and cyclists accessing from Dixons Hill Road and travelling along Welham Manor.

255 o Insufficient off-street parking in Welham Manor currently results in on on-street parking which blocks footpaths causing safety concerns for pedestrians. o Welham Manor road not wide enough for emergency and refuse vehicles and two-way traffic. o Cumulatively with other sites, the proposed development would lead to significant traffic and congestion on Dixons Hill Road and surrounding roads. o Adverse impact on wildlife and habitats through loss of trees and hedgerows. o Adverse impact on landscape. o Proposal would result in the loss of community spirit and the identity and heritage of Welham Green and Welham Manor. o Development would harm the setting of the Grade II listed building nearby. o Poor bus service in Welham Green. New residents will drive, increasing traffic congestion.

Other matters o Development here would affect existing property values in Welham Manor.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

256

16 Welham Green – Site WeG6 – Skimpans Farm

Number of responses received 106 (General 7, Support 1, Object 98).

Support o Support the inclusion of WeG6 in the Local Plan. o Site well connected, with good links. o Most of site is in flood zone 1, a small part is in a flood plain and this will be omitted from development. o There are existing utilities links. o Development will have a limited impact on the significance of two listed buildings -outweighed by need for housing in area. o Herts Wildlife Trust confirms the site no longer meets designation criteria and planning policy designation has been removed. o Landform has a track record of public engagement has met with a number of stakeholders. o Site available, suitable and deliverable for residential development in the short and medium terms (0-5 years).

Main Issues o Impact of to 140 extra cars - double the number of cars existing onto Bulls Lane. o Site assessed as significant for Green Belt purposes - makes a significant contribution to the visual gap between Welham Green and Brookmans Park; displays typical rural and countryside characteristics, has a high level of visual openness. o Development would harm the setting of a Grade II listed building. o Site used for recreation by local residents.

Green Belt o SKM’s Green Belt Assessment (2014) in respect of WeG6 is flawed. We previously responded to the consultation on the SKM Green Belt Assessment in October 2014, disagreeing with the findings. Landform request that the pre- submission Local Plan due for consultation later this year includes the correct analysis. Amend Green Belt Review part 2 for WeG6 in line with recommendations of SLR Landscape Consultants o Proposal contrary to national Green Belt policy and recent Ministerial Statement March 16th. o Assessed as Significant for Green Belt local purpose (Makes a significant contribution towards the visual gap between Welham Green and Brookmans Park). Proposal would narrow a sensitive and tenuous gap between Welham Green and Brookmans Park. o Assessed as significant for Green Belt National Purpose - Encroachment. (Displays typical rural and countryside characteristics and high levels of visual openness). o Not demonstrated exceptional circumstances for taking this site out of the Green Belt.

257 o Retain Green Belt boundary and land. Previous attempts in the 1990s to alter the boundary here failed, with a planning inspector finding that Bulls Lane was the natural and correct southern boundary of Welham Green. No change in precedent has occurred since. o If the site does not fulfil Green Belt purposes, the assessment should consider sustainability as a core element, as the NPPF states sustainability is a golden thread that runs through plan-making. o Find more suitable brownfield sites that do no encroach on Green Belt. There is enough brownfield land elsewhere to accommodate housing needs. o Anomalies between the SKM Green Belt assessments and WHBC’s subsequent in-house assessments of parcels of land around Skimpans. o Inconsistencies in assessing WeG6 in relation to other Green Belt sites as part of a sequential approach to assessing Green Belt sites against ‘exceptional circumstances’.

Settlement pattern o Proposed scale of development would overwhelm Welham Green. Would lose its character and cease to be a village. o Other areas in the borough are more sustainable locations for development and face fewer constraints. o Proportion of housing excessive in comparison to Brookmans Park proposals, which have similar adverse impacts. Given the obstacles to development the SHLAA identifies, lack of explanation as to why this site was found more favourable ahead of other suitable, sustainable and available sites, particularly around Brookmans Park. o Develop New Barnfield, northern parts of Welham Green around Dellsome Lane/Pooleys Lane BrP6 and BrP12 for housing instead. The New Barnfield already has the infrastructure in place. o If development is needed in Welham Green, then Marshmoor is the best alternative. o Equal distribution of new homes per settlement as a proportion of existing houses. o Reassign existing industrial areas along Travellers Lane for housing instead. o Leave existing villages alone that don’t need new development. o Use another site that does not encroach on the safety and wellbeing of existing residents. o Build a new garden village or city in North Herts/land elsewhere in the country where encroachment on the Green Belt is less likely and infrastructure and jobs can be delivered to support development. o Tell government we can only meet part of their forecast.

Infrastructure issues o Planning infrastructure after sites are allocated is unsound. Need to plan for infrastructure impacts upfront, rather than after development, which may make the site undeliverable. o Existing problems with sewage and drainage infrastructure. Infrastructure unable to cope with the proposed development and no improvements planned. Three old sewers run across this site and converge at the old sewerage junction, cannot

258

cope with the amount of sewage and pose a risk to the site, Welham Green, the Mimmshall Brook and SSSI at Water End. o Lack capacity at primary school and doctors/Potterills Medical Centre to support development. o Cumulatively with other sites would lead to significant traffic and congestion within the village.

Flooding and Water o Site within the flood zone, flooding from surface water, permanently waterlogged in winter. o Station Road, Watersplash Cottages and Mary Church floods every 1-2 years to a depth of 40cm making it impassable. Bulls Lane regularly floods, particularly around the railway bridge, making it impassable. o Raw sewage has often been seen on Skimpans field and has affected the church in the past. Surface water run-off from Holloways Lane across Skimpans has been the root cause of Thames Water Incident reports of effluent contamination. o Herts Flood Risk Management Strategy should not be compromised by developing this site. o Site within groundwater source protection zone 1. Development here would put water quality at risk. o Site has occasional spring wells and subterranean watercourses.

Site specific o Makes some sense to allocate this small area. Access should from Bulls Lane rather than Station Road to avoid loss of access to and viability of the existing community centre. o Development would destroy a recognised local heritage asset. Recent research indicates the site is an historic park and garden with relic pleasure gardens and wooded park, a typical small gentry estate of the period surrounded by pastureland o Site previously an Elizabethan Manor House, this heritage appears to be ignored. o Wastewater network capacity in this area unlikely to be able to support the demand anticipated from this development. Likely to require upgrades to drainage infrastructure. Infrastructure delivery is likely to take 18 months to 3 years to deliver (Thames Water). o Site in flood zone 2 or 3. Should direct allocations away from areas at highest flood risk, but where development is necessary make it safe without increasing flood risk elsewhere. If looking to allocate sites in flood zone 2 and 3 require a Level 2 Strategic Flood Risk Assessment (SFRA). If following the Sequential Test and assessment of flood risk, sites are allocated in flood zones 2/3 site allocation design principles and Development Management Policies should reflect Level 2 SFRA recommendations. The sequential approach should inform development layout so that more vulnerable uses such as residential are located in areas at least risk of flooding. Need to be satisfied that developments minimise the risk of flooding on and off site. Herts County Council, as Lead Local Flood Authority (LLFA), will have requirements for the ordinary watercourse watercourse on this site similar to our requirements for Main Rivers

259 o Site is an Ecosite adjacent to a grassland Ecosite ‘Playing field near Skimpans . Low opportunities for habitat creation. Retain trees or compensate for loss, potential for GI along railway embankment so seek to protect existing habitat o Local opinion opposes this site because of access and flooding issues, it being Green Belt land with a high degree of visual openness, and concerns about creating a new defensible Green Belt boundary o Holloways Lane is a very busy narrow road. Development would make matters worse. o Clarify how access arrangements will work. o The site is a Local Wildlife Site. Unclear why it been declassified as there has been no change to this site in recent years. The site should not be declassified until the Council and public are satisfied there are objective, robust reasons for this, and not until the Local Plan is adopted. o Adverse impact on protected species (Great Crested Newts, bats), other wildlife and habitats. o Adverse impact upon new residents’ amenity, health and wellbeing of due to noise and vibration from the railway. Would not meet World Health Organisation’s thresholds for noise pollution. o Site affected by contamination from the adjacent farm area. o Investigate the extent of swallow holes in the area and instability issues on the site. o Inconsistent scoring and rating within Landscape Capacity and Sensitivity Study part 2 in relation to sites in Welham Green, Brookmans Park and Little Heath, in particular WeG6 o Should have fully appraised this site in the 2012 SHLAA to highlight all issues affecting its suitability, rather than dismiss at the first stage because it is a Wildlife Site. This would have given the impression to the promoter that there were no other issues. o Remove this site from the more favourable category.

Impact on the wider area o Grade II listed farmhouse and granary (Skimpans Farm) adjacent to northern boundary of the site. Potential for development to urbanise their setting and divorce them from open agricultural land, an intrinsic part of the setting. Should consider how the setting of Skimpans Farm might be protected, through revising the boundary in the immediate vicinity or by requiring public open space to form a buffer between Skimpans Farm and new housing (Historic England). o Adverse impact on listed buildings along Station Road, including Grade II listed building (Skimpans Farm). o Proposal would result in the loss of community spirit, identity and heritage of Welham Green. o Impact on Watling Chase Community Forest as site within the eastern boundary. o One the most beautiful, rural parts of the village. Adverse impact on landscape and public views. o Adverse impact on water quality and biodiversity at Water End SSSI due to polluted run-off. o Significant highway safety concerns. Access would be off Bulls Lane, which is too narrow to serve development of this size. Used by schoolchildren, cyclists,

260

pedestrians, horse riders, and runners. There are no footpaths along Bulls Lane from Welham Green to Bell Bar/Brookmans Park. o Junction of Bulls Lane with Station Road (the triangle) is already dangerous due to traffic levels and school children crossing. Development would make matters worse. o Junction of Bulls Lane with the A1000 at Bell Bar, which new residents would use, is already dangerous and would be worse with development. o Limited opportunities for on-street parking on roads near the site. o Loss of recreational space for local residents. o Should the site be allocated, protect community centre facilities and woodland area around the community centre, improved by local groups to provide an attractive semi-natural area for wildlife and the community.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

261

16 Welham Green – Site WeG10 – Dixons Hill Road

Number of responses received 53 (General 4, Support 1, Object 48)

Support o Site should be built upon as it would encourage growth of the industrial area and local shops and greater use of the local train station.

Main Issues o Wastewater network capacity unlikely to be able to support the demand anticipated from this development. Likely to require upgrades to drainage infrastructure. Infrastructure delivery is likely to take 18 months to 3 years to deliver o Development/redevelopment of this site for residential use would not adversely impact on the historic environment o No recognised ecology sites within the site. Adjacent to Local Wildlife Site Bush Wood. Poor grassland and scattered trees, with protected species being unlikely. Potential for habitat creation (meadow, pond, hedgerows, trees, community orchard). Buffer adjacent wildlife site o Proposed development would increase traffic on Dixons Hill Road, a busy thoroughfare at peak times and affect openness of the Green Belt. Concerns with defensible Green Belt boundary due to the proximity of Dixons Hill Close o Traffic generated by 120 houses (up to 240 cars) – dramatic impact on Dixons Hill Road. o Site is subject to surface water flooding most of the year. o Adjoins wildlife site WS88 and ancient woodland to the north west o Site has high levels of visual openness o The western side of the village's Green Belt boundary would be weakened o Site not offered by the landowner and is not for sale - remove from the plan (Welham Green Residents Association). Site put forward by Welwyn Hatfield Council without the consent of the owner, who is not willing to sell this site for development

Green Belt o Green Belt boundary and land should be retained. o Proposal contrary to national Green Belt policy and a recent Ministerial Statement, March 16th. o High level of visual openness which would be lost. o Western side of Green Belt boundary would be weakened. o Not demonstrated exceptional circumstances for taking this site out of the Green Belt. o Find more suitable brownfield sites that do no encroach on Green Belt. There is enough brownfield land elsewhere to accommodate housing needs without building on this site. o Amend the Green Belt Review part 2 for WeG6 in line with the recommendations of SLR Landscape Consultants Landowner

262 o Windfall housing projections are too low. Housing projections are too high. Job creation-led scenarios are substantially lower than the projection used in the Local Plan.

Settlement pattern o Proposed scale of development is excessive and unreasonable in contrast to Brookmans Park with only 21 dwellings proposed. o Build a new garden village or city in North Herts/land elsewhere where encroachment on the Green Belt is less likely and infrastructure and jobs can be delivered to support development. o Would result in ribbon development.

Infrastructure issues o Existing problems with sewage and drainage infrastructure. Infrastructure unable to cope with the proposed development, and no improvements planned. o Lack of capacity at Primary school and doctors/Potterills Medical Centre. o Cumulatively with other sites, would cause significant traffic congestion within the village.

Site specific o Highway access and road safety issues: near a blind bend, traffic entering the village travels at high speed. Dixons Hill Road too narrow for the amount of traffic. o Impact upon adjoining Wildlife Site WS88 and ancient woodland to the North West. o Site is prone to flooding, and serves as flood plain which should not be lost. Site and adjoining housing adjoining suffer from surface water flooding. o Development would urbanise this rural area of the village. o Development would result in the loss of grazing land for the local community’s horses. o A major gas main runs across the site. o Loss of habitat and foraging for great crested newts and red kites. o Increase the site size and capacity to encourage growth and viability of services. o Leave a green corridor between the site and the recreational ground and keep a gap to the corner of the ancient woodland. o Remove this site from the plan.

Impact on the wider area o Increased traffic and congestion on Dixon Hills Road will make it difficult for emergency vehicles to access the village and site, and for residents of Welham Manor to exit on to Dixons Hill Road. o Parking in the village centre and roads near to the site will become even more difficult o Proposal would result in the loss of community spirit, identify and heritage of Welham Green. o Loss of recreational space for local residents.

263 o Increased noise pollution for existing residents. o Devalue properties which currently have an open aspect across fields.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

264

Appendix A Finely Balanced Sites – Welham Green – Site WeG4a, Marshmoor

Number of responses received 7 (General 2, Support 0, Object 5)

Main Issues o Whilst having a scruffy appearance, part of land that buffers Hatfield House Grade I Registered Park and Garden from Welham Green. Enhancement of the landscape would enhance the significance and setting of the Grade I Registered Park and Garden (Historic England). The Sustainability Appraisal underestimates the historic environment impact, rating it as only minor negative. WeG4a could potentially have a significant negative effect on the registered park and garden of Hatfield House. Recommend further development is not brought forward for this area. (Historic England). o Adjacent to Local Wildlife Site: Marshmoor Lane Grassland Strip. Potential for protected bird species in trees. No other constraints. Opportunity to retain trees and hedgerows and buffer adjacent Local Wildlife Site (Herts Ecology). o Welham Green Residents Association raise the following concerns: . Flooding on site and surrounding area. . Currently the only entrance to Marshmoor is Marshmoor Lane. Site access here would be hazardous, but if traffic were to exit to the A1000 major work would be needed to ensure safety. . Health risk of living under electricity cables. Has National Grid been consulted? . Plant species exclusive to marshlands found on site when previously considered for housing. . Should remain as Green Belt to ensure a visual barrier between Hatfield and Welham Green, and prevent dangerous traffic conditions in the surrounding area. . A new Green Belt Boundary around the site would be weaker than the existing one and lead to continuous development along the A1000. . Site assessed as significant for the national Green Belt purpose on encroachment, because it displays typical rural and countryside characteristics and high levels of visual openness. Development would narrow the gap between Welham Green and South Hatfield. . An employment site does not need to be in the Green Belt – it could go on a brownfield site.

Green Belt o Should retain Green Belt boundary and land. o Narrowing the gap between Welham Green and South Hatfield, risks coalescence. Green Belt around Welham Green and between the towns retains character and identities o Assessed as Significant for Green Belt National Purpose – Encroachment. (Displays typical rural and countryside characteristics and high levels of visual openness) o There is enough brownfield land nationwide to accommodate housing and employment needs without building on the Green Belt.

265 o Loss of greenery provided by Green Belt. Would destroy what is desirable about Hertfordshire.

Site specific o Harm to wildlife, including rare species of reeds which grow here, through loss of habitat o Area prone to flooding o Pylons and power lines would preclude or affect development. o Access dangerous from Marshmoor Lane due to narrow blind access close to the bridge. o A smaller development within the middle of the site with green edges would be a better option.

Infrastructure issues o Primary school at capacity with no scope to expand or proposals for any new or replacement school site acceptable to HCC.

Impact on the wider area o Traffic and congestion on the A1000 and Dixons Hill Road will be made worse. Road safety concerns along the A1000 where there have been accidents and fatalities due to speeding and dangerous access. o Proposals would worsen the parking situation in the village centre which is already poor. o Long-term detrimental effects.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site in isolation has not been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report) and instead is allocated as part of the larger WeG4b allocation, which is subject to Policy SADM 30 and Policy SP 23.

266

16 Welham Green – Gypsy and Traveller Sites

Number of responses received 37 (General 0, Support 1, Object 36).

Support o Support the development of traveller sites near Welham Green provided this is planned well and not an eyesore.

Main Issues o The proposal to increase the number of Gypsy and Traveller sites/pitches in the parish/ Welham Green, is a major concern o Unfair, disproportionate to concentrate almost all Welwyn Hatfield Borough sites/pitches in one location. Welham Green would have 28 of the 34 new pitches (excluding GTLAA06 at Panshanger). 80% of all pitches in one location is misguided for the settled and the Gypsy and Traveller community. A proportional approach taken for housing but not Gypsy and Traveller sites.Welham Green will have 60% of the sites in the borough. o Object to any further sites around Welham Green. Three Gypsy and Traveller sites would be excessive. Welham Green already has a number of sites and a significant traveller community. Question the need for more sites. The existing site is of a suitable size for the village and is sufficient. No further provision is needed or should be allowed around Welham Green. o Current enforcement is ineffective. Sites have more caravans than permitted, at Foxes Lane site for example. The Council should control existing sites before adding new sites. o The Foxes Lane site should have reverted to a single pitch. o Foxes Lane should remain as 3 pitches o Green Belt land should not be developed. Minister Brandon Lewis states that Gypsy and Traveller sites are inappropriate in the Green Belt. o The Local Plan excludes the temporary site at Bulls Lane. o Opportunity for a business park at Marshmoor and for the Council to work with landowners to identify potential locations for Gypsy and Traveller provision o There are other sites in the area at Potters Bar, South Mimms and Essendon. o Brookmans Park can have a site. o Two further sites are identified as an alternative to the Marshmoor development. o Sites GTLAA01 and GTLAA03 have planning problems. GTLAA03 should remain as 3 pitches. GTLAA02 should not be considered due to Green Belt impact and direct access onto the A1000.

