web viewconcerned about the economic strategy to support these developments: there is the assumption...

Appendix A

Summary of the issues raised in response to the Emerging Core Strategy

Key Points raised during November 2012 – January 2013 consultation

Document: Emerging Core Strategy

Section Foreword

Consultation Point

GENERAL comments raising the following points Number of comments

Hertfordshire County CouncilThere are a number of areas where it is considered that there is a need for either additional wording or for further work to be undertaken

the need for the IDP to be supported by a comprehensive assessment of the necessary infrastructure required to support growth over the plan period;

the need for greater clarity relating to, and safeguarding of potential mineral reserves within the locations identified as ‘possible broad locations’ and ‘possible urban extensions;

the need to ensure that future iterations of the Core Strategy accurately reflect recent changes/forthcoming changes relating to the statutory functions of the county council (e.g. in its capacity as Lead Local Flood Authority) and emergence of other bodies (e.g. Local Nature Partnership);

where necessary update the supporting evidence base to ensure that the growth set out within the emerging core Strategy is deliverable (particularly in relation to transport modelling), and update the Sustainability Appraisal where necessary;

the need to take into account potential constraints relating to growth areas which may come forward on land outside of Welwyn Hatfield

Comments by individuals and other bodies Regarding first bullet point – sites for housing should be selected throughout the

borough in a fair and balanced manner without influence or bias.

Total No. of GENERAL comments 2

OBJECTIONS raised on the following grounds Number of comments

Consultation Process

Hatfield Town Council Concerned that we are only being given one option to consider. Believe that

there must have been other options which we and the community should have been consulted on.

Endorse the charrette approach to building new communities with the tolerance or approval of the existing community that will be affected.

The consultation timetable has not been convenient, having been postponed many times

Some residents believe that this has been done deliberately to stifle healthy

debate and is contrary to localism.

Some of the community perceives to be the only option is "a done deal". More work needs to be done to change that perception.

Welwyn Garden City Society It would appear that the end product has been chosen and the facts cherry

picked to support the decision. It is not very convincing

The NPPF lists the core planning principles that should underpin planning. The first is that planning should be genuinely plan led empowering local people to shape their surroundings

CPRE The Core Strategy and the Land for Housing outside Urban Areas have to be

read together to fully understand the council's intentions

Both documents as inextricably linked and none of the questions online allow CPRE to cover the concerns the documents raise

Consider therefore that the consultation is flawed and if the Core Strategy is based on this may be unsound.

Comments by individuals and other bodies Opportunities for responding are too complicated.

Consultation was very opaque.

Consultation not well advertised.

The requirement to use a separate paper response form to comment on each part of the document is discouraging.

There has been no public meeting to allow people to ask questions, which would go a long way towards a clearer understanding.

The glossy brochure is very good as far as it goes, but it only provides an overview. Readers should be directed to learn more from the website.

Lack of options being consulted on.

Important decisions seem to be already made (‘a done deal’).

Many of the concerns raised at Issues and Options 2009 consultation are again reflected in the comments made on this document.

The Document

Welwyn Garden City Society The suite of documents covering the Emerging Core Strategy is complex and

boring, difficult to navigate and cluttered by a large amount of irrelevant detail obscuring the main issues.

Garden cities concept is being revisited and should be reflected in the Core Strategy.

Difficult to see how Core Strategy can be delivered when responsibility for so many aspects rest with other organisations.

Core Strategy does not take account of current social and economic trends.

WGC has already reached optimum size and the size that the infrastructure of

the town was designed for.

There is no mention of the option of building a new separate town/village to meet the Housing Target along the lines of the suggestion made at the University of Hertfordshire Charrette in December 2008.

The Emerging Core Strategy talks endlessly about sustainability, but the Society could find very few places where the principles were properly addressed.

Concerned about the economic strategy to support these developments: there is the assumption that the private sector will jump into the breach. Given the current global economic crisis, this does not seem likely and we need a clearer, more definite economic policy to link to housing developments otherwise we could end up with a housing situation similar to Spain, Ireland or parts of China.

Comments by individuals and other bodies Document does not meet the core planning principals of the NPPF and duty to

cooperate.

Document is too long for residents to understand.

Does not meet the Sustainable Communities Framework.

Has ignored results of Charrette in 2009.

The whole method of planning is back to front. The council should be deciding what infrastructure is required to support expansion and deciding where those can be supplied, before deciding where to put the houses.

Strategy is a quick fix solution designed to create least amount of ‘pain’ for Councillors. How can responses from the 2009 consultation have been thoroughly considered if the plan is now just to focus on Hatfield and Panshanger and to ignore the other areas in the borough that were identified as suitable for housing?

Document is not really a developed core strategy and methodology is flawed. Proposals for development locations are based upon nothing more than a call to land owners to identify land they would be prepared to sell (to developers, not the council) for development. Whole process then hinges upon those locations offered by the land owners who have ultimately only one aim; to make money.

Total No. of OBJECTIONS 7

SUPPORT Number of comments

Comments by individuals and other bodies Document is supported

Total No. of Expressions of SUPPORT 1

CHANGES suggested Number of comments

Hatfield Town Council There should be more options and more consultation.

Comments by individuals and other bodies The emerging core strategy should not be carried forward.

Review the process of the consultation and carry out full formal consultation

Charrette approach should be used for consultation

There is a major need to improve the consultation process and to involve more residents in it.

There should be a review of the 2009 consultation process that led to this strategy being formed. The public are not kept fully informed.

Re-think the whole planning process by cooperating with neighbouring boroughs to provide a plan for the region.

Need to provide further information and evidence as to why housing requirements are being focussed on Hatfield and Panshanger and not the other locations which may in fact be more suitable for the housing and potential traveller sites that are now in scope.

Strategy as proposed below would give the council more control of the process and prevent landowners driving the process.

1) Develop a proposal that allows the number of proposed dwellings to be challenged. It should question and challenge the evidence upon which this figure is arrived at and present a clear, comprehensive and defensible argument supporting the number of homes. This fundamental approach should be extended to all aspects of the strategy.

2) Identify where people want to live.3) Identify where the existing infrastructure and geographic characteristics can

best support some limited additional population increase with the aim of spreading the social burden and limiting costs associated with significant infrastructure change.

4) Model the effect of the population increases (in conjunction with neighbouring boroughs).

5) Having identified the zones that can support development land only then should land owners should be approached. They should be pressed to make land available where it is needed, where they want to sell it.

Total No. of CHANGES suggested 15

Section 1 Introduction

Consultation Point 1 Introduction


Hertsmere Borough Council

The document appears to be generally sound and consistent with national policy. The main spatial planning topics are suitably reviewed with comprehensive detail.



Welwyn Garden City Society Do not consider that the comments of residents from earlier consultations have

been taken into account. Some of the investigations in this report are superficial and lacking depth. Too many assumptions have been made about economic recovery, led by the

private sector. There is also little acknowledgement of climate change threats to the community.

Comments by individuals and other bodies Socially and sustainably unacceptable to continue to stuff as many houses as

possible into the south-east. Local residents’ views from previous consultations have not informed or directed

this consultation. The planning process is clearly politically motivated and has not been adequately

justified. An inquiry into the way the options way this was decided should be conducted and the strategy suspended.

Concern that the opportunity to participate in this consultation was limited due to confusion between summary documents/full documents on objective and the section headings/reference points given.

Concern public consultation was limited and did not provide transparent and clear options.

Concern that widening of motorways is self defeating and my lead to more vehicle dependence.



No comments received.



Welwyn Garden City Society Refer to results of previous consultations and amend accordingly.

Comments by individuals and other bodies Initiate a more effective awareness programme for residents and involve the

people affected at a much earlier stage when their input can be effective. Do not allow political influences to prevent other alternatives to be considered

e.g. development within the current 'excluded villages' surrounding Welwyn and Hatfield.

Create greater balance of the proposals to be taken forward, not just concentrating the new (as opposed to brownfield development) housing to the two key sites.

Shift policy to take account nationally of the number of ‘brown field’ sites, which should be fully utilised and developed before any other land developed. The number of unoccupied houses should be mapped nationally and used to accommodate people with the aid of a policy taxation promoting full occupation.

National road and rail network should be developed with the idea of inclusively expanding trade and business throughout Great Britain.

Make it easier to participate.

Total No. of CHANGES suggested7

Document: Emerging Core Strategy

Section 2 Welwyn Hatfield Now

Consultation Point 2 Welwyn Hatfield Now


Oshwal Association

In relation to the reference to cultural heritage, this includes the Oshwal Centre which aside from being the headquarters of the Oshwal Association is also the site of the largest Jain Temple or Derasar in Europe.

English Heritage Suggest that all designated heritage assets should be referred to i.e. scheduled

monuments, along with references to the undesignated heritage assets of the district, including undesignated archaeological remains

Herts Biological Records Should reflect the role agriculture plays in managing countryside and food

production. Should also include grasslands as a habitat type. References to chalk stream and river habitats are welcomed. The serious water stress in the district is noted and should be fully considered in

other policies reducing the environmental impacts of development. References to the issues noted in para 2.64 is welcomed.

WHBC Environmental Health The new public health agenda is changing current roles and introducing new

roles for the various agencies dealing with public health. It is recommended that the strategy uses current available data over the ensuing years of the life of the document and should aim to engage with stakeholders throughout the life of the document.

Another important document that should be given due regard is a Department of Health "A toolkit for supporting engagement with local business". This provides principles for businesses to engage with the concept of improving the health and wellbeing of its staff and customers and implementing that at a local level. For example the Core Strategy should aspire to enable the resident of every new development to have easy access to affordable and healthy food.

Comments by individuals and other bodies Para 2.13 refers to the carbon footprint per person compared with the UK

average. The University of Hertfordshire was highlighted in an ENDS special report in December 2011 as being No.14 out of 20 of the highest carbon emitting universities in the country.



Oshwal Association The profile of the Borough should refer to the wider context of the area, in

particular the relationship between southern parts of the Borough and Potters Bar.

Welwyn Garden City Society Overall this section provides a reasonable analysis of the status quo. However,

the Emerging Core Strategy fails to address many of the key issues identified in this section, relating to Green Belt, sustainability, housing, transport, the impact of climate change, the results of previous consultations, local history and heritage and the individual local character of the different settlements in the Borough.

Land Improvement Holdings It is imperative that the population and household projections, used to inform the

policies and proposals within the Core Strategy, are up-to-date and robust, particularly now that the Regional Strategy has been revoked. In the circumstances, Lands Improvement Holdings has decided that once the 2010 based household projections are published and further demographic and household data deriving from the Census is released, it will be commissioning its own assessment of the need for housing within the Borough.

LIH object to the perception that Cuffley is disconnected from the rest of the borough and is therefore a less sustainable location for new housing, as it has excellent connections to Enfield and Hertford.

Environment Agency Welwyn Hatfield's Chalk Streams are a habitat of international importance and

not just regional importance; identified as a habitat of Principle Importance for England in the Natural Environment and Rural Communities Act (NERC) 2006, section 41. They are a globally scarce habitat and their importance should be reflected here.

Under the section on 'Climate change and sustainable development', the second bullet point, should be amended to note that the inclusion of sustainable features will ensure development is more sustainable and to ensure that it is in line with the NPPF.

Two challenges for Welwyn Hatfield are missing and should be included – 1) to manage and reduce flood risk and 2) for Welwyn Hatfield's water bodies to reach good ecological status in line with the Water Framework Directive.

Comments by individuals and other bodies Town heritage also includes Panshanger aerodrome which is an historic and

present day community resource and amenity for Welwyn Garden City. The allotments are vital and are part of the character of the community. They

encourage wildlife. Many on the housing waiting list won’t be able to afford housing even it were

available because the banks aren't lending, not because it’s not available. Growth forecasts have not included the 2011 census results which show a lower

growth estimate than previously predicted. The council acknowledge that it doesn’t know what will happen to the population

because you used trend data. Job increase in the 2000s are unlikely to be repeated in the next 20 years so

local jobs may not be available for new residents. No explanation is given for the housing targets numbers 4 and 5 referred to. Do

we have to read yet another document to understand this one? Brookmans Park, Cuffley and Welham Green are supported by local boreholes

in to the aquifer and reasonable development here would therefore not impact on the sensitive rivers Lea or Mimram.

The natural resources of the river Mimram are already being stretched to the disadvantage of the water course. Additional demands will make the situation worse.

You have identified the areas considerable natural resources that shape the area and in addition mentioned the dryness of the region. How does the Council justify eroding the Greenbelt or take measures to supply water all the new homes to be built without contributing to further environmental issues.

Do not agree that Welwyn Garden City is served well by rail. Strong links to London would suggest that new housing would mean more

people wanting to travel to London. Building homes about 3 miles from the town centre will increase the amount of traffic and the demand for parking in the town centre.

Creating another large housing estate adjacent to an existing large estate with inadequate services and infrastructure is not the way to create a ‘place where

people want to live’. Too much development in either of the two areas identified will lead to

imbalance. This would lead to unnecessary pressure on local services and infrastructure. Smaller numbers in more locations would help keep the character of an existing area while promoting growth at manageable levels.

Concern that feedback and objections raised at Issues and Options stage as noted in this section has not been fully taken into consideration.

What happened to localism? Para 2.48 states that residents want minimal development. You might not like it, but you can’t ignore it. The council is elected to deliver what the residents want.

Question the statement ‘there was a good response in para 2.40 - 1400 responses from over 45000 houses and 80000 employees in the area is a drop in the ocean. Consider that consultations can be manipulated.

Consider that there are major biases towards selling these plans and the truth hasn't been told i.e. redundancies across the county at major employers, neighbourhoods destroyed due to high multiple occupancy and high investors not home owners are not providing strong community or quality neighbourhoods.

Para 2.3 states that the town centre is smaller and serves a smaller catchment area but this ignores the Galleria which with some improvements and marketing could attract people from a far wider area than Welwyn Garden City.

Para 2.7 refers to water stress but makes no mention of the water demands that the proposed incinerator.

Para 2.14 refers to the garden city but fails to mention the more important (in heritage and visitor terms) Hatfield House.

Para 2.22 reveals the cumulative effect of Hatfield town centre being used as a repository for social needs cases – possibly a deliberate tactic by the council to secure national or EU funding rather than spending its own funds.

The economic downturn is used as an excuse for Hatfield to play second fiddle to Welwyn Garden City.

It should be acknowledged that if the residents of Hatfield don’t bother to respond then it suggests they are either happy or have given up as the local authorities do as they please. The same authorities appear to have been congregating people who are unlikely or unable to voice effective opposition in Hatfield (short term residents, those with learning disabilities, new immigrants unfamiliar with UK standards or those with substance dependencies).


SUPPORT for Section 2 Number of comments

Oshwal Association Note the comment that the proportion of the population over age 65 is expected

to increase. This reflects upon the need for planning policy to be able to react positively to the needs of an elderly population, especially in terms of care provision and the opportunities that it creates to enable care to be provided.

Strongly welcome the recognition that planning has the potential to improve the health and well-being of the population.

Strongly support reference to the Sustainable Community Strategy and consider that the proposition submitted on behalf of the Oshwal Association addresses four of the five limbs of the strategy.

Herts & Middlesex Wildlife Trust Pleased to note that the natural environment, rivers and water resources are

given attention and recognised as central considerations for the borough. The introductory parts of the strategy seem to take a balanced approach to sustainable development.

Environment Agency This section recognises that Welwyn Hatfield is in an area of ‘serious' water

stress. This means there is a high population with high water demands and limited water availability.

Comments by individuals and other bodies Support the detail that seems to have been undertaken and the research but

raise concern that the council hasn't read its own research and taken it into account.


CHANGES suggested for Section 2. Number of comments

Oshwal Association Reference should be made to the Oshwal Centre in relation to cultural heritage. The profile of the Borough should refer to the wider context of the area, in

particular the relationship between southern parts of the Borough and Potters Bar.

Herts and Middlesex Wildlife Trust Strategy should specify green infrastructure as critical infrastructure and include it

alongside other infrastructure. Environmentally sustainable measures reduce economic and social costs in the

long run. Market values do not accurately or completely account for total value of the

natural value. When describing wildlife sites “Local Wildlife Sites” should be used instead of

“County Wildlife Sites”. For clarity the colour of the motorway lines on the constraints map should be

changed to differentiate it more clearly from rivers and flood zones.

Lands Improvement Holdings It is requested that to enable the 2010 based household projections once

published (understood to be early in 2013) together with further demographic and household data deriving from the Census to be taken into account and further representations submitted as appropriate.

Suggest para 2.31 which gives the settlement profile for Cuffley should be amended to reflect its important role and to read: Cuffley is the largest of the Borough's villages, as reflected by the size of the village centre and the range of shops, services and other facilities which it contains. Cuffley has good connection by road and rail to Hertford, Enfield and London and by bus to Cheshunt and Potters Bar, therefore enabling residents to access higher order services and facilities, as well as a wide range of job opportunities by a range of sustainable modes of transport. The daily needs of the residents are further met by the large primary school. It also has an allocated employment area. The population was estimated to be around 4,295 in 2001 and around 40 additional homes have been completed between 2001 and 2011 .

Herts Biological Records Para 2.12 should also end by stating 'Maintaining and improving habitat

connectivity to help movement through the landscape is also important in this respect'.

Environment Agency While supporting the section on water resources, it would be helpful to show the

stresses on water resources by detailing the average water consumption per person per day in the Borough and how this measures up against the Code for Sustainable Homes level 3/4.

WHBC Environmental Health The ECS should refer to the Health and Wellbeing Strategy written by

Hertfordshire Health and Wellbeing Board and consultation undertaken with - the Health and Wellbeing Group, The Health Working Group, The local Healthwatch group and the Officer Public Health Interest Group for technical advice at Officer level with a corporate approach. The strategy should also include reference to the Marmot Review "Fair society, healthy lives" and its 6 policy objectives and framework for action.

Herts County Council Suggest delete last sentence of para 2.6 as this reads as a policy intent or

objective as opposed to a description of Welwyn Hatfield now. Para 2.18 would be improved if suitable comparators from

Hertfordshire/surrounding housing market areas were provided instead of reference to national averages (they are stated in the jobs/economy section).

Suggest delete last three sentences of para 2.23 as this is stating what planning can do as opposed to a description of WH now.

Section 2.3 (Previous Consultation) would be better if presented either separately or following section 1.

Comments by individuals and other bodies The constraints map should also include the neighbouring boroughs to show

what constraints exist in adjacent areas and the impact they have on the borough.

Put more houses in Brookmans Park, Cuffley and Welham Green as opposed to Welwyn Garden City area.

Developers would need to make commitment to increase rail services or should not be allowed to build on land.

More attention needs to be paid to the impact of the University of Hertfordshire on the Borough.

Having a ‘charette’ style consultation rather than this format to find out what people want as there are a significant number of people who have learning difficulties and disabilities that are likely to prevent them from participating.

Ask the residents of Hatfield if they are content to see their town relegated rather than setting it out in this document and assuming that ‘well, they didn’t object so they must be happy’.


Section 3 Vision and Boroughwide ObjectivesConsultation Point 3 Vision and Boroughwide Objectives


Herts Biological Records Centre The spatial vision with respect to the environment is welcome as are the broader

environmental aims for addressing climate change.

Herts County Council HCC development services support and welcome the fact that opportunities for

education are acknowledged within Strategic Objective 12. Given the amount of land required for schools, both primary and secondary, it would be appropriate to make the allocation of school sites and reserve school sites a specific objective for the plan. The amount of land required to be released and explicitly allocated is likely to be significant and unless resolved this is likely to become a soundness issue at pre-submission stage.

JB Planning (for Gascoyne Cecil Estates) Topic Specific Policies of the Strategy: broadly supportive of the council's

approach. In particular, commend the commitments to providing a mix of housing which responds to the needs of the Borough's residents at any given time and to promoting high quality design, which creates a sense of place, has a clear identity, promotes accessibility and permeability, creates high quality public realm and open spaces and minimises the use of resources. These principles would be at the forefront of any master planning exercise that we would engage for the site.

Turnberry Planning Ltd (for CEMEX and Gascoyne Cecil Estates) Topic Specific Policies of the Strategy: broadly supportive of the Council's

approach. In particular, we commend the commitments to providing a mix of housing which responds to the needs of the Borough's residents at any given time and to promoting high quality design, which creates a sense of place, has a clear identity, promotes accessibility and permeability, creates high quality public realm and open spaces and minimises the use of resources. These principles would be at the forefront of any master planning exercise that we would engage for the site.

Tesco Stores Ltd Support the main objectives as set out with the overarching strategy of the Core

Strategy subject to the comments/qualifications below. Support Strategic Objective 2 which promotes the delivery of sustainable

growth in existing locations, prioritising over Green Belt locations. Support the promotion of Welwyn Garden City as a main centre of economic

activity under Strategic Objectives 12 and 13 but advocate a ‘localist' approach in the emerging development plan to the specific issues evident at Shire Park. This will require that planning policies avoid the long term protection of sites allocated for employment use where there is no reasonable prospect of a site being used for that purpose, with applications for alternative uses of land or buildings treated on their merits having regard to market signals and the relative need for different land uses to support sustainable local communities.

Comments by individuals and other bodies By only identifying one large growth area in Hatfield and one large growth area in

Welwyn Garden City, the council has created a policy which is unduly restrictive and unlikely to facilitate the required growth, particularly in the early stages of the plan period.

The Core Strategy must retain and reinforce the Garden City ethos as exemplified in Sir Ebenezer Howard's vision of ‘a perfect place to live', which is fundamental to the philosophy of the Garden City movement.