How these views have been taken into account

267

(To clarify, the term settled community is used by the government in national Planning Policy for Traveller sites. It means the general community living in towns and villages. In this context, it does not mean a settled gypsy and traveller site, which is how some responses to the consultation appear to have interpreted its meaning).

Due to the level of need for pitches and lack of sites suitable for allocation in the urban areas, the Council considers there are exceptional circumstances to justify release of Green Belt land for housing, including Gypsy and Traveller pitches.

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

The outcomes for each Welham Green site in the LPCD 2015 are set out below.

268

16 Welham Green – Site GTLAA01 – Foxes Lane

Number of responses received 14 (General 3, Support 0, Object 11).

Main issues o No recognised ecology sites within the site. Adjacent to Ecosite (Foxes Lane). Protected species – possibly birds and reptiles. Opportunity for grassland or woodland habitat creation – buffer Ecosite. Should retain boundary along railway bank – railway bank vegetation only – ecologically sensitive. Fundamental ecological constraint – may require reptile survey o Ordinary watercourse on site falls under the jurisdiction of Herts County Council as Lead Local Flood Authority who will have requirements for development o Land between the south-west boundary of Hatfield House (Grade 1 Registered Park and Garden) and railway provides a buffer between the park and Welham Green. Whilst partly scruffy in appearance, recommend no further development in this area o Inconsistencies in the Sustainability Appraisal: GTLAA01 (and GTLAA02) assessed as potentially negative effect on the historic environment while GTLAA03 and WeG4b assessed as minor negative o Site occupied by more caravans than it is meant to have. Lack of enforcement action. o Investigate how many caravans have planning permission at present. o The site is being used to run a business. o The existing site is sufficient. Question need for more sites. o Highways issues due to proximity to the railway bridge – visibility is poor, Foxes Lane is narrow. More caravans would increase vehicular movements. o No further expansion should be allowed on Green Belt land. o The number of pitches is disproportionate to the size of the site. o Is GTLAA01 an expansion of an existing site? o Site looks overcrowded– consider a reduction in pitches. o Welham Green already hosts a number of sites – no justification for more. o Cancel any expansion – remove the site from the proposed plan.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include reen belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

269

This site in isolation has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

Policy SADM 30 and Table 14 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development.

270

16 Welham Green – Site GTLAA02 – Highdene Number of responses received 11 (Support 0, Object 7). Main Issues o No recognised ecology within site. Adjacent/close to Local Wildlife Site, Marshmoor Lane. Protected species: possibly birds in trees/scrub. Opportunities: Habitat creation – potential grassland. Retain hedgerows. Buffer to wildlife site. Ecological sensitivity: Low. Fundamental ecological constraint: none apparent (Herts Ecology). o Land between south-west boundary of Hatfield House Grade 1 Registered Park and Garden and the railway provides a buffer between the park and Welham Green. Whilst partly scruffy in appearance, recommend no further development in this area. o Appear to be inconsistencies in the Sustainability Appraisal with GTLAA01 (and GTLAA02) assessed as potentially negative effect on the historic environment while GTLAA03 and WeG4b assessed as minor negative (Historic England).

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site was withdrawn as a proposed Gypsy and Traveller site and promoted for housing as part of WeG4a. WeG4 as a site in isolation has not been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report) and instead is allocated as part of the larger WeG4b allocation, which is subject to Policy SADM 30 and Policy SP 23.

271

16 Welham Green – Site GTLAA03 – The Willows

Number of responses received 9 (Support 0, Object 7).

Main Issues o No recognised ecology within site. Opportunities limited due to size of site. Ecological sensitivity: low. Protected species: unlikely. Fundamental ecological constraint: highly unlikely. Adjacent/close to Local Wildlife Site, within 75m - Marshmoor Lane. Millwards Park Local Wildlife Site is separated by a road and other development – site may have some impact. No other features o Land between south-west boundary of Hatfield House Grade 1 Registered Park and Garden and the railway provides a buffer between the park and Welham Green. Whilst partly scruffy in appearance, recommend no further development in this area. o Inconsistencies in the Sustainability Appraisal: GTLAA01 (and GTLAA02) assessed as potentially negative effect on this historic environment while GTLAA03 and WeG4b assessed as minor negative o Disproportionate distribution to Welham Green. Further sites in and around the area would be unfair and unacceptable. The existing site at Foxes Lane is sufficient. o Unmet need unlikely to outweigh harm to the Green Belt to constitute the very special circumstances justifying inappropriate development in the Green Belt. o Would not object to existing sites if the Council enforced properly. o Access to site from very narrow road and in poor state of repair. o Failing to plan for infrastructure until sites have been allocated is unsound. o Marshmoor Lane has bad drainage. Site has been extended – causes flooding which creates access problems for Marshmoor Crescent residents. o Loss of wildlife. o Access via Dixons Hill Road which is already busy.

How these views have been taken into account

The wider area of land surrounding GTLAA03 is being removed from the Green Belt for SDS7 (see section on WeG4b above). In so doing, this site also is released from the Green Belt. The site has been assessed within the HELAA 2016 which concluded this site was suitable available and achievable. However, the site is too small to allocate in the LPPS 2016, and so it has been counted within the sources of supply for Gypsy and Traveller pitches, as a potential windfall site, within Table 6 of the LPPS, as the mixed use scheme at WeG4b would not preclude development taking place on this site.

As stated above, the overall number of proposed pitches at Welham Green is less than set out in the consultation document as site GTLA002 has been withdrawn and now forms part of the wider site WeG4b.

272

17 Brookmans Park

Number of responses received 13 (General 2, Support 1, Object 10)

Support o Brookmans Park is one of the most sustainable locations in the borough

Main Issues

Green Belt o Erode the gap between Brookmans Park and other settlements, with risk of coalescence with Little Heath, Potter Bar, Welham Green and Bell Bar o Contrary to minister’s statement in October 2014 that unmet housing need is unlikely to outweigh the harm to the Green Belt o Green Belt land was established after the Second World War to maintain our villages and to stop all the villages coalescing into one o Brookmans Park developments should not be built as there should be no building on Green Belt land

Settlement pattern o All settlements should receive allocations for new homes evenly across the borough to reduce reliance upon Hatfield and large sites. o Should leave no stone unturned in finding ways to meet housing needs. Not allocating the four sites totalling 600 homes in close proximity to Brookmans Park railway station would be a lost opportunity.

Infrastructure o Bus service is very poor in the village, with one bus per hour o Brookmans Park is already congested at peak times, with parking difficult, o There are no amenities to support the expansion. Roads, rail, shops, parking and schools are already under strain and cannot sustain new housing o The existing local infrastructure in Brookmans Park would not be suitable for large developments

Impact upon wider area o No assessment appears to have been made taking into account climate change, and flood risk of individual and cumulative sites. This particularly relates to Water End which is entirely within Flood Zones 2 and 3 and downstream of sites in Brookmans Park o Some of the identified housing sites could exacerbate the problems of surface water flooding o Some of the development sites in Brookmans Park are separated from the village and would encourage the use of cars o The developments would create significant highway concerns for pedestrians, cyclists and horse riders

273 o BrP4, 6, 7, 9 and 10 are on high ground and would smother Brookmans Park and encroach on conservation and wildlife sites and woodland

Other o There are serious inconsistencies in the Council's Landscape Sensitivity & Capacity Study (Part 2) published in October 2014 when considering conclusions drawn for sites in Welham Green (less sensitive, higher capacity) in comparison to conclusions for very similar sites in Brookmans Park (more sensitive, lower capacity) o Three suitable sites in Brookmans Park seem to have been dismissed because three ward Councillors live there

How these views have been taken into account

Following the completion of site assessment work and consideration of the benefits and adverse impacts, the LPPS 2016 sets out the following local planning objectives for Brookmans Park which the Council will take into account when considering development proposals in Brookmans Park, alongside borough-wide objectives:

 Identify and deliver necessary infrastructure improvements, in particular primary school provision and wastewater capacity, in parallel with the development process to support sustainable growth.  Improve the choice of housing with a range types, sizes and tenures, including smaller affordable homes for young people, smaller homes for older residents and specialist accommodation such as a care home or sheltered housing.  Maintain the vitality and viability of the village centre.

Brookmans Park is a large excluded village and is considered to be a sustainable location for growth due to its range of facilities and services available. This has been reflected in Policy SP 3 of the LPPS 2016 which regards Brookmans Park as being suitable for limited growth that is compatible the scale and character of the village. The LPPS 2016 makes provision for 274 dwellings at Brookmans Park over the plan period which is considered compatible with the village’s character and scale, as well as infrastructure constraints relating to primary school infrastructure. Green Belt purposes assessments have been undertaken and have informed the overall consideration of site allocations in Brookmans Park and the wider borough. Exceptional circumstances are considered to exist to justify the release of certain sites from the Green Belt around Brookmans Park. Further explanation is set out in responses relating to CS2 Meeting the Needs for Growth, CS3 Settlement Strategy and CS4 Green Belt Boundaries and Safeguarded Land of this statement

A Strategic Flood Risk Assessment was undertaken in 2015 (updated in 2016) which fully appraises flood risk and accounts for climate change. The conclusions of this

274 work have informed the LPPS 2016 strategy and site allocations, and supporting site assessment work.

The LPPS 2016 includes policies on movement and quality of development which mean that adverse impacts of development in Brookmans Park will be avoided or mitigated to an acceptable level.

275

17 Brookmans Park – Housing

Number of responses received 29 (General 1; Support 0; Object 28)

Support

Main Issues (Object to development in Brookmans Park)

Green Belt o Erode the gap between Brookmans Park and other settlements. Risk coalescence with Little Heath, Potter Bar, Welham Green and Bell Bar o Contrary to minister’s statement in October 2014 that unmet housing need is unlikely to outweigh the harm to the Green Belt o Harmful impact on the rural, open and undeveloped character of the Green Belt in this area

Settlement Pattern o Proposals would double the size of the village, changing its character and identity o Village has changed beyond recognition over the last 30 years due to recent development (e.g. RVC) o Additional 350 houses would not be consistent with a policy of gradual development – this would be a step change

Infrastructure Issues o There should be a thorough consideration of the required infrastructure to support 350 houses, e.g. train services. o Roads, rail shops, parking and school are already under strain and cannot sustain new housing o There is no public transport in the village o There is no taxi office in the village o Many of the roads in the village are privately maintained at residents’ own cost. o The shops do not service weekly shopping needs. Residents will end up driving to Potters Bar, Hatfield or Welwyn Garden City. o No local hospital.

Impact on wider area o BrP4, 6, 7, 9 and 10 are on high ground and would smother Brookmans Park and encroach on conservation and wildlife sites. o It is difficult to access the A1000 due to increasing traffic. o Junction of Golf Club Road and Georges Wood Road is already hazardous o New homes would mean more car journeys and traffic o Additional traffic would have an adverse impact on wildlife o Additional traffic would have an adverse impact on the village centre o Where will water runoff drain to? o Noise and pollution from increased traffic

276 o Loss of valuable green space which provides amenity and environmental benefits

Site specific issues o Many of the sites are inappropriate due to poor drainage and increased flood risk o Many of the sites have inadequate/poor access

Other matters o None of the proposed sites are viable in this location o You cannot be bullied by Government into forcing developments into areas that cannot sustain such encroachment. Proposals are inappropriate for an area of Great Britain that is already overpopulated o Several flats have been built in the village recently. These should county towards our additional housing requirements o Should not build on agricultural land when food security is becoming an increasing issue o A longer term solution (New Town) should be found instead of proposals that meet short term goals of local Councillors and which allow some developers to profit at the expense of local residents. Do not set up battles between villages

Main issues (Object to little or no development in Brookmans Park)

Settlement Pattern o There are insufficient sites proposed for Brookmans Park to support the intentions of CS3 or the long-term vitality of the village o Illogical and irrational that every proposed site in Brookmans Park has been excluded from the consultation for ‘More Favourable’ status. o Brookmans Park should shoulder its share of the burden. o The village has no social housing and is treated as a virtual "gated community". Social housing should be provided. o We need new houses in Brookmans Park o Brookmans Park is a highly sustainable location for housing with services and facilities that are more akin to a town than a village: the station is under used, wide range of shops, services and community facilities, and it has good road access, two schools o New homes are needed to support shops and businesses. o Why are no gypsy and traveller sites being proposed for Brookmans Park? o Difficult to understand why Little Heath and Welham Green are seen as fit for building, whereas similar sites which appear to fulfill the same criteria in Brookmans Park are deemed unfit. o New homes might make it possible for some of the children of Brookmans Park residents to find homes locally.

Infrastructure Issues

277 o A new primary school could be built and nearby secondary school could be expanded if some of the Finely Balanced site are allocated

Site specific issues o Brookmans Park has plenty of space for housing. Build housing on Brookmans Park golf course o Some of the Finely Balanced sites should be used, namely BrP4 and BrP6 which are close to the village centre and would make the village a more balanced settlement o BrP1 and 12 are the best options for the village o BrP9, 10 and 6 would have least impact on traffic and congestion in the village centre as most traffic would use Hawkshead Road o BrP13 and 14 seem viable, albeit with safety concerns

How these views have been taken into account

Please see response in the section immediately above.

278

17 Brookmans Park – Table 18 Summary Table - Brookmans Park Capacity

Number of responses received 2 (General 0, Support 0, Object 2)

Support

None

Main Issues o Object to Brookmans Park appearing to be given a different treatment to other settlements, in only having sites identified as more favourable to meet 10% of the need in Table 18 with consequent impacts for the rest of the borough. o Brookmans Park has the potential to deliver more than the OAN share.

How these views have been taken into account

The LPPS 2016 makes provision for 274 dwellings at Brookmans Park over the plan period which is considered compatible with the village’s character and scale, as well as infrastructure constraints relating to primary school infrastructure.

279

17 Brookmans Park – Site BrP14, Land East of Golf Club Road

Number of responses received 53 (General 4, Support 3, Object 46)

Support o Fits well with existing urban area. o Creating cycle routes to Chancellors school and incentivising cycling amongst pupils should be a priority. o Should make contribution to cycle way between Potters Par, Brookmans Park, Welham Green and Hatfield.

Main Issues

Green Belt o Encroachment on the countryside setting. Sets a precedent for further development on adjacent Green Belt and countryside. o Piecemeal development of the green built should be resisted. o Contrary to recent ministerial statement, NPPF para 83-85 and the PPG.

Settlement pattern o Flats developed at junction with A1000 have already met our need.

Infrastructure issues o No capacity in schools and services to absorb the additional population. o Extension Chancellors school is extended this will increase levels of traffic, congestion and parking problems in the area. o Increased demand for parking at the train station will result in more on-street parking in the village. o Increased surface water runoff and waste water placing increased stress on sewage system.

Impact of the Development on the wider area o Adjacent to Local Wildlife Sites (WS165). o Development would erode this historic site, Georges Wood and Brookmans Park historic parks. o Overlook houses nearby. o Noise and air pollution caused by construction traffic. o Increased traffic and congestion, road safety concerns. o Bring house prices down. o Adverse impact on quality of life of existing residents. o Small site, so unlikely to have sufficient parking. o Maintenance of roads is paid for privately by residents. Increased traffic will mean additional costs borne by residents without support from the Council. o Gold Club Road cannot take two way traffic.

280 o High density development would be out of character with surrounding area which has larger houses on large plots. o Impact on visual amenity. o Outside of the WHaSH transport model and mitigations measures have not been proposed or included within the draft IDP. Issue with sustainability of the location. Limited bus services in the vicinity of the site, footway provision is not continuous, and the train station is not within walking distance. These issues will need to be addressed if the site comes forward.

Site specific issues o TPOs on the site. o No access to sewage system. o Development would not adversely impact on any designated heritage assets. o Wastewater network capacity in this area which is unlikely to be able to support the demand anticipated from this development. Upgrades to the existing drainage infrastructure are likely to be required. o Adjacent to George’s Wood Local Wildlife Sites. Possible protected bird species in trees. Opportunities include retaining trees. High priority for habitat creation for grassland and woodlands, possibly and orchard due to proximity to housing. Buffer Local Wildlife Site.

Sustainable Development issues o Outside of the village core.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

Policy SADM 31 and Table 15 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development .

281

Appendix A Finely Balanced Sites Brookmans Park – Site BrP1, Land at Bell Lane

Number of responses received 79 (General 2, Support 1, Object should be more favourable 4, Object should be Less Favourable 1, Object should not be considered 71)

Support o Access problems. o Assessed as Significant for Green Belt local purpose as it makes a significant contribution towards the visual gap between Bell Bar and Brookmans Park.

Main Issues

Site specific o Site unlikely to have an adverse impact on any designated heritage assets. o Potential for protected reptile species. Reptile survey may be needed. o Opportunity for habitat creation.

Object – should be More Favourable o Bell Bar is a sustainable location given proximity to a number of services and amenities within Brookmans Park, which is itself the most sustainable location in the borough for development. o The site makes limited or no contribution to national Green Belt purposes and the local purpose. o Site would not narrow gap between Brookmans Park and Welham Green. o Site falls within the Brookmans Park urban area, in terms of the county’s Landscape Character Areas. o Area between the site and the existing Green Belt boundary has already been developed for housing. o No highway access or capacity issues are anticipated; Bell Lane could be improved through land in the promoter’s ownership, and it could be widened to create a new pavement. o There are bus stops adjacent to the site, with the opportunity to create new bus laybys on land within the promoter’s ownership. o Visual and noise impact from the A1000 would be mitigated by a bund and landscaping. o New footpath and cycle ways connecting the site with the village, Chancellors School and Golf Club Road are being proposed on land within the promoter’s ownership. o There are no planning or environmental designations, or ecological constraints, affecting the site. o Site is assessed as medium for landscape sensitivity, low for landscape value (in contrast to WHBC’s assessment of medium), and medium to high capacity to accommodate change. o Site could be delivered in the next five years.

282 o Sustainable location and site for development, should be designated More Favourable. o Assessed as suitable in the 2014 SHLAA, and is more suitable than other sites deemed More Favourable, therefore Council’s assessment of sites is inconsistent. o Attached to urban area, surrounded by existing development, and close to secondary school and the village. o Good road access and access to bus service on A1000.

Object – should be Less Favourable o Development here would change the character of Bell Bar from a historic rural hamlet.

Object – should not have been considered

Green Belt o Exceptional circumstances for release of Green Belt have not been demonstrated. o An alternative Green Belt boundary would need to include land (including woodland) between the site and existing urban area, which it is not necessary to release. o Assessed as Significant for Green Belt local purpose as it makes a significant contribution towards the visual gap between Bell Bar and Brookmans Park. o More north/south ribbon development along A1000 – increases coalescence with Welham Green and Hatfield.

Settlement pattern o Would turn Bell Bar from a hamlet into a village. o Not sustainable – Bell Bar has no amenities and is not within walking distance of the village centre, amenities and train station which are over a mile away. o There are other viable alternative locations in the borough.

Impact of the Development on the wider area o Bell Lane is unsuitable for extra traffic. Change the rural character of Bell Lane to urban/suburban. o Generate additional traffic, congestion and inappropriate parking on Pine Grove and Bell Lane. o Additional traffic making it more difficult to exit on to the A1000, which is already a very busy road. o Additional traffic heading into Brookmans Park centre along unsuitable private roads (Georges Wood Road, Brookmans Avenue). o AI Dairies Home Farm is integral to Bell Bar, and development would mean the loss of equestrian services for local residents and employment associated with the business.

Site Specific

283 o Access problems. o No public transport serving the site.

Infrastructure o Schools and doctor surgery are already oversubscribed, additional development would place further stress on these services.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

In particular, development of this site was also considered to contrary to Policy SP 3 and the proposed Settlement Strategy for the borough in that it would result in significant disproportionate growth of a small washed over settlement.

284

Appendix A Finely Balanced Sites Brookmans Park – Site BrP4, West of Brookmans Park

Number of responses received 113 (General 4, Support 0, Object should be More Favourable 5, Object should be less favourable 0, Object should not have been considered 104)

Support

None

Main issues o This site is unlikely to have an adverse impact on any designated heritage assets. o Adjacent to Local Wildlife Site Brick Kiln Wood and Ecosite E. of Brick Kiln Wood o Opportunities for potential habitat creation, buffer Local Wildlife Site and Ecosite. o There is an ordinary watercourse on this site. The LLFA will likely have requirements for development around ordinary watercourses that are similar to our requirements for main rivers. o The ‘least worst’ option acceptable if a smaller scale development with reduced dwelling numbers. o Close to village centre and access to public transport. o Key considerations should be design and character, road layout and infrastructure, and the site boundary must be permanent and defensible with a tree belt to reduce visual impact.

Object (should be More Favourable) o Site is suitable, available and achievable. o Site does not conflict with NPPF policy provisions. o Development here would not threaten the Green Belt objective of preventing towns from merging o It is not of any particular beauty or charm, does not contribute to any "great views" or significant points of access to the countryside. o Access would not add traffic to the village, damage village amenity or result in any "short cut through" situations. o Development on this site would have minimal visual impact on existing residents of the village. Loss the green space would be a far less upsetting loss than the view over Brookmans Park from Hawkshead, which would be lost if the Southern sites were to be developed. o Developing the site would balance the shape of the village, with the village centre more logically "at the centre". o If development is needed in the village, this is the best site. o Brookmans Park is a very sustainable location for development o Site is within walking distance of and has excellent access to shops, the railway, primary school and other facilities in the village centre. o Site is screened by woodland, minimizing landscape impact. o Clearly defined boundary preventing further development and risk of future coalescence.

285 o Development would enable improvements to the bridge, improving the entrance to the village and the costs of doing this would be borne by the developer.

Object (should not have been considered)

Green Belt o Risk of coalescence of Brookmans Park with Welham Green o Contrary to national Green Belt purposes – unmet housing need does not constitute very special circumstances o New Green Belt boundary would be weaker o Assessed as Significant for Green Belt local purpose o Assessed as Significant for Green Belt National purpose – Encroachment o Low capacity to accommodate landscape change and is assessed as having high sensitivity o Narrowing of gap between Brookmans Park and Welham Green – risk of future coalescence o Risk of coalescence with RVC site to the southwest o Urban sprawl, with loss of village identity

Settlement pattern o Detached from Brookmans Park by railway o Would result in Brookmans Park losing its village identity

Impact on wider area o Adjacent to Wildlife Site which is an Ancient Woodland o Within 250m of Potterells Wood Wildlife site o Area is of significant wildlife value for rare species o Impact on attractive and undeveloped countryside which would lose its character, loss of recreational spaces and a healthy environment o Risk of creating precedent leading to further development in the countryside o High density development next to flood plain, with Flood zone 2 and 3 along southern boundary o Increased surface water runoff from the site with increased risk of flooding along the Mimmshall Brook and within Water End, which already floods. The Environment Agency make it clear that it is impossible for SuDS to control flood runoff for all rainfall events o Increased traffic and congestion o Creation of new access and traffic measures would change nature of road from rural to semi-urban o Significant highway safety concerns Bradmore Lane and Warrengate Road are inadequate width the serve a development of this size. o Lies within 10km of a SAC o Alter the character and tranquility of Water End o Impact on the five Grade II listed buildings on Warrengate Road o Potential adverse impact on the Water End SSSI

Site specific

286 o The land is in agricultural use and should be kept for food production o Site is within an inner ground source protection zone. Mitigation may be necessary to minimise any risk of pollution o Potential for noise pollution from railway which may need to be mitigated o Site floods in the winter with surface water, stretching across Bradmore Lane

Infrastructure o Access to the site and village would be via a bridge over the railway and there is currently uncertainty about the viability of achieving suitable vehicular and pedestrian access across the railway line. New houses at BPLH44 have precluded upgrade to the bridge. o Would require footpath improvements along the length of the site. o Current infrastructure cannot support the number of new dwellings proposed.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

287

Appendix A Finely Balanced Sites Brookmans Park – Site BrP6, Land at Bluebridge Road

Number of responses received 130 (General 3, Support 67, Object should be more favourable 3, Object should be less favourable 0, Object should not have been considered 57)

Support finely balanced assessment

Green Belt o Assessed as Significant for Green Belt local purpose o Assessed as Significant for Green Belt National purpose – Encroachment. o Low capacity to accommodate landscape change. o This site lies within the strategic Green Belt gap between Hatfield, Little Heath and Potters Bar o No strategic green wedge can be incorporated into the site.

Impact upon wider area o Creation of new access and traffic measures would change nature of road from rural to semi-urban. o It is not within easy walking distance to the station, shops, schools, and medical centre. o Flood zone 3 along the northern boundary of the site. o A number of trees are protected by a preservation order. o Within 120m of Moffats Meadows Wood Wildlife site; 300m from registered historic park and garden.

Site specific o The steep slope of the site means that any new dwellings would overlook and look down into the houses and gardens in The Gardens, and some in Oaklands Avenue and Westland Drive. o The very steep slope of the site will increase build cost and increase the sale price. o Land is in agricultural use. o There is a public footpath around the field regularly used by walkers, dog walkers and joggers. o Site is within an inner ground source protection zone. Mitigation may be necessary to minimise any risk of pollution. o Proximity of the railway means there is a potential for noise pollution which may need to be mitigated. o Can only accommodate 170 dwellings.

Infrastructure o It is only accessible to the station and shops by narrow road bridge with very narrow pavements.

288 o No current infrastructure, including flood water management, to support the number of new dwellings proposed. o Pinch point at entrance to village will need addressing.

Object (should be more favourable) o Suitable, available and achievable as a site for future residential development. o Site does not conflict with NPPF policy provisions. o Brookmans Park is a very sustainable location for development o Infrastructure is adequate to support development o Development of Hat1 has been deemed acceptable, thus development on the site that includes Raybrook Farm should be considered similarly.

Object (should not be considered)

Green Belt o Assessed as Significant for Green Belt local purpose. o Assessed as Significant for Green Belt National purpose – Encroachment. o Low capacity to accommodate landscape change. o This site lies within the strategic Green Belt gap between Hatfield, Little Heath and Potters Bar and would contribute to a significant cumulative impact on coalescence between settlements. o Risk of coalescence with RVC site to the southeast. o No strategic green wedge can be incorporated into the site.

Settlement pattern o Would result in Brookmans Park losing its village identity.

Impact upon wider area o Risk of coalescence of Brookmans Park with Welham Green and Potters Bar/Little Heath. o Registered landscape around Gobions estate would be substantially harmed. o The steep slope of the site would overlook and look down into the houses and gardens in The Gardens, and some in Oaklands Avenue and Westland Drive. o Within 120m of Moffats Meadows Wood Wildlife site, 300m from registered historic park and garden. o High density development next to flood plain, with Flood zone 3 along the northern boundary. Increased surface runoff from the site sloping downwards toward the brook, with increased risk of flooding along the south side of The Gardens. o Increased traffic and congestion. o Creation of new access and traffic measures would change nature of road from rural to semi-urban. o A number of trees are protected by a preservation order. o Significant highway safety concerns – used by many pedestrians, cyclists and horse riders.

289

Site specific o Land is in agricultural use and should be kept for food production and food security. o Site is within an inner ground source protection zone. Mitigation may be necessary to minimise any risk of pollution. o There is a public footpath (No: 11) around the field regularly used by walkers, dog walkers and joggers. o Proximity of the railway means there is a potential for noise pollution which may need to be mitigated. o Evidence of contamination from polluted runoff from the railway line – would add cost to any development. o How these views have been taken into account. o Can only accommodate 170 dwellings.

Infrastructure o Local schools currently oversubscribed. o Current infrastructure cannot support the number of new dwellings proposed. o It is only accessible to the station and shops by narrow road bridge with very narrow pavements.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

290

Appendix A Finely Balanced Sites – Brookmans Park – Site BrP12, Peplins Wood 17

Number of responses received 141 (General 2, Support 0, Object should be more favourable 7, Object should be less favourable 1, Object should not be considered 131)

Support

None

Main Issues o These sites are unlikely to have an adverse impact on any designated heritage assets o Site is an Ecosite and adjacent to Local Wildlife Site and Ecosite. o Within 500m of Great Crested Newt breeding pond. Survey may be required. Opportunities for creating green infrastructure links between sites for ecological interest. Buffer the adjacent Local Wildlife Site and Ecosite.

Object (should be more favourable) o Site should be designated as More Favourable, with delivery within 5 years. o Existing highway network can accommodate proposed development without need for mitigation, as per advice from Herts Highways. o Fire and Rescue service has confirmed emergency access is acceptable. o The scheme could be adopted that limits the extension of the Green Belt boundary to east of the settlement edge. o Site has medium to high capacity within the landscape, so appropriately designed development could be accommodated with some mitigation. o Site does not contribute partially or significantly to any national Green Belt purpose or the local purpose. o A new primary school or care home could be provided for. o If development is needed in the village, this is the best site. o Brookmans Park is a very sustainable location for development. o Site is within walking distance of shops, the railway and primary school. o It would not increase the perceived size of the village, visual intrusion or risk of coalescence as it is enclosed by mature trees, the golf course and existing development, unlike BrP4 and BrP6. o New boundaries are all permanent o Impact of traffic and congestion would only be in peak hours, and existing problems caused by commuters will be overcome by forthcoming parking controls in Bradmore and Peplins Way. o Low value agricultural use. o Assessment of sites has been inconsistent. o Development here would provide a new 2FE primary school and scout hut.

Object (should be less favourable) o Narrowing gap between Brookmans Park and Welham Green.

291 o Adjacent to ancient woodland and Wildlife Site, with numerous species adversely affected. o Peplins Way and/or Bradmore Way are very narrow with no prospect of widening, and already experience severe traffic and congestion beyond their design capacity. Additional traffic would adversely affect road safety. Emergency vehicles would not be able to access the site. o Bottleneck where Peplins Way and Bradmore Way meet in the village centre causes congestion. o Increased risk of flooding from surface water to nearby properties due to slope of the site o Development would increase strain on school, refuse collection, doctors and hospitals, national grid o Water company stated they could not guarantee further water supply for more houses here. o Bus service is very poor and is not an alternative to travelling by car o Gas main runs across the site which would need be accessed in emergencies

Object (should not be considered)

Green Belt o Risk of coalescence of Brookmans Park with Welham Green o Green Belt should be retained in the South East to protect identities of villages as separate settlements o Significant contribution to a national Green Belt purposes and the local Green Belt purpose o Assessed as having a low capacity to accommodate landscape change. o Narrowing gap between Brookmans Park and Welham Green o High levels of visual and physical openness will be lost

Impact upon wider area o Adjacent to ancient woodland and Wildlife Site with numerous species adversely affected o Close proximity to Wildlife Site o Peplins Way and/or Bradmore Way are very narrow with no prospect of widening, and already experience severe traffic and congestion beyond their design capacity. Additional traffic would adversely affect road safety for existing residents, pedestrians and users of the school. Emergency vehicles would not be able to access the site. o Bottleneck where Peplins Way and Bradmore Way meet in the village centre causes congestion. o Construction traffic using Peplins Way and Bradmore Way would represent an unacceptable road safety risk. o New dwellings may overlook existing dwellings in Peplins Way and Bradmore Way due to the sloping nature of the site o Parts of the site are at risk of flooding from surface water. o Increased vehicle movements to the village centre given the distances to parts of the site

292

Site specific o Site is within Ground Water Source Protection Zone o Large areas of site are at risk of flooding from surface water o Land is in agricultural use o Potential for noise pollution from railway, which will need to be mitigated o Unclear what number of dwellings are being proposed for this site o Gas main runs across the site which would need be accessed in emergencies

Infrastructure o There isn’t adequate sewerage capacity or facilities for the extra houses. o Development would increase strain on school, refuse collection, doctors and hospitals, national grid. o Water company stated some years ago that they could not guarantee further water supply for more houses here. o Strain on railway services – Brookmans park station may not be able to take modern trains. o Bus service is very poor and is not an alternative to travelling by car. o We do not need more four and five bedroom houses. We need affordable homes.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

293

Appendix B Less Favourable Sites – Brookmans Park – Site BrP2, Land North East of Great North Road

Number of responses received 58 (General 2, Support 2, Object should be more favourable 0, Object should not be considered 54)

Support o Not sustainable - site is a long way from village centre, leading to car use o Highways concern - access to the Great North Road Would lead to continuous development along Great North Road o Risk of coalescence of Brookmans Park with Welham Green and Potters Bar/Little Heath. o Poorly located in respect of the village centre. o Urban areas would not be joined to the village.

Main Issues o This site is unlikely to have an adverse impact on any designated heritage assets. o Potential for protected birds species. o Opportunity for grassland creation/management.

Object, should not be considered

Green Belt o Exceptional circumstances for release of Green Belt have not been demonstrated. o An alternative Green Belt boundary would need to include a much larger area of land and new boundaries would be much weaker. o Assessed as Significant for Green Belt local purpose. o Partial contribution to purpose of protecting countryside from encroachment. o More north/south ribbon development along A1000 – increases coalescence with Welham Green and Hatfield.

Impact upon wider area o Bell Lane is unsuitable for extra traffic o Generate additional traffic, congestion and inappropriate parking on Bell Lane o Additional traffic making it more difficult to exit on to the A1000 o Additional traffic heading into Brookmans Park centre along unsuitable private roads

294

Site specific o Access problems. o No public transport serving the site.

Infrastructure o Schools and doctor surgery are already oversubscribed, additional development would place further stress on these services.

How these views have been taken into account

This site is considered to be unsuitable and unachievable (HELAA 2016) and therefore has not been considered for allocation within the LPPS 2016.

295

Appendix B Less Favourable Sites – Brookmans Park – Site BrP9, Friday Grove

Number of responses received 84 (General 2, Support 2, Object should be more favourable 4, Object should not be considered 76)

Support o Adjacent to two wildlife sites o Creation of new access and traffic measures would change nature of road from rural to semi-urban o Assessed as significant for Green Belt local purpose and Green Belt national purposes o Narrowing of gap between Brookmans Park and Little Heath; risk of coalescence of Brookmans Park with Welham Green and Potters Bar/Little Heath o Detached from existing settlement in Brookmans Park o Poorly located in respect of the village centre.

Main Issues o Development of this site is likely to result in harm to the setting of Gobions Grade II Registered Park and Garden which adjoins the site. We recommend that these sites are not brought forward for development. o Potential for protected birds species. Opportunity for grassland creation/management.

Object (should be more favourable) o New Green Belt boundaries would be strong and defensible. o Would not lead to increased coalescence. o Low level of visual openness and would be screened. Natural features would be retained to limit visual impact. o Sensitive design could mitigate cumulative Green Belt impact and impact on Gobions. o Sustainable location. o Every part of the borough needs to take its share of development. o Site and Brookmans Park is the most sustainable location for development in the borough, with infrastructure already in place o Within 700m of the village centre and its amenities and services. o Development is needed to support shops to remain in business. o Would not result in additional traffic and congestion in the village centre. o Screened by mature trees, which could be added to in order to meet requirements of Watling Chase Community Forest. o Allocate site for housing rather than as a gypsy and traveller site as the latter would make homes unsaleable.

Object (should not be considered)

Green Belt

296 o Retain Green Belt for the purposes it was created for. o The site does not benefit from any strong features which could provide a logical and defensible Green Belt boundary. o Assessed as Significant for Green Belt local purpose and Green Belt National purpose – Encroachment/Historic setting. o Narrowing of gap between Brookmans Park and Little Heath/Potters bar o Site has high levels of visual openness. o Exceptional circumstances for release of Green Belt have not been demonstrated.

Settlement Pattern o Detached from existing settlement in Brookmans Park.

Impact upon wider area o Countryside provides a beautiful, historic and essential antedote to the built up landscape of London and urban areas, recreational spaces and a healthy environment. o Creation of new access and traffic measures would change nature of road from rural to semi-urban. o Agricultural land that is valuable for food production. o Adjacent to two Wildlife Sites and Gobions Wood Nature Conservation Area.

Infrastructure o Road and rail services cannot absorb extra population o Traffic and congestion are already very bad on local roads. o Noise and air pollution from additional traffic would be intolerable in Bradmore Green. o Schools are already oversubscribed.