Any development involving more than a few dwellings must be based on the principal of creating communities and not simply a collection of dwellings. Whilst the core strategy proposal states this, it is of such overwhelming importance that the references to it should be enshrined within criteria that can be enforced.

The council should consider the outcomes of the Hertfordshire Charrette held at the University of Hertfordshire. This tackled many of the difficulties faced in providing the prescribed number of houses and provided some excellent guidelines on what types of solutions would be most sustainable.

The model should incorporate the garden city principles and include adequate play provision for children, including imaginative play, and a combination of urban and landscape features with community facilities within easy walking distance of all areas of the town, and good public transport provision. There needs to be adequate provision for education and health. Housing should follow garden city principles, in the newer context of sustainability.

One of the worst ways to develop communities is the "tacking on" of housing on the edge of existing communities. This was a key outcome from the Charrette. Many of the schemes currently being suggested by developers are exactly of this

nature and these should be resisted at all cost.

Total No. of GENERAL comments13


Oshwal Association Support the borough-wide strategic objectives particularly so far as they seek to

reduce people's impact on the environment but invite consideration that there are other bodies such as the Oshwal Association (UK) which also provide education, cultural heritage, religious and recreational opportunities to the community and should be offered similar positive encouragement.

Bidwells The proposed spatial strategy is solely focused on the two main settlements of

Welwyn Garden City and Hatfield and there is no recognition of the crucial role that smaller settlements have in creating sustainable and healthy communities. A spatial strategy which plans for the limited growth of large villages would represent a far more proactive and sustainable approach, which is reflective of the actual status of such settlements as community hubs.

Welwyn Garden City Society The draft spatial vision statement is not based on the current situation prevailing

in the country but seems to be a wish list/blue sky thinking to which everyone would subscribe to but then the Emerging Core Strategy then seems to be disconnected from this Vision statement.

A motto of "Wisdom & Design", the heritage of ancient villages and the best Garden City in the world might lead you to expect a moving and uplifting vision for the future of the borough in the 21 st Century. But WHBC, despite many public meetings, has not managed to capture the enthusiasm of residents to the varied communities of the Borough opting instead for a politically correct vision that is not dissimilar to that for Slough. The Society feels that the Emerging Core Strategy continues this lack of a proper vision and is at present serving up a biased and restricted option to its residents.

Lands Improvement Holdings The spatial vision is silent on the vision and objectives for the villages and

ignores the role of villages as places to live, work and meet.

Robin Bretherick (for Mr and Mrs Ferry) Restricting the planned release of land from the Green Belt to sites adjoining

WGC and Hatfield prejudices the flexibility of the strategy and precludes a wider spread of land releases in sustainable locations adjacent to the larger villages. The resulting economic benefits to those villages will be lost for a variety of reasons.

Strategic Objective 2 – object as more flexibility should be allowed for development within and adjoining the excluded villages in order to support village centres and their established services, and to support strategic objective 4.

JB Planning (for The Fairfield Partnership) Understand the need to identify the Borough's main towns as the primary focus

for development, but are concerned that the Core Strategy plans for less housing than is required, and that it will therefore fail to meet the needs of the borough's

more sustainable rural settlements.

Comments by individuals and other bodies The “spatial” vision is pretty meaningless overall, and as a “vision” statement is

far too long. The very first sentence "By 2029......." is also incredibly insulting and shows council to be out of touch - Welwyn Hatfield already is vibrant and culturally rich!

This strategy will not deliver the vision and borough-wide objectives as the plans stated are not balanced and concentrate developments in Hatfield and Panshanger only.

It is stated that 'the natural and historic environment in both urban and rural areas will be protected, maintained and enhanced'. Consider that Panshanger Aerodrome is part of our historic environment having been there since WW2.

Developing the Panshanger site will result in a built environment right up the East Herts border. East Herts council have not yet released their local plan proposal, this could easily include new homes provision radiating out from Hertford toward WGC. It is easy to envisage that WGC would run into Hertford before long under this plan. Strategic objective 1 states that preventing coalescence is an objective. The proposal for Panshanger does the opposite.

Consider the vision and borough-wide objectives have been ignored with regard to the loss of Panshanger Aerodrome. Particularly Spatial Objectives 2, 5, 8 and 12.

How will the council ensure developers meet commitments to improving infrastructure?

Strategic Objective 2 - this constraint on growth restricted to Welwyn Garden City and Hatfield contradicts the Sustainability Appraisal and the Green Belt SHLAA report (Oct 2012). This option was only adopted in November 2012 in order to remove planned housing from the larger southern villages of Welham Green, Brookmans Park and Cuffley, where 400 proposed houses have been removed from the core strategy.



Herts and Middlesex Wildlife Trust Welcomes the council's ambition in the vision to protect, maintain and enhance

the natural environment and generally supports the strategic objectives, which seem to balance well economic, environmental and social components. In particular we support objectives 5, 8 and 9.

Natural England Welcomes the intention set out within the vision in particular the reference made

to the management of the natural environment. Welcomes the range of borough-wide strategic objectives - more specifically,

Strategic Objectives 2, 3, 5, 6, 8 and 9 which emphasise the commitment to ensure development is delivered in a sustainable way.

University of Hertfordshire The University is supportive of the spatial vision and borough-wide objectives

which are seen as important aspirations and measures to deliver sustainable growth and development over the plan period.

The University is please to note that the vision recognises the significant role of higher education in contributing to a prosperous economy and the commitment in Strategic Objective 13.

John Lewis

Generally supports the council's spatial vision and borough-wide strategic objectives to 2029. In relation to retail development and other town centre uses, JLP supports the vision that Welwyn Garden City and Hatfield will continue to be the main focus for shopping, leisure, culture, housing and employment opportunities.

JB Planning (for Gascoyne Cecil Estates) Welcome the identification of Welwyn Garden City and Hatfield as the main focus

for development in the new plan but consider that the Core Strategy should also allow some development in the borough's more sustainable villages, such as Welham Green, to maintain sustainable communities in the long term.



Oshwal Association In respect of Strategic Objective 13 there should be recognition of the role of

bodies such as the Oshwal Association (UK) which provide education, cultural heritage, religious and recreational opportunities to the community.

Welwyn Garden City Society A plan that is based on rational projections for the Borough, which takes into

account the political, economic, social, technical, legal and environmental factors.

Herts and Middlesex Wildlife Trust Suggest the council expands the final paragraph of the vision on climate change,

to ensure that sustainability and environmental issues are dealt with in a holistic and integrated manner.

Environment Agency Spatial vision should be expanded to take account of the Water Framework

Directive as well as The River Basin Management Plan. Spatial vision should be changed to read managing and reducing the risk of

flooding. Strategic Objective 5 should include reference to a reduction in flood risk along

with managing flood risk. Strategic Objective 8 should include specific reference to rivers and waterbodies

(either within this objective or within a new objective).

Herts Biological Records Centre Strategic Objective 10 should also support the development of a local food

economy.

Robin Bretherick (for Mr and Mrs Ferry) Change para 2 to read: “To deliver a sustainable pattern of

development by directing new housing to the main towns and villages where it can support and be supported by established and improved infrastructure, service and and community facilities , where the need to travel is minimised and where opportunities for using previously developed land and small peripheral Green Belt sites can be maximised”.

Change 3 rd para to read:At end of first sentence add "...... with more limited new development within and adjoining the larger villages".

Change 4 th para to read: After "Hatfield" add "and on the edges of the larger villages ......."

Lands Improvement Holdings Suggest vision is amended to state:

A limited amount of development will have taken place within and adjoining the larger villages, necessitating the release of some land from the Green Belt, in order to sustain the local population and meet the need for new homes and jobs, not least to maintain the existing range of services and facilities.

JB Planning (for The Fairfield Partnership) Strategic Objective 1 should be more properly simplified and limited to meeting

the boroughs objectively assessed needs over the plan period. The additional caveats and explanation of the proposed strategy are unnecessary and do not help make the objective clear so should be removed.

Strategic Objective 2 should be amended to reflect the changes to the suggested changes to the strategy i.e. that development should be directed to the boroughs more sustainable villages as well as the main towns.

Strategic Objective 4 should be expanded to refer to the need to provide development to sustain rural communities as well as the main towns.

Tesco Stores Ltd Reword Strategic Objective 6 to read ‘To maximise the opportunities to travel by

sustainable transport modes and manage parking demand as part of a balanced approach to enhancing accessibility'.

Bidwells The spatial strategy needs to recognise the role that large villages play in

providing sustainable and healthy communities and make allowances for limited new development around the boundaries of such settlements in order to meet their development needs over the plan period. Welham Green has been identified to accommodate only 5 new dwellings over the entire plan period which is not considered sufficient to sustain a large village which is served by a range of local services and amenities. Further residential development must be directed to Welham Green in order to meet the needs of the community and allow the settlement to grow and prosper.

JB Planning (for Gascoyne Cecil Estates) The vision should be expanded to refer to the importance of new development

being of a high quality and the need to take account of local vernacular styles and local character when designing new development.

Comments by individuals and other bodies Produce a proposal/strategy which prevents coalescence between towns. Look at how the vision and objectives can be achieved across the borough in a

more balanced way. The spatial vision is based on a utopia non-recession version of Welwyn and

Hatfield. There should only be 30% combined housing compared to the 100% housing planned.

Amend Strategic Objective 2 to refer to ‘main towns and villages’. Amend the vision to refer to limited new development within and adjoining the

larger villages. Revise the development policy to exclude any development at the area referred

to as area BLG1. To protect the special status of this area until at least 2029. Remove the Panshanger development which has massive infrastructure

constraints. Do not build here and keep the aerodrome.

In order for the strategic objectives to be realistic aspirations, a more flexible approach is needed in which other smaller sites are built into the "model" to provide a more deliverable range of sites in the shorter term to achieve housing targets.

Reincorporate the proposed houses in Welham Green, Brookmans Park and Cuffley etc. These should be more fully investigated by the council as have comparatively few infrastructure constraints and less impact on the green belt.

In reference to Strategic Objective 2 there are other much more suitable sites exist both within and around the towns of Welwyn Garden City and Hatfield which should be more fully investigated by the council. To deliver a sustainable pattern of development by directing the majority of new development to the main towns the need to travel is minimised.

Total No. of suggestions for CHANGES28

Section 4 Delivering Sustainable Development

Consultation Point Section 4 and Policy CS1


Welwyn Parish Council General Comments:

Believes the borough must work with other bodies to minimise any infrastructure constraints that might jeopardise the creation of viable sustainable communities. Supports the creation of truly mixed communities to ensure social cohesion and inclusivity.

Sustainable development should not just concentrate on protecting the areas of highest environmental value but aim to improve the environment where this has, in the past, been degraded. Should include positive efforts in land reclamation and improvement and a commitment to improving the existing built environment as well as preserving and enhancing the natural and heritage assets and resources of the borough.

Energy conservation and the efficient use of natural resources are of critical importance.

Notes the borough's commitment to rapid approval of applications that are in accord with the policies in the Development Plan. However, are concerned that this should not reduce or eliminate the ability of the Parish Council, residents and interested parties to comment on and on occasion and, to object to developments and applications in the Parish.

Paragraph 4.4. Support the strategy of maximising the use of previously developed land and undeveloped urban areas before the release of green field sites. Degree of uncertainty in predicting population and economic growth from trends as the current census figures show means releasing green belt land too

early in anticipation of growth would be risky. Paragraph 4.6.This comment relates specifically to Welwyn Parish. The

over-extraction of water from the Mimram in Welwyn is an established fact, Appreciates there is relatively little that the borough can do on its own to minimise water usage and wastage. However, not only should it ensure that developments are water and sewerage efficient it should make a strong commitment to working with adjoining Authorities, the Environment Agency and the Water Companies to ensure that future plans acknowledge the environmental damage that has already been caused and seek to ameliorate it.

Paragraph 4.7. HCCs Local Transport Plan acknowledges uncertainties over possible population and economic growth in the county in the next 20 years. The Emerging Core Strategy and that of neighbouring Authorities should now be making their expectations clear to HCC. You note that there has been a change in HCC policy from increasing the road network to making better use of existing roads. It is our view that this runs the risk of being inadequate, given the anticipated growth throughout the county. The borough together with other Authorities must ensure that their necessary growth is not compromised and quality of life reduced by a failure to join up the thinking between themselves and the county in the matters of transport and traffic.

Welwyn Hatfield Borough Council Environmental Health

Each land area identified through the Emerging Core Strategy for provision of land suitable for housing development should be subject to a Health Impact Assessment (HIA).

Herts County Council HCC Landscape

Environment is generally described just as a constraint which needs enhancing. Could usefully be described as an opportunity. For example, better restoration of the urban fringe would assist its appeal and value for housing, recreation and wildlife.

Herts County Council HCC – Lead Local Flood Authority

HCC has to develop, maintain, apply and monitor a Local Flood Risk Management Strategy (LFRMS) for Herts. Will have a number of detailed policies and procedures which WHBC must act consistently with, and have regard to, in carrying out its statutory functions.

Will become the Sustainable Drainage (SuDs) Approval Body in 2014 with its own statutory process. Would like a paragraph on SuDs to include a reference to the SuDS Approval Body.

Would like references to the Thames Catchment Flood Management Plan within Core Strategy. Flood storage areas are an important natural asset and Broxbourne ( Strategic Flood Risk Assessment (SFRA) identifies several on the Welwyn-Hatfield border.

Housing proposed for Digswell and Cuffley (?) has the potential to increase the risk of flooding elsewhere because of their location in areas likely to generate overland flow and themselves be subject to surface water flooding. A level 2 SFRA will be required to investigate these areas further during Site Allocations document.

WHBC residents experience regular bouts of isolated small scale flooding. Further development in the borough is likely to further exacerbate this problem. Property specific flood resilience measures may be suitably proportionate esponse for this type of flooding.

Would like to see discussion of the role of blue infrastructure within the strategy in conjunction with the references to green infrastructure

English Heritage

Notes the reference to the historic environment in CS1, the spatial vision (pg28) and the strategic objectives (pg30). These references are helpful and set important parameters for the plan. Need to be clear which policies are strategic under terms 156 & 184 of NPPF to ensure any neighbourhood plans are underpinned in terms of key policy areas. Note that para 18.62 defines these as policies in the ECS and it would be helpful if such a statement was made earlier on.

Welwyn Hatfield Borough Council Environmental Health

Consideration should be given to the effects of existing sources of air pollution on the population in addition to the overall air pollution contribution that is likely to occur.

The proposed developments will generate increases in traffic and some mitigation measures shall be necessary to limit air pollution and at the same time reduce greenhouse emissions. However, in anticipation of any development the impact from increased vehicle uses and any other potentially polluting activities will need to be assessed and modelled prior to establish appropriate mitigation measures.

Comments from Individuals and Other bodies

This policy will not deliver what it is promising - it does not protect areas of greatest environmental value.

Water abstraction already too high.

The ideals of growth should be reconsidered where growth means the increased use of natural resources

Sustainable growth would seek to keep the natural environment viable. Core Strategy is unsustainable and not in accordance with NPPF

Lack of sustainability of the settlement strategy focus for development

The area of WGC4 is complete at odds with the statement of ‘at a scale which recognises environmental and infrastructure constraints’

Additional drain on natural resources, Possible flooding downstream at Hertford Review sustainable statements to ensure they align with conclusions for WGC4,

the development is not sustainable.

Housing

No commitment to use of current properties/developments. Consideration should be given to changing the use of some of these so they can be for residential use. No building should be undertaken until all current property is fully utilized.

Loss of sense of community due to large increase in housing. Lack of delivery of social housing - Recent housing development in the Borough

has only achieved 14.7% social housing rather than the 30% suggested.

Transport

Linking up the main parts of Hatfield; the Old Town, station, Business Park, Town Centre, Galleria and University - Good public transport is needed to achieve this. Walking and cycling links between these places also need to be safe and well sign-posted.

Good public transport links are also needed between Hatfield Town Centre and other Hatfield local centres such as neighbourhood centre High View and

Birchwood and Oldings Retail Park, The documents state what A1 (M) junctions improvements would be needed if

houses are built. What guarantees are there of such improvements?


OBJECTIONS to CS1 raised on the following grounds Number of comments

Metropolis PD In their review of Green Belt locations, the council have not taken account of the

need to promote sustainable patterns of development (ref NPPF para 84). Policy should commit the council to undertaking a comprehensive Green Belt review based on sustainability criteria.

Policy fails to acknowledge that there may be special circumstances within such locations to enable the delivery of truly sustainable developments. Supporting text should acknowledge this

David Lock Associates (for Lafarge)

CS1 Bullet point 3 should be modified the reuse of previously-developed and worked land within and adjoining major settlements. In bullet point 4, the word “prudently” should be replaced with “effectively”. Strategy should focus on providing new housing on previously worked land as well as PDL while protecting viable mineral resources.

Spawforths (for Langtree Group PLC) Para 4.4 Disagree with phasing strategy– PDL should not be prioritised over

green field sites. This is not a requirement of the NPPF.Robin Bretherick (for Mr and Mrs Ferry):

CS1 first bullet point the words “increases the supply of housing” are not strong enough to reflect the extent of the local and wider housing need.

Para 4.4 There is a risk that in putting such emphasis on the use of PDL, the Council could lose sight of other sustainability benefits which could result from developing certain accessible green-field sites.

Para 4.6 The issue of water stress should not be given priority over the need for housing. Welwyn Hatfield is not alone in suffering from this problem, and the wider housing need demands a level of development which requires action to alleviate the water shortage. Policy CS10 requires development to address water conservation issues, and contributions should be sought towards improved water infrastructure where necessary

Herts & Middlesex Wildlife Trust HMWT

CS1 5th bullet point is presumed to relate to climate change adaptation and mitigation but requires clarity and wording should be revised. Adaptation and mitigation of what?

Veolia Environmental Services – CS1 Not positively prepared, not consistent with national policy, To plan

positively for growth whilst allowing infrastructure constraints is not consistent with principles of sustainable development.

Supports the third principle of protecting sites of the highest environmental value, whilst allowing sustainable development to take place in those areas of lesser environmental value, such as previously developed sites, particularly where they can demonstrate good access to the primary transport networks.

CS1 5th fifth principle requires that adaptation and mitigation measures are incorporated into the design and construction of new development, which include energy and water efficiency measures and the use of low carbon and renewable

energy. Supports the principle of the inclusion of these matters into development proposals generally, however VES considers that broader support should be given within the policy for new low carbon and renewable energy development proposals in their own right.

The end commentary which accompanies these principles suggests that a positive approach will be taken to development proposals which reflect the presumption in favour of sustainable development set by the NPPF. Considers that where the plan is absent or silent (as it is for example in terms of minerals and waste development) then the commentary should have a similar default position in favour of all categories of sustainable development provided that the impacts of the development do not substantially and demonstrably outweigh the benefits.

Herts Biological Records Centre

Para 4.4 Reasoned Justification should mention Biodiversity Offsetting as a means of compensation where ecological interest may be lost.

Para 4.6 a cautious approach to setting appropriate levels of growth is welcomed in respect of limiting demands on water, a major resource and ecological consideration.

Welwyn Garden City Society

Consider the ECS to be unsustainable. To be specific: Paras 4.3 and 4.6 The strategy will be an additional drain on the natural

resources such as the River Mimram which is already the subject of concern as evidenced by the Friends of the Mimram and the Herts and Middlesex Wildlife Trust. The strategy may contribute to flooding downstream in Hertford. It will encourage use of car since the identified areas are not within walking distance of the town centre and station and not well served by public transport.

Challenges the assertion that this plan will protect and enhance natural resources as we do not feel an adequate assessment has been conducted on the local nature reserves and surrounding countryside within and without the green Belt. We have highlighted these concerns in response to the Habitats Assessment report.

Para 4.6 The report emphasises the problems identified above, but seemingly is taking no note of its own findings.

Para 4.7 There is no commitment to new infrastructure and these developments expect people to walk and cycle more. Is this realistic when considering current patterns of behaviour, and the limitations for the elderly and infirm.

Environment Agency

Policy CS1 - third bullet point. The location and design of new development needs to take into flood risk and should be located in areas of lowest flood risk.

Policy CS1 – fourth bullet point. The term ‘areas of highest environmental’ is too

vague and needs to be clearer. Does it include areas of high flood risk, rivers and their buffer zone, national, regional or local wildlife sites? Or is it types of Green Infrastructure identified in the Welwyn Hatfield Green Infrastructure Plan? What about the importance of wider biodiversity for sites not officially designated? It is important to clarify this especially as some areas of importance for Biodiversity will no longer be protected by saved policies R11, R13 R14 and R15.

Individuals and other Bodies

This large increase in housing would potentially decentralise the small local community losing the sense of coherence and community, as the area would move away from a smaller settlement and feel like a small town.

Unclear where the 2014/15 - 2018/19 target of 82% on PDL comes from or what is envisaged for after 2019 - for the period through to 2029?

Economic Growth is not a sustainable objective, the ideals of growth should be reconsidered

Welwyn Garden City was planned to be a balance between town and country. Its' objective to have work for people in the town with food produced at its outskirts. The continual erosion of green belt / farm land takes away any notion of sustainable development.

The East of England is one of the driest regions in the UK and Welwyn Hatfield is an area of serious water stress (the Rivers Lee and Mimram already suffer from over-abstraction). Borough has a higher per person water use rate than the national average. There seems to be no plan on how this will be addressed. To conserve water, not only would any new developments need to be water efficient, but measurements would need to be introduced either to reduce water usage by the existing occupiers of Welwyn Hatfield, or to identify new sources of water in the area.