How these views have been taken into account

This site is considered to be unsuitable (HELAA 2016) and therefore has not been considered for allocation within the LPPS 2016

297

Appendix B Less Favourable Sites – Brookmans Park – Site BrP10, Raybrook Farm

Number of responses received 82 (General 2, Support 3, Object should be more favourable 3, Object should not be considered 74)

Support o Highly inappropriate location for development. o Impact on grassland immediately adjacent to Gobions Wood which is a recognised Wildlife Site and Nature Conservation Area. o Development would isolated and intrude into open countryside around Gobions. o Part of Ecosite: Raybrook Farm meadow Adjacent to County Wilidlife Site Moffats Meadow. o Possible protected bird species in hedgerows. Opportunities include retaining hedgerows and grassland creation. o Risk of coalescence of Brookmans Park with Welham Green and Potters Bar/Little Heath. o Poorly located in respect of the village centre. o Impact on historic setting. o Adjacent to two wildlife sites o Creation of new access and traffic measures would change nature of road from rural to semi-urban o Assessed as significant for Green Belt local purpose and Green Belt national purposes - encroachment/historic setting. o Narrowing of gap between Brookmans Park and Little Heath o Detached from existing settlement in Brookmans Park

Main Issues o Development of this site is likely to result in harm to the setting of Gobions Grade II Registered Park and Garden which adjoins the site. We recommend that these sites are not brought forward for development. o There is an ordinary watercourse on this site. The LLFA will likely have requirements for development around ordinary watercourses that are similar to our requirements for main rivers.

Object (should be more favourable) o New Green Belt boundaries would strong and defensible. o Would not lead to increased sense of coalescence. o Low level of visual openness and would be screened. Natural features would be retained to limit visual impact. o Sensitive design could mitigate cumulative Green Belt impact and impact on Gobions. o Sustainable location. o Every part of the borough needs to take its share of development. o Site and Brookmans Park is the most sustainable location for development in the borough o Within 700m of the village centre and its amenities and services.

298 o Development is needed to support shops to remain in business.

Object (should not be considered) o Registered landscape around Gobions estate would be substantially harmed.

Green Belt o Retain Green Belt for the purposes it was created for. o The site does not benefit from any strong features which could provide a logical and defensible Green Belt boundary. o Assessed as Significant for Green Belt local purpose and Green Belt National purposes – Historic setting; displays typical rural and countryside characteristics. o Area of Green Belt already has a lot of developed land within it (Swanley Bar, Boltons parks Farm, RVC campus, car park and playing). Narrowing of gap between Brookmans Park and Little Heath/Potters bar. o Site makes significant contribution to visual gap and openness between Brookmans Park and Little Heath/Potters Bar.

Settlement pattern o Detached from existing settlement in Brookmans Park

Impact upon wider area o The site also suffers the same cumulative impacts from development around Brookmans Park as identified for BrP6. o Change nature of area damaging the community. o Creation of new access and traffic measures would change nature of road from rural to semi-urban. o Adjacent to two Wildlife Sites and Gobions Wood Nature Conservation Area. o Harmful impact on the setting of the adjacent Gobions Wood Historic Park and Garden. o Increase likelihood of flooding at Water End.

Site specific o High density development on a flood plain.

How these views have been taken into account

This site is considered to be unsuitable (HELAA 2016) and therefore has not been considered for allocation within the LPPS 2016

299

Appendix B Less Favourable Sites – Brookmans Park – Site BrP13, Land West of Golf Club Road

Number of responses received 44 (General 2, Support 0, Object should be more favourable 2, Object should not be considered 40)

Support

None

Main Issues o Unlikely to have an adverse impact on any designated heritage assets. o Part of Brookmans Park Golf Course Ecosite. Potential for protected bird species in adjacent trees. Opportunities for planting.

Object (should be more favourable) o Exceptional circumstances exist for Green Belt boundary change. o Insufficient land in the Brookmans Park to meet objectively assessment need for the village. Site would provide much need housing on a suitable and sustainable site. o Highway concerns cited in SHLAA have now been addressed. o Limited contribution to Green Belt purposes. o Landscape is of medium sensitivity so can accommodate development without undue harm. o Sustainable location close to services, amenities and public transport o Well related to the existing urban area. o Screened from open countryside to the north by trees. Site is distinct from the open countryside. o Fits well with existing urban area.

Object (should not be considered) o Significant safety concerns. Golf Club Road is inadequate width to the serve a development of this size. Many children walk to and from school along Golf Club Road, which has not footpath. o Maintenance of roads is paid for privately by residents. Increased traffic will mean additional costs borne by residents without support from the Council.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

300

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

301

18 Little Heath

Number of responses received 11 (General 1, Support 0, Object 10).

Main Issues

Green Belt o Development will contribute to coalescence and weaken the existing Green Belt boundary o Object to loss Green Belt, it should be protected. o Visual impact of the development on the Green Belt. o Planning minister has stated housing need is not sufficient reason to build on Green Belt land. o Erodes a fragile Green Belt gap between Brookmans Park and Little Heath - elsewhere in the borough development has been ruled out for this reason. o Natural Capital Committee emphasise the importance of maintaining Green Belt and enhancing access.

Settlement pattern o Develop a garden city further north, outside Green Belt, where infrastructure is less constrained. o New development will eradicate gap between Little Heath and Swanley Bar. o Little Heath receives a disproportionate amount of borough’s housing requirements.

Infrastructure issues o Sites in Little Heath outside WHaSH model so cannot assess using this model. Need pinch point assessments in the local highway network that may be impacted most - A1000 / Hawkshead Road Junction. A1000/ Church Road and Darkes Road/ Mutton Lane junctions are congested, at capacity. Will need bus infrastructure improvements o Increasing Little Heath by over 30%, which has no employment, facilities or shops will increase congestion on roads already at capacity. Impact on local residents o Roads cannot cope with more traffic, particularly around Lochinver House School, Osbourne Road and Darkes Lane. A safety issue. Difficult to park, particularly at Potters Bar Station. Infrequent bus services. Development would be car dependent, adding to congestion. o No local services- hospitals, doctors, shops and employment. Schools in Little Heath and Brookmans Park at capacity and feasibility for expansion unproven. Drainage and sewerage system at capacity.

Impact of development on the wider area o Ethos of the village will be ruined, like Stotfold in North Herts. o Plan presupposes problems can be resolved by links to Potters Bar - without evidence to support this. Lack of evidence of consultation with Hertsmere

302

How these views have been taken into account

Following the completion of site assessment work and consideration of the benefits and adverse impacts, the LPPS 2016 sets out the following local planning objectives for Little Heath which the Council will take into account when considering development proposals in Little Heath, alongside borough-wide objectives:

 Ensure sufficient infrastructure capacity, including primary school provision and wastewater capacity, in parallel with the development process to support sustainable growth  To promote the provision of community facilities and services.  To provide better walking facilities between Little Heath and Brookmans Park (A1000 Great North Road)

Little Heath is a small excluded village. Consistent with the proposed settlement strategy and hierarchy (LPPS 2016 Policy SP3), provision is made for a limited amount of development compatible with the settlement's place within the hierarchy. The LPPS 2016 makes provision for 141 dwellings at Little Heath over the plan period which is considered compatible with the village’s character and scale, as well as infrastructure constraints. Green Belt purposes assessments have been undertaken and have informed the overall consideration of site allocations in Little Heath and the wider borough. Exceptional circumstances are considered to exist to justify the release of certain sites from the Green Belt around Little Heath. Further explanation is set out in responses relating to CS2 Meeting the Needs for Growth, CS3 Settlement Strategy and CS4 Green Belt Boundaries and Safeguarded Land of this statement

303

18 Little Heath – Housing

Number of responses received 56 (General 0, Support 0, Object 56)

Main Issues

Green Belt o Setting a dangerous precedent by developing on Green Belt o Oppose development on Green Belt. It should be protected and kept open. Area assessed as significant against national Green Belt purpose, has high levels of visual openness. Visual impact. o Contravenes government aim to avoid building on the Green Belt. o Building on Green Belt will create urban sprawl. Could set a precedent. Should be the last resort. o Erodes Green Belt gap between villages, causing settlements to merge. o There are no exceptional circumstances for changing Green Belt boundaries in Little Heath. o Objections apparently supported by MP Grant Shapps and Eric Pickles. o Find more suitable sites elsewhere in the county, outside the Green Belt. o Prioritise brownfield before Green Belt sites.

Settlement pattern o Lack of planning coordination on a county basis or cooperation with Hertsmere. o A garden city / new town to the north or east of the county where infrastructure is less constrained would be a better option. Should be adjacent to transport links. o Hertsmere have rejected Green Belt Site S40 (next to BrP7) because it is remote from services, why is this inconsistent with the approach for BrP7? o Proportionate distribution is inappropriate. There is no evidence Little Heath’s population will increase significantly in future. Proposed increase is unsustainable. o Expanding Little Heath by 30% is disproportionate and unfair, especially given the low number of houses allocated in Brookmans Park. o Locate housing in an area with more amenities and facilities to support development.

Infrastructure issues o Infrastructure should be in place before development commences. o Schools, dentists and doctors are already at capacity. Unclear how the NHS will cope. o No local services - hospitals, doctors, shops and employment, so traffic issues will be exacerbated. No evidence how the Council will help reduce car use. o Facilities in Potters Bar are constrained and limited. o Developing the three Little Heath sites will put more pressure on congested roads, schools, parking and NHS services, damage adjoining residents’ amenity. o Road congestion - Hawkshead Road, Osbourne Road, A1000, High Street and Darkes Lane. A safety issue.

304 o Roads are poor quality, lots of potholes. Relocation of students at Royal Vet College from Camden has increased traffic in the area. o Public transport infrequent, unreliable. Proximity to bus stops irrelevant as buses are not used. o Trains from Potters Bar at capacity. o Loss of the Builders Arms Public House car park will exacerbate local parking problems. o Drainage and flooding issues on local fields and roads. Problems with local sewage system.

Impact upon the wider area o Little Heath will lose its individuality as a small, quiet historic village. o Village will disappear. It will become a conurbation with Potters Bar. o The density of development will alter the character of Little Heath o Proposed density, higher than existing housing, will change the character of Little Heath. o Increased congestion will increase pollution.

Sustainable development issues o Build on brownfield land. Consider brownfield land within the town. o Development is unsustainable in Little Heath as is too far away from amenities and employment. o Appreciate need for more housing, but identified sites are not appropriate. o Question whether housing will be affordable.

Site Specific o Unacceptable loss of wildlife (including bats, badgers), habitat and natural environment. o Will spoil beautiful views and affect property values. o Sites should all have ‘LHe’ references not ‘BrP’ references, as it’s misleading. o Process of determining site suitability is inconsistent between sites. o Covenants exist to protect land from development and must be adhered to. o Construction traffic will have a significant impact locally. o Three sites in Little Heath should be assessed as unfavourable.

How these views were taken into account

Please see the section immediately above. Please see the sections below regarding the issues and response relating the specific sites in Little Heath.

305

18 Little Heath – Site BPLH30 – Land to the rear of Builders Arms Public House

Number of responses received 36 (General 6, Support 1, Object 22).

Support o If the pub went out of business, then redevelopment for housing would be supported.

Main Issues o Wastewater network unable to cope with demand were the site to be developed. Infrastructure upgrades likely to be necessary. Upgrades can take from 18 months to 3 years to deliver o No objection, but note site adjacent to the Grade II listed London Coal Duty marker post, sited in front of 57 Heath Road o No fundamental ecological constraint; limited ecological opportunities and no ecological sensitivity. No recognised ecology sites within the site or nearby o Site reference BPLH30 [referring to Brookmans Park and Little Heath borough ward] does not reflect that Little Heath is a village in its own right. Development of the site, along with the two larger Green Belt sites in Little Heath, would have unacceptable cumulative impacts on Little Heath and Potters Bar o Developing the car park may undermine the viability of the pub, as the only public community facility in Little Heath putting it at risk of closure -xontrary to other plan aims and objectives. Question how these issues could be outweighed by the benefit of gaining just 5 new homes. o If the pub went out of business would support its reuse for housing. o The pub owners permit use of the car park by parents picking up children from Lochinver House School – lessening parking and traffic pressure at school pick up times - this would be worsened if the car park was lost. o Building 5 homes on the site would constitute overdevelopment – site too small to accommodate the detached family dwellings with sizeable gardens typical of the area. o Oppose the site being taken forward. Rather than develop a patchwork of small sites develop a new garden city elsewhere.

How these views have been taken into account

While the HELAA (2016) assesses this site as suitable, it is not proposed for allocation in the local plan as its capacity, 2 dwellings (net), is too small, below the threshold the Plan sets for site allocations. IT has been counted towards the sources of supply as a potential windfall site.

306

18 Little Heath – Site LHe1 – Land North of Hawkshead Road

Number of responses received 76 (General 4, Support 3, Object 69).

Support o The site could be a ‘least worst’ case and might be suitable. It is in the Green Belt and the site boundary must be permanent and defensible. o Site is well related to the existing built form. o Well screened, reduces the potential and magnitude for impact on the Green Belt in terms of openness and coalescence. Northern boundary can be more strongly landscaped. o Site is available and can deliver 35 dwellings without constraint. o Site size could be increased, as coalescence is not an issue here.

Main Issues o No recognised ecology sites within/adjacent to LHe1. Wooded boundary on southern edge of site is a fundamental ecological constraint of moderate sensitivity. Possible protected species (birds), but unlikely. Potential for grassland habitat creation o Grade II Listed Osbourne House opposite the site. If the existing hedgerow is retained and reinforced, development should be possible without any harm o Water End residents Group is critical of the North Mymms Parish Council response, which promotes LHe1 as the ‘least worst’ site suitable for development. o Local residents should be considered first.

Green Belt o Oppose development on Green Belt. Development of LHe1 would erode valuable Green Belt land and have a negative impact on Green Belt purposes o Development would weaken the existing Green Belt boundary o Would narrow the gap between Little Heath, Swanley Bar and Brookmans Park, create urban sprawl and coalescence between the settlements. Will remove Green Belt land, which for many years has been a barrier to the steady spread of Little Heath. o Site is assessed as significant against the national purpose of encroachment and against the local Green Belt purpose. Goes against the fundamental purposes of the Green Belt. o Loss of pleasant green spaces and recreational opportunities in the Green Belt. o Impact on the openness, character and appearance of the Green Belt, contrary to national policy in the NPPF. The area currently has a high level of visual openness. Sites around Little Heath are highly visible. Cuf 4 and 5 have been rejected on the basis of their visibility. o Eric Pickles has confirmed housing targets are not exceptional circumstances. o The Prime Minister, Eric Pickles and Grant Shapps support preservation of the Green Belt. o The claim that sufficient housing can’t be delivered on non-Green Belt land cannot be considered ‘exceptional circumstances’ or it would set a precedent.

307

Once you start building on Green Belt, where does it stop? Plundering the Green Belt is morally wrong. o Amount of Green Belt land lost is disproportionate in Little Heath.

Settlement pattern o There are likely to be far more suitable sites than LTHe1 which haven’t been promoted. o Disproportionate impact on Little Heath, compared to villages such as Brookmans Park and Digswell. An additional 180 dwellings represents a 60% increase in the number of dwellings. This is inconsistent with the proportionate approach to development in the Local Plan. o Object to Little Heath increasing in size by 30%. The new houses will be inhabited by people wanting to commute to London rather than meet Welwyn Hatfield housing need as it is on the edge of the borough. o Given that Little Heath has no open spaces outside the Green Belt and can only expand in one direction due to its boundary with Hertsmere, the proportional distribution should be half the 140 identified. o The area will feel like a London suburb rather than separate villages. Little Heath should remain as a village. o Unacceptable proportion of WHBC’s housing need on the border of Hertsmere. o Housing should be directed to Welwyn Garden City and Hatfield. Welwyn Garden City seems to get preferential treatment. It a far more sustainable growth option than the villages. o The OAN of 12,500 is too high due to assumptions made about student numbers from abroad. o A new Garden City would deliver its own services, employment and industrial land. o There are inconsistencies in site assessments. Brp4 should be reconsidered as it is close to the station and village centre. Brookmans Park School could be relocated to Brp12 and the former school site redeveloped for housing for young adults and elderly residents. LHe1 should be assessed as ‘less favourable’ and sites such as Brp4 and WeG4b assessed as more favourable given their greater proximity to meaningful village centres and train stations. o The site should be increased to fill the natural triangle between Swanley Bar Lane, Hawkshead Road and the Great North Road. The enlarged site would have better roads links and could deliver shops and infrastructure. Could deliver 350 houses. o Housing needs would be better met by development around Hatfield or a new town to the north of Hertfordshire o Develop a new Garden City in north Hertfordshire, beyond Green Belt land or on a site around Bayford/ Brickendon. o Consider sites elsewhere in the borough with employment opportunities and sufficient infrastructure, so the impact is on Welwyn Hatfield Council and residents not Hertsmere. o Reduce the number of dwellings and make provision for continued public access to the views of parkland to the north. o Sites are impossible without a special road access.

Infrastructure Issues

308

o Little Heath lacks a village centre so people will have to travel elsewhere. No confidence that Local Plan can deliver services and facilities needed to support development. Housing forecasts are too high - influenced by the number of students coming to the borough, the majority of students are unlikely to want to live in Little Heath o LHe1 will impact negatively on Hertsmere residents. Impact on Potters Bar’s infrastructure (public services, shops, schools); increased congestion around Osbourne Road, Heath Road and Church Road and two main routes in Potters Bar; loss of recreation will impact on existing residents’ amenity; flooding and drainage issues; high density out of character with existing area o Impact on infrastructure, already constrained, including water supply, sewerage, police, doctors, street cleaning, elderly care and waste collection. Little Heath has no local shops or medical services. The new development will put pressure on constrained facilities nearby. o LHe1 will increase pressure on existing infrastructure. Not large enough to deliver new facilities. o Development will put additional pressure on the roads. Local Roads (A1000, Hawkshead Road, Osbourne road, Heath Road) are very congested, particularly from school traffic (3 schools in the area), and cannot cope with more traffic. Problems on the M25 makes the situation is worse. o Will exacerbate safety issues. Roads difficult to cross. There have been several accidents at Osbourne Road and Hawkshead Road. Hawkshead Road has only a limited footpath. o New residents will drive to Potters Bar station, adding to congestion. o Limited public transport serving the area. Train service at Potters Bar is at capacity. o Schools are at capacity. o Impact on services in Potters Bar, not Welwyn Hatfield. o Hospitals (QE2 and Lister) are already at capacity and cannot accommodate increased demand. Future of Chase Farm is uncertain. Doctors’ surgeries are oversubscribed. o sewerage upgrades may be insufficient to mitigate the impact of increases to flow downstream. o Wastewater network capacity may be unable to support the demand from this development. Likely to require upgrades. Where capacity upgrades are not proposed by Thames Water, the Local Authority should require developers to provide a drainage strategy and recommendations of the strategy to be implemented prior to development. Infrastructure delivery is likely to take 18 months to 3 years

Impact of Development on the wider area o Development will increase the size of the village by 20% and have a significant impact on local infrastructure and residents’ quality of life causing problems for the local community. o Scale of proposed development out of character with Little Heath which has a residential non-urban character. o Most facilities are in Potters Bar. There is no evidence that Hertsmere have been consulted and facilities can cope.

309 o Potential wider impact on Gobions Wood. o Additional traffic will increase noise and air pollution in Little Heath and Potters Bar. o Will exacerbate parking problems on roads close to Little Heath School, Potters Bar town centre, station and on-street parking, already at capacity, would become an acute problem. o Problems with flooding on the roads during severe weather. Additional housing will increase flooding as Little Heath has poor rainwater drainage. Hawkshead road often floods.

Site Specific issues o Site is available, can deliver 35 dwellings without constraint is well related to the existing built form, well screened and reduces the potential and magnitude for impact on the Green Belt in terms of openness and coalescence Northern boundary can be more strongly landscaped o Site size could be increased, as coalescence is not an issue. o LHe1 should be a less favourable site. o Loss of existing residents’ views, open space and countryside. o Would change the rural character of the area north of Hawkshead Road. Undulating farmland is important aesthetically for the village and will result in the loss of valuable landscape. o LHe1 currently provides access to farmland for recreation. If developed, a planning condition should require part of the site to be landscaped so that people can continue to enjoy views of parkland to the north. o Negative impact on local wildlife due to loss of habitat, particularly for bats and owls. Trees are used for roosting and feeding. o Site appraisal inconsistent because sites in Brookmans Park assessed as finely balanced have similar impacts as the Little Heath sites. o LHe1 covers the access to Osbourne House Farm. The owner is 50% responsible for maintaining this access. Development of the site will alter owner’s responsibilities. They query why they were not contacted directly. Concern the value of their property may fall. o Site is close to the conservation area so should not go ahead. o Site could be a ‘least worst’ case and might be suitable. It is in the Green Belt and the site boundary must be permanent and defensible o Little Heath sites have been mislabeled by the Council to imply Brp7 is in Brookmans Park.

Sustainable development o Lack of employment in the area, including at Little Heath and Potters Bar. New residents would commute increasing pressure on the road infrastructure. o Not within walking distance of local facilities in Potters Bar. Bus services are limited. o More effort should be made to identify development opportunities on brownfield land. o Hertsmere should decide if the sites are suitable because the impact will be felt there.

310 o Unlikely to actually meet ‘need’. Young people unlikely to able to afford housing in Little Heath. o Need low-cost starter homes for people currently living with parents. Covenants should restrict excessive resale value if possible. o Assessment inconsistent because other sites distant from local centres, have been found less favourable. o Site adjacent to Brp7 is considered unsuitable and remote from services in Hertsmere’s Strategic Housing Land Assessment. o Land adjacent to playing field, owned by North Mymms Parish Council, offers a better option and money could be used to fund a Neighbourhood Plan. o Prioritise Sites where new roads and services are incorporated into development before LHe1.

Duty to co-operate o Cross boundary issues need to be addressed with Hertsmere for all sites in Little Heath.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

Policy SADM 32 and Table 16 of the LPPS 2016 set out specific provisions and requirements for when development of the site comes forward. In addition, Policy SP 13 sets out a requirement for suitable provision to be made for new or improved infrastructure to support development .

311

18 Little Heath – Site BrP7, Land South of Hawkshead Road

Number of responses received 108 (General 5, Object 102, Support 1)

Main Issues

Green Belt and landscape o Oppose development of Green Belt land, should be protected and kept open. Avoid building on the Green Belt and creating urban sprawl, which could set a precedent. Should be the last resort. o Effectively an expansion of Hertsmere, setting a dangerous precedent by developing on Green Belt o Cumulative impact on Green Belt purposes with LHe1 would be significant. Assessed as significant for national Green Belt purpose: Encroachment - displays typical rural and countryside characteristics and high levels of visual openness. o Assessed as significant for local Green Belt purpose significant contribution to visual gap between Little Heath and Brookmans Park. o Would increase coalescence between Little Heath and Brookmans Park, and Potters Bar and Brookmans Park; disproportionate for small parish ward; new development highly visible within landscape; a large land loss for the number of houses indicated o Site makes a significant contribution to protecting towns and villages from merging. Risk of coalescence– narrowing gaps between Little Heath and Brookmans Park; Little Heath and Swanley Bar; Potters Bar and Brookmans Park; Potter Bar and Hatfield (cumulatively with other sites in the corridor). Coalescence and urban sprawl would mean the loss of individual identities associated with Little Heath and Swanley Bar o New Green Belt boundary to the west (a fence) would be weaker than existing Green Belt boundaries and not defensible during and beyond the plan period. Would create a precedent and lead to further development towards the RVC campus o Inability to meet housing need outside the Green Belt does not constitute exceptional circumstances for reviewing Green Belt boundaries, for this and other sites in the borough. o Contrary to NPPF policy on Green Belt and recent Ministerial Statements. Objection to building on Green Belt is supported by David Cameron MP, Grant Shapps MP and Eric Pickles MP. o Site is on an elevated position with high degrees of visual openness and long distance views. Development would be highly visible within the landscape, with consequential impact. o Land around Brookmans Park is far less scenic and sensitive and should be allocated instead

Built and natural heritage, sense of place, local character o Site adjacent to Ecosite Field South of Bolton’s Park. Moderate ecological sensitivity in wooded areas, otherwise low. Potential for protected bird species in trees/scrub. Phase 1 habitat survey would be needed. Opportunity to retain

312

trees/scrub and pond or compensate for loss, creation of grassland or an orchard. Buffer adjacent Ecosite o Proximity of Gobions Grade II Registered Park and Garden and Grade II* listed Folly Arch - would need addressing. May be possible for some development without unacceptable harm. Require careful consideration of views to/from Gobions and the Folly arch, including retaining and reinforcing existing hedgerow and trees along the north-western boundary o Significant negative effect in conserving and enhancing the borough’s character, sense of place and local distinctiveness, historic environment, heritage, cultural assets and setting. Would need mitigation. Within 250m of Gobions Park and Garden and Folly Arch, and 1km of four listed buildings within Hertsmere (Tiverton and Seldown). Potential significant negative effect on the setting of heritage assets o Will damage adjoining residents’ amenity. Density of developments will alter the character of Little Heath

Infrastructure, highways, transport o Sites in Little Heath outside WHaSH model so cannot assess using this model. Need assessment of potential local highway network pinch-points. The A1000 (Great North Road) / Hawkshead Road junction is likely to accommodate a high proportion of vehicles generated by LHe1 and BrP7. The A1000 (Hatfield Road) / Church Road, and Darkes Lane / Mutton Lane junctions south of the sites operate at capacity and have known congestion issues. Sites likely to require to bus infrastructure improvements to support sustainable modes of transport o Wastewater network capacity unlikely to be able to support the demand from development. Likely to require upgrades to drainage infrastructure. Infrastructure delivery is likely to take 18 months to 3 years to design and deliver o Request that Welwyn Hatfield and Hertsmere residents are kept informed of the proposal, and would welcome letters being sent to residents in the immediate vicinity . The SA identifies the site as having a significant negative effect in retaining local distinctiveness and settlement pattern along with BrP1, BrP4, BrP6, BrP7, BrP9, BrP10, BrP12, BrP, WeG6, Cuf4 and Cuf5, but only BrP7 and WeG6 have been found More Favourable with the others Less Favourable or Finely Balanced. o The BrP prefix is misleading and has meant many residents were unaware of the proposal. Should rename the site with a Little Heath prefix o A restrictive covenant on the land prevents building which may be or become a nuisance or annoyance of owners/occupiers of adjoining premises. Should not therefore allow development. o Development would result in continuous development from Potters Bar via Little Heath to Swanley Bar o Social infrastructure in Potters Bar is under pressure, particularly medical services and primary schools. There are no shops in Little Heath so residents will travel into Potters Bar o Increased traffic and congestion around Osborne Road, Heath Road, Church Road, Darkes Lane particularly during morning rush house. Impact on Hatfield Road and High Street main arterial roads in Potters Bar

313 o Loss of amenity for existing residents of Green meadow, Heath Road, Kerdistone Close, Wain Close, Hawkshead Road and Osborne Road Land drainage problems would be exacerbated o Proposed density would be much higher than and out of keeping with surrounding areas o If vehicular access is via Heath Road, this would cause further chaos on Heath Rod Parkfield Ward Councillors (Hertsmere) o Potter Bar Society object as allocating this land will increase chances of Green Belt land adjacent to it within Hertsmere being taken out of the Green Belt and allocated for housing, leaving a sliver of Green Belt land isolated within Hertsmere.

Evidence o SHLAA site assessments, including BrP7, have been inconsistent with some incorrect assessments. The SHLAA should be looked at again. Other sites have been found Less Favourable due to distance from facilities being too great, yet BrP7 - an equivalent distance from services in Potters Bar - has been found suitable and More Favourable. Classification of site as More Favourable is inconsistent when compared to Brookmans Park sites also found suitable, but classified as Less Favourable or Finely Balanced. o Site was previously found unsuitable in 2012 SHLAA o Concerns with the accuracy and robustness of the Green Belt Study, as the section for BrP7 shows photos of a field which is not the BrP7 site o Landscape Sensitivity and Capacity Study is flawed. There is no assessment of the current BrP7 site in the 2014 study. Scores do not reflect the true sensitivity of the site as elevated with high visual openness. No evidence to support the Landscape Study’s conclusions with regard to BrP7. The site’s scores for landscape sensitivity and capacity to accommodate change should be higher, and consistent with assessments for other sites with similar characteristics. o BrP7 and LHe1 have similar landscape and Green Belt characteristics (elevated open position in the landscape) to Cuf4 and 5, and should therefore be rejected on the same grounds. o Over optimistic growth figure for housing - assumes the borough’s student population will increase when students are unlikely to want to live in Little Heath.

Settlement pattern o Remove the site from the Local Plan. Classify as Less Favourable, or Finely Balanced. Three sites in Little Heath should be assessed as unfavourable o Little Heath should not be a specified settlement. It has little or no services or facilities. Allocating this site and LHe1 would be contrary to the settlement strategy and CS1. o Building on Green Belt land around a small village with no services like Little Heath is illogical. Find more suitable sites elsewhere in the county, on non Green Belt land o Investigate solution of new garden city or town outside of Green Belt elsewhere in the county. o Investigate more suitable sites within the borough.

314 o Locate housing in another area, with more amenities and facilities to support development o More sites in Brookmans Park should be allocated – BrP4, 5, 6, 9 and10 o Use land owned by North Mymms Parish Council behind the playground/recreation ground instead as it is less visible. Use the money received to improve Little Heath and develop a Neighbourhood Plan o Develop a sustainable garden city / new town, outside the Green Belt, in the north or east of the county, where infrastructure is less constrained and can be designed accordingly. Would assist Welwyn Hatfield and other boroughs o Proposed level of growth for Little Heath disproportionate with expansion of 30%. Not compatible with the scale or character of the Little Heath. Proposed levels of growth in Little Heath unfair compared to Digswell, Brookmans Park and Cuffley allocations. o Development around Hatfield, Panshanger Airfield, Hertsmere or Barnet would better meet housing needs o Densify existing towns and cities o Prioritise brownfield sites before Green Belt sites. o Hertsmere have rejected Green Belt Site S40 (next to BrP7) on the basis it is remote from services, why is this inconsistent with the approach for BrP7? o Housing need should be met through rebuilding and redesigning existing housing stock and developing brownfield sites in towns throughout Hertfordshire o Build low-cost starter homes for young people, protected by covenant to keep them low-cost.

Infrastructure issues o Lack of solutions to mitigate impacts on roads and services. These should be in place before development commences. o Little Heath has no village centre. People will have to travel elsewhere for services and facilities. Any increase in Little Heath’s population needs to have services and facilities properly planned for. The draft Local Plan contains no firm proposals to address this, o The three Little Heath sites will put more pressure on congested roads, schools, parking and NHS services o Proposed scale of development is enough to create significant adverse impacts but not large enough to fund appropriate infrastructure mitigation and improvements. o Road and pedestrian safety are currently at risk due to traffic, congestion, speeding and on-street parking, particularly at peak hours, and this will be made worse. road problems are exacerbated when there is a problem on the M25/A1. Roads are severely congested at peak times and due to school-related traffic, especially Hawkshead Road, Osborne Road, Church Road, Heath Road, Darkes Lane, A1000, and the High Street. o Osborne Road and Heath Road are effectively single lane due to on-street parking, made worse during the school run at Lochinver School. These roads cannot be widened. o Heath Road would become a through road for new residents o Previous application for development at corner of Osborne Road and Church Road was refused on grounds of highway impact and safety

315 o Heath Road and Hawkshead Road have partial footpaths, presenting pedestrian safety concerns for new residents walking to services/facilities in Potters Bar and Brookmans Park train station o Parking at Potter Bar station is oversubscribed, leading to on-street parking in residential streets. o Public transport is absent or infrequent and unreliable. Proximity to bus stops is irrelevant, as bus services are poor and not really used. No train station in Little Heath. o Train from Potters Bar is at capacity. o No local services/amenities/facilities in Little Heath other than a primary school, church and pub. o Proposals take no account of the impact on Potters Bar services, already overstretched, which new residents would use and are outside of Welwyn Hatfield Borough Council responsibilities. o Little Heath School is oversubscribed and cannot expand within its current site o How will NHS cope with more residents, especially as The QEII and Chase Farm recently closed? o Sewerage systems are at capacity in this area. o Infrastructure improvements would have an adverse impact.

Site specific o Site regularly floods in the winter due to poor drainage in this area. o Loss of trees, hedgerows, meadow and pond. Significant adverse impact on wildlife, namely bats, birds and birds of prey, badgers, deer, grass snakes and foxes. o Site has previously been contaminated with raw sewerage, with it collecting in the pond. o Vehicular access from Hawkshead Road would present significant road safety issues due to current levels of speeding on this route. Vehicular access from Heath Road would exacerbate traffic, congestion and road safety risks on this road. o There is a restrictive covenant on the land preventing any building which may be or become a nuisance or annoyance of owners/occupiers of adjoining premises. Development should therefore not be allowed given it would be an annoyance to adjacent residents o Development would result in the loss of a working farm. o Site is suitable available, and achievable. Site does not conflict with the NPPF and should be allocated in the next stage of the Local Plan.

Impact on the wider area o Adverse impact on existing residents’ amenity, health and wellbeing and quality of life through increased traffic and congestion, noise and air pollution associated with new residents. o Loss of privacy for residents adjoining the site, particularly properties on Kerdistone Close. Development would reduce the value of houses nearby, in particular on Kerdistone Close which were specifically designed as upside down houses to take advantage of the view over open fields

316 o The site and other Green Belt areas provide much needed green space to counter-balance urban landscape, providing opportunities for people to escape urban living and experience the countryside. Contrary to Local Plan objective of connecting green spaces together. o Adverse impacts on Gobions Registered Historic Park and Garden and Folly Arch due to views from this site. o Risk of flooding along Hawkshead Road/Blue Bridge Road and Heath Road/Church Road would be increased by the development. Loss of rainwater storage capacity. o Development would significantly alter Little Heath’s character as an historic hamlet in a quiet rural residential setting. Little Heath will lose its individuality and classification as a small, quiet historic village. o New homes will be architecturally detrimental to Little Heath o Implied density would be out of keeping with the character of the surrounding area. o This site contributes greatly to wildlife and biodiversity. Would result in further destruction of wildlife and the planet. There should be equal consideration of the needs of nature and people. o Global warming, and increased pollution and extinction of animals, means we should not just develop all land o The relocation of students at Royal Vet College from Camden Town, and expansion of the campus, has placed great strain on Little Heath, particularly through the increased traffic.

Sustainable development issues o Unsustainable location. There is no employment or services in Little Heath. The site is not within 1400m of an employment area, so traffic will be exacerbated o Potters Bar train station is 1.6-2.2 miles away, not within walking distance of the site (more than 10 minutes walk). Further car use and traffic would result. o Site is a long distance to Potters Bar town centre. A site adjacent to BrP7 in Hertsmere was found unsuitable in Hertsmere’s SHLAA as it was too far from facilities and services. o New housing would be unaffordable for Little Heath or Welwyn Hatfield residents. They will instead be bought by Londoners who will commute into London.

Consultation process o Lack of no consultation with Hertsmere Borough Council. Consultations should be done jointly. o Proposals are a short term politically convenient solution and will compromise the future for people and nature. o Site is incorrectly labeled as Brookmans Park site through the BrP prefix. This belies its position next to Little Heath and resulted in many Little Heath residents left unaware of the proposals. o Allocations for Brookmans Park and Cuffley compared to Little Heath are based on an undemocratic decision making process influenced by senior people living in Brookmans Park and Cuffley. A conflict of interest.

Employment

317 o Lack of plans to create in employment in the area will exacerbate overcrowding on trains and congestion on Osborne Road and Hawkshead Road. o New housing should be supported by employment opportunities and, as this is not possible in Little Heath, LHe1 and BrP7 should not be considered favourable options.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

The entirety of this site has not been allocated, however a smaller portion of it has as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

318

18 Little Heath – Employment

Number of responses received 1 (General 0, Support 0, Object 1).

Main Issues o There are no plans to create in employment on the area. This will exacerbate overcrowding on the trains and congestion on Osborne Road and Hawkshead Road, as well as the extreme congestion suffered in the vicinity if the M25 becomes congested. o New housing should be supported by employment opportunities and, as this is not possible in Little Heath, LHe1 and BrP7 should not be considered as favourable options.

How these views have been taken into account

There are employment areas within Potters Bar, which Little Heath adjoins, that will help to support housing growth in Little Heath.

Decisions on which sites to allocate in the Local Plan have been informed by detailed site selection work, which has itself been informed by a number of studies, responses to the LPCD 2015 and the site appraisals within the latest Sustainability Appraisal. The issues addressed include access and highway impacts.

319

19 Cuffley

Number of responses received 3 (General 0, Support 0, Object 3)

Main issues o Cuffley’s Objectively Assessed Need is assessed as being 500 dwellings, yet total potential housing capacity is 193 dwellings. This leaves a significant shortfall against the OAN of 272 dwellings (Promoter of Cuf5). o Question whether Cuffley needs more housing. There is no need to build on the Green Belt in Cuffley. o Just because Green Belt land has been put forward as being available does not mean that it should be included and built on. Individual sites in the Green Belt should be individually assessed to see if there are any Very Special Circumstances that would justify building on Green Belt land.