North West Hatfield

This policy will not deliver what it is promising. It does not protect areas of greatest environmental value. How can planning to drop 2000 houses in a single location of the Green Belt, currently successfully farmed (and farmed for generations), be described as protection of environmental value.

Greenbelt Land should be left as Greenbelt, already have a new estate beside the original Garden Village Hatfield. Why do we have to have enormous amount of housing which will put strain on schools, doctors, surgeries, sewerage system etc.

Panshanger

The area for development planned in Panshanger was the subject of a large campaign to prevent gravel extraction only a few years ago. Campaigners won and future extraction was ruled out. Panshanger residents do not want gravel extraction on their doorstep.

This development planned for Panshanger will be a drain on natural resources such as water and will deplete not enhance natural resources such as the Mimram. By comparison, the SHLAA proposed locations in Cuffley, Brookmans Park and Welham Green all have water extraction from the underground aquifer, therefore not impacting any local rivers.

Para 4.6 Too large a development in WGC4 will cause serious stress on the Mimram and the water supply will be insufficient.

700 houses is completely out of scale, swamping existing community facilities and infrastructure

Para 4.3 With one local shop in the proposal this will not be achieved. Building 700 homes will do nothing to enhance the built environment and character of the local landscape - quite the reverse

Our local community is balanced now. To protect areas of greatest enviornmental value and minimise the need to travel - don't concrete them over and build houses.

Para 4.3 None of these objectives are met by the Panshanger airfield proposals

This large increase in housing would potentially decentralise the small local community losing the sense of coherence and community, as the area would move away from a smaller settlement and feel like a small town.


SUPPORT for CS1 Number of comments

Bayard Developments Supports Policy CS1 as the policy content is in accordance with Government

policy guidance.

Turnberry Planning Ltd (for Cemex and Gascoyne Cecil Estates) Welcome the vision and borough-wide objectives. Agree that a planned release

of green belt land is necessary in order to meet the Borough’s need for growth over the plan period and that, with due care this can be delivered so as to avoid coalescence with existing settlements and to maintain the integrity of the green belt around the towns and the villages.

Support the commitments set out in the overarching policies to: deliver sustainable development as set out in draft policy CS1.

AECOM (for the Royal Veterinary College) Proposals for sustainable development outlined in CS1. In particular, the

importance of ensuring that the support of economic growth and the reduction of social inequalities are not just limited to the main towns, but that these benefits are distributed throughout the borough.

Herts & Middlesex Wildlife Trust (HMWT) Welcomes policy protecting areas of highest environmental value – previously

developed sites can be of remarkable ecological value and may qualify as SSSIs or local wildlife sites. This also includes GI and SuDs considerations in new development

Strongly welcomes policy seeking to enhance as well as protect natural assets. Also important that the concept embeds ideas of ecological networks and landscape scale conservation restoration and enhancement. Nature conservation cannot focus solely on protecting existing sites.

Para 4.6 –is pleased that the council recognises the serious water shortage issues facing the borough.

Welcomes the recognition that environmental infrastructure constraints need to be factored in as part of positive planning. Policy should encourage develops to consider the environmental context of any proposed development site from earliest opportunity.

DPP Tesco Supports the principle that the location of new development should deliver a

sustainable pattern of development which protects areas of highest environmental value; minimises the need to travel by directing growth to those areas with good transport networks and which are well served by jobs, services and facilities.

The Oshwal Association (UK) Fully supports the provision of Policy CS1 apart for exceptional circumstances of

a particular body with established location and needs.

Veolia Environmental Services Supports the principle of protecting sites of the highest environmental value and

the principle of mitigation and adaptation measures being incorporated into the design and construction of new developments.

Homes and Communities Agency HCA Supports the inclusion of Policy CS1.

Natural England Welcomes the use of the Planning Inspectorate’s model policy in for a

presumption in favour of sustainable development.

Hertfordshire Biological Records Centre

CS 1 is welcomed,as this highlights the protection of areas of highest environmental value, that natural assets of the borough should be protected and enhanced, and that natural resources are to be used prudently. This also includes GI and SuDs considerations in new development.

Welwyn Parish Council

Supports this Strategy. Acknowledges the overarching principles of the NPPF and the need for all levels of local government to work within them

University of Hertfordshire ( Turnberry Planning Ltd )

Supports the Strategy set out in CS1 to deliver mixed –use sustainable development and the principles identified to achieve this that is planning positively for growth which supports the local economy , and directing development to locations which minimise the need to travel and are supported by jobs, services and facilities.

Individuals and other bodies

More emphasis should be placed on the preservation of all agricultural land - with a growing population and the effects of climate change, this irreplaceable resource is crucial


CHANGES suggested for CS1 and Section 4 Number of comments

Robin Bretherick (for Mr and Mrs Ferry)

CS1 first bullet point The extent of the increased housing supply should either be quantified (at the higher end of the range) or the wording should be expanded to say “increases the supply of housing to a level which meets the anticipated need…”.

Para 4.4, Delete or lower the target figure of 82% for PDL. Para 4.6 The reference to “a cautious approach to setting the appropriate levels

of growth” should be deleted and cross-ref should be made to policy CS10 aimed at limiting water use within new housing and to policies for contributions to water infrastructure through CIL if necessary.

Herts and Middlesex Wildlife Trust HMWT

Para 4.6 Addition of some text is required - The nature of new development is important in addressing water resource issues, firstly in minimising the additional demand that will be created by new development, and secondly in enabling infiltration of water and groundwater recharge. The planning system clearly has a significant role in determining how development is delivered. Policy must ensure

that new development improves water use efficiency, increases grey water recycling and rain water harvesting, and requires uptake of SUDs.

5th bullet point Revise wording of: climate change adaptation and mitigation. 7th bullet point Revise wording of: 'Taking into account whether... the

development accords with the principles set out above. Addition of some text, needed. The nature of new development is important in

addressing water resource issues, firstly in minimising the additional demand that will be created by new development, and secondly in enabling infiltration of water and groundwater recharge. The planning system clearly has a significant role in determining how development is delivered. Policy must ensure that new development improves water use efficiency, increases grey water recycling and rain water harvesting, and requires uptake of SUDs.

The Oshwal Association (UK) suggest adding ‘ other than in exceptional circumstance the location….’ as a

preface to the third bullet point as a means to recognising that in some circumstances the established location or needs of a particular body cannot always be addressed within the expected framework of the strategy and that exceptional circumstances will therefore arise.

Environment Agency 3rd bullet point. add the location and design of new development needs to take

into flood risk and should be located in areas of lowest flood risk 4th Bullet point is too vague, clarify what areas of “highest environmental value”

are. Depending on the classification given, we would like to see policies R11, R13,

R14 and R15 saved until adequate protection can be given under a Development Managment Policy document.

Veolia Environmental Services 1st principle CS1 Revise wording to. “The need to plan positively for growth in a

form and at a scale consistent with the identified needs and aspirations of the Borough. Where environmental or infrastructure constraints to growth are identified, a positive and proactive approach to sustainable development and infrastructure provision will be taken, by the Council which helps to support sustainable growth... et al'

5th Principle CS1 Revise wording to. New energy development proposals either standalone or in association with other forms of development, which can bring forward low carbon and renewable forms of energy in the Borough within the Plan period will be supported in principle'.

Commentary.... Add “Where sustainable development proposals are submitted in the Borough and Borough Plan contains no policy provisions relevant to the consideration of a planning application or policies are out of date, the Council will grant planning permission unless; Policies in the National Planning Framework, or · Other material circumstances indicate otherwise.”

Comments from Individuals and other bodies More emphasis to be placed on/ a commitment given for all current vacant

properties to be reviewed prior to further building activity undertaken. Would help to eradicate 'ghost towns', and aid the easing of housing demand.

Build elsewhere Use other areas identified as having a better (water) supply, e.g. in the outlying

villages.


Section 5 How Much Growth

Consultation Point CS2 Meeting the Needs for growth


John Lewis note that town centre boundaries and new retail sites will be allocated in a

separate Site Allocations DPD or AAP, but have concerns over the future scale and nature of development in light of identified capacity.

seek reassurance that any future retail development will be directed into existing centres in the first instance and that edge or out of centre will be reviewed in accordance with national policy and sequential and impact tests.

Broxbourne Borough Council presumes housing figures take account of CLG household + ONS population

projections, new census data and “SHMA Evidence”. requests Welwyn Hatfield demonstrates that the housing target selected does not

have any adverse impact on Broxbourne’s housing market area. Broxbourne’s SHMA identifies limited housing market relationship with Welwyn

Hatfield.

North Hertfordshire District Council Housing target of 7200 seems reasonable on the basis that 7200 is the

objectively assessed need for housing as required by the framework and; there is no overspill housing need that neighbouring local authorities would be expected to absorb.

Comments by individuals and other bodies Increasing the supply of affordable homes by other means that building has not

been properly taken into account. 5.14 and 5.22 - Mentions East Hertfordshire development but no maps are

shown in document East of England Plan stated that WH had specific planning issues being

constrained by two estates and a river system



Green Belt

CPRE

The Emerging Core Strategy proposes 7,200 new houses, with 6,800 to be provided in Welwyn Hatfield with some in the Green Belt. Even more green belt land will have to be set aside for development to ensure that Green Belt boundaries will not need to be moved until after 2029, but the amount is not quantified. Paragraph 5.13 in the Emerging Core Strategy reveals the actual target is for 9,200 new houses, most of which would have to be built in the Green Belt. This is not made clear in either document.

Comments by individuals and other bodies Objection of any loss of Green Belt The approach of the less GB released the better is not sound. Council should have undertaken a full review of the entire green belt as existing. Given that East Herts have recently objected to the inclusion of the 400 dwellings

proposed in its borough this should not be included. This also applies to the housing shown in St Albans

Housing target too low

Bidwells 400 dwellings per year is too low to meet the backlog of housing need (context of

the RSS cited) and no contingency is allowed for. East Herts land should not be included in calculations. Plan should deliver at least 500 dpa – but a target falling within 643-709 dpa to meet affordable housing need and 809 dpa to meet full needs of natural population growth and in-migration would provide a more robust approach meeting the tests of soundness.

David Lock Associates (for Lafarge Tarmac) Providing insufficient housing will result in increased rates of in-commuting. ONS

2008 projections predict household size will reduce from 2.42 in 2008 to 2.35 in 2033. Would adversely affect the local economy.

Plan downplays the migration element of projections leading to continued underprovision of housing and housing pressures in the borough (implied ref to para 159 of NPPF). Proposed target of 400 dpa will lead to 5,600 households with unmet needs by the end of the plan period leading to increasing problems with access to affordable housing

JB Planning (for the Fairfield Partnership) It is only acceptable to provide for less than the objectively assessed housing

need if there is no way in which the need for housing can be met. Agree with EHDC’s assertion that there are other ways in which the need could be met within Welwyn Hatfield’s boundaries, such as Green Belt releases around the villages.

AECOM (for the Royal Veterinary College), David Lock Associates (for Lafarge Tarmac), Spawforths (for Langtree Group)

Question if 7,200 will be sufficient. It is at the lower end of the range of scenarios and runs the risk of not delivering the amount of housing (including affordable housing) needed in the borough (WH Sustainability Appraisal)

Metropolis PD Insufficient opportunities for housing growth have been identified. 6,800 dwellings

is too few and in conflict with emphasis of NPPF on housing growth.

NLP (for Mariposa) Proposed target of 400 p.a. is not sufficient to meet the objectively assessed

housing requirement including evidence of demographic growth contained in the council’s own background paper. NLP’s contend that 600 to 950 dwellings per annum are required with a target at the lower, 600, end of the range being appropriate. No evidence to suggest that below 450-470 per annum would meet objectives of NPPF whilst supporting the 12,200 jobs monitoring target. The 400 target is not rationally and objectively drawn; 2 imperatives – does not reflect migratory patterns and consistent net in-migration (the selected approach is constrained) and the economic scenarios rely upon a static jobs/dwelling ratio, which fail to take into account demographics, economic activity and unemployment. Problematic because an ageing population and decline in household sizes mean that the number of jobs supported by each house is likely to fall due to a similar decline in the number of workers per household.

Maddox Associates (for Goodman) 400 dwellings per year will fail to meet the backlog of housing need (context of

the RSS cited plus past delivery rates). NPPF requires the full objectively assessed housing requirement for market and affordable housing in the housing market area to be met.

Mark Rayner East of England Plan envisaged a target of 10,000 new dwellings for Welwyn

Hatfield. Although this plan has now been shelved it should represent an independent view of what is reasonable for the area.

Comments by individuals and other bodies The council’s proposed housing target does not meet the full need for market and

affordable housing in the borough. The plan is therefore unsound. Flaws in the current strategy mean that additional land for housing will be

required and further land from the Green Belt will have to be released. The need for housing is notably higher than the target.

Housing

St Albans District Council

Although the Emerging Core Strategy suggests that urban extensions could potentially include land within St Albans and the Land for Housing Outside Urban Areas document identifies such an extension, St Albans Council has not formally been asked to meet any of WHBC's housing need.

CPRE

Not convinced that all avenues and options to deliver residential accommodation have been explored. The University of Hertfordshire has recently received approval for a substantial number of Student Residences which have not been included in the calculation of residential requirement in the Core Strategy. With

the high proportion of houses in Hatfield and other parts of the borough in student occupation a more rigorous approach to the provision of student residences could free those houses for general occupation.

Barton Willmore for Landform Estates

WHBC relies on East Herts to accommodate 400 units identified as expansion to Welwyn Garden City, but outside of the borough. None of the neighbouring LPAs has a final housing target. Two of them, East Herts and Stevenage, are still at an early stage of their plan making and they do not have targets at all. Until these authorities have completed their plans, it is simply not possible to know how much housing can be imported or exported to neighbouring LPAs.

Discussions with East Herts and St Albans under the duty to co-operate may be ongoing, but we understand that there is no agreement at the time of writing. In the event that St Albans do not agree to additional housing growth there is no 'Plan B'. The plan is therefore deficient and does not provide certainly of delivery.

AECOM (for the Royal Veterinary College) Additional provision for housing beyond 2029 does not appear to be adequately

accounted for in sites identified in the current Emerging Core Strategy. Growth target will not be met: insufficient opportunities within the borough to

meet the target. The 400 dwellings identified on sites outside the Borough have not been justified and do not meet the ‘tests of soundness’. There is a danger of double counting as these dwellings could be allocated in other Local Authorities figures. Failure to indentify sufficient opportunities means that Core Strategy has not been positively prepared.

strategy fails to provide reasonable flexibility to deal with changing circumstances Strategy fails to meet identified (and potential future) needs.

Bayard Developments if no new employment land is to be allocated, planning for housing numbers only

on a self-serving basis is not justified.

JB Planning (for Fairfield) Paragraph 5.24 states that the council will consider the need to review the Core

Strategy in the event that a significant level of windfall development takes place, meaning that the Borough’s housing target would be exceeded in the early years of the plan. This is illogical, as the available evidence indicates that the need for housing is in fact far higher than that which is being planned for, and it appears that only a political desire to avoid changes to Green Belt boundaries is preventing the council from meeting this need.

para 5.24 runs counter to NPPF para 159 because it does not plan positively for growth. .

Metropolis PD Not using 10,000 homes as a starting point means that the council will not be

able to ensure an appropriate supply of housing to meet local needs and the Core Strategy will be unsound.

Council should have given weight to the evidence that led to the East of England Plan’s target of 10,000 dwellings.

Maddox (for Goodman) Chosen approach is not the most appropriate given the reasonable alternatives

(more land could be identified), strategy is not consistent with national policy as it does not meet the full objectively assessed need for market and affordable housing in the housing market area (47, NPPF).

NLP (for Mariposa) and Barton Willmore (for Landform Estates) The council has not carried out an objective assessment of the need for housing.

AWD Perkins If around 6,000 homes are required for natural growth in the population, then only

1,200 has been allowed for net migration and changing demographic trends. This is inconsistent with government projections.

Strutt and Parker (for Mrs C Horton and for Trustees of Brocket Estate and Barratt Strategic)

No certainty or evidence in the Emerging Core Strategy that there is a consensus with St Albans or East Herts to accommodate the 460 homes. This must be justified as those two authorities have only just announced proposals for a Review of Green Belt.

Garden Village Preservation Society According to the Campaign for the Protection of Rural England's report, Housing

the Future, the government has been using a set of data, to calculate future housing requirements, that is out of date and contains immigration anomalies. The government is also using predictions as opposed to forecasts (the latter being far more accurate, being based on a larger data set). The CPRE states that the government is using a system of "predict and provide" as opposed to "plan, monitor and manage". This all suggests a knee-jerk reaction to what could be wildly inaccurate information and a set of predictions which could become self-fulfilling. How has the council calculated the requirement for housing in the borough over the next sixteen years?

According to most recent forecasts from the Office for National Statistics, the population in the UK is set to grow by 14% between now and 2029. If 7,200 new homes are built in the borough in the same period (using an average of three people per home), we are looking at a population increase of approximately 19%. Why are we expected to take more than our fair share of the increase?

524 residents of the Ellenbrook area The target for development is based on projections of growth which are based on

what has happened in the past and so they might not be realistic. There has been no full review of housing availability, needs and current demand. The possibility of increasing the supply of affordable housing by means other than vast building projects has not been properly taken into account.

Comments by individuals and other bodies Building 7,200 homes is unjustifiable and is not based on robust evidence and is

not objective, not deliverable and is clearly not the best strategy Hertfordshire has had its fair share of development since 1960s Number of house sales in the area has remained consistently low Consideration should be given to the number of houses that will become

available once UoH new halls of residence are built. People will have to live elsewhere and new housing should be given to those who

have lived in the area for a number of years. Incorrect decision to build so many houses Objection to the housing requirement identified and the sites chosen Housing target is too high. Align housing target to availability of water.

Employment

CPRE A more flexible approach to the designation of employment areas in order to

implement the Government's intention to allow change of use of redundant office space to residential without planning permission could result in a significant contribution towards the housing requirement.

Roehyde Consortium object to the level of employment land identified and the absence of any

requirement for a new employment floorspace (by way of either business park or warehouse/distribution development).

David Lock Associates (for Lafarge Tarmac) Proposed jobs monitoring target is too low. It is not as high as the figure in the

Fordham work (14,000) nor that in the LAHELR (13,400 to 16,200). Suggest CS2 should set a minimum target of 12,400 jobs (figure in HSES). Fordham work suggests that a jobs growth figure of 12,400 would require a housing target of 11,500 as a minimum, but demographic and population changes would dictate that 14,000 new homes would be recommended target (2011 to 2031).

Comments by individuals and other bodies Unlikely to increase jobs significantly due to recession Not enough local jobs for the new residents Document inconsistent. States that it is difficult to identify a realistic jobs target

but monitoring chapter has a target of 12,200 jobs.

Retail

Comments by individuals and other bodies Question need for additional retail floorspace when there are vacancies in the

town centres and online sales increasing

Methodology (Evidence Used/Population Projections)

CPRE The Core Strategy and the Land for Housing outside Urban Areas have to be

read together to fully understand the council's intentions. The ECS contains information which amplifies the significance of the potential development sites in the LfHOUAs which in turn raises questions about the ECS. Both documents as inextricably linked and none of the questions online allow CPRE to cover the concerns the documents raise. Consider therefore that the consultation is flawed and if the Core Strategy is based on this, it may be unsound.


shares similar concerns about the ONS population and CLG household projections as Welwyn Hatfield Borough Council. (St Albans) cannot comment on the approach or assessed level of need in the WHBC Emerging Core Strategy. This is most appropriately determined by Welwyn Hatfield Borough Council and tested at examination of the Welwyn Hatfield Core Strategy to ensure that it accords with paragraph 182 of the NPPF in that it is positively prepared, justified, effective and consistent with national policy.

would encourage WHBC to ensure that all relevant parts of the NPPF, such as those set out in paragraphs 14, 47 and 182, where need is required to be balanced against other policies, in the pursuit of sustainable development, are fully considered.

Barton Willmore (for Landform Estates) Objective Assessment of the need for housing has not been undertaken to inform

the Strategy.Bayard Developments

The housing growth forecast is linked to employment. This second criteria used in the selection is seen in paragraphs 7.4 to 7.6 of Housing Background Paper 1. The figure of 8000 new homes (over the 20 year period 2011-31) has regard to current economic circumstances at the very start of the plan period.

Comments by individuals and other bodies Population data from the 2011 Census indicates boroughs population is lower

than previous estimates 7000 houses equate to approximately 21,000 new residents. This assumes a

population increase of over 19%. The Office of National Statistics predicts a 13% increase by 2031 that would require an additional 4800 houses

The LCB West SHMA is out of date and is not based on up to date population and household projections.

Council has not properly considered the need for housing as so much of the evidence of need has been ignored when setting a target (set out in the housing background papers).

The council’s argument that recent in-migration figures have been higher than average and can therefore be discounted is unsound

Target is based on projections derived from past trends so may not be realistic. Need a full review of housing availability, needs and current demand

Questions the need to encourage migration growth, which is not supported by the community.

Scale of growth will encourage migration into prime commuter area rather than satisfying genuine need.

No detailed argument and evidence to support this level of housing Forecasts of employment opportunities by Hertfordshire Employment Land

Review was based on economic forecasts which pre-date the credit crunch and subdued activity...(and) would suggest lower rates of potential jobs growth would now be more realistic'.