How these views have been taken into account

Following the completion of site assessment work and consideration of the benefits and adverse impacts, the LPPS 2016 sets out the following local planning objectives for Cuffley which the Council will take into account when considering development proposals in Cuffley, alongside borough-wide objectives:

 Identify and secure solutions to deliver the necessary infrastructure improvements, in particular primary school provision and wastewater capacity, in parallel with the development process to support sustainable growth.  Work with the Parish Council to help take forward priorities identified in the Neighbourhood Plan.  To protect local community facilities.  Manage the volume of vehicles through the village.  Maintain the supply of employment land to provide local job opportunities.  Deliver a range of housing types, sizes and tenures to help meet housing need and demand, such as sheltered housing for older people and starter homes for young people.  Provide high quality, well designed housing which reflects local character.  Sustain and where possible, improve the vitality and viability of the village centre.

Cuffley is a large excluded village and is considered to be a sustainable location for growth due to its range of facilities and services available. This has been reflected in Policy SP 3 of the LPPS 2016 which regards Cuffley as being suitable for limited growth that is compatible the scale and character of the village. The LPPS 2016 makes provision for 299 dwellings at Cuffley over the plan period which is considered compatible with the village’s character and scale, as well as infrastructure constraints relating to highway junctions and primary school infrastructure. Green Belt purposes assessments have been undertaken and have informed the overall consideration of site allocations in Cuffley and the wider borough. Exceptional circumstances are considered to exist to justify the release of certain sites from the Green Belt around Cuffley. Further explanation is set out in

320 responses relating to CS2 Meeting the Needs for Growth, CS3 Settlement Strategy and CS4 Green Belt Boundaries and Safeguarded Land of this statement

321

19 Cuffley Housing and Table 23 Sources of housing supply for Cuffley

Number of responses received 11 (General 3, Support 1, Object 7)

Support o Proportional housing need for Cuffley during the plan period is 500 homes, but only identifies more favourable sites for 193 homes. Agree that Cuffley should not be intensively developed as this will place significant pressure on transport, education and healthcare. However, appropriate infrastructure for the new homes must still be provided. Any shortfall in housing not met in Cuffley should also be provided within Welwyn Hatfield.

Main Issues o There is a need for provision of more sheltered/warden control and potentially an elderly resident’s home o The need for additional housing is appreciated. o People are not against a manageable amount of growth in the villages; it is the amount that is being forced on them. o Table should include more brownfield sites within the village, with particular reference to the suitability for housing of the Everest offices on Sopers Road.

Green Belt o There is no need for more housing in Cuffley and no need to build on the Green Belt. o Individual sites in the Green Belt should be individually assessed to see if there are any Very Special Circumstances for building on Green Belt land. o Development on Green Belt should be resisted. The land is required for feeding an ever growing population.

Settlement pattern o There are insufficient sites allocated in Cuffley to support the intentions of policy CS3 or to support the long term diversity and vitality of the village o The housing target figure of 500 for Cuffley is too high o No land has been allocated to take such numbers of houses.

Infrastructure o Roads are in poor condition. B156 is unfit for purpose and the situation will only worse. Major traffic problems on Cattlegate Road, the B156 and Station Road. The siting of the composter has increased the number of HGVs. o The plan is not sustainable. Fails to address the issue of the provision of adequate transportation infrastructure to cope with the additional traffic o Need to provide safe access/links to and between existing rights of way. There is a need for a safe access strategy for all.

322 o The assessment of local infrastructure and identification of areas that require improvement should be the first step.

Other o The plans for housing in Cuffley do not refer to the garage site on the south side of Station Road, opposite The Meadway, with intentions to develop for housing. This site should be considered as it is not within the Green Belt. o The plan is bottom-up. o There must be a balance between “so called” affordable housing and other.

How these views have been taken into account

Please see response in the section immediately above. For response on specific sites in Cuffley, please see below.

323

19 Cuffley – Site No02, 36 The Ridgeway and land to the rear

Number of responses received 5 (General 4, Support 1, Object 0).

Support o Northaw and Cuffley Parish needs to accommodate new homes, and this site is not in the Green Belt.

Main Issues o On the information available, no wastewater capacity issues are expected o Development in proximity the the ordinary watercourse on this site will need to meet County Council requiresments, as Lead Local Flood Authority o Development will not adversely affect any heritage assets o Site has moderate ecological sensitivity, with a likely presence of protected birds and possibly protected reptiles. No recognised ecology sites within the site. Adjacent to Home Wood Local Wildlife Site. Phase 1 survey will be required pre- development to assess the site’s value and possibly a reptile survey. Development must avoid harm to the adjacent wildlife site, but has opportunities for the retention and/or compensation of existing habitat

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

324

19 Cuffley – Site No10, Land west of St Martin de Porres Catholic Church

Number of responses received 3 (General 2, Support 1, Object 0)

Support o Northaw and Cuffley Parish needs to accommodate new homes, and this site is not in the Green Belt.

Main Issues o Site has no fundamental ecological constraint; low ecological opportunities and sensitivity, unlikely to be home to any protected species with the exception of a small possibility of nesting birds. No recognised ecology sites within the site, nor nearby

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

325

19 Cuffley – Site Cuf1, The Meadway

Number of responses received 15 (General 6, Support 3, Object 6)

Support o English Heritage is satisfied that development/redevelopment of these sites for residential use would not adversely impact on any designated heritage assets and we do not wish to comment in detail on them. o Cuf1 should go ahead as it is bordered by the Borough Boundary which hopefully would then act as a brake for further development o The distribution as envisaged is consistent with sensible placing to avoid encroachment on the Green Belt and alteration of the general character of the area.

Main Issues o No recognised ecology sites within Site. Recognised sites adjacent / close to Site: Ecosite: Pasture by Burleigh Cottage. Protected species unlikely. Opportunities: limited “buffer north-east edge with Cuffley Brook and Ecosite. Ecological sensitivity: low. Fundamental ecological constraint: avoid lighting north-east boundary features, otherwise none apparent o Site in flood zone 2 or 3. Site allocations should be directed away from areas at highest flood risk, but where development is necessary make it safe without increasing flood risk elsewhere. If following the Sequential Test and assessment of flood risk, sites are allocated in flood zones 2/3 site allocation design principles and Development Management Policies should reflect the Level 2 SFRA recommendations. The sequential approach should inform the layout of development locating more vulnerable uses such as residential in areas of the site at least risk of flooding; this should be reflected in the design considerations/principles. o Wastewater network capacity unlikely to be able to support the demand anticipated from this development. Upgrades to existing drainage infrastructure likely to be required. Where there is a capacity constraint and no improvements are programmed by Thames Water, the Local Planning Authority should require the developer to provide a detailed drainage strategy informing what infrastructure is required and how it will be funded. o Cuffley is outside the area covered by the WHaSH model. As a result potential impacts cannot be assessed using this model. Cuf1 and Cuf6 may require localised modelling to assess the impact on the B156. This is due to The Meadway forming a single point of entry for Cuf1 and the narrow highway frontage along Cuf6 which limit vehicle access points. Both sites are within easy walking distance of the Cuffley rail station. o The information provided in the Local Plan states there has been a fall in population within Cuffley, this somewhat contradicts the suggestion that there is a “need” to expand the urbanisation o With our country-wide ageing population some dwellings are under occupied. This could be partly due to the lack of suitable properties for elderly homeowners wishing to down size whilst staying within their communities

326 o If housing is allowed on this site, approval should be conditional on traffic management measures being taken before the identified problem arises.

Infrastructure o The proposed field slopes steeply down towards the Cuffley Brook which has a history of flooding. Cuffley Hill is flooded several times each year. Protection of the proposed houses against flooding in the field may increase flooding further downstream at Cuffley Hill o Site has drainage problems. o There is already traffic congestion at peak times in Cuffley and this gets worse when there are problems on the M25 or the A10. o Outside of the existing parking restriction times of 11.00am 1.00pm it is often very difficult to drive up the road and virtually impossible for emergency vehicles to gain access. Parking restrictions should be increased to all day rather than just for two hours a day o It is very difficult to turn right onto Station Road with traffic coming from several directions i.e. Cuffley Hill, Station Road, Station approach, Sopers Road and the exit from the Turbo Centre and petrol stations. o Exit from The Meadway onto Station Road is already hazardous due to vehicles from both directions not observing the speed limit and the volume of traffic on Cuffley Hill, particularly in rush hour. Further developments will exacerbate the situation at the junction and increase the dangers. Road safety measures need to be implemented prior to the construction of any further Meadway properties ie at the Station Rd end and also along the length of The Meadway. Approval should be conditional on traffic management measures being taken before the identified problem arises.

Site specific o Meadway is a very narrow road, unsuitable for large heavy lorries used in the construction industry.

Settlement pattern o Proposed housing developments in Goffs Oak can only increase traffic congestion

Other o Cuff 1 (30 units) is similar in size to Cuff 6 (110 units). Concern that the number of homes will increase due to the size of the site and/or when the developer has to include affordable housing. o Restrict development of Cuff 1 to the Council's assessed 30 units. Redraw the site boundary so as to ensure a defensible boundary around the proposed 30 properties and minimize the loss of Green Belt which is valuable for arable farming. o The field contains an area previously used for gravel/clay extraction described as 'Potentially contaminative industrial uses'.

327

Green Belt o Object to encroachment of the Green Belt and to developing this site for housing. o As well as Green Belt, this is farmland used to produce food for an ever increasing population.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

328

Appendix A Less Favourable Sites – Cuffley – Site Cuf4, Cuffley Hills Farm

Number of responses received 4 (General 1, Support 1, Object should be more favourable 1, Object should not be considered 1)

Support o Location inappropriate for development. Impacts upon what could be older grassland immediately adjacent to Dell Local Wildlife Site; Intrudes into open countryside Recognised ecology site within Site: Ecosite: Cuffley Hills Farm Meadow: adjacent to County Wildlife Site: The Dell (Cuffley). Other features: grassland. Survey for reptiles may be required (Herts Ecology).

Main Issues o Residential development on these sites unlikely to have an adverse impact on designated heritage assets

Object should be more favourable o Cannot understand why Cuf4 have been found less favourable, should be considered to be more favourable for development o Every part of the borough needs to take its fair share of housing. o These sites all have good connection to the local train station and good links to the road network o Discounting these sites in favour of sites with less current infrastructure makes no sense at all.

Object should not be considered o This is prime Green Belt land. There are no "special circumstances" or legal basis under which development of this Green Belt land should be permitted.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

329

This site has not been allocated as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

330

Appendix A Less Favourable Sites – Cuffley – Site Cuf5 Land West of Northaw Road East

Number of responses received 10 (General 3, Support 0, Object should be more favourable 4, Object should not be considered 1)

Support

None

Main Issues o Residential development on these sites unlikely to have an adverse impact on designated heritage assets o Site in flood zone 2 or 3. Site allocations should be directed away from areas at highest flood risk. Where development is necessary make it safe without increasing flood risk elsewhere. To allocate sites for development in flood zone 2 and 3 require a Level 2 Strategic Flood Risk Assessment (SFRA). If following the Sequential Test and assessment of flood risk, sites are to be allocated in flood zones 2/3 site allocation design principles and Development Management Policies should reflect the Level 2 SFRA recommendations o Site is on or adjacent to a main river. The Water Framework Directive (WFD) requires the restoration and enhancement of water bodies to prevent deterioration and promote recovery of water bodies. Development should leave an appropriate naturalised buffer strip to these watercourses. This will help protect biodiversity and improve green infrastructure; rivers provide green corridors for a variety of important species. Watercourses in culvert should be deculverted wherever possible and re-naturalised as part of a development to re- establish river and bankside habitat and the continuity of the river corridor o Appears less ecologically constrained than Cuf4. No recognised ecology sites within site. Adjacent: Ecosite: Cuffley Hills Farm Meadow. Protected species unlikely. Opportunities: potential for habitat creation. Low ecological sensitivity and constraints

Object should be more favourable o Promoter on behalf of Cuf5: Evidence has been assessed incorrectly. The site’s considerable merits for release have been not been accurately reported or given sufficient weight. Cuf5 makes only a limited contribution, at best, to the wider strategic role and function of the Green Belt. o The subject site forms a logical and natural extension to the built up area o A gap of 0.9 miles would be maintained between Cuffley and Northaw, with a new physically robust boundary being formed by Hempshill Brook o The site comprises poor quality agricultural land, with defensible boundaries which would help prevent encroachment into the surrounding countryside o It will provide a significant level of ecological and environmental enhancement; o A truly zero carbon solution to development well situated in close proximity to public transport networks; o Proposal is for a mixed use scheme with valuable social and community infrastructure;

331 o Development of this site would be an exemplar of high quality sustainable design. o Cannot understand why Cuf4, Cuf5 and Cuf7 have been found less favourable. These sites all have good connection to the local train station and good links to the road network o Every part of the borough needs to take its fair share of the housing allocation o Discounting these sites in favour of other sites with less current infrastructure makes no sense. o Disagree that the site makes a significant contribution to protecting the countryside any more than site WGC4. The impact of just developing Cuf 5 and 7 without Cuf 4 will be less o The "protected species" argument is not a valid objection as masterplanning could mitigate this. o While there will be some visual disadvantages for the site, the need for housing within the borough demands compromises and the sustainability of the site helps mitigate this. o The addition of housing in this location will improve the diversity of the housing stock in Cuffley and ensure the continued viability of the village without creating any more sprawl. o In combination with Cuf7 and the proposals by the developer, it will provide a highly sustainable location, enhance the village therefore be included as a more favourable site. o Cuf 4 (and Cuf5 and Cuf7) should be considered more favourable for development. o Developers have promised a carbon neutral development.

Object should not be considered o This is prime Green Belt land which should legally protected.

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

The entirety of this site has not been allocated, however a smaller portion of it has (part of Cuf12) as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

332

Appendix A Less Favourable Sites – Cuffley – Site Cuf7 Wells Farm

Number of responses received 6 (General 3, Support 0, Object should be more favourable 2, Object should not be considered 1)

Support

None

Main Issues o See Cuf4 above o No recognised ecology sites within, adjacent or close to Site. Protected species: unlikely. Opportunities: potential to create an orchard as one was historically present. Ecological sensitivity: low. Fundamental ecological constraint: low o Site in flood zone 2 or 3. Adjacent to watercourse See Cuf4 comments o Cuf7 should be re-classified as 'inappropriate' for development rather than 'less favourable'. o There are no "special circumstances" or legal basis under which development of this Green Belt land should be permitted. o Cuf7 will provide a highly sustainable location, enhance the village and should therefore be included as a more favourable site. o Building on the greenbelt is necessary to achieve the assessed housing numbers. o Developing Cuf5 and Cuf7 will make policy CS3 - spreading development around the borough slightly more achievable.

Object should be more favourable o Cannot understand why Cuf4, Cuf5 and Cuf7 have been found less favourable. Sites have good connection to the local train station and good links to the road network o Every part of the borough needs to take its fair share of the housing allocation o Discounting these sites in favour of other sites with less current infrastructure makes no sense. o Disagree that the site makes a significant contribution to protecting the countryside any more than site WGC4. The impact of just developing Cuf 5 and 7 without Cuf 4 will be less o The "protected species" argument is not a valid objection at the local plan stage as masterplanning could mitigate this. o While there will be some visual disadvantages for the site, the need for housing within the borough will demand some compromises. o Addition of housing here will improve the diversity of the housing stock in Cuffley and ensure the continued viability of the village without creating any more sprawl. o It is a highly sustainable location. o Developers have promised a carbon neutral development.

Object should not be considered o This is prime Green Belt land and should legally protected.

333

How these views have been taken into account

Decisions on which sites to allocate in the LPPS 2016 have been informed by detailed site selection work, which has itself been informed by a number of technical studies (including the site appraisals within the latest HELAA and Sustainability Appraisal), as well as responses to the LPCD 2015. The issues addressed include Green Belt purposes and boundaries, strategic advantages/disadvantages, access, highway impacts, biodiversity and ecology, heritage, flood risk, minerals, viability, agricultural land, landscape, site specific and wider infrastructure issues, ground conditions, pollution, amenity, proximity to services and a number of other matters.

This site has been allocated, however a smaller portion of it has as an outcome of this process (a detailed justification is provided in the Employment/Housing Sites Selection Background Paper 2016 and associated committee report).

334

Major Developed Sites and Policy Intention on Major Developed Sites

Number of responses received 7(General 2, Support 2, Object 3)

Support o Support the provisions of policy for major developed sites in the Green Belt. o Notes the commentary on the Royal Veterinary College MDS at paragraph 20.5 and welcome the acknowledgement in principle that the College has a need for future development of their site driven by demand that can only reasonably be met at the existing campus and by amendment to the MDS boundary to allow it to be accommodated. o Consider that the Royal Veterinary College should make substantial contributions to the creation of a cycle path to Potters Bar station using a suitable route for all year commuting.

Main Issues o It is unclear what the proposals for the existing Major Developed Sites are and whether these are interested to make up the shortfall in housing provision elsewhere, or to provide some land for employment. o Object to the continuing use of the Major Developed Site policy as it is inconsistent with national policy and is unsound. o For the RVC to meet its needs, additional land is required over and above the proposed change in the MDS boundary o Oshwal Centre should be designated a MDS with its own policy to help it meet its unique needs

How these views have been taken into account

Policy SP 25 of the LPPS 2016 supports rural development that contributes to rural economies and is compatible with their Green Belt location, and MDS have been designated on the Policies Map for the LPPS 2016 Further amendments (in addition to those consulted on in the LPCD 2015) to the boundaries of the RVC campus were not considered o be justifiable under Green Belt policy.

Proposals for the Oshwal Centre were not considered to meet the criteria for designation as a MDS, and therefore it is not designed at as a MDS in the LPPS 2016

335

Cemeteries

Number of responses received 2 (General 2, Support 0, Object 0)

Main issues o The burial of human remains releases substances and organisms into the subsurface. Groundwater can therefore be at risk of pollution where burial numbers are sufficient and the protection afforded by the subsurface geology is poor. o The Emerging Core Strategy, Local Plan Consultation and Draft Infrastructure Delivery Plan do not mention Welwyn Cemetery. Whilst not a Borough Council asset, should have taken this into account of in one of these documents.

How these views have been taken into account An extension the Southway cemetery is allocated in the LPPS 2016, and is accompanied by Policy SADM 8 which requires any cemetery proposal there to take account of the protection of groundwater. Policy SADM 18 also sets out requirements from preventing environmental pollution from development proposals, which would apply to cemetery development.