When asked a panel of 937 people (presumably representative) supported a target of 2950 houses between 2011 and 2031 by 81.64%. This would appear to indicate the feelings of the population of the Borough regarding housing expansion and accord with the findings G, W and X in the list of indicators. It is supposed to be the task of the Council, surely, to represent the wishes of the population of the district.

Infrastructure

Comments by individuals and other bodies Existing infrastructure is inadequate for this scale of development Not confident that required infrastructure will be made possible. Increase in people and required infrastructure not sustainable. There is no credible evidence that the necessary infrastructure could be provided

to support 400 houses per annum.

Previous Consultation

Comments by individuals and other bodies Previous consultation results have been ignored in forming this strategy The case for this housing target has not been convincingly made



Tesco

Support principles of Policy CS2 of meeting the needs for growth.

Homes and Communities Agency

Supports policy CS2 and the approach the council has taken in establishing its

housing target. Target of 7200 homes consistent with a strategy seeking to maintain current alignment of jobs to housing. It would make a significant contribution to meeting the need for affordable housing in the borough.

Tesco

Support identification of 308 hectares of employment land to maintain a sufficient supply of jobs in the borough

Cemex

agree with the council that a planned release of green belt land is necessary in order to meet the borough's need for growth over the plan period and that, with due care, this can be delivered so as to avoid coalescence with existing settlements and to maintain the integrity of the green belt around the towns and the villages.

Comments by individuals and other bodies

CS2 is the best approach given the circumstances Support Welwyn Hatfield’s commitment to partnership working with surrounding

authorities. Balanced approach taken with regard to strategic employment and residential

development. Agree with average of 400 dwellings per year. A few extra houses in Welwyn Garden City will do no harm and provide the

opportunity to improve the environment Agree that more housing is needed.



Roehyde Consortium

additional employment land should be safeguarded to compensate for the recent and future losses of allocated employment land to other retail, leisure and housing uses.

Policy CS2 should include a policy requirement for development of one or two employment sites (as business park and/or warehouse/distribution centre) in the St Albans and Welwyn Hatfield area having regard to the London Arc Job Growth and Employment Land report dated March 2009, and Policy CS2 should properly reflect the employment need based on a robust and credible assessment of what degree of this need should be catered for.

Barton Willmore for Landform Estates change wording to reflect opportunities at Welham Green

Bayard Developments

believe the delivery during the plan period should be higher than the stated 6800 of the 7200 new homes and consider that the housing delivery should be at least 10000 new homes from 2011 to 2029.


Housing target should be increased to reflect reflect the wider housing need having regard to, among other things, previous higher targets, in-migration and the Government’s and HBF’s concern about the implications of the wider shortfall across the country as a whole.

Increase housing target figures and undertake a full review of GB boundaries throughout the Borough in relation to available SHLAA sites.

BLG 1 should be deleted and the additional housing requirement should be met from land within, and on the edge of, the larger inset villages.

NLP (for Mariposa)

Housing target should be no less than 470 per year subject to further evidence to demonstrate the impact of delivering higher objectively assessed housing requirements: 621p.a. (economic) and 725 p.a. (demographic) to enable a conclusion that there is a caser to outweigh the benefits and/or that unmet need will be met through the Duty to Cooperate.

Metropolis PD

Housing target should be 10,000 dwellings 2011- 2029.

Maddox (for Goodman)

Housing target should be at least 8,600 dwellings 2011- 2029.

AWD Perkins

Housing target should be at least 9,000 dwellings 2011- 2029 plus 2,500 from 2029 to 2034.

David Lock Associates (for Lafarge Tarmac)

Minimum jobs growth of 12,400 over the plan period is needed. The council’s own evidence shows that this would require a housing target of 11,500 as a minimum, but demographic and population changes would dictate that 14,000 new homes would be recommended target (2011 to 2031).

Turnberry Planning (for University of Hertfordshire)

Policy should be reworded so that aligns more with the sustainable ambitions of CS1 as follows:

“In order to effectively manage the borough’s resources, the council will resist any net loss in the stock of existing dwellings and any allocated employment land and will explore how both can be maximized through mixed-use development. It will also resist the loss of retail floorspace in the borough’s town, neighbourhood and village centres, unless otherwise in accordance with other plan policies.”

JB Planning (for Fairfield)

Delete paragraph 5.24

Mark Rayner

Housing requirement should be for at least 500 dwellings per year.524 residents of the Ellenbrook area

The target for building could be reduced by providing purpose built student housing and reallocating houses as affordable family homes. The target for building should be based on a review of housing availability, needs and current demand, rather than just calculated projections.


Given the current economic climate and the trend in employment and population figures the increase in housing is over-stated and should be revised to a lower level.

The rural areas should be a major part of a revised scheme and the policies should be redefined to include them. All local villages in the Borough should be considered able to sustain the addition of small housing project s confined to single numbers of houses (under 10) suitably placed on the landscape.

Do not build at all and then people won’t come The rural areas should be a major part of a revised scheme and the policies

should be redefined to include them. All local villages in the Borough should be considered able to sustain the addition of small housing project s confined to single numbers of houses (under 10) suitably placed on the landscape.

Put East Herts growth on map Growth should be restricted to brownfield availability


Section: 6

Consultation Point: CS3


North Herts District Council

North Hertfordshire District Council’s Core Strategy Preferred Options 2007 Core Policy C indicates a draft village boundary for the part of Oaklands settlement that it within North Hertfordshire District.

NHDC would like to be involved should Welwyn Hatfield council intend to review any settlement boundaries in the area of the adjoining borough e.g. Welwyn Village, Oaklands and Mardley Heath and Woolmer Green.

JB Planning (for Gascoyne Cecil Estates)

Welcome the identification within CS3 of Welwyn Garden City and Hatfield as the main focus for development for the new plan period and the identification of the secondary and tertiary foci for development in the Borough's villages.

However concerned that the Core Strategy both plans for less employment development than is required, and also that this will fail to meet the needs of the Borough's economy and the more sustainable rural settlements.

Do not seek any change to policy CS3 but note that the proposed strategy is not entirely consistent with its aims.

JB Planning (for Fairfield Partnership)

Whilst we do not seek any change to Policy CS3, we note that the proposed strategy is not currently consistent with its aims, and we advocate a change to other aspects of the document as drafted, to make it consistent with Policy CS3.

Humphrey Brosnan

Welham Green has the advantage of having a large amount of local employment – 3,500 jobs.

Comments by individuals and other bodies Settlement extensions should be last resort if all other options not suitable (i.e.

Intensify town centres, Build a new garden city, Build satellite garden villages, Brownfield infill).

The council should be actively seeking sites that have been identified as offering good potential for development even if they have not been put forward by landowners as available.

Concern the increase in the University’s student accommodation numbers of approximately 1,500 has not been considered

Concern about the reasons behind the villages of Brookmans Park and Welham Green being excluded.

Danger that there will be insufficient provision of new homes to sustain existing services and facilities within the villages without green belt release.

Of the 16 sites brought forward in issues and options only 2 have been chosen for housing

Infilling development at Digswell, Woolmer Green, Mardley Heath, Oaklands is strangling the villages.

Sustainability of development should also be looked at and written into Core Strategy (approach to design, construction, use of materials, use of solar etc)

There are plenty of brownfield sites available. Villages have 22% of population and 7% of proposed new homes.


OBJECTIONS raised on the following grounds

General Objections

St Albans Council

Concerned that this distribution may not fully reflect the settlement hierarchy as set out in the Table 2 of the Emerging Core Strategy.

Comments by individuals and other bodies Deeply disappointed that the council has not chosen to support the creation of a

new Garden City. Housing on previously developed land should exceed 85% target.

Soundness of Delivery/Distribution Strategy

AECOM (for the Royal Veterinary College)/AWD Perkins

400 dwellings on land outside the borough have not been properly justified and fail the test of soundness. Also a risk that the 400 will be double counted. Unrealistic approach and no basis in NPPF for allocating in neighbouring authority areas. Authorities must work together to achieve this. It should be discounted from WH’s strategy.

Fails to provide reasonable flexibility to deal with changing circumstances (WH Housing Background paper 2 recognises that Option 4 leaves little room to manoeuvre).

Failing to identify sufficient opportunities means that CS2 has not been positively prepared.

Beyond 2029 - Unclear where shortfall will be delivered; uncertainty around 1,400 homes at Hat2 which is the only safeguarded site

JB Planning (for Fairfield) Council’s distribution strategy, set out in Table 3 would fail to make adequate

provision for development around villages and would be found unsound.

Spawforths (for Langtree Group PLC) Lack of evidence in the document that St Albans DC is being engaged under the

Duty to Co-operate means that the Core Strategy could be found unsound.Maddox (for Goodman)

The council has failed to take into account evidence previously submitted by Goodman which demonstrated accessibility of Hat2 by non-car modes and that the residual highway impact is not material.

Not published supporting evidence on transport to support the Core Strategy Not the most appropriate strategy given the reasonable alternative of identifying

more land within the plan period (Hat1 and Hat2). Core Strategy has not demonstrated why Hat1 is the most appropriate site given the reasonable alternative of Hat2.

Soundness (Most appropriate strategy when considered against alternatives – justified)

AECOM (for the Royal Veterinary College)/AWD Perkins/Humphrey Brosnan No. The villages should have a role in housing provision. There are sites around

Cuffley, Brookmans Park and Welham Green which would be sustainable and ensure a flexible and deliverable Core Strategy.

Maddox (for Goodman) No. Hat2 should be allocated for a minimum of 1,500 homes during the plan

period to meet housing needs, provide a flexible and deliverable supply of housing ensuring choice and competition in the market. Relying upon one site (Hat1) for 25% of the housing target is a risk to the strategy.

The Core Strategy should include accurate information on the alternative options, particularly on heritage and minerals, with a clear explanation of why sites are not selected as the best option.

AWD Perkins No. All sites across the borough should be assessed in a fair and balance

manner without political interference.

AECOM (for the Royal Veterinary College) Reasons for discounting development around one or more of the borough’s

villages are not sufficient. Land currently proposed to be released is of higher agricultural value than land around Brookmans Park.

Land in East Herts should not be relied upon as it is not clear if East Herts is minded to take the location forward (the council’s Housing Background Paper 2).

AWD Perkins No. Panshanger should not be advanced within the plan period; there are more

suitable sites in the borough. No. Hat1 will result in minerals sterilisation & adversely affect Hatfield Garden

Village. Hat3 is unsuitable for development due to its location, car dependency, lack of amenities and coalescence with St Albans. Hat2 is wholly unsuitable for development. Land within East Herts and St Albans is unsuitable. Regardless, housing numbers in adjoining area should not count towards Welwyn Hatfield’s requirements.

Council was wrong to adopt Option 4 rather than Option 6 as presented to CHPP on 27 September 2012. Option 4 is inflexible and will not deliver the housing target.

Reasons stated at Cabinet on 9 October 2012 (recorded in the minutes) for adopting option 4 and not 6, do not meet the tests of soundness.

Humphrey Brosnan Council was wrong to adopt Option 4 rather than Option 6 as presented to CHPP

on 27 September 2012. Objections to development at Hat1 and Panshanger, as well as EHDC concerns

about land east of WGC mean that the distribution strategy lacks credibility. Hat 1 and WGC4 also have minerals that would need to be cleared first whereas

Cuffley, Brookmans Park and Welham Green are on clay. Panshanger site was rejected by a previous Inspector at the last Local plan

Inquiry.

Lack of robust and credible evidence

AWD Perkins Urban capacity has been over estimated and an over reliance on urban sites in

the first 8 years of the plan period. Calculations provided suggesting reduced delivery rate for SHLAA sites and sites

with planning permission (para39). Urban capacity suggested as 2,730. This leaves 4,470 to come from rural sites. The council’s analysis suggests this is not achievable. 3,448 + 2,730 (6,178) leaves a shortfall of 1,022.

Significant over-estimation of the capacity on the four rural sites identified in the LFHOUAs report.

Barker Parry (for Hubert C Leach Ltd) Given that the emerging strategy is predicated upon the release of Green Belt in

order to realise the housing figures proposed, it is strange that the Council has not carried out a Green Belt Review.

Decision Making Process/Previous Consultation/Public Opinion

AECOM (for the Royal Veterinary College) [Public Opinion] should be taken into account but the negative impacts of the

proposed Settlement strategy on the future of the villages should be equally considered.

North Mymms Parish Plan recognises the housing need is an issue for low cost started homes, the elderly, disabled; and young adults.

Humphrey Brosnan Huge public opposition to Hat1 and WGC4 should be taken into account.

Barton Willmore (for Landform Estates Ltd) Option 6 – considered in private and subsequently dismissed (5 options were

considered in July 2012). Option 6 is a more balance distribution strategy with growth spread around service centres. Discounting Option 6 is a failure of process.

Metropolis PD Council’s strategy has been unduly influenced by local politics based on an early

public outcry on the general issue of Green Belt releases rather an informed assessment of benefits flowing from specific proposals.


Decision to choose Option 4 over Option 6 not justified and will not be sound. An inquiry into the way this was decided should be conducted.

Cabinet should have deferred the decision until the full Sustainability report was available as this would weaken the case for Option 4.

This decision has been made for political not planning reasons Previous consultation on housing targets has been ignored. This is not localism The consultation responses in 2011 were based on a very small number of

respondents. Not reflective of population. Previous consultation was clearly opposed to development at Panshanger as well

as the villages – this has been ignored. Hatfield Garden Village residents not previously made aware of proposals.

Duty to cooperate/Neighbouring authorities

CPRE No indication in either document that appropriate cross boundary dependencies

with St Albans or East Herts have been agreed. The response from East Herts Council is negative. Consequently proposed extensions beyond the Council Boundary are speculative, premature and misleading.

Spawforths (for Langtree Group PLC) Lack of evidence in the document that St Albans DC is being engaged under the

Duty to Co-operate means that the Core Strategy could be found unsound.

Barker Parry (for Hubert C Leach Ltd) It is noted in the Sustainability Appraisal (SA para 9.45) that the extension to

Welwyn Garden City into East Herts District has not been discussed with that Council. Likewise, St Albans District Council (to the west) has only just instigated a Green Belt Review and it seems premature and perverse for Welwyn Hatfield to be suggesting district border releases and encroachments without full and proper cooperation with surrounding districts.

Robin Bretherick (for Mr and Mrs Ferry) East Herts has objected to the inclusion of land in WGC in figures for Welwyn

Hatfield and therefore should not contribute to Welwyn Hatfield figures

Comments by individuals and other bodies Table 3 - East Herts has objected to the inclusion of land in WGC in figures for

Welwyn Hatfield and therefore should not contribute to Welwyn Hatfield figures

Opposition to lack of growth around villages

AECOM (for the Royal Veterinary College)/Metropolis PD/Bidwells Development focussed on WGC and Hatfield with no GB review around large

excluded villages is not supported.

Metropolis PD Focus on WGC and Hatfield creates an unsustainable pattern of development

disadvantaging other settlements that will be deprived of inward investment.

AECOM (for the Royal Veterinary College) /JB Planning CS3 conflicts with CS20 which aims to support rural economies and yet

restrictions on growth means that villages will not realise their potential and services may not be maintained.

AECOM (for the Royal Vet College) CS3 conflict with ECS Objectives 10 and 11. The current strategy for housing delivery outlined in Policy CS3 will fail to meet

the sustainable development objectives outlined in Policy CS1 due to the lack of focus on rural areas, particularly the large excluded villages, which are in need of inward investment and growth to ensure that their vitality is retained.

Bidwells – Andrew Holloway (on behalf of Stephen Austen) Policy CS3 seeks to focus new development on the main towns of Welwyn

Garden City and Hatfield. The larger villages such as Welham Green are excluded from any growth proposals.

Only 5 dwellings have been identified for Welham Green over the entire plan period. This is insufficient and will not meet Welham Green’s growth needs.

Robin Bretherick (for Mr and Mrs Ferry) Objects to the extent that the policy relates to residential development, the

primary focus should be restricted to Hatfield. The secondary focus should be within “or on the edge of” the large excluded villages.

Residential garden land should not be precluded from development just because it now falls outside the definition of PDL.

The figures for the larger villages or at least Welwyn are too low to assist in supporting established service provision

Bayard Developments Bayard Developments object to aspects of this policy. The settlement strategy

places too global a policy strategy that Hatfield and Welwyn Garden City have better accessibility than other parts of the district.

Bayard Developments consider that the settlement strategy should include land at Welwyn as a primary focus, not as only secondary focus.

Barker Parry (for Hubert C Leach Ltd) The concentration of development in Welwyn Garden City and Hatfield fails to

sustain larger villages in the district wherein a third of the population currently lives and where there are services and facilities to be used and supported and housing needs to be met.

Contrary to what is said in Policy CS3, the villages in the district are not the focus for development. Secondary or otherwise policy CS20 makes quite clear and it is an understatement, to say the least, to state that the “majority of development” is directed to the main towns when it is almost wholly so directed.

Duo Enterprises for Mr John O Connor/ Mr Fernandez/ Mr David Dance/ Shirley Wray/ Carol Beckerman

The policy does not allow for the expansion of the villages so it does not fit local needs.

Barton Willmore (for Landform Estates Ltd) Policy CS3: Distribution of housing doesn’t reflect the settlement hierarchy e.g.

Digswell takes more than Brookmans Park and Welham Green. Query 2001 ONS data and population of Welham Green. ECS sets out objectives for the Parishes. North Mymms contains Brookmans

Park and Welham Green. The distribution of housing growth will not meet the objectives. There will be no improved mix of housing including smaller homes for

young people, older residents and specialist accommodation. Impact on villages: If villages are not allowed to grow then local people may have

to move away, villages will become less sustainable as shops and services may close and more journeys will be made by car.

This is not a positive or sustainable approach and it is contrary to national policy (NPPF 28) ... promote the retention and development of local services and community facilities in villages such as shops, meeting places, sports venues, cultural buildings, public houses and places of worship.

Objects to distribution strategy as it relates to Welham Green because it allocates 5 dwellings over the plan period, which is substantially less than even has been allocated even to some small villages. The village accounts for 2.8% of the borough’s population, but would only receive 0.1% of its growth.

Option 4, which would have provided for 215 dwellings in the village, would have been more reasonable. The option chosen may result in people moving out of the village and a decline in services.

This is not a positive or sustainable approach and is contrary to para 28 of the NPPF as well as being contrary to the Core Strategy’s Vision and strategic objectives as it relates to a sustainable pattern of development.


Table 3 should be reviewed, to reflect new Green Belt releases for development throughout the Borough, and to be distributed in accordance with the settlement hierarchy set out in draft Policy CS3.

CPRE

There is a conflict between para 6.10 which says " The following option was considered to be reasonable alternative " and paragraph 6.11 which rejected the option as it would result in more Green Belt being released for housing, increasing the urban sprawl, and impact on the landscape.

Either it is or is not a reasonable alternative, it is difficult to see how limited growth around the large excluded villages would result in more Green Belt land being released, unless there was an overall increase in the number of houses being built in the Green Belt. Growth around the villages should lead to a reduction in growth around the major towns.

There is a potential for over 450 units in Brookmans Park, Cuffley and Welham Green (SHLAA) but no clear explanation why they have been excluded.

524 residents of Ellenbrook

The parish objectives set out in the Core Strategy document show that villages recognise the need for affordable housing in their areas. All of these villages have shops and some have a train station and so meet sustainability objectives. By having virtually no development in these villages, they will eventually housing only the wealthy and elderly.

Comments by individuals and other bodies Strategy is imbalanced A contradiction in the number of homes - fewer in secondary focus Welham

Green than in Little Heath Limited development opportunities within the villages. Policy CS 3 calls for some

development in the larger villages but these have been removed from the Core strategy.

The approach of focusing growth around the two towns is fundamentally flawed, the borough is small and distribution should be across the region.

The strategy completely ignores current commuting/shopping patterns (i.e. people in Brookmans Park and Welham Green shop in Potters Bar)

Object to the secondary focus for development being limited to sites within the four large excluded villages.

The policy does not allow for expansion of the villages so it does not fit local needs.

Affordable housing will not be provided in the villages without green belt release.

Green Belt


Objection to loss of recreational use of Green Belt. Objection to loss of wildlife in Green Belt. Green Belt alteration at Hatfield seems to be given less significance than

alteration at the villages. Political mistakes of bad planning the past should not mean we suffer in the

future by building on green belt.

Coalescence

Comments by individuals and other bodies Objection to potential coalescence between WGC and Hatfield Strategy promotes coalescence into East Herts towards Hertford

Infrastructure

Bayard Developments Housing background paper 1, paragraph 1.60 indicates that for housing growth

over 8000 new dwellings to 2031 the overall road network would 'struggle to cope'.

Bayard Developments believe little weight should be given to this transportation criterion since that situation can be improved by planning and highway obligations, transportation criteria should not dictate the growth since it is always possible to deal with transportation matters as is proposed in the Council's suggested growth areas.

Lands Improvement Holdings Concerned to understand from HCC that Cuffley’s primary school will be affected

by large scale growth in the Goffs Oak area and would consider that a new school should be provided as part of that development of contributions should be sought to improve schools in Broxbourne.

Comments by individuals and other bodies Focusing development on the two large areas will cause infrastructure pressures

in these areas. A lot of the population from the growth areas will be commuters The strategy focuses on delivering housing in a small number of locations, failing

to take into sufficient account the additional supporting infrastructure requirements and burden created.

Such a strategy will lead to over-development and the required infrastructure is not in place

Water shortages – Mimram already over extracted Drainage – insufficient consideration has been made of issues such as drainage. Increased risk of flooding Sewerage at capacity Putting all development in 2 areas put too much of a strain on infrastructure in

those areas

Broad Location for Growth Areas


When considering the overall longer term proposals and potential urban extensions together, there are concerns of over concentration and infrastructure impacts of development to the west of Hatfield.

For this reason this Council has significant concerns over the impact on St Albans District that may arise from Broad Location for Growth 2, safeguarded land and urban extension HAT3.

Light Aircraft Association

I Section 6 at the end of the Policy CS 3 section you state that:" Development which would ...... result in a reduction of its services and facilities which would be to the detriment of the local community will be resisted". However the plan to close Panshanger would destroy the very services and facilities provided by Panshanger Aerodrome.


Both of these areas are a long way from main shopping centres, train lines, leisure and entertainment centres, secondary schools and from medical facilities.

Panshanger is a long way from employment areas BLGs1 and 2 are not previously-developed sites and so are not consistent with

the strategy of the ECS. BLG1 is remote from transport links and other facilities and services and so does

not fit with CS3 (and Table 2 and Para 6.3) Policy CS 3 states that: "Development which would ...... result in a reduction of its

services and facilities which would be to the detriment of the local community will be resisted". However the plan to close Panshanger would destroy the very services and facilities provided by Panshanger Aerodrome.

Welwyn Garden City


Welwyn Garden City has already experienced substantial development over the past few years, as has Hatfield. Halt development in these two areas, with the exception of brown field sites

It is hard to see how Welwyn Garden City itself could be altered except by natural change such as with the Roche site.

Use brownfield sites instead of greenfield sites. Green Belt land is supposed to be only used when there are no other reasonable alternatives. Welwyn Garden City has conveniently located sites ready for development (Tesco and Lafarge Tarmac).

Welwyn Garden City has 44% of population and 32% of proposed new homes. Object to PE (land in East Herts), Panshanger would lose even more of its ‘Green

Space’ which is now deemed necessary in urban areas for public health, both physically and mentally

Hatfield


The proposal is to concentrate development on Hatfield to meet the objectives of regenerating Hatfield and providing good transport links. The selected sites are to the west of the A1 and so some distance from the town and railway station. Development in this location will undermine the regeneration of Hatfield and lead to increased car use on already congested roads.

Hatfield has taken most of the development for Welwyn Hatfield over the last decade and should not be expected to do this again. The earlier development came with the promise of improved facilities and an attractive District Centre. These have not materialised, and there is no reason to believe that they would this time round.

We are offended by the statement ‘Hatfield doesn't have much character to preserve' in paragraph 3.1 of the Housing Background Paper Part 2. One of the sites recommended is in Green Belt, surrounds a listed building and has seven other listed buildings nearby. If this outrageous judgement has contributed to the decision to concentrate development in Hatfield, then that decision should be immediately reversed.


Hatfield Garden Village should be listed separately from Hatfield in the settlement hierarchy.

Salisbury Village should be listed separately from Hatfield in the settlement hierarchy.

Hatfield has 29% of population and 40% of proposed new homes.

Offensive statement “Hatfield doesn’t have much character to preserve”.

Reasoning that more homes in Hatfield will assist in redeveloping the town centre is not reflected in recent trends.

Development of sites to the west of the A1(M) are too far from the town centre and will undermine regeneration of Hatfield

Strategy focussing development on Hatfield which has taken most development over the last decade. Previous promised to improve facilities in Hatfield have

never materialised.

Proposals will divide Hatfield into: 1) Old Hatfield; 2) Central Hatfield; and 3) New Hatfield north-west of the A1(M).

False promise of improved facilities and an attractive District centre never materialised previously



Turnberry (for Gascoyne Cecil Estates and CEMEX) Agree with the council that a planned release of green belt land is necessary in

order to meet the borough's need for growth over the plan period and that, with due care, this can be delivered so as to avoid coalescence with existing settlements and to maintain the integrity of the green belt around the towns and the villages.

Support the commitments set out in the overarching policies to: Direct growth to the most sustainable locations as set out in draft policy CS3

David Lock Associates (for Lafarge Tarmac) Agrees with settlement strategy, but over reliance on urban capacity sites in early

years means that there will be increased pressure on social infrastructure without opportunities to meet demand.

Natural England

Welcomes the inclusion of the settlement hierarchy within policy CS3 (Settlement Strategy). Natural England welcomes this strategy as it ought to promote the most effective use of existing services and infrastructure networks.

HCA Supports policy CS3 and the principle of focussing sustainable growth around the

two main towns to ensure that new development has access to jobs, shops and services.

Broxbourne Borough Council Appears to be a sustainable option in terms of providing good access to higher

order transport services/facilities.

North Mymms Parish Council Strongly supports the proposals for this parish. The Parish Council agrees with

the limited number of new dwellings proposed for this area where building will be mainly on brownfield sites and no green belt land would be released, avoiding coalescence of villages, which we consider very important to the character of this parish

North Mymms Parish Plan We support Policy CS3 Settlement Strategy which proposes that there should

only be infill development within Brookmans Park, Little Heath and Welham Green.

North Mymms District Green Belt Society Agree in principal with the settlement strategy however, does regret the loss of

Green Belt land in the county. We do not agree with the use of Green Belt for urban extensions suggested in the Land for Housing Outside Urban Areas paper.

Woolmer Green Parish Council Building ten houses in Woolmer Green over the next sixteen years is acceptable

growth

Welwyn Parish Council

We agree with the primary focus on WGC and Hatfield. Secondary focus on the large excluded villages seems appropriate.

The commitment not to extend into green belt land around the excluded settlements is welcomed. While Welwyn Parish will receive the largest increase of the excluded villages, 3.9% of the total, the majority of this is the Frythe and is a sensible use of previously developed green belt land.

The proposed tertiary development within the parish seems appropriate but there may be scope for neighbourhood Plans for land in Digswell and indeed possibly for the Tudor Road site in Welwyn Village.

Comments by individuals and other bodies In general, support the approach Concentrating growth in the towns which already have the infrastructure to

support additional residents is better than putting new housing in villages. Support this approach subject to improved hospital and other medical facilities

across borough. Support this approach subject to all brownfield being used first. Support exclusion of the villages from development. Support – Villages do not have the infrastructure/capacity for growth Hope extension of Hatfield Garden Village + Panshanger happen only after all

other possibilities have been exhausted.

Total No. of Expressions of SUPPORT


General Changes

AECOM (for the Royal Veterinary College) Opportunities to meet the 7,200 target should be identified within the borough.

Other suitable and available land exists within the borough.

North Mymms Parish Plan Include a statement that should the proposals for housing in other parts of the

borough not happen, there will not be any attempts to compromise on Policies CS3 and CS4.


Table 3 should be reviewed, to reflect new Green Belt releases for development throughout the Borough, and to be distributed in accordance with the settlement hierarchy set out in draft Policy CS3.


Growth should be spread more evenly throughout the borough.


Development by individual site and probably by individual building firms would allow a variety of approaches and styles and also allow for individual landscaping to suit each site. This could also allow participation by the local community at the earliest stages of development - unlike the present policy.

Start again and reread the Charrette report from 2009. Restart the process and provide justification for the selection of the option Make information more transparent and available to the public on time. Listen to the DPM who calls for more garden cities Stop pandering to landowners and the better off Use brownfield land and protect Green Belt at all costs. Scale down the development plans. Consider smaller plots of up to 20 acres be released in the Green Belt so as not

to have an adverse effect of agricultural output Spread-out development in a way around the whole borough, rather than so

much of it in one area of Hatfield That brownfield sites throughout the borough are fully developed for housing

such as Broadwater West. Use vacant property for housing.

Need for Green Belt Review

Metropolis PD

Strategy should be directed to the most sustainable locations based on a comprehensive Green Belt review (NPPF para 84)


The reasonable alternative should be the preferred solution. There cannot be any justification for retaining marginal pieces of peripheral GB land which make little contribution to GB objectives simply because a boundary line was drawn to include land in the GB.

The development of these sites cannot be considered to be urban sprawl. Suggested change revise strategy to undertake a comprehensive Green Belt Review

Development in villages


Table 2 and para 6.4 Large Excluded Villages should not include a presumption that Green Belt boundaries must be maintained. Suggested change to table: Under “Large excluded villages” delete the last seven words: “and the maintenance of Green Belt boundaries”. Suggested change to paragraph 6.4 Delete last sentence

The delivery of new housing should be focused on Hatfield and the larger villages excluding the geographical expansion of WGC and BLG1. Increase number of new dwellings to be provided in and around larger villages, or at least for Welwyn, following a review of Green Belt boundaries.

Bidwells – Andrew Holloway (on behalf of Stephen Austen)

Appropriate provisions must be made for limited growth of well established villages such as Welham Green. The evidence provided in the HBP – Part 2 at Option 6 would direct 215 new dwellings over the plan period to Welham Green.

This represents a more effective, flexible and well- balanced strategy, which is supported.

Lands Improvement Holdings (LIH) The council classes growth of a scale up to 10% as minor. At Cuffley, if you took

the urban capacity of 62 dwellings together with green belt releases of 150 dwellings, this would be fractionally over the ‘minor’ growth threshold. Here, it should be noted that the LIH site to the east of Northaw Rd East is 130 dwellings.

So if this site were brought forward it would fall within the council’s definition of ‘minor’ growth.

Duo Enterprises for Sanjay and Anamika Gadvhi

The policy does not allow for expansion of the villages so it does not fit local needs. A housing site should be allocated in Oaklands as there is easy access to strategic transport, it would make efficient use of previously developed land, it would provide affordable housing for local families, it would support growth in local shopping areas etc.

Strutt and Parker (for Trustees of Brocket Estate and Barratt Strategic) Development of housing land at Stanborough would be in the spirit of the

settlement strategy because it would effectively be development on the edge of WGC.

Bidwells Insufficient housing is being allowed for at Cuffley – will not meet Cuffley’s growth

needs. Site in The Meadway should be allocated for housing

AECOM (for the Royal Veterinary College) Sites around the large excluded villages, including land to the south of

Brookmans Park, can provide sustainable options for carefully managed growth.

Metropolis PD/JB Planning (for Fairfield) Option 6 as considered by the Council can provide sustainable options for

carefully managed growth to ensure the sustainability of the large excluded villages. Consequential changes should be made to Spatial Vision and Objective 4.

JB Planning (for Fairfield) Should plan positively for growth in villages.

AWD Perkins CS3 should be amended to permit development around Brookmans Park,

Cuffley, Welham Green and Welwyn at an appropriate scale (see submission for suggested wording).

Metropolis PD Cuffley should be identified as a growth point.

H J Brosnan Welham Green is close to Hatfield and has its own station on the east coast

mainline. In respect of land to the east of Welham Green, the site is known as Marshmoor and covers an area of 21.3 Ha. The site is within Green Belt, however given that it lies within a sustainable public transport corridor, has

regular bus services to St Albans, Welwyn Garden City and Enfield and is adjacent to an existing employment area this site represents a sustainable location for development to meet part of the district’s future housing requirements.

Bidwells Insufficient housing is being allowed for at Cuffley – will not meet Cuffley’s growth

needs. Site in The Meadway should be allocated for housing

Metropolis PD/JB Planning (for Fairfield) Option 6 as considered by the Council can provide sustainable options for

carefully managed growth to ensure the sustainability of the large excluded villages. Consequential changes should be made to Spatial Vision and Objective 4.


Change the focus of new housing to fit the stated policy and do not exclude the larger villages on spurious grounds.

A strategy of virtually no development in villages will mean they will only house the wealthy and elderly

Dispersal of housing development, with smaller numbers of houses in more locations would help to maintain the character of existing towns and villages, whilst promoting growth at a more manageable level.

The rural areas should be a major part of a revised scheme for housing provision and the policies should be redefined to include them.

All local villages in the Borough should be considered able to sustain the addition of small housing projects. This would not add significantly to traffic flows and would not add unduly to pressure upon local services but could be an aid to the sustainability of small local businesses.

Building in villages more balanced way of building. Villages also need expansion to enable them to thrive.

Adopt Option 6 which is more justifiable, flexible and deliverable.

Distribute the growth more widely and evenly around the borough/extend the release of Green belt to around villages.

Policy should state that the secondary focus of development will be within and adjoining the large excluded villages, which will be in the order of 10% of the dwelling stock at 2011.

Reinstate the four hundred missing houses planned in Welham Green, Brookmans Park and Cuffley.

Consideration should be given to infill development (of no more than 3 residential units) within those small villages situated in the green belt where it can shown to be of economic or community benefit

Build the 7,000 homes in an out of town location

Development around towns


WHBC and EHDC should work together to produce joint planning policies to deliver Birchall Garden Suburb.

Extra 2,500 dwellings should be added in for WGC in Table 3 (though 1,300 of these would be at Birchall Farm ion East Herts).

Strutt and Parker (for Mrs C Horton)

Development of housing land at South Way would be in the spirit of the settlement strategy as it is within the catchment of Hatfield and will be viewed as an urban extension to Hatfield rather than Welham Green

Comments by individuals and other bodies Take account of land near A414

Total No. of suggestions for CHANGES suggested 576

Section 6 and Policy CS4

Consultation Point


AECOM (for Royal Veterinary College) Release of some Green Belt is justified given insufficient supply of PDL in urban

areas. The suitability and achievability of unspecified locations for 315 dwellings should

be clarified.

St Albans District Council A Strategic Green Belt Review is likely to be required to support Green Belt

green field proposals in the Site Allocations DPD. Such a review could be undertaken jointly by St Albans District Council, Dacorum Borough Council and Welwyn Hatfield Borough Council.

Stevenage Borough Council Support approach, but needs to be supported by a strategic Green Belt review.

Welwyn Parish Council It is inevitable that there will be some loss of Green Belt land. We assume that

the indicative timings for development, site allocations and identification of safeguarded land will be included in the pre-submission consultation documents.

note the commitment to maintaining a green corridor between Hatfield and Smallford.

note the need to include Green Belt land in East Herts as part of the Plan and that some of this will be required post 2029 for possibly up to 1100 houses. Will this land be safeguarded as part of the Plan?

While the borough recognises the need to work with other Authorities where the Plan indicates use of land outside the borough it is silent on the reciprocal needs of other Authorities that might wish to extend their developments into Welwyn Hatfield and the extent of any proposed encroachment. This should be addressed now.

Turnberry Planning (for Cemex and Gascoyne Cecil Estates) re land north west of Hatfield: initial feasibility work indicates that early phases of

development on this site could be brought forward without the need for major upgrades to either roads or utilities infrastructure.

David Lock Associates (for Lafarge) Joint working is needed between EHDC and WHBC to produce a Green Belt

boundary around Birchall Garden Suburb.

Comment by individuals and other bodies Talks should be set up with other Hertfordshire councils with a view to possibly

creating a new settlement within their boundary (i.e. North or East Hertfordshire) Concern Gypsy camp and housing development planned in Sleapshyde region of

West Hatfield, football stadium, 100’s of homes in Colney Heath, large development of Oaklands College area and rail freight terminal in Park Street will result in the decimation of the Green Belt and half the country.

Support and balance new housing by including open spaces, sports, recreation areas and playgrounds.

Using the word ‘exceptionally’ all the time is unnecessary as the exceptional circumstances for reviewing the Green Belt have already been established.

Future Green Belt releases will need to be judged against the 5 stated purposes of the Green Belt and the sustainable nature of the location and the development proposed.



Premise of policy

Barker Parry (for Mr Whitten and Leach Homes) Plan is unsound and not in accord with the NPPF because there has been no

Green Belt review, the extension into East Hertfordshire has not been discussed with East Hertfordshire District Council and St Albans District Council has only just instigated a Green Belt review. This is compounded by the fact that the only document now put forward for consultation is “Land for Housing Outside Urban Areas” which deals exclusively with the areas around Hatfield and Welwyn Garden City

JB Planning (for Gascoyne Cecil Estates) Delaying the review of GB boundaries to a Site Allocations DPD or Area Action

Plan will lead to a shortfall in deliverable housing land in the short to medium term.

Comment by individuals and other bodies CS4 not positively prepared.

Distribution Strategy

Duo Enterprises

Oaklands could make a contribution to housing. The policy does not allow for the expansion of the villages so it does not fit local

needs.

Lands Improvement Holdings

Has previously submitted information to the council about its site (south of Cuffley) and requests that this continue to be taken into account.

Strutt and Parker (for Brocket Trustees) Distribution strategy chosen is not the most appropriate when considered against

reasonable alternatives. Land between Stanborough and Lemsford should have been included in the distribution strategy.

Neil Bedford

The reasons stated at the Cabinet meeting of 9 October 2012 for adopting Option 4 in preference to option 6 do not meet the tests required in the NPPF. It was perverse to choose Option 4 as it is less flexible than Option 6 and is not the most appropriate strategy. The large villages are in reality urban areas developed on the back of the railways 80 years ago. Brookmans Park is a good location for new housing as it is close to a station and has easy access to employment in Welham Green.

Mark Rayner Option 6 should be reconsidered.

Comment by individuals and other bodies The distribution of where extensive development is proposed is where councilors

do not live Political interference has led to a number of locations included within the initial;

consultation being excluded. Option 6 should have been chosen instead of Option 4 There are other locations around Hertfordshire have greater capacity for further

housing. Do not put almost all new housing for the next 18 years in only two locations as it

will put pressure on services, infrastructure and quality of life. The adoption of option 6 (CHPP report 27/09/12) would have been a better

strategy, allowed for greater flexibility in housing delivery and would help to sustain existing services and facilities.

The policy does not allow for expansion of the villages so it does not fit local needs

Land to the south of Cuffley could make a significant contribution towards achieving sustainable development in the borough and HBP 2 endorses this approach.

75% of borough residents live in the two towns which have seen 99% of recent growth (mainly the old British Aerodrome site). Plenty of land and scope for more growth near to other 25%

There would appear to be a prejudicial stance taken on sites at the edge of urban areas, which are considered by themselves not large enough to create the required ‘critical mass’ in the Green Belt for a sustainable neighbourhood and therefore have been discarded. However, each site must be assessed on its merits in consultation with the local community. Provision of a range of different sized sites, to help facilitate incremental growth around the edge of settlements in Green Belt locations.

Restart the process and provide justification for the selection of the option. Distribution strategy means that Hatfield will have a disproportionate number of

new dwellings. Hatfield Garden Village and Salisbury Village should be considered as

settlements in their own right and not parts of Hatfield. There are over 700,000 empty properties across the UK, so release of Green belt

land in Welwyn Hatfield is not necessary. Green Belt SHLAA should have been included in this consultation.

Phasing

NLP (for Mariposa)

object to statement that land at the broad locations for growth is unlikely to be released before 2019. This is unrealistic and unduly restrictive and could result in underdelivery of housing in Welwyn Hatfield in the first five years of the plan. An over reliance on one form of development places significant risks on the delivery of a consistent supply of homes and to meet infrastructure requirements. Phasing release after all brownfield is used is neither justified nor effective. Significant aspiration to develop a masterplan for Panshanger with public engagement and the site could be available before 2019.


Phasing strategy should not prevent broad locations for growth coming forward as soon as possible. Cole Green could start delivering new homes in 2017/18.

Release of land from Green Belt and safeguarded land - general

Robin Bretherick (for Mr and Mrs Ferry) There is no justification for restricting Green Belt review to the edge of the

borough’s towns

524 residents of the Ellenbrook area The Green Belt between Hatfield and St Albans is narrow and fragile and so

changing it in this area will cause St Albans and Hatfield to be joined.

CPRE

This policy is ambiguous. It refers to safeguarded land being released for development only when including green infrastructure has been established to provide a permanent separation between Hatfield and the village of Smallford. There is currently permanent separation between Hatfield and Smallford, green infrastructure already exists with a clearly defined Green Belt boundary. The proposal in Land for Housing Outside Urban areas will breach that boundary and destroy current green infrastructure, consequently the two documents contradict each other.

Hertfordshire County Council Minerals and Waste

re BLG1, BLG2, land south of WGC, land west of Ellenbrook, land in East Hertfordshire, land south east of WGC, land south of Ellenbrook and land north of Roehyde. Not located in three preferred areas for sand and gravel extraction, their status as most undeveloped areas means that they may contain economically viable mineral.

Although Minerals Policy 4 aims to resist the development of land for mineral extraction outside of the three preferred areas, this does not preclude the fact that applications for mineral extraction could still be approved on other sites.

Minerals Policy 5 seeks to protect mineral resources within the county from sterilisation by encouraging extraction prior to development taking place. Need to ensure that the objectives of both the ECS and Minerals Plan can be achieved. If the CS is to rely on any of the locations for the delivery of housing then evidence must be forthcoming on how it will be possible to extract minerals. Or how the tests of Policy MP5 can be met and the reasons clearly set out in the evidence.

Northaw and Cuffley Parish Council Strongly objects to any significant incursion into, or reduction of, the Green Belt

surrounding Northaw and Cuffley.

Comments by individuals and other bodies Object to any loss of Green Belt. Development at the broad locations for growth would contravene all five

purposes of Green Belt and the NPPF. Should retain agricultural land. Object to Green Belt loss from west of Hatfield, Hatfield Garden Village and

Ellenbrook Fields Major Green Belt releases at Welwyn Garden City and Hatfield are unacceptable.