336

Cemeteries Site CEM01

Number of responses received 4 (General 3, Support 1, Object 0)

Support o Extending the existing site is preferable as it will give cost savings and already has many of the necessary buildings. There would be less visual impact than CEM02.

Main issues o CEM01 will not have a significant impact on any designated heritage assets. o The Environment Agency note that the site is located within a Source Protection Zone 3. There is no drift layer on top of the Lambeth group rock formation, and the site is located near swallow holes. This means that there could potentially be shorter travel time for contaminates entering the ground to reach groundwater. o Landowner: Has sought to engage with the Council and has produced a landscape strategy plan that allows for a cemetery enhancement, landscape enhancements and approximately 6 hectares of residential development. Support is expressed for a planning strategy for the South of Hatfield which accords with this approach and maximises opportunities for the landowners holdings. This would ensure that residential development, landscape enhancement and the extension to the cemetery could all be delivered to meet local needs. o Requests that the Council formally allocates the land in this area for residential, open space and cemetery development. This approach would maximise this sustainable opportunity and is entirely consistent with the objectives of national planning policy. Should the development indicated on the masterplan not be supported this would fail to deliver opportunities for enhancement. This would also result in the potential cemetery being isolated at the centre of the existing land holding and would cause issues for future use and management of the land and on this basis would not be supported. The landowner therefore requests that any cemetery allocation is made alongside the wider allocation for landscaping and residential development as set out in their submitted drawings.

How these views have been taken into account

An extension the Southway cemetery is allocated in the LPPS 2016, and is accompanied by Policy SADM 8 which guides development of the cemetery, and in particular requires any cemetery proposal there to take account of the protection of groundwater. Policy SADM 18 also sets out requirements from preventing environmental pollution from development proposals, which would apply to cemetery development.

337

Cemeteries Site CEM02

Number of responses received 5 (General 2, Support 0, Object 3)

Support

None

Main issues o Site in close proximity to Brocket Hall Registered Park and Garden Crooked Chimney Public House, both Grade II Listed. Subject to suitable boundary treatment, location of access/parking and the landscaped design it should be possible to develop a cemetery here without harm to the setting of the nearby designated heritage assets. Historic England would wish to advise further on specific proposals, and would expect the next version of the Local Plan to contain explicit requirements for this site allocation in relation to the historic environment o Site within Source Protection Zone 3; however, the geology may offer some protection for groundwater. A superficial layer of gravels over chalk would imply that the groundwater is at a sufficient depth to reduce the risk of potential contamination o The B653 is very busy with fast flowing traffic. Access to and from this road is extremely difficult at peak times and can be unsafe. The suitability of this site is questioned (Landowner of site CEM02). o The site is located adjoining Brocket Park and Brocket Hall which is Grade I listed and it is the landowners' view that the site is in an inappropriate location. o The site and its location are much less sustainable than the alternative, requiring significant additional infrastructure to deliver. o Expand existing cemetery in Welwyn. Adjacent land available at Wel1 and Wel2. Use of this site will permanently preserve the break in housing developments between Welwyn and Codicote. o The option for the extended cemetery at CEMO1 is a more reasonable option, cheaper and less visually obtrusive.

How these views have been taken into account

CEM02 has not been allocated in the LPPS 2016 following consideration of the LPCD 2015 responses

338

Part 3 Development Management Policies

Number of responses received (Support 7, Object 5)

Support o Would welcome the opportunity to further comment on policy wording as part of further consultation on the emerging Local Plan Hertfordshire County Council o Supportive of policy intention SADM6 Development in the Green Belt. Future policy wording should reflect NPPF guidance and offer appropriate flexibility o Support policy intention SADM6 and reference to the NPPF paragraph 89. o Support policy CS11 and SADM7 heritage assets. Would welcome seeing policy wording o Support policy intention SADM9 Proposals for development within an employment area o Support deletion of Policy EMP8 (Employment sites outside of employment areas) to allow for more flexibility for changes of use o Support policy intention SADM8 Environmental Assets and Resources o Support intention of SADM9 Proposals for development within an Employment Area in line with the NPPF o Support SADM19 Approach to the development of the remaining part of Hatfield Aerodrome and will seek close cooperation with the Council and other parties relating to waste and mineral issues

Main Issues

General approach o Development Management Policies can be inflexible. Would prefer to rely on national policy and DM policies limited to those deemed essential due to local circumstances o Difficult to comment without policy wording, detail and evidence o Unclear whether the intention is to continue with policy CS7 Type and Mix of Housing (Emerging Core Strategy) which set a target for affordable housing and threshold o Amend policy CS17 and supporting text referring to the 2020 Estates Vision within policy and a stronger focus to on-campus student accommodation o Happy to work with borough Council on policies where public health is a significant consideration – SADM1 Accessibility, SADM2 Amenity, SADM3 Highway network and safety, SADM 4 Health Impacts and Pollution, SADM5 Environmental impacts / climate change and SADM16 Sustainable neighbourhoods o Policy R3 Energy Efficiency and R4 Renewable Energy Sources should have regard to the Government’s approach on energy as set out in the report ‘Next Steps to Zero Carbon Homes- Allowable Solutions, July 2014’. The replacement for policy R10 Water Conservation Council should refer to the Government Housing Standards report; Policy M14 Parking Standards for New Development should reflect that the government is considering removing maximum car-parking standards. D10 Public Art- Planning Practice Guidance advises that contributions (planning obligations / CIL) towards public art should not be sought.

339 o The HMO Article 4 Direction must apply to all new housing in Hatfield o SADM3 needs to give an explicit commitment to developing cycle commuter routes to major centres, stations and school

Water, flood risk and sewerage o Policies need to address fluvial flood risk, surface water drainage, preserve overland flow routes, where applicable and prevent a net loss of flood storage on site, water quality, contamination. If sites within flood zones 2/3 are allocated, design principles and DM policies should reflect the Level 2 SFRA recommendations. Recommend a separate SUDS policy to address flood reduction, water quality and biodiversity o Concerned by the absence of policy on water and waste water infrastructure. Given the importance of planning in ensuring development does not commence before infrastructure is in place, water infrastructure should be addressed in the Local Plan o Supports recognition of climate change but would like to see policies on water conservation and water efficiency included o Welcome policy intentions SADM2 Amenity and SADM4 Health Impacts and Pollution. Where a development is proposed within 800m of a sewage works, Thames Water should be consulted to assess whether an odour impact assessment is required. Advise that no habitable rooms should be built within 15m of a sewage pumping station

Built and natural heritage o Comfortable that Policy CS11 Protection of Critical Assets and SADM7 Heritage will replace R24, R27, R28 and R29 provided these adequately cover historic environment issues o Consider it not unreasonable to replace the following policies, providing specific issues are addressed in the new policies: - Policy R6 (River Corridors) with Policy CS11 (Protection of Critical Assets) - Policy R11 (Biodiversity and Development) with CS9 (Good Quality Design), CS10 (Sustainable Design and Construction) and SADM 8 (Environmental Assets and Resources). - Policy R13 (Sites of Special Scientific Interest) and R14 (Local Nature Reserves) with Policy CS11 (Critical Assets). These sites have formal protection and should be recognised. - Policy R17 (Trees, Woodland and Hedgerows) by CS9 (Good Quality Design) and CS11 (Protection of Critical Assets). - Policy R20 (Light Pollution) with SADM4 (Health Impacts). Ecological impacts should also be referred to as impacts are wider than for just human health. - Policy R28 (Historic Parks and Gardens) with CS11 (Protection of Critical Assets) and SADM 7 (Heritage Assets). In most cases there may also be significant ecological features present. - Policy D8 (Landscaping) by CS9 (Good Quality Design) and SADM2 (Residential Amenity). Reference should be made to landscape and local ecological character in influencing landscape design.

340

- Policy OS1 (Urban Open Land) by CS11 (Protection of Critical Assets) and SADM8 (Environmental Assets and Resources). Ecology and ecosystem services can benefit from provision of open space within urban areas. - - Policy OS4 (Allotments) by CS11 (Protection of Critical Assets) and SADM8 (Environmental Assets and Resources). Ecology and ecosystem services can benefit from provision of allotments, particularly reptiles and pollination. - - RA11 (Watling Chase Community Forest) to be rolled forward into new policy SADM8 (Environmental Assets and Resources). - Policy RA15 (Agricultural Land) by CS11 (Protection of Critical Assets). - Policy RA24 (Riding and Livery Stables) with SADM6 (General Criteria – Development in the Green Belt). - Policy M15 relating to Panshanger Airfield must consider existing ecology and ecological compensation and management of the site that may be appropriate. - Policy R15 Wildlife Sites - Whilst are a critical ecological asset, their representation on proposals maps may not be the most appropriate means of presenting them as boundaries change. LPAs are informed and updated annually on changes to boundaries or sites and this is the information that needs to be readily available on request, either from the LPA or the Hertfordshire Environmental Records Centre. o Welcome aim to protect heritage and landscape. Concern that unregistered historic parks and gardens have not been appraised and included in the Local Plan o Recommend landscape related policy wording for SADM2 Amenity and SADM8 Environmental Resources and Assets. Refer to local SUDs policy and the importance of local food production for the landscape. o Support policy intention SADM4 Health Impacts and Pollution, however water and light pollution can impact on local biodiversity as well as the human environment o SADM7 Heritage Assets should recognise the importance of both designated and undesignated heritage assets with archaeological, historic or architectural interest and provide clear guidance for the protection of undesignated heritage assets, within the planning system, and beyond o Welcome inclusion of SADM7 Heritage Assets. Response sets out issues that a locally specific policy should address including how applications involving heritage assets will be assessed, designated and un-designated assets (supports a local list), conservation areas, clarity on archaeological expectations and potential for heritage enhancement o The Planning Authority should request that pre-application archaeological assessments are included within all development briefs and other proposals for sites that are formally adopted o Policy SADM19 Hatfield Aerodrome Masterplan must recognise existing role and intent of Ellenbrook Country Park and its likely future. If the biodiversity resource is going to be downgraded, appropriate offsetting provisions are required o Welcome reference to noise in policy intention SADM2 Amenity. Propose policy wording in relation to noise sensitive developments in areas of aircraft noise o Policy SADM8 should state how ‘no net biodiversity loss and where possible net gains’ will be delivered. Recommend policy wording

341 o SADM8 Environmental Assets and Resources in too generic. To reflect the NPPF para 113, should distinguish statutory from non-statutory sites and the hierarchy of protection these afford and refer to the mitigation hierarchy set out in the NPPF o Lack of reference to protecting and enhancing Watling Chase Forest in policy intention SADM8 and elsewhere in the Local Plan. Should review and consider the approach to Watling Chase Community Forest that Hertsmere Borough Council has taken o Add a new policy that seeks to protect the setting of Hatfield House and Park and Gardens. The policy would signpost the creation of a View Management Framework, to be adopted as SPD. This will enable decision makers to seek to reconnect Hatfield House and Park to its original landscape and assist in proactively managing future development in this sensitive landscape

Retail, employment, community facilities infrastructure, waste, minerals o Amend the threshold in Policy CS5 in line with the NPPF which requires impact assessment on development over 2,500sqm o Seek more detailed criteria in Policy SADM16 to support CS6. Suggest criteria and a definition of ‘community facilities’ for inclusion within the Local Plan o Policy CS10 Sustainable Design and Construction should encourage construction and demolition methods that minimise waste generation and promote re-use and recycling of materials on site o Policy CS12 (Infrastructure Delivery: Waste facilities are important community facilities and developers should be asked to contribute to their provision. Accept deletion of Policy M11 Rail Freight Depots. Would welcome the opportunity to comment on the brief for the provision of dirty user industries which is to replace policy EMP7 o SADM8: promote sustainable waste management, such as waste prevention, reduction and recycling. Refer to Waste Core Strategy and Development Management Policies SADM5- Provision should be made for the storage and collection of water and recyclables in new developments. Include criteria on contamination and waste minimisation o Note that waste uses are acceptable in an employment area o To support the level of growth additional household waste recycling capacity will be required. It is noted that saved policy EMP1 (Employment Areas) and EMP2 (Acceptable Uses in Employment Areas) will be rolled forward into policy SADM9 (proposals for development within Employment Areas o Welcome the intention to prepare a Community Infrastructure Levy (CIL) Charging Schedule. As the County Council is responsible for key infrastructure, we are committed to collaborative working and assisting Welwyn Hatfield in the preparation of CIL and in establishing governance and spending arrangements o Policy M15 (Panshanger Aerodrome): Any policy or masterplan should mention the possibility of mineral extraction from the site

Green Belt and re-use of buildings o Object that policy SADM6 excludes reference to the partial or complete redevelopment of previously developed sites in the Green Belt, in line with paragraph 89 of the NPPF

342 o Object to policy SADM6. Education sites’ Green Belt designation constrains the ability to respond to the need for new/ enhanced facilities. Important to consider additional / extended playing for some schools in the borough (Hertfordshire County Council o As policy SADM6 will replace RA17 Re-use of Rural Buildings, reference should be made to paragraph 55 of the NPPF. o Would welcome policy intention SADM15 to be supportive of the conversion of vacant buildings.

How these views have been taken into account

The LPPS 2016 contains development management policies the Council consider necessary in order to address local circumstances and deliver the Local Plan aims and objectives. These set out general criteria which will be used to determine planning applications and help to deliver the strategy set out in the plan. The Council has sought to provide sufficient information to enable the policy and reasoned justification to be readily understood, while avoiding unnecessary detail, and to provide flexibility, where appropriate.

The Council has updated policies, supporting text and related documents, such as the IDP, taking into account evidence, other relevant plans and initiatives, and changes in national policy.

LPPS 2016 policies SP 10 Sustainable design and construction and Policy SADM 13 Sustainability requirements replace Welywn Hatfield District Plan policies R3 Energy Efficiency and R4 Renewable Energy Sources.

LPPS 2016 Policy CS7 Type and mix of housing (SP 7) while based on the ECS draft policy, is amended to reflect more recent evidence and national policy. The policy sets thresholds for affordable housing sought according to site size and location, but sets no borough wide affordable housing target. Policy SP 21 University of Hertfordshire continues to approach set out in the ECS and seeks to concentrate new student accommodation on campus wherever possible.

A new Transport and Travel Policy SP4 seeks to achieve a shift towards more sustainable modes. New developments will be expected to encourage cycling through the inclusion of safe cycle routes and parking for cycles. In drafting the LPPS 2016 The Council has taken into account the public health strategy for Hertfordshire.

Water and Flood risk

The Council has worked with the Environment Agency, Hertfordshire County Council and other stakeholders to develop a Strategic Flood Risk Assessment that has helped direct allocations to areas in the borough with the lowest risk of flooding. Some allocations will need to consider fluvial and surface water flood risk, albeit of limited extent. Similarly, proposals for windfall development elsewhere within the borough may be at risk of flooding. The policy approach aims to be proportionate and consistent with national policy and guidance. LPPS 2016 Policy SADM 14 Flood

343

Risk and Surface Water Management aims to ensure new development addresses flood risk, flows, storage, run-off, source control, water quality, provision and long term maintenance of SUDS, management and control measures that aid multi- functionality of space, enhance visual amenity, support biodiversity and allow for safe interaction with the water environment, as opposed to hard engineered and/or sub-surface features. Strategic site policies specify a requirement for sustainable drainage and provision for flood mitigation.

The LPPS 2016 addresses water and waste water infrastructure under various policies; site specific, a section on sewerage in LPPS 2016 Chapter 13 Infrastructure; Policy SP 10 Sustainable Design and Construction (water sensitive design), Policy SADM 13 Sustainability requirements (water conservation), Policy SADM 14 Flood Risk and Surface Water Management, Policy SP 12 Strategic Green Infrastructure (river corridors), Policy SADM 16 Ecology and Landscape (chalk river habitats), Policy SADM 18 Environmental Pollution.

Retail, employment, community facilities infrastructure, waste, minerals

LPPS 2016 Policy SP 5 Quantity and location of retail development sets out the approach with regard to assessing retail proposals. The thresholds set out in the policy for requiring retail impact assessments are informed by recommendations contained in Welwyn Hatfield Retail and Town Centre Needs Assessment Update, May 2016. The LPPS 2016 designates several employment areas (Policy SADM 10). Among these EA11 Cole Green Lane, incorporates an existing waste site. The Council are aware that the county’s Waste Site Allocations Document identifies most of the borough's designated Employment Areas as 'Employment Land Areas of Search' for new waste management facilities, reflecting they can be an appropriate location for waste management uses.

LPPS 2016 Policy SADM 7 New community services and facilities and losses of community services and facilities sets out criteria for the provision of new facilities and changes of use. Section 8.2 lists types of community facility. A new section on materials in Policy SP 10 encourages reuse and recycling of materials that arise through demolition and refurbishment, including reuse of excavated soil and hardcore within the development site. The policy seeks to ensure that provision is made for storage and collection of waste and recyclables and in all large-scale developments, sufficient land made available for recycling centres where necessary. Where necessary, when planning for the strategic growth locations the Local Plan identifies, the Council will work with the County Council to explore opportunities for the provision of waste management facilities to help achieve greater self sufficiency in Hertfordshire.

With regard to provision for dirty user industries, due to the close proximity of residential users it is considered this policy (EMP 7) / development brief is no longer appropriate.

Policy SP 18 North East of Welwyn Garden City (SDS1) deals with the proposed allocation at Panshanger. The policy will require the developer to demonstrate that

344 the ‘opportunistic’ use of some minerals within the site has been fully considered, subject to it not prejudicing the delivery of housing within the plan period.

Built and natural heritage

The LPPS 2016 (Chapter 11) states that the Council will encourage the use of pre- application consultation and Design Review so that a robust design framework can be discussed and agreed at an early stage to arrive at the best possible design solution. The LPPS 2016 notes that Design Review should, in particular, be undertaken for major development proposals and proposals that are in a sensitive location or which have the potential to alter the character of a place significantly.

The LPPS 2016 (Chapter 12) acknowledges that Historic Parks and Gardens, both within and neighbouring the borough, make a key contribution to the borough's heritage and quality and character of the landscape, reflecting cultural and horticultural ideas of their time. The LPPS 2016 notes that unregistered Historic Parks and Gardens can be of local importance and that the Council will seek to preserve the character and setting of Registered Historic Parks and Gardens, and unregistered parks and gardens according to the integrity and significance. The Council will work with the County Council, the Hertfordshire Building Preservation Trust and the Hertfordshire Gardens Trust to promote the protection and enhancement parks and gardens within and neighbouring the borough”.