Further development around the towns and villages will blur their identities. Core Strategy will lead to coalescence of towns Land which prevents the two towns merging should be protected. Loss of biodiversity. Wooded areas and wildlife habitats should be protected. Concern that whilst some Green Belt may have to be released, the removal of

Green Belt around Hatfield removes too much green space from the area in particularly around the NW of Hatfield

It should be explained that in order to meet the overall housing target during the plan period land needs to be released from the Green Belt.

Will lead to urban sprawl and merging of towns and villages. It is as a result of the requisite review of the Green Belt that an appropriate

amount of safeguarded land needs to be identified to meet longer term housing needs.

The proposed housing target is not considered adequate and therefore more land will need to be released from the Green Belt.

Loss of setting and character of the towns and other settlements Some Green Belt land can be classified as brownfield and should be developed

e.g. Kimpton Road, Welwyn. A fundamental aspect of the WHBC strategy is to release land from the Green

Belt to meet identified growth. The NPPF states that Green Belt boundaries should only be altered in exceptional circumstances (paragraph 82). It is understood that apart from the level of growth identified by Welwyn Hatfield there are no explicit circumstances identified to justify the alteration of Green Belt boundaries.

Release of land from Green Belt and safeguarded land BLG1

Comments by individuals and other bodies Strategy should reflect the overwhelming level of objection at issues and options

stage to development at Panshanger. Panshanger should not be advanced for development within the plan period.

Panshanger Aerodrome cannot be developed because this would necessitate a major upgrade to Rye Meads Waste Water Treatment Works. Panshanger Aerodrome is generally unsuitable for development as well as being unviable and not a sustainable option.

Remove this area from the Core Strategy as developable land; protect it as a valuable community asset.

There are other more suitable sites e.g. brown field sites and disused offices.

Release of land from Green Belt and safeguarded land WGC1

Comments by individuals and other bodies Object to the development of WGC1 and building in the Green Belt. Object to loss of countryside. Such as wooded areas and wildlife habitats Surely the pylons across WGC1 make it undevelopable An increase in population in this location would put pressure on existing services

and facilities and impact on local roads The roads around the proposed site to the south of Welwyn Garden are already

overcrowded and far too narrow to take further traffic, in particular Boundary Lane, Linkfield and Middlefield.

Release of land from Green Belt and safeguarded land – Hat1

AECOM (for the Royal Veterinary College) Loss of Grade 2 agricultural land, resulting in the merger of Hatfield and

Stanborough.Strutt and Parker (for Mrs C Horton)

provision of 2,000 new dwellings in this location is not the most suitable and or ‘effective' strategy for the Borough as required by the NPPF. Growth should be spread between two locations, including provision on land to the south of South Way, Hatfield in conjunction with the release of land at north-west Hatfield.

Comments by individuals and other bodies Concerned that if development goes ahead here it will be poorly designed Area is prone to flooding

Bayard Developments object to release of this land from the Green Belt


AECOM (for the Royal Veterinary College) Unsustainable level of growth requiring substantial infrastructure improvements.

Maddox (for Goodman) There is a demonstrable need to bring forward Hat2 within the plan period to

meet an undersupply of housing rather than safeguarding this area for beyond the plan period. NPPF requires choice and competition in the market, which Hat1 will not ensure.


Bayard Developments object to release of this land from the Green Belt

Release of land from Green Belt and safeguarded land – land in East Hertfordshire

East Hertfordshire District Council objects to the inclusion of dwellings within East Herts District within Welwyn

Hatfield Council’s proposed housing trajectory, and requests that the housing trajectory for Welwyn Hatfield Borough be amended to reflect removal of these numbers within East Herts District.

Hertingfordbury Parish Council object to the loss of this pleasant piece of Green Belt land.

AECOM (for the Royal Veterinary College) Land has not been scrutinised through the WH SHLAA. WGC5 was discounted in

the first stage of SHLAA including its poor relationship to existing development & incoherent GB boundary so how is land in East Herts considered to relate well to the eastern side of WGC? Part of East Herts land is intended for mineral extraction. East Herts Local Plan is not sufficiently progressed creating uncertainty for timescales & EH did not support this location at its Issues and Options stage. Site should be discounted.

Strutt and Parker (for Trustees of Brocket Estate and Barratt Strategic) Not the most suitable or effective strategy as required by the NPPF para 182,

because it relies on development outside the borough boundary which may not happen. Develop land at Stanborough instead.

Bidwells (for Stephen Austen) land in East Hertfordshire should not form part of the strategy because there is

no certainty that East Hertfordshire will bring it forward. If the site has no prospect of delivery, the Core Strategy will be unsound. Limited release of Green Belt sites adjacent to large villages, including Welham Manor would obviate the need for further large Green Belt releases including land in East Hertfordshire.

Comments by individuals and other bodies Object to suggested development in East Herts as it is valuable Green Belt and

would cause an unacceptable coalescence with Cole Green. It is clear from their website that East Hertfordshire District Council object to the

approach taken. The land is not part of WGC and East Herts do not want to cede it to WGC. The land would remain within the administrative remit of East Herts yet miles

from Hertford centre and physically attached to WGC. However its housing would not count towards the numbers to be built by Welwyn Hatfield.

The area is good agricultural land. Concerned that ECS proposals, combined with as yet unknown proposals in East

Hertfordshire’s District Plan could result in Welwyn Garden City coalescing with Hertford.

Environmental concerns

Comments by individuals and other bodies Increased pollution as a result of development in the Green Belt. CS4 should be more specific regarding provision of low carbon energy

infrastructure

Other concerns

Metropolis PD

Target of achieving 85% of new housing from 2014 to 2018 on previously developed land is unrealistic and likely to result in the council not having a five-year housing land supply – meaning that Green Belt boundaries will not endure.

Roehyde Consortium (Cemex and A1M Securities) object to the fact that Policy CS4 does not refer to the release of Green Belt land

for any employment uses. Policy should refer to release of land from the Green Belt at Roehyde. Removal of this land from the Green Belt would not result in any harm to the character of Green belt because:

1. There would be no coalescence of settlements.2. This site has no role in separating neighbouring settlements.3. The boundaries of the site are clearly defined and defensible.4. The scheme would have no detrimental visual impact on the adjoining areas of

Green Belt5. The principle of development to the south west of the A1M-A414 junction has

already been established.

Oshwal Association

Support CS4 inasmuch as it protects the general extent of the Green Belt. However, the Oshwal Association considers that that its own circumstances are exceptional. Accordingly, the policy should acknowledge that there may be circumstances where exceptional development can be permitted in the Green Belt subject to other provisions of the Plan and where it does not conflict with the

overall purpose and function of the designation.

Comments by individuals and other bodies Development of Green Belt sites will lead to devaluation of homes nearby. Para 6.24 Housing on previously developed land should exceed 85% target. Distribution strategy should include Sherrards Park Wood, Lemsford Springs,

Commonswood. Building housing is not the same as building communities and building more

housing will make this worse.



Natural England Supports the intent of the policy to promote restraint in the Green Belt. West of

Hatfield offers a variety of ecosystems which should be considered along with the opportunity to promote public access to nature.

HBRC CS4 is welcomed in respect of retention of long-standing Green Belt land. There

will be an increased ecological impact if the safeguarded land at Hatfield is ever released for development. Appropriate compensation should be considered as part of the establishment of permanent GI separation with Smallford

Woolmer Green Parish Council Is satisfied that the green belt around the village is protected otherwise

coalescence with neighbouring villages would be unavoidable.

AECOM (for the Royal Veterinary College) broadly support urban extension north east of Welwyn Garden City.

Spawforths (for Langtree Group) supports the identification of Green Belt land west of Ellenbrook (at Hat3) for

housing.

Comments by individuals and other bodies At some point in the future some modest movement of the Green Belt will be

required; the proposed locations for amending the green belt boundary are reasonable.

Support identification of a broad location of growth area to the east of Welwyn Garden City, within East Herts

Green Belt is under stress from developers, so a carefully managed extension into it with appropriate infrastructure is the best way to protect it.



Robin Bretherick (for Mr and Mrs Ferry) Do not proceed with support for development of land in East Hertfordshire

Duo Enterprises Release land rear of 5 The Avenue for housing development. Build more houses in Oaklands.

524 residents of the Ellenbrook area do not change the Green belt boundary between Hatfield and St Albans.

North Mymms Parish Plan Include a statement that should proposals for housing in other parts of the

borough not come forward, there will be no attempts to compromise on CS3 and CS4.

Arqiva Green Belt boundary around Brookmans Park transmitting station should be

reviewed to enable to develop.

Veolia Environmental Services add following text to penultimate paragraph of CS4: “Where appropriate and consistent with the commitment to actively tackle climate

change, further Green Belt land may be released, where justified, from selected site locations in the Borough, on sites which are capable of bringing forward new decentralised low carbon and renewable forms of energy infrastructure in the Plan period in accordance with Policy CS 10”

Robin Bretherick (for Mr and Mrs Ferry), AECOM (for the Royal Veterinary College), Metropolis PD, Bidwells

Green Belt review should include excluded villages

NLP (for Mariposa) References to the phasing of land releases for broad locations for growth in para

6.23 should be deleted.

Strutt and Parker (for Mrs C Horton) In Hatfield, growth should be spread between two locations, including provision

on land to the south of South Way, Hatfield in conjunction with the release of land at north-west Hatfield.

Callum Durran Land at formerly Home Farm, The Frythe should be released from the Green Belt

to enable its inclusion within the major development at The Frythe.

Barker Parry (for Mr Whitten and Leach Homes) Decisions on how much Green belt should be released, and where, should be

made in the Core Strategy. This would enable a transparent discussion of what Green Belt and where is to be released and also (see objections/comments in respect of CS3) to examine other areas of Green Belt within the district to see whether they are not equally good or better long term releases and this should include all of the larger villages or secondary settlements which are identified in the settlement strategy. Clearly the views of adjacent authorities, which are lacking thus far, are relevant to policies which in particular involve Green Belt releases either at or across borders.

Spawforths (for Langtree Group) Land west of Ellenbrook (Hat3) should be allocated as an urban extension in the

Core Strategy.

JB Planning (for Gascoyne Cecil Estates) Land south of Welwyn Garden City (WGC1) should be allocated in the Core

Strategy. Land at Marshmoor should be released for office-based employment

development as the site is well-connected with the road and rail networks.

Bayard Developments Should refer to the release from the Green Belt of land at North West Welwyn.

Bidwells (for Stephen Austin) Release Green Belt land around large villages (including at Welham Manor)

instead of large Green belt releases such as land in East Hertfordshire.

AWD Perkins Policy should be amended to allow for 500 to 1,000 new homes around each of

the villages of Brookmans Park, Cuffley, Welham Green and Welwyn subject to site allocations and local sustainability assessment.

AWD Perkins Delete reference to land in East Herts and Hat2. Both are unsustainable.

Woolmer Green Parish Council Housing proposals should be scaled down significantly.


Development in (and around) the excluded villages need not be limited to land within the defined urban areas. Some limited geographical expansion can be accommodated on peripheral sites while securing most sustainability objectives.

Comments by individuals and other bodies Strategy should promote brownfield first including Broadwater Road West and

Chequersfield Support for housing development on fields near Essendon and Brookmans Park Select Option 6 Spread development between settlements to maintain character of settlements

and keep growth manageable. Focus development on the Green Belt around the villages The increase in housing is over-stated and should be revised to a lower level. The rural areas should be a major part of a revised scheme and the policies

should be redefined to include them. In light of the current economic situation, the number of houses should be revised

down. Change the focus of new housing to fit the stated policy and do not exclude the

larger villages on spurious grounds.

Land at the Dutch Nursery, Brookmans Park should be excluded from the Green Belt


Section 7 Key Diagram

Consultation Point


Herts & Middlesex Wildlife Trust (HMWT) pleased that Welwyn Hatfield is seeking to embed strategic green infrastructure

and green links into its strategic development plan. Wish to see more clarity on what this allocation would mean in practical terms. What policies will apply to these sites, and what action will the council be taking to ensure that these areas are protected, managed and enhanced to improve their function in this respect?


OBJECTIONS to Key Diagram raised on the following grounds Number of comments

Comments by individuals and other bodies East Herts District Council have no intention of allowing land east of Welwyn

Garden City in their district to be used to meet any of Welwyn Hatfield’s housing requirements


SUPPORT for Key Diagram Number of comments

Tesco

Support the proposed allocation of land for employment uses providing this takes full account of the need for supporting infrastructure, such as adequate car parking. Improving accessibility to existing employment sites can have a positive impact in ensuring such sites achieve optimum employment densities.


CHANGES suggested for Key Diagram Number of comments

Herts & Middlesex Wildlife Trust (HMWT)

The Council should update the Key Diagram and Constraints map to include the Lee Catchment Nature Improvement Area, as encouraged by NPPF paragraph 117. "Planning policies should... identify and map components of the ecological networks, including... areas identified by local partnerships for habitat restoration and creation."

HCC Landscape Officer

The key diagram needs to better reflect the strategic initiatives sought re Woodland Arc , Thames Tributaries, River Valleys and Corridors which also relates to The TLC NIA, urban greening. In addition existing Watling Chase boundary and proposed Mimram Valley Greenspace Strategic Project need to be

shown.


Remove the PE area from the map until such time as East Herts are in agreement.

BLG1 should be reclassified as an area of special interest and its existing protection continued at least until 2029

Total No. of suggestions for CHANGES 4

Section 8: Centres, Services and Facilities

Consultation Point: CS5 (and Section 8 relevant to CS5)


John Lewis

As the major town centre, the majority of mainstream comparison retail development should be focused with the town centre of WGC in the existing retail core. Any housing and employment growth areas should not be identified for any new major comparison retail development.

Ayot St Peter Parish Meeting Query the assumptions made regarding the need for new retail development in

view of the significant effect that the growth of supermarkets and internet shopping is having on vacancy rates in local and town centres.


Investment should be focussed on the redevelopment of Hatfield Town Centre.



CGMS There is scope to increase the evening economy/ offer after the shops close at

the Galleria. This would make full use of the Gallerias facilities and increase employment opportunities. It would attract more trade to Hatfield and reduce the need to travel for Hatfield residents who journey outside the town for evening entertainment. It would not divert evening trade for Hatfield town centre as there is none there of significance and no evening operators would go there because they would be isolated with insufficient trade to be viable. If the evening economy at the Galleria is not allowed to develop such benefits will be lost to the borough.

The Galleria’s sub-regional role in the retail and leisure market should be recognised. Approx two thirds of visitors come from outside the borough and a quarter are 45mins drive time or more away. The impact of additional development is spread thinly and widely to the benefit of the local economy and residents

Bayard Developments

this policy does not give sufficient support for existing retail areas such as Welwyn Village. Supporting housing growth in these areas should take preference over designating new housing areas which will have to rely upon new convenience shops and new service and social facilities.


Objection to a multi-storey retail block on land between John Lewis and

1

Debenhams. Land provides open space in the town and should be preserved. Objection the proposed additional 19,000 square metres of retail floor space due

to recession and increase in online sales. Hatfield, in effect, has three town centres. None of these are successful. Radical

reorganisation to attract retailers should be initiated. There is a complete lack of sufficient good retail development and community

facilities for the existing residents of Hatfield and will be made worse by any new development.



Natural England

support policies CS5-CS12 which together reinforce the sustainable development ethos set out within the borough-wide objectives

Broxbourne Borough Council Support policy to focus retail activities in Welwyn Garden City and Hatfield Town

Centre

John Lewis

supports policy CS5 in accordance with NPPF. Supports the comprehensive approach considered for additional development and where this should be located in accordance with the NPPF. New retail development should be suitable to meet the scale and type of required within individual centres.

Ayot St Peter Parish Meeting Support measures to revitalise neighbourhood shopping centres which is an

essential part of ensuring sustainable communities.


The locations, types and scales of retail development appear to be appropriate.



CGMS The Galleria's absence from the Retail Hierarchy (Table 5) is an anomaly and

must make the Core Strategy unsound. It ignores the Galleria's role as Hatfield's durable retail centre, a role the town centre is never likely to achieve. It should be included in the Retail Hierarchy (Table 5). It should acknowledge that the Galleria performs as Hatfield’s main durable goods and leisure centre as well as a sub-regional outlets destination. Hatfield town centre provides the town’s main convenience shopping offer. This relationship is unlikely to change in the future even if the town centre shrinks in order to become more viable and vital.

We also suggest that Hatfield town centre's function is redefined so that it concentrates on what it actually does i.e. 'Provides the town's main convenience shopping plus community and leisure facilities serving Hatfield in the main'

Paras 8.7 and16.11 should be deleted as they are overly negative. Development at the Galleria could be acceptable if it passes the tests for out of centre retail development in the NPPF

Ayot St Peter Parish Meeting Policy should object to fringe developments by supermarkets as there is currently

an oversupply of this type of retail

Welwyn Parish Council Paragraph 8.5: In the summary of the RTCNA there is little reference to retail

centres in non-town-centre neighbourhoods and the large and small excluded villages. If the borough is serious about maintaining the viability of these neighbourhoods there should be commitment to that objective and therefore some statement of principles and planning.

Bayard Developments the very first line of this policy should reinforce CS20 and state "The Council will

support the existing centres services and facilities."


Section 8.2 Community Services and Facilities

Consultation Point CS6 Centres, Services and Facilities


David Lock Associates (for Lafarge Tarmac) Birchall Garden Suburb could meet the policy objectives set out by Policy CS6,

ensuring that new communities can easily access a range of community services and facilities for example local shops, playgrounds, parks of different sizes and character, doctors' surgery and community centre/village hall.

Natural England Welcomes the range of policies within the Emerging Core Strategy that reinforce the

sustainable development ethos as set out within the Borough-wide objectives. Welcomes both policies as locating retail and community services within accessible

locations has the potential to reduce the need to use the private motor vehicle.

The Theatres Trust Note the examples of cultural facilities in the last bullet point of para.8.15 where the

absence of theatres is surprising as your Draft Infrastructure document lists three in the Borough as being key cultural and arts facilities.



Light Aircraft Association

The planned closure of Panshanger Aerodrome would clearly go against Policy CS6.

Section 8 makes no mention of the facilities provided today by Panshanger Aerodrome which would be lost if the area was allocated to housing.

as a valued service providing social, recreational and sporting facilities, Panshanger Aerodrome should be encouraged rather than destroyed.

The provision of sufficient aerodromes for sport and recreational aviation is fundamental to its survival and this is particularly so in the south-east of England where land demand and planning constraints make the establishment of new sites virtually impossible.

The Local Plan must give a proper unbiased view of the existing facilities. The Strategy does not note that Panshanger is a facility for Air Sports that are

recognised by Sport England which places a number of planning requirements on councils.

Council is obliged to take comments into account and if having done so it continues with this policy it must identify, in its Local Plan, an equivalent or better provision in the form of a new aerodrome.

Object to the closure of Panshanger Aerodrome on the grounds that ;- Contrary to Policy CS6, bullet point 1 (guarding against the loss of existing

community facilities).

- Contrary to NPPF, p17 (para70) and p18 (para74).- Development would seriously damage the recreational and sporting facilities in

the region and destroy a small but important set of businesses.- Adds a special uniqueness to an area that cannot be easily replaced, and

should be protected.- Serves as an important national asset that particularly services north London

and which cannot be replaced as all other facilities in the south east are at capacity.

- Would result in an acute shortage of light aircraft parking in the South of England.

Sport England

The policy is considered to particularly accord with the relevant provisions of the NPPF such as paragraphs 73 and 74 which focus on planning for sport and recreation provision. Overall, the policy is considered to meet all of the tests of soundness set out in paragraph 182 of the NPPF.

The strategy does not recognise Panshanger is a facility for Air Sports

Panshanger aerodrome has a special uniqueness to an area and cannot easily be replaced, it should be protected

Welwyn Hatfield Borough Council Council’s Head of Environment objects the policy does not recognize the need for

more burial space or a need for a crematorium in accordance to the local Authorities Cemetery Order and the Burial Act of 1816, local authorities have a duty to provide for its residents.

Kingdom Light Centre

Object to this policy, there are no places or buildings available for D1 use (places of worship).

Welwyn Hatfield Borough Council Environment Services The need for a crematorium needs to be recognised in the Core Strategy.

Welwyn Parish Council A growing population will require existing facilities to be protected, enhanced and

enlarged. With specific reference to the Parish, enlargement of the healthcare facilities will be critical as the current surgery appears to see itself as a limiting factor. We do not consider this satisfactory.

Comments by individuals and other bodies Object to Panshanger site as it would be contrary to this policy, it is a important

community facility; One of two flying schools in Hertfordshire providing local employment Is an area of historical and environmental significance Doctors, police, dentists and transport will not cope with 7-8000 new residents -

already overstretched Lack of confidence in policies to safeguard or provide required facilities (previously

let down e.g. loss of QE2 Hospital) All local services are stretched to the limit now, threatens with large budget cuts. How can this policy ensure expansion - a contradiction.

New neighbourhood centre would need to be kept small, or the new housing would not help to sustain a good Town Centre.

Hatfield is short of school places because of poor planning, with schools being closed without sufficient forward planning. (e.g. Hazel Grove and Briars Lane primary schools were closed, and then it was realised that a new primary school was

needed and extensions to existing schools). Hatfield at option PG38 i.e. New Barnfield area has “potential alternative use for a

secondary school”. This option should be explored, particularly as the site has been used since 1970 for a secondary school and then for the Central Resources Library.

No hospital in Hatfield. Residents in ill-health, and visitors, have to make long and expensive journeys to the Lister hospital in Stevenage, concern those in need won’t be treated fast enough.

Hatfield now has a tiny public library, open only part-time. This is in a town with many students and with a proportion of under-privileged families.

The facilities in Hatfield for culture and the arts need to be improved. There is potential for further provision of theatre, music, film, and art exhibitions etc in Hatfield.

More needs to be done to celebrate and show Hatfield’s history to its residents, permanent and temporary.

How will the QE2 Hospital cope it struggles now and with an additional 7- 8000 new residents, Doctor, Police ,Dentist, and Transport are over stretched as it is.

Panshanger Airfield within the proposed development area known as BLG1 (Panshanger - Welwyn Garden City) is an important community facility, to include this as a development site would be contrary to this policy.

No faith in the will or ability to provide services and facilities or even safeguard them should large developments proceed on the scale foreseen.

Policy states that it will guard against the loss of existing community facilities. Panshanger Aerodrome will be the loss of a very valuable community facility.



Oshwal Association

Strongly supports the provision for expansion and/or enhancement of existing facilities to assist continuing viability.

Natural England

Support policies CS5 through to CS12 which together reinforce the sustainable development ethos set out within the borough-wide objectives

Support SC6 on the basis that locating retail and community services within accessible locations has the potential to reduce the need to use private motor vehicle.

Fully supports CS6 policies as sports facilities and leisure centres (as part of a wider community facility) form a key part of policy. In particular, the proposals in the policy to safeguard existing community facilities and take a positive approach to their enhancement and expansion is welcomed.

Bayard Developments

Supports this policy.

The Theatres Trust Supports this policy.

Turnberry (for University of Hertfordshire) As a provider of cultural and sports facilities, the University is pleased to see the

Council's approach within Policy CS6, supporting the upgrading of existing sports facilities where there are known to be gaps in provision, or where existing facilities are out of date or past their best.

Comments by individuals and other bodies Support the reference to existing facilities being improved to meet the needs of both

new and existing residents

Support the reference to the council working in partnership on the wider use, dual use and co-location of buildings and services



Natural England

Suggest the Policy WGC4 should be cancelled and support given to the valuable community facilities it provides.


Suggest the opportunity is provided for land (BLG2 AREA) to build a four hundred seater conference centre or be provided with an empty building in the town centre.

Suggests Churches in Hatfield need suitable church buildings for modern church groups to establish and grow.

David Lock Associates (for Lafarge Tarmac) Suggest Birchall Garden South could meet the policy objectives set out by Policy CS6.

Turnberry (for University of Hertfordshire) To recommend a more evidenced-based approach to identifying new facilities and

would suggest the following text make Policy CS6 sound: 'the provision of new facilities where there are identified gaps in provision'.

The Theatres Trust Suggest that a description of the term ‘community facilities’ should be included in the

Glossary for clarity, and we recommend - community facilities provide for the health and wellbeing, social, educational, spiritual, recreational, leisure and cultural needs of the community.

Welwyn Parish Council, Suggests enlarging healthcare facilities as growing and ageing population will require

existing facilities to be protected, enhanced and enlarged.

Comments by individuals and other bodies Removed BLG1 as a potential development site from this review so that it remains

protected from development at least until 2029. Guarantee that new schools will be provided in Hatfield, should 2000 homes be built. The site in the New Barnfield area should be used as a site for a new school not an

incinerator. Hatfield requires a larger library with better facilities and a new hospital, especially

since the closure of QE2. A new, culture, arts and leisure facilities for culture and the arts in Hatfield which also

celebrate Hatfield’s history need to be improved.

Total No. of suggestions for changes 12

Section 9 Type and Mix of Housing

Consultation Point: Section 9 and Policy CS7


Lands Improvement Holdings (LIH) Are willing to provide 42 affordable homes on their site in Cuffley to meet this

need Regarding lifetime homes, LIH wishes to reserve its position until a viability

assessment as required by para 173 of the NPPF has been undertakenWelwyn Parish Council

The target for affordable housing represents 25% of the proposed expansion of the borough. This suggests that only 50% of the estimated affordable housing need will be met. The problem will still be with us in 2029. However, we recognise that targets have to be realistic and that there is also a demand for market housing that must be addressed.

The requirement that affordable housing remains affordable (paragraph 9.5) is critically important.

We note that the 70% rented figure includes a social rent component. Can the borough confirm that they intend to increase their social housing stock and to what extent?

It is important that that the borough has a well-defined plan for Gypsy and Traveller sites and brings it into operation without delay.



Hertsmere Borough Council Core Strategy does not identify a number of traveller pitches/plots required or any

time period. This is not a justified approach and is inconsistent with national and regional policy.

LIH object to any attempts to micro manage the size and type of market housing to

be provided as part of residential developments to fit a theoretical requirement.Campaign to Protect Rural England (CPRE)

Paragraph 6.24 states around 45% of all new housing would take place on previously developed land. This means that 55% of the total housing provision would have to be built on the green belt. Neither the ECS or LfHOUA makes this clear. Concerned that the public could easily be misled about the full implications of the proposals. Nor is it clear that the process which the Council has adopted represents either a formal review of Green Belt Boundaries or their intended permanence, as required by paragraph 83 of the National Planning Framework.

JB Planning (for The Fairfield Partnership) The level of housing being planned for in the Emerging Core Strategy is

inadequate to meet the Borough’s housing need. The only reliable way to increase the supply of affordable housing is to make provision for a higher level of housing overall

Village Homes (Southern) LLP Policy fails to cater for demand for purpose-built student accommodation off-

campus and there will be a continued reliance on HMOsBayard Developments

Object to the target of only a minimum 1770 affordable new homes. This should be 4492 new affordable dwelings (reference Table S9 of the future Housing targets, Tenures and Sizes report). If this target is below 4492 new affordable

dwellings, the Council need to provide a robust and credible justification for any reduction.

Goodman The Emerging Core Strategy is unlikely to meet future housing need.

Underprovision of homes is likely to have a number of negative impacts in Welwyn Hatfield including rising house prices, exacerbating affordability issues

Comments by individuals and other bodies Gypsies and Travellers have enough land available to them via the two sites Unclear where the affordable housing target or G&T need for pitches comes

from. Need and requirement differ – the inference is that people will be able to afford to

buy but few people can afford the large deposits required Emerging core strategy is inconsistent with national and regional policy. NPPF requires local authorities to identify the size, type, tenure and range of

housing reflecting local demand – a clear distinction with the core strategy which is based on need

A target of 35% affordable housing is meaningless in the large excluded villages where housing development is limited to urban capacity, as the sites coming forward are unlikely to meet the threshold and where they do will only generate minimal levels of affordable housing.

Danger of building by quotas Danger of building developments that are a hotch potch of different communities

– i.e. that aren’t integrated Developments should be planned around who is going to live there Nothing in the strategy about reducing the number of HMOs No more HMOs should be permitted in Hatfield until the town is at the national

average There should be more affordable housing to buy and to rent, particularly for

people on the Welwyn Hatfield housing waiting list There must be homes for older people There must be homes for disabled people. Hatfield requires as much affordable housing as Welwyn Garden City. Providing an ‘accessible location’ should not be the determining factor of

acceptability in the provision of care facilities/sheltered housing It would be inappropriate to accommodate Gypsies and Travellers next to

housing estates With two Gypsy and Traveller sites close to Panshanger, a new site here will

result in an over-provision in this area Support the drive for affordable housing but believe that 80% of market rent as

required by DCLG should be a minority. The major need is for social housing. Primary concern is the approach taken towards Gypsy and Traveller provision.

We note that the core strategy does not identify a number of pitches required in any time period. This is not a justified approach to pitch provision What will be done to ensure there are not problems arising from mixing both communities

There is no definition of the term affordable housing in the document. NPPF enables local authorities to set their own approach to housing densities Shared ownership – worst of both worlds (remain leaseholders and restrictions

but also exposed to market interest rates) There should remain some control over the market housing to make sure some

of them are truly affordable Affordable housing should be protected from market forces and property

speculators There are far too many Houses in Multiple Occupation in Hatfield already.

Without strict planning controls, the new suburb would end up with even more houses in multiple occupation.

There needs to be a compulsory licensing scheme for landlords, not just a voluntary scheme.

Landlords must be stopped from dumping rubbish in their front gardens and in garage forecourts, streets and green spaces of Hatfield. Such fly-tipping should be prosecuted

HMOs will cost the council more money Failure to provide adequate Gypsy and Traveller sites could result in the

imposition of sites by the Planning Inspector in undesirable locations. The administration should seek cross-party consensus on the issue.

Actively seek to reduce the number of HMOs by enforcing housing covenants. Why are additional pitches required to meet the accommodation needs of

Gypsies, Travellers and Travelling Showpeople?



Countryside Development Agency support the inclusion of Rural Exception Sites in Policy CS7 and CS20. Some

changes suggested to CS20 – see CS20. May wish to consider adding a clarification to explain how need is identified for rural exception site to avoid doubt. Suggested additional text – see full comment.

Homes & Communities Agency Welcomes and supports the inclusion of lifetime home standards within Policy

CS7.Environment Agency

Supports the provision of Gypsy and Traveller pitches. North Mymms Parish Council

support CS7 which proposes 20% of all sites for 5 or more dwellings are built to Lifetime Homes Standards.

University of Hertfordshire supports Policy CS7 and the emphasis on providing on-campus, purpose-built

student accommodation supports objective of ensuring that houses in multiple occupation do not

“reinforce or create a high concentration of accommodation resulting in an imbalance with local communities”.

Hertfordshire County Council good to see provision for elderly and disabled

Natural England support policies CS5-CS12 which together reinforce the sustainable development

ethos set out within the borough-wide objectivesOshwal Association

Support the general overview of housing provision in paragraphs 9.16 – 9.18 as these reflect the Association's concerns about providing for elderly members of their community

Supports recognition that providing extra-care and flexi-care schemes within the private housing sector is likely to be the optimum solution in the foreseeable future

Supports Policy CS7 in respect of reference to the provision of flexi-care, extra-care, continuing care retirement communities and sheltered housing

Welwyn Parish Council Agree with Policy CS7 Support the on-site delivery of affordable homes and the 70/30 split between

rented and intermediate tenures.North Mymms Parish Plan

Support Policy CS7 in respect of Lifetime Homes StandardsLafarge Aggregates

Generally support Policy CS 7 objective for increasing the number of affordable homes in the borough of differing types and tenures

Comments by individuals and other bodies Support the general overview Support the recognition that providing extra and flexi-care within the private

housing sector is likely to be the optimum solution Support the idea of Lifetime Homes. Paragraph 9.22 says only one public Gypsy and Traveller site when it is thought

there are two



McCarthy & Stone A specific policy, promoting the needs of the ageing population should be

included to identify the wide ranging issues that will be associated with a larger proportion of people in need of accommodation, care and other facilities which cannot be addressed under the wider "residential" heading. The complex needs, expectations, provision of care and support will vary considerably within this age group and there will be a need to provide a holistic approach to different types of housing and care provision from the public and private sector, and across all types of tenure.

Paragraph 9.16 suggests that all Extra-Care housing should be classified under a C3 Use Class as residential housing. Extra-care developments which have similar characteristics to Residential Care Developments which fall within Class C2, should be treated the same

Tesco suggest sentence added to first bullet point to reflect viability and assessment of

affordable on a site by site basis.CPRE

The total quantum of housing is confusing. 5960 units are proposed in the Green Belt, even if all the council's favoured sites came forward this would only contribute 3015 houses in the Welwyn Hatfield Green Belt,(3535 houses with expansions into St Albans and East Herts). The policy should explicitly state how this shortfall will be taken up either through further Green Belt boundary review, use of sites currently considered as unsuitable, or more expansion into East Herts.

Spenhill objects to blanket requirement for 30% affordable in WGC. Instead suggest 30%

should be a target but the actual level of affordable delivered will be determined upon assessment of viability.

Oshwal Association Policy CS7, page 64, final bullet – substitute ‘accessible’ for ‘appropriate’

Royal Veterinary College Delete the final sentence of Paragraph 9.21 in order to ensure the Core Strategy

remains relevant throughout the plan periodLafarge Aggregates

Paragraph 9.26 should be reworded as follows: "New gypsy and traveller and travelling showpeople sites in the Green Belt are normally inappropriate development. The authority will use a range of options for making future pitch provision including a requirement for new sites to be delivered in association with growth either on site at the Broad Locations for Growth or off-site if suitable alternative locations are available"

Comments by individuals and other bodies Explain why mixed communities are being promoted and provide evidence to

show they are positive. Affordable housing should be calculated using average wages and household

information Two thirds will be rental tenure therefore the term should be affordable rents Accommodate Gypsies and Travellers where they would prefer, away from

housing Allow large employees on business parks to provide workers flats/dormitories. Include some of para 9.6 in the policy wording.


Section 10 and CS8

Consultation Point


Broxbourne Borough Council Suggest in time we may wish to more closely relate strategic policies and site

allocations with the Hertfordshire LEP.

Arqiva Brookmans Park transmitting station is of importance to the national economy.

Turnberry Planning (for University of Hertfordshire) Policy promotes inward investment and the creation of new jobs ensuring that

provision is made both for business sectors that are already well represented in the borough and for new a range of new opportunities, in terms of sites and premises.

Comments by individuals and other bodies The number of empty offices indicates that there are not jobs, and these will not

be created by building houses. What is more likely is that people will commute from here to London.

One-third of shops in Welwyn Garden City town centre are closed, so the economic outlook for the Borough needs to be reconsidered.

Whilst there are some local jobs for residents, an equal amount commute out Council is ‘Welwyn-centric’ meaning that Hatfield Town Centre will never change Local jobs are not always going to local people, hence there are still families in

poverty Despite the initial success of Hatfield Business Park, many properties are vacant

and employees under redundancy notice. The strategy proposed to maintain the ratio between jobs and houses. Economic

forecasts predict considerable job growth – is it sensible to allow for such an increase of jobs?

The policy would depend entirely upon market forces. As such it is generally assumed that it will change and react not according to any planning but reactively over time and as such it can be ignored.



Aviva

whilst some sites are foci for high value employment uses the vision should not preclude industry and warehousing developments in the WGC employment area – this could be the interpretation of the policy as currently drafted.

Stevenage Borough Council do not wish to limit Welwyn Hatfield Borough’s reasonable economic aspirations

or object per se to the quantum of employment development proposed. Raise concerns in relation to the A1(M) between Junctions 6 and 8. Need to work

jointly through the duty to co-operate to address this strategic issue.

Roehyde Consortium object because there is a need for a more strategic site, which could be provided

at Roehyde. The council’s evidence points to the benefit of using Roehyde as a strategic employment site. They state that they have the benefit of a Lands Tribunal Award stopping any highways policy objection to access from the A414.

Comments by individuals and other bodies To use the argument that one of the economic benefits of developing land north

west of Hatfield for housing would be that it would assist with the regeneration of Hatfield town centre would be unfounded.

Shire Park is already at capacity – how will it become the focus for high value employment uses. Congestion around this area is already a problem and Tesco have to provide parking outside of Shire Park. There are also issues re capacity on the A1(M) junctions 6 and 8. How will ambulances etc be able to get to Lister in the future.

There will be insufficient jobs for the proposed increase in population. Forecasts used by Welwyn Hatfield do not take account of recession and current

economic climate – there will be no increase in jobs. Panshanger Airfield is an economic asset and this should be recognised. There are not enough jobs in the borough to justify housing development at

Panshanger. Building 700 homes at Panshanger will put a huge drain on the economy. The low level of starting salaries locally mean that new housing will not be

occupied by local people.



Hertsmere Borough Council We support the balanced approach which has been taken to strategic

employment and residential development.

Broxbourne Borough Council Support the focus on economic activity at Hatfield Business Park, Hatfield and

Shire Park, Welwyn Garden City.

Woolmer Green Parish Council We are satisfied that designating Woolmer Green as an employment area will

protect its remaining industrial land against changes for other purposes.

Tesco As an existing employer in the Shire Park location of Welwyn Garden City, our

clients support the promotion of the area for ‘high value employment uses’. We support the continued designation of Welwyn Garden City Industrial Area for employment uses in principle. We stress that the employment land at Shire Park is well occupied but that further supporting infrastructure is required to support the existing employment base and make the area more attractive to prospective future employment growth.

Natural England support policies CS5-CS12 which together reinforce the sustainable development

ethos set out within the borough-wide objectives


CHANGES suggested for [Policy number] Number of comments

Aviva

add words ‘ or that industry and warehousing development will not be encouraged’ to the last sentence in para 2.

HCC Forward Planning Businesses which are directly linked to the sustainable management of the

district’s green infrastructure could be enabled to develop and not just through diversification.


An additional paragraph should be added as part of CS8 to acknowledge the important role that objectively assessed housing growth targets will play in supporting and further stimulating the local economy.

"A new housing growth target will be used to help support and enhance the local economy by addressing high house prices that exclude people from moving into the borough and accessing jobs, increasing labour mobility and flexible economic growth and increasing the attraction and retention of workers"

JB Planning (for Gascoyne Cecil Estates)

should set an employment target over the plan period. Employment land should be distributed sustainably around the district, including villages and Green Belt land should be released accordingly.


Panshanger Airfield is an economic asset and this should be recognised. Use brownfield employment sites for housing

Total No. of suggestions for CHANGES 6

Section 11 and CS9

Consultation Point – Section 11 and CS9


Hertfordshire County Council Forward Planning Could usefully refer to the importance of delivering green infrastructure unless it

is considered this would duplicate another policy. Benefits sought from design could be expanded brought up to date – i.e.

assisting prestige, opportunities for improving health, and supporting food production and climate change adaption.

Landscape text could be expanded to discuss landscape matters Scope of principles and issues covered considered to be suitable and mirrors

those addressed within the Building Futures Sustainable Design Toolkit. The Building Futures Sustainable Design Toolkit, as described above, can

provide WHBC and applicants with a robust mechanism for understanding and demonstrating how the sustainable design issues cited in policy CS9 have been implemented in development proposals. Should WHBC decide to take forward the Toolkit in this way, we suggest that the below text be incorporated into Para 11.21 – 11.25 of the ‘Implementation’ section of the supporting text for policy CS9: “All applications for new development will be required to submit a Sustainable Design Statement evidencing how the design principles set out in policy CS9 have been implemented in the proposal, using the Building Futures Sustainable Design Toolkit to structure and inform this statement.”

Welwyn Parish Council High quality development is essential.

Hertfordshire and Middlesex Wildlife Trust Pleased that the council intends to expand more upon its expectations and

requirements for good, sustainable design in subsequent policy and guidance documents. We strongly endorse the use of SPDs to set out more detailed policy guidance on biodiversity and green infrastructure, as well as sustainable design and construction. The council should ensure that any such documents reflect best practice in these areas and input is sought from experts to ensure guidance is robust and coherent.

Supports the concept of multi-functional open space and green space. Inspiring people about the natural world and connecting people with nature are core objectives of the Trust. Creating areas where people can engage with nature without harming sensitive wildlife is highly important. Semi-natural habitats and Green Infrastructure networks are not only vital in supporting wildlife and enabling species to move and disperse, but often bring to society a host of public benefits and co-benefits, such as recreation opportunities, improved health and wellbeing, attracting investment, flood risk management, urban cooling, air quality improvement, etc.

Welwyn Hatfield Borough Council Environmental Health One of the priority health outcomes is to support residents to achieve a healthy

weight and reduce obesity. Therefore the layout and design of developments should encourage walking and discourage car use for short journey. All routes should be clearly laid out and be safe by design. The access routes should be safe from traffic and safe from crime

Play areas must be located to encourage their use. They should be part of the community and aim to achieve the secured by design award.

Easy access for all residents, both geographically and financially, to sports areas is essential for provision for the priority area of reducing obesity. However, they need careful planning and consultation to ensure they do not adversely impact on nearby residents homes.

Proper provision for refuse storage areas in all types of housing is vital to encourage a clean and pleasant living environment. Storage areas should be designed and located to eliminate abuse or areas for anti social behaviour.

Ownership of all land and all premises including non residential premises such as garages must be clearly documented.

Welwyn Hatfield Cycle Forum All main districts in Welwyn Garden City and Hatfield should have off road cycle

paths connecting them to key centres of demand. Cycle routes must be constructed and completed in advance of or at worst at the

same time as new housing. All new flats and houses without garages must have access to secure cycle

parking for one bike per member of the household, not one bike per property. WHBC should work with HCC to develop key inter-urban cycling routes to and

from other towns and the borough villages.

Monitor all cycling journeys and plan for growth.

Comments by individuals and other bodies Based on the positive experience of the two charrettes held in Hatfield, suggest

that any master planning exercises should include this mechanism for the involvement of local residents and expert but independent designers/architects.



English Heritage

Welcome policy wording on character and context in first bullet of CS9, but suggest a more explicit reference to the historic environment would be appropriate as well.

Hertfordshire Biological Record Centre

Biodiversity and Landscaping – is supported and reasoned justification 11.20 is also sound but would be better worded ‘enhanced habitats provide increased opportunities for species and ecosystem services, helping development…’

Aviva Investors

The 'Biodiversity and Landscaping' section of this policy states that developments should' incorporate soft and hard landscaping, using high quality local materials, which reflects local character and increases or enhances biodiversity' [emphasis added]. This policy, as drafted, is too onerous on willing developers, such as our client. Sourcing local materials is not always feasible or viable for developers.