Policy SADM 18 Environmental Pollution addresses contaminated land, air, soil and light pollution and vibration from noise. The policy acknowledges that impacts can be wider than human health and aims to ensure that pollution will not have an unacceptable impact on human health, general amenity, critical environmental assets or the wider natural environment. Policy SP 10 seeks to encourage newly created habitat and soft landscaping to prioritise the use of native species.

Policy SP 12 Strategic Green Infrastructure commits the Council to work with partners to actively support the creation and enhancement of strategic green infrastructure across the borough. Priorities for the creation and enhancement of green infrastructure include river corridors, sites designated for their nature conservation, heritage and/or landscape value and areas of Urban Open Land that are important for community recreation. The policy states that development proposals within the borough should plan positively for, and contribute to, the creation and management of high quality, multifunctional green spaces linked to the surrounding green infrastructure network. To ensure beneficial results for biodiversity and habitat creation, Hertfordshire’s Ecological Networks Mapping should be used (where appropriate) to inform the location and nature of green infrastructure provision. Developer contributions will be sought to deliver strategic green infrastructure including that identified in the Welwyn Hatfield Green Infrastructure Plan and green infrastructure proposals brought forward in the Local Plan.

Development will be expected to address principles set out in Policy CS10 Sustainable Design and Construction, such as “new and existing habitat and landscaping are incorporated into the layout and design of proposals in line with sound ecological principles. Site and building-level landscaping and features

345 promote biodiversity and help achieve other aims, such as climate change adaptation, flood risk and amenity”.

LPPS 2016 Policy SP 11 Protection and enhancement of critical environmental assets seeks to secure the protection, enhancement and management of environmental, ecological and historic assets within the borough commensurate with their status, significance and international, national and/or local importance. Chapter 12 provides further information on the types of proposals and circumstances that would require a Heritage Statement, Heritage Impact Assessment and/or an Archaeological Assessment and the information that these should contain. Reference is made, as appropriate, to consultation with the County Council’s Natural, Historic and Built Environment Advisory Team.

Proposals will be expected to maintain, protect and wherever possible enhance biodiversity, the structure and function of ecological networks and the ecological status of water bodies (Policy SP 11). The policy is supported by criteria based development management policies including SADM 15 Heritage and SADM 16 Ecology and Landscape. SADM16 covers consideration of International sites, Sites of Special Scientific Interest, National Nature Reserves, Local Nature Reserves or other statutorily protect features or species, local wildlife sites, habitats, landscape and ancient woodland. The policy distinguishes statutory from non-statutory sites and the hierarchy of protection these afford and requires the mitigation hierarchy to be followed, as set out in the NPPF.

A new paragraph in LPPS 2016 Chapter 12 acknowledges that part of the borough lies within Watling Chase Community Forest area, where the aim is to achieve major environmental improvements through provision of green infrastructure such as planting trees, areas for nature, landscape enhancement and public open space around urban areas. The LPPS 2016 states that the Council will support delivering the aims of Watling Chase Community Forest through the appropriate retention and protection of trees, or planting of new and replacement trees.

At Panshanger, an area of ecological enhancement is proposed for the north west of the site. Provision of open spaces will contribute to wider ecological networks including a strategic green infrastructure corridor from St Albans through to Hertford. The development would be required to provide safe routes for wildlife, protecting and enhancing wildlife assets; balance the needs of recreation and nature, providing animal infrastructure and undisturbed areas (LPPS 2016 Policy SP 18).

SADM19: Hatfield Aerodrome Masterplan is no longer considered necessary as the site is now almost entirely consented and the policy has served its purpose.

Green Belt

The LPPS 2016 addresses provision for additional education facilities and associated playing fields through site specific policies, where appropriate, and a new policy SP 14 New Schools.

LPPS 2016 policies SP 25 and Policy SADM 36 Development within the Green Belt support the re-use or conversion of existing buildings where compatible with their

346

Green Belt location, the settlement strategy and the protection of critical assets. The policy addresses proposals to develop on previously developed sites in the Green Belt and limited infill development or replacement buildings at major developed sites within the Green Belt, subject to the same criteria.

Protection of Hatfield House and Gardens is addressed by several LPPS 2016 policies, including Policy SP 23 Marshmoor Policy Area (SDS7 and wider area) Policy SP 11 Protection and enhancement of critical environmental assets , Policy SADM 15 Heritage, Policy SADM 16 Ecology and Landscape and site allocation policies, where relevant.

347

Appendix C – Sites that failed the first SHLAA test

Table 26 (Sites that failed the first SHLAA test) and Table 27 (Sites withdrawn from SHLAA review) Number of responses received: 14 (Support 1, Object 7)

Support o Failed sites WGr2 and Wgr3 are close to the boundary with Knebworth and should be discounted as they would lead to coalescence

Main Issues o Have not considered the failed sites, but hope that historic environment impacts have been taken into account where relevant. Note that BrP8 was rejected due to its location within a Grade II registered Park and Garden o While the site does not adjoin an urban boundary development will not harm Green Belt purposes. Site is self contained, infill development, avoiding encroachment and coalescence, closely associated with urban area, within 1km of Welwyn Garden City town centre o Include OMH6 as an allocated site. Shortfall of housing in Oaklands and Mardley Heath, so should alter the Green Belt boundary north of the settlement. Site size has been reduced. OMH6 would not be unduly prominent in the countryside nor undermine the large rural gap between Welwyn and Oaklands and Mardley Heath, which would be retained as open land. Landowner offered to give southern part of the site to Welwyn Hatfield Borough Council to ensure its continued wildlife protection o A highly sustainable location on the edge of Potters Bar, close to a residential site. There are clear defensible boundaries which can be enhanced to delineate the extent of future development o Developing only part B of the site for residential would not lead to the coalescence of Stanborough and Lemsford. Enclosed on three sides, the site performs no specific Green Belt function and will provide open space for recreation. Landowners’ land elsewhere could alleviate parking problems at Lemsford school. SHLAA criteria have been inconsistently applied because other sites which cause coalescence (Hat1), have been found more favourable o Include Wel6 as a designated housing site. Green Belt Review concludes the site does not contribute to Green Belt purposes. Site well contained. Would be logical to develop if Wel1 and Wel2 come forward. Highway upgrades can be undertaken to support development o BrP7 was sieved out at the first stage of the SHLAA, but is not included in this list. o Roehyde might be suitable for development, has this been considered? o Consider allocating land behind 1-6 The Hollies (STL8) for housing. o Nor3 should be re-evaluated. o STL1 should be reviewed and included in the Local Plan.

348

How these views have been taken into account

The Council has carried out further work to assess sites (HELAA 2016). The outcomes of this work can be found in the HELAA 2016. Of the sites within Appendix C of the LPCD, only WGC7 (now part of WGC4) and WGr2 passed Stage 2 of the HELAA and were considered for site allocation within the Housing Sites Selection Background Document 2016. WGC7 is to be allocated as part of SDS1/WGC4, however WGr2 has not considered suitable for allocation on Green Belt grounds.

349

Appendices

350

Appendix A

Specific bodies notified of the LPCD 2015

Affinity Water Arqiva Ltd Ayot St Lawrence Parish Meeting Ayot St Peter Parish Meeting Bayford Parish Council Brickendon Liberty Parish Council Broxbourne Borough Council BT Openreach Cable & Wireless UK Codicote Parish Council Colney Heath Parish Council Datchworth Parish Council East Hertfordshire District Council English Heritage Environment Agency Essendon Parish Council Everything Everywhere Ltd Hatfield Town Council Hertfordshire County Council Hertingfordbury Parish Council Hertsmere Borough Council Hutchison 3G UK Limited Kimpton Parish Council Knebworth Parish Council Little Berkhamsted Parish Council London Borough of Enfield Mayor for London Mobile Operators Association National Grid Natural England Network Rail Infrastructure Ltd NHS East and North Hertfordshire CCG NHS Hertfordshire Northaw and Cuffley Parish Council North Hertfordshire District Council North Mymms Parish Council Orange Personal Communication Services Ltd Police and Crime Commissioner for Hertfordshire Sandridge Parish Council South Mimms Parish Council St Albans City and District Council Stevenage Borough Council Telefonica UK Limited Tewin Parish Council Thames Water Property Thames Water Utilities Ltd

351

The Coal Authority Three Rivers District Council UK Power Networks Virgin Media Limited Vodafone Limited Welwyn Parish Council Wheathampstead Parish Council Woolmer Green Parish Council

Duty to Cooperate bodies notified of the LPCD 2015

Broxbourne Borough Council Civil Aviation Authority Dacorum Borough Council East Hertfordshire District Council English Heritage Environment Agency Epping Forest District Council Hertfordshire County Council Hertfordshire Local Enterprise Partnership Hertfordshire Local Nature Partnership Hertsmere Borough Council Highway Authority Highways Agency Homes and Communities Agency London Borough of Enfield Mayor for London Natural England NHS East and North Hertfordshire CCG NHS Hertfordshire North Hertfordshire District Council St Albans City and District Council Stevenage Borough Council The London Borough of Barnet The Office of Rail Regulation Three Rivers District Council Transport for London Watford Borough Council

General Bodies notified of the LPCD 2015

Adventist Community Church Advisory Council for the Education of Romany and other Travellers (ACERT) Baha'is of Welwyn Garden City Baptist Fellowship Bethesda Christian Fellowship Birchwood Methodist Church Brookmans Park United Reformed Church Catholic Diocese of Westminster Catholic Women's League

352

Christ Church (United Reformed) Christchurch Baptist Church of England Diocese of St Albans City Church Hatfield Digswell Village Church Digswell W I East of England Local Government Association Essendon W I Evangelical Baptist Church Federation of Small Businesses First Church of Christian Scientist Fountain of Life Church Friends Meeting House Gypsy & Traveller Empowerment Handside W I Hatfield Townswomans Guild Hertfordshire Action on Disability Hertfordshire Chamber of Commerce and Industry Hertfordshire Society for the Blind Herts International Church Hornbeams Society Howlands Baptist Church Impact Christian Centre Irish Traveller Movement in Britain Jehovah's Witnesses Kaleidoscope Enterprise Ltd Kingdom Light Centre Life Church London Gypsy and Traveller Unit Ludwick Way Methodist Church Mardley Heath W I MENTER (East of England Black and Minority Ethnic Network) Northaw W I Oxlease Methodist Church Panshanger Church Roe Green W I Romany Institute Rotary Club of Brookmans Park Rotary Club of Hatfield Salvation Army Showmens Guild of Great Britain St Johns Church, Hilltop The Ayots and Welwyn W I The Traveller Movement The Twelve Apostles Church Vineyard Barn Methodist Church Welwyn Garden City Spiritualist Church Welwyn Evangelical Church Welwyn Garden City Free Church Welwyn Garden City Hebrew Congregation

353

Welwyn Hatfield (Community & Voluntary Services) Welwyn Hatfield Access Group Welwyn Hatfield Chamber of Commerce Welwyn Hatfield Interfaith Group Welwyn Hatfield Islamic Society Welwyn Hatfield Polish Forum WGC Central Congregation of Jehovah's Witnesses WGC Rotary Club & Anglican Churches Woodhall Lane United Reformed Church

Other Key Stakeholders notified of the LPCD 2015

11th Welwyn Garden City Scout Group Affinity Sutton Age Concern Hertfordshire AIM Securities Ltd/CEMex & Gascoyne Cecil Estates Aldwyck Housing Association ALPS Group Ancient Monuments Society Arlington Property Development Arriva The Shires and Essex Ayot St Lawrence Society Barton Willmore Bayard Developments Ltd Bellway Bidwells Birchwood Residents Association BNP Paribas Real Estate Boon Brown Architects Bovis Homes Ltd Central Region Breaks Manor Youth Bride Hall Holdings Ltd British Gas Properties British Horse Society British Telecommmunications Property Brocket Estate Brocket Trustees Brookmans Park Golf club Brookmans Park Residents Association Built Environment Advisory and Management Service (BEAMS) Burnett Planning & Development Burycroft Residents Caravan Club CBRE Investors Cemex and A1M Securities Chase Green Developments Chris Thomas Ltd. Circle Anglia Coleman Properties Ltd Commonswood Nature Watch

354

Costco Wholesale UK Ltd Countryside Development Agency Countryside Management Service CPRE Hertfordshire Croudace Homes Danesbury Residents Association David Lock Associates Development Project Manager Digswell Lake Society Digswell Residents Association DLA Town Planning East and North Herts NHS Trust East Coast Ellenbrook Residents Association English Golf Union Environment Agency Epping Forest District Council Fairview New Homes Ltd Faulkners O.B.O. Mr D Thomas Fields In Trust Finesse Leisure Partnership Fire Rescue Service First Capital Connect Forestry Commission Garden History Society Garden Village Preservation Society Gascoyne Cecil Estates George Wimpey North Thames Georgian Group Gerald Eve Girlguiding Guessens Gobions Woodland Trust Green Lanes Primary School and Governing Body Groundwork Hertfordshire Guido & CO Guinness Trust Hammersmatch Properties Ltd. Hastoe Housing Association Hatfield Association of Rail Travellers Hatfield Town FC Health and Community Services Health and Safety Executive Hertfordshire Association of Parish and Town Councils Hertfordshire Biological Records Centre Hertfordshire Constabulary Hertfordshire Forward Hertfordshire Gardens Trust Herts & Middlesex Wildlife Trust Herts Bus and Coach Operators Association Hives Planning

355

Home Builders Federation Ltd Home Group Homes and Communities Agency Hubert C Leach Ltd (Leach Homes) Indigo Planning Ltd J I Thomas & Son James Crawford Trust Jane Orsborn Associates JB Planning Associates Ltd JJ Property LLP Keymer Cavendish Development Consultants Knebworth Estates Lafarge Aggregates Landform Development Ltd Landform Estates Ltd Lands Improvement Holdings Plc LaSalle Investment Management Lawn Tennis Association LIDL UK Gmbh Light Aircraft Association Linden Homes (Chiltern) Ltd. Living Villages London Green Belt Council London Luton Airport Operations Ltd Longcroft Allotment Association Ludwick Family Centre Management Committee Maddox & Associates Mariposa Investments Limited Marrons Marshmoor Consortium Martin Grant Homes Metropolis Planning and Design LLP Metropolitan Housing Group Metropolitan Housing Trust Mid Valley Residents Association Mid-Herts Footpaths Society Monks Walk School Friday Evening Swimming Club Moult Walker Chartered Surveyors Mr R E Whitten Nathaniel Lichfield and Partners Ltd Network Rail Newgate Street Village Hall Committee NFU East Anglia Region North Mymms Action Group North Mymms District Green Belt Society North Mymms Parish Plan Committee Northaw & Cuffley Residents Association Nursery Gardens Management Company (Welwyn) Oaklands Association Oaklands College

356

Optimis Consulting Ltd P T P Architects Panshanger Considerate Flying Group Paradigm Housing Group Pegasus Planning Group Persimmon Homes Persimmon Homes (Essex) Ltd Ponsbourne Tennis Club Park Post Office Property Holdings Potters Bar Society Queenswood School RAF Air Cadets at Haileybury Ramblers Association Robin Bretherick Associates Roe Green Area Residents Association RSPB Ryde Residents Association Sea Cadets Corps Skills Funding Agency Smallford Residents Association Spen Hill Developments Ltd Spenhill Regeneration Ltd Sport England Sport Hatfield St Albans Civic Society St Johns Youth & Community Centre St Michael's School Stanborough School Stewart Ross Associates Strutt and Parker LLP Sycamore Avenue Residents Association Taylor Wimpey TCPA Telefonica UK Limited Terence O'Rourke Terrace Hill Group Plc Tetlow King Thames Water Property The Avenue Road Association The Essendon Society The London Borough of Barnet The Places for People Group The Planning Bureau Ltd (McCarthy and Stone Retirement Lifestyles ltd) The Residents Association of Welwyn Heath The Royal Veterinary College The Sylvia Adams Charitable Trust The Tewin Society The Theatres Trust The Welwyn Garden City Heritage Trust The Woodland Trust

357

Together Centre Turley Associates Turnberry Consulting Ltd Twentieth Century Society University of Hertfordshire Uno Victorian Society Waitrose Limited Welham Green Rail Users Group Welwyn & District Local History Society Welwyn Archaeological Society Welwyn Community Housing Trust Welwyn Garden City & District Scout Council Welwyn Garden City Band Welwyn Garden City Housing Association Welwyn Garden City Society Welwyn Garden Estates Ltd. Welwyn Hatfield Alliance Welwyn Hatfield Conservatives Welwyn Hatfield Cycling Forum Welwyn Hatfield Liberal Democrats Welwyn Hatfield National Trust Association Welwyn Hatfield Tenants Panel Welwyn Hatfield YMCA Welwyn Planning & Amenity Group Welwyn Rail Users Group Westfield Residents Association WM Morrison Supermarket PLC YMCA

358

Appendix B

Copy of letter/email notifying individuals, bodies and organisations of the LPCD 2015

359

360

Copy of letter/email notifying individuals, organisations and bodies of the additional consultation events.

361

Appendix C

362

Appendix D

Drop in events for the LPCD 2015

Date Venue Times Wednesday 28 January Welwyn Civic Centre, Main 3:30pm – 7:30pm Hall, Prospect Place, Welwyn AL6 9ER Wednesday 4 February United Reform Church, 3:30pm – 7:30pm Oaklands Avenue, Brookmans Park, Hatfield, AL9 7UJ Saturday 7 February Hatfield Hub, 56 Town 10am – 12:30pm Centre, Hatfield, AL10 0JJ Tuesday 10 February Howard Centre, Welwyn 3pm – 7:30pm Garden City, AL8 6HA Thursday 12 February Cuffley Hall, Maynards 4:30pm – 9:00pm Place, Cuffley, EN6 4JA Thursday 19 February Sir Frederic Osborn School, 4pm – 8:30pm Herns lane, Welwyn Garden City, AL7 2AF Wednesday 25 February Green Lanes Primary 5pm – 9pm School, Green Lanes, Hatfield, AL10 9JY Thursday 5 March North Mymms Memorial Hall, 3:30pm – 7:30pm Station Road, Welham Green, Hatfield, AL9 7PG Friday 6 March Little Heath Parish Hall, 3:30pm – 7:30pm Thornton Road, Little Heath, Potters Bar, EN6 1JJ

363

Appendix E

Hertford Mercury and Welwyn Hatfield Times Advert

364

Appendix F

Life Magazine Autumn/Winter 2014 article.

365

366

Appendix G

Flyer sent to deposit points

367

368