Hertfordshire and Middlesex Wildlife Trust Para 11.20 - The environmental and biodiversity value of grass, trees and other

'soft landscaping' depends on its location, context, species composition, species diversity, origin (native, non native, locally native etc), management, and other factors. Only native species, suited to the local environmental context should be used.

Agree that new development should reflect the context and character of an area. We would add that new development should respect, integrate with, and, where opportunities arise, improve the ecological context. For instance, protecting, expanding and improving existing habitats and features; creating and strengthening ecological links, etc

Tesco

We have concerns over the aims of the Core Strategy seeking that all development proposals should ‘shift away from car travel, taking account of local circumstances’. Shire Park has issues with the demand for car parking spaces which needs to be considered as part of a balanced approach to accessibility issues.

Environment Agency

Good design should recognise the importance of the habitat features of a site (rivers, wetlands etc) and biodiversity seen as key opportunity of site and a positive feature. Through the use of sensitive design these habitat features can be protected and enhanced, so providing a more attractive, resilient and sustainable development.

Spawforths, for Langtree Group

Support general principles of CS9. However, the policy is too prescriptive about densities which may be higher or lower than those identified by it.

Comments by individuals and other bodies Good quality design is vital. Higher standards of sustainable design should be sought. Agree with key principles of prudent use of resources and biodiversity. Do not agree with any building on greenspaces – why destroy a wildlife habitat

and then replace part of it with an inferior landscaped area? Support the reference to the importance of good design and reinforcing the sense

of place. At least the need for parking is recognised.

While explicit reference is made to the provision of adequate well designed parking, there is no mention of adequate well designed housing layouts. Too often developers anxious to maximise their returns offer up miserable cramped dwelling more reminiscent in terms of living space of the Victorian slums that Ebenezer Howard created his Garden Cities to replace. Some attempt must be made to ensure new housing has the space in which families can live, the sound insulation to allow privacy and sufficient garden space to allow children to play. It will also be important for planning to be more insistent that plans as approved must be followed exactly.

The Council must ensure that good design is carried out and that developers are not allowed to take money saving short-cuts. The Hatfield airfield site is an example of very poor design which should be avoided at all cost.

We are talking, according to the project, about private developers. Their main concern is as many as possible at the least cost, both of building costs and planning gain.

The council must ensure that good design is carried out and that developers are not allowed to take money saving short-cuts. The Hatfield airfield site is an example of very poor design which should be avoided at all cost.

Concern that private developers will build poor quality housing as their main concern is cost, both of building costs and planning gain.



Natural England

Support policies CS5-CS12 which together reinforce the sustainable development ethos set out within the borough-wide objectives.

Welcomes the criteria in CS9 which seeks to ensure the overall design of development incorporates open spaces and promotes accessibility by creating places that connect with each other via different modes of transport.

Hertfordshire and Middlesex Wildlife Trust Welcomes the inclusion of this policy and supports the approach taken.

North Mymms Parish Council Welcome requirement for Good Quality Design to ensure local character of the

Parish is respected.

Oshwal Association (UK) Supports the provisions of the policy so far as it emphasises the importance of

good design and the reinforcement of a sense of place. It is considered that this policy underpins the consideration of the proposition as set out elsewhere in these representations.

North Mymms Parish Plan Implementation Group

Supports the proposals for the Parish in the Welwyn Hatfield Emerging Core Strategy 2011-2029 Consultation Document. We were pleased to see the requirements for Good Quality Design within Policy CS9 which will help to ensure that the local character of the Parish is respected.

Metropolis PD The policy properly recognises the importance that must be attached to ensuring

that a high standard of design is achieved within new developments throughout the borough. The key urban design principles identified are welcomed and will hopefully be embraced by the development industry.

Comments by individuals and other bodies Agree that good design should be a key part of the policy. Welcome the policies in this section and the contribution they make to achieving

CS1 and Strategic Objectives 3, 5, 6, 7, 8 and 9.



Aviva Investors Amend policy to state conserve and/or enhance biodiversity where possible.

Bayard Developments

Support this policy but suggest further reference is made to 'Building for Life 12'.

English Heritage

Welcome policy wording on character and context in 1st bullet of CS9 but suggest a more explicit reference to the historic environment would be appropriate as well.

Reference to landmark buildings in 3rd bullet of CS9 could be read as encouraging tall buildings – it would be useful to clarify that the policy does not necessarily encourage tall buildings.

Hertfordshire County Council Forward Planning Level of detailed explanation and guidance is informative and covers the main

sustainable design issue however the level of detail is thought to be inappropriate for a strategic policy within a Core Strategy. Suggest is replaced with summary of key headings set out in para 11.8 of the ECS with some additional headings (see full response for details).

It is also suggested that the following text be added to Para 11.23: “Applicants should refer to and make use of the Building Futures Sustainable Design Toolkit and online resource at the early design concept and pre-application stages of their proposal(s)”.

Spawforths (for Langtree Group) Policy should be reworded to say: “Density of development shall be in keeping

with the character of the local area.”

Hertfordshire and Middlesex Wildlife Trust Supports this key principle but some changes in wording in Policy CS9 needed.

Interpretation of ‘well maintained' - The council should ensure that where appropriate areas are managed to improve their biodiversity value and ecosystem function. Biodiversity and Landscaping - Addition of wording, eg. ‘Landscaping should integrate from the outset ecological principles and good practice, aiming to increase biodiversity and ecological connectivity where possible.'

Para 11.6 - Addition of some text to reflect that new development should respect, integrate with, and, where opportunities arise, improve the ecological context. For instance, protecting, expanding and improving existing habitats and features; creating and strengthening ecological links, etc.

Comments by individuals and other bodies Higher density accommodation on brownfield sites should be the favoured option

for meeting housing targets. Well built four to six storey blocks are a solution to the housing needs of the growing number of smaller family units.

Higher sustainability targets for new homes should be sought. Water consumption should be charged according to the amount consumed.

Water meters should be fitted in all homes to reduce consumption. Flood protection measures should not allow run-off from roads, farms etc to

pollute natural water resources. CS 9 - Biodiversity and landscaping Incorporate soft and hard landscaping, using

high quality local materials, which reflects local character and increases or enhances biodiversity, is supported. The reasoned justification 11.20 is also sound, but would be better worded ‘enhanced habitats provide increased opportunities for species and ecosystem services, helping development....'

The 'Biodiversity and Landscape' section of this policy should read as follows: ' Incorporate soft and hard landscaping, using local materials, which reflects local character and conserve and/or enhance biodiversity, where possible'.

Some changes in wording in Policy CS9 to reflect comments above and add clarification. Interpretation of ‘well maintained' - The council should ensure that where appropriate areas are managed to improve their biodiversity value and ecosystem function. Biodiversity and Landscaping - Addition of wording, e.g. ‘Landscaping should integrate from the outset ecological principles and good practice, aiming to increase biodiversity and ecological connectivity where possible.

Addition of some text at para 11.6 to reflect that new development should respect, integrate with, and, where opportunities arise, improve the ecological context. For instance, protecting, expanding and improving existing habitats and features; creating and strengthening ecological links, etc.

Clarify at para 11.20 that the environmental and biodiversity value of grass, trees

and other 'soft landscaping' depends on its location, context, species composition, species diversity, origin (native, non native, locally native etc), management, and other factors. Only native species, suited to the local environmental context should be used.

Reword to make specific reference to 'local circumstances and proven parking demand’.

Good design principles, paragraphs 11.8 to 11.10, p77 - we suggest that the historic environment is referred to here.


Section 11 and CS10

Consultation Point – Section 11 and CS10


Hertfordshire County Council – Landscape Officer Energy opportunities map conflicts with some constraints. Not sure how easy it

would be to support using landscape sensitivity criteria.

Hertfordshire County Council – Building Futures Scope of key issues should be expanded (see full response for suggested word

changes).

Comments by individuals and other bodies Water consumption should be charged according to the amount consumed.

Water meters should be fitted in all homes to reduce consumption.

The provision of adequate water supply needs to be properly considered before developments are started in the Welwyn Hatfield area.

Flood protection measures should not allow run-off from roads, farms etc to pollute natural water resources.

Concern that private developers will build poor quality housing as their main concern is cost, both of building costs and planning gain.

Level of detailed explanation and guidance is informative and covers the main sustainable design issue, there is too much detail for a strategic policy within a Core Strategy.



English Heritage The incorporation of energy efficiency measures can damage the fabric and

integrity of historic buildings. It would be appropriate to refer to the need to assess historic buildings/areas to determine suitability and EH has recommended some of their guidance on the topic.

Concerned that the map on p87 appears to identify most of the district as suitable for wind energy and other developments that could have a very significant effect on the setting of heritage assets, and the wider historic landscape.

Natural England Largely welcome commitment in policy to re-use of land and buildings, use of

SUDS, renewable/low carbon energy and measure which enhance biodiversity. However it should be recognised that some brownfield sites are of high environmental value and only low value land ought to be allocated for development.

Environment Agency WH is in an area of high water consumption and serious water stress. The

supporting text on reducing water usage needs to be stronger. We would expect new development proposals to show how they will incorporate appropriate measures to use water efficiently to meet code level 3/4. Water efficiency target of code level 3/4 should be set for all new development.

We expect that SuDs will be planned and designed in line with the SuDs hierarchy. We would like to see the drainage hierarchy promoted and the last section of the sentence removed which reads ‘unless it can be demonstrated this is not appropriate in a specific location’ (para 11.47). In a case where SuDs are not suitable due to ground conditions, evidence of this would need to be submitted and agreed with yourselves or the SuDs Approval Body at Herts CC.

Sustainable Design and Construction 3rd bullet point – support use of SuDs to reduce flood risk but they also have a role in improving water quality and improving biodiversity – this should be included. Supporting text should be amended too to mention the importance of the location of new development out of high risk zones.

7th bullet point – Support the incorporation of measures to improve biodiversity features however, would also like measures included such as buffer strips, linking of green spaces, river restoration and de-culverting. Supporting text should be amended to reflect this.

Would like to see an additional bullet point to include the treatment of water bodies (rivers, canals, groundwater, lakes etc) to show how development will

meet the actions and aims of the Water Framework Directive. Env Agency can provide further information to Welwyn Hatfield on River Basin Management Plans etc. Core Strategy must comply with detailed actions which are being written by the Env Agency and will be published in 2013.

Homes and Communities Agency Consideration should be given to the inclusion of reference to higher levels of the

code for sustainable homes.

Hertfordshire County Council – Building Futures Include the required Code for Sustainable Homes and BREEAM ratings into

policy CS10, rather than only the supporting text.

Hertfordshire County Council – Landscape Officer Could usefully be extended to refer to hard and soft landscape construction as

well as building construction.

Veolia Supports in principle but policy requires amendment to be more positively

prepared. CS10 should provide greater support and clarity in relation to the provision of decentralised energy and so is not sufficiently positive prepared in its current form. Suggested wording provided (see full response).

Herts and Middlesex Wildlife Trust Welcome this policy but considers that all development should aim to achieve

targets set within BREEAM and CSH (i.e. BREEAM very good, or CSH level 4). Applicants should indicate the targets set and measures taken to achieve this within their sustainability statement. If developments fail to meet these standards, robust justification must be given. A full assessment is not reasonable or proportionate for small scale development, but should be done for developments of 10 plus dwellings or 1000 sq m floorspace.

Welwyn Parish Council Paragraph 11.46: It is regrettable that the borough does not feel able to require

standards of water usage in individual buildings. This seems contradictory to the borough’s aspirations as to sustainable developments (policy CS1 paragraph 4.6). Surely rainwater harvesting and grey water recycling can be made mandatory.

Paragraph 11.34: It is not clear why developments of less than 1000m 2 or fewer than 10 houses should be exempt.

Welwyn Garden City Society This is incomplete. There is no reference here to good design as advocated by

the NPPF.

JB Planning for Gascoyne Cecil The reference to encouraging the use of decentralised energy in order to reduce

carbon emissions needs to be reconsidered. In our experience, decentralised energy may not be the most efficient or effective way of reducing carbon emissions in a major development proposal. Alternative measures, such as enhanced thermal insulation or other design- related measures can often be more efficient and cost effective, making more funding available for other essential items, such as affordable housing and planning obligations.

David Lock Associates for Lafarge Tarmac Support, but should go further e.g. encouragement of proposals which meet

Passivhaus, and lifecycle thinking in planning and construction of new buildings.

Spawforths, for Langtree Group PLC Does not support emphasis on achieving Code level 4 in the reasoned

justification.

Comments by individuals and other bodies The ECS states: 11.30 Water is also a significant issue in Welwyn Hatfield.

Domestic consumption is above the national average with 154 litres used per person per day(30) and yet the East of England is the driest region in the UK and Hertfordshire is one of the driest counties in the region. Welwyn Hatfield has been identified as an area of serious water stress where demand for and water use is currently not sustainable and will be exacerbated by further housing and economic growth.” In ECS section 11.46, it is admitted that introducing ways of implementing water efficiency is difficult because fittings etc for this are not covered by the planning process. The provision of adequate water supply needs to be properly considered before developments are started in the Welwyn Hatfield area.

We welcome the inclusion of a section on water use but would prefer to see the harvesting of rainwater and use of grey water made mandatory rather than ‘supported’.

Water supply is an issue in Welwyn Hatfield. This needs to be resolved before any development is started.

Would like to see more sustainable design features incorporated, to the passivehaus standard, or higher.

Good design should be a key part of the policy. No reference to good design, as advocated in the NPPF.

There is no entry on solar panels.



Environment Agency Support 2nd bullet point re the conservation of water and provision for water

recycling.

Like to see an additional bullet point to include the treatment of waterbodies to show how development will meet the actions and aims of the Water Framework Directive.

Natural England Support policies CS5-CS12 which together reinforce the sustainable

development ethos set out within the borough-wide objectives.

Hertfordshire County Council - Building Futures Welcome policies in this section and the contribution they make to achieving CS1

and Strategic Objectives 3, 5, 6, 7, 8 and 9.

Bayard Developments Agree with this policy.

Metropolis PD The policy properly recognises the importance of achieving sustainable design

and construction. In particular, the supporting text identifies that the provision of new housing should provide a focus for reducing CO2 emissions.



English Heritage Concerned map on pg 87 identifies most of district as suitable for wind energy

and other measures which could impact on the setting of heritage assets and wider historic landscapes. Suggest that plan should provide clear guidance and appropriate limitations on energy related developments.

Hertfordshire County Council – Building Futures Would like to continue discussions to take forward the informal officer agreement

to embed the Building Futures Sustainable Design toolkit into WHBCs emerging plan, supporting docs and dev management process. Strongly suggest ECS makes clear reference to the Toolkit (see full comment for description) so that it may support and form part of WHBCs sustainable DM process.

Recommend that 11.36 is amended. See full response for wording suggestion.

JB Planning (for Gascoyne Cecil) propose that the final sentence of this policy is revised to read as follows: "In

appropriate locations the use of decentralised energy will be considered, to determine whether this would be an efficient and cost-effective means of reducing carbon emissions".

Comments by individuals and other bodies Welcome the inclusion of a section on water use but would prefer to see the

harvesting of rainwater made mandatory rather than supported. Drainage hierarchy should be promoted and the last section of the sentence

removed which reads ‘unless it can be demonstrated this is not appropriate in a specific location’. Where SuDS are not suitable due to ground conditions, evidence of this would need to be submitted and agreed with yourselves or the SuDS Approval Body at Herts CC. Design of SuDS should be in line with the Interim SuDS Policy Statement approved by Herts CC.

Suggest that the plan should provide clear guidance and appropriate limitations on energy related developments.

Strongly suggest ECS makes clear reference to the Sustainable Design Toolkit so that it may support and form part of WHBCs sustainable DM process.

Higher targets of sustainability should be sought with regard to the borough's housing standards. I am aware that some work is already going on, but this should be increased.


Section 12 Protection of Critical Assets

Consultation Point: Section 12 and Policy CS11


Herts & Middlesex Wildlife Trust Welcomes reference to the WH Green Infrastructure Plan. The council should

seek through the Infrastructure Delivery Plan and CIL spending to help the realisation of the identified projects and priorities and ensure it adapts to new information developed or endorsed by Local Nature Partnerships. Work is ongoing on identifying and mapping restoration priority areas through HMWT Living Landscapes development Project.

NPPF paragraph 117 requires councils to identify and map components of the local ecological network, including the hierarchy of international, national and locally designated areas etc.

As per NPPF paragraph 117 the council should consider what types of development may be appropriate in the Lee Catchment Nature Improvement Area (adoption expected in February 2013). This covers the Upper Lea and the Mimram in WH.

Environment Agency The borough’s chalk streams are a habitat of international importance, only found

in south east England, some part of North West Europe and New Zealand. They are a globally scarce habitat and their importance should be reflected here.

Under the Water Framework Directive (WFD) which has been part of UK law

since 2003, all rivers, lakes, streams, canals, estuaries, coastal and groundwater (known as waterbodies) must be in good ecological status by 2027. The UK has a legal obligation to meet this target and Local Authorities has a duty to work to achieve this. The EA has produced a River Basin Management Plan and detailed actions will be published throughout 2013. The Local Plan must have regard to these actions.

It is not clear how the Core Strategy will protect the assets previously covered by policies R11, R13, R14, R15.

Para 13.11 to 13.14 – there are capacity issues with waste water treatment works particularly at Mill Green and Rye Meads. The council must work closely with Thames Water and the Environment Agency to ensure consent standards are met.

Welwyn Hatfield shares infrastructure with a number of other local authorities, all who have their own growth plans which will put pressure on shared infrastructure. Joint working should address the cumulative effects of growth on infrastructure and look at issues of phasing development and timescales for growth.

Hertfordshire County Council – Landscape Officer How are you intending to handle the Strategic GI plan? This needs to be

handled alongside the district GI, particularly if it is intended to allocate any CIL levy to GI.

Hertfordshire Biological Records Centre Paragraph 12.17 perhaps implies that the Habitat Survey is updated annually;

whilst some wildlife sites may be re-surveyed, not all sites are updated (only known changes).

Royal Veterinary College Broadly supports this policy, however the development sites currently identified

for achieving Policies CS2 and CS3 conflict with the assertion in Policy CS11 that growth will be directed to the poorer qualities of agricultural land unless this would significantly compromise the delivery of other objectives set out in this strategy.

The land proposed to be safeguarded to the west of Hatfield is to be managed in part as a Country Park until required to be released for development. The proposed future loss of this important public open space contradicts the Council's commitment to protect and enhance the borough's natural assets and network of green infrastructure, as outlined in Policy CS11.

Light Aircraft Association Policy CS 11 says the Council is “committed to protecting and enhancing the

borough's natural and historic environment”. It goes further by stating that "any loss or damage to the value of these assets will be resisted and opportunities for enhancement will be supported". This is clearly the opposite to the loss and damage that will be done if the aerodrome is allowed to be closed. According to this policy the aerodrome should be "protected and enhanced" and we look to the Council to implement that policy here by removing Policy WGC4.

Comments by individuals and other bodies The River Mimram is one of only 200 chalk streams in the world, it provides a

unique habitat for wildlife as well as big a community asset. The EU Water Framework Directive standards state the river is currently of ‘poor’ status and work is being done to bring it to s a ‘good standard’ Development will threaten it.

The Green Belt is the most important critical asset we have – it should be protected.

There is nothing to outline how the protection will be enforced. There should be

conditions included in planning consents. The policy is diametrically opposed to the loss of Panshanger aerodrome field so

the aerodrome should be protected and enhanced instead. The Mimram is already over extracted. The capacity of Rye Meads STW is very

low (and other authorities are also planning for large housing growth). Panshanger Airfield is of historic importance with its links to World War 2, and

flying schools in Hertfordshire. Welwyn Hatfield Borough Council must protect and promote the interests of the

residents of Hatfield equally with the residents of Welwyn Garden City and the villages.

The assets of Hatfield, including Hatfield House and its park, other historic buildings e.g. mid twentieth century buildings such as St John’s Church and the swimming pool which must be protected.

The Council has an important role to play in protecting Hatfield and its people, e.g. from destructive proposals such as the waste incinerator at New Barnfield.

Flood prevention methods would need to be introduced if Panshanger were to be developed.



Aviva Investors Policy is unsound as it fails to take account of the economic and social roles of

sustainable development and is therefore unbalanced.

Light Aircraft Association The aerodrome at Panshanger is not just a series of aviation related businesses

but also a large green open space that allows the sport of flying and many other local activities to take place. It is also the habitat of many species of wild flora and fauna. Something not recognised by the Strategy. This should be revisited and taken into account by the Strategy.

Paragraph 12.11 states that access to the sports pitches are essential for the creation of sustainable communities. The potential closure of the sporting facility of Panshanger Aerodrome would be in contradiction to this policy. Under policy CS11 aerodrome should be ‘protected and enhanced’.

General Aviation Awareness Council Panshanger Airfield is a critical asset, being an open space with wild fauna and

flora and historical associations. It should not be included in the housing distribution strategy.

Friends of the Mimram Putting 700 houses on Panshanger Aerodrome will mean cementing over most of

what is currently a natural rainwater soak. So at times of heavy rainfall, when Thames Water cannot cope, it will run off into the Mimram causing pollution. By EU Water Framework Directive standards the river is currently of 'poor' status and work is being done to improve it to reach the 'good status' standard required by 2027. Such run-off will only make the situation worse.

Welwyn Parish Council Notes that BLG2 will consume high-grade agricultural land.

Comments by individuals and other bodies Regarding Panshanger Aerodrome, whilst allowing flying to take place, it is also a

wildlife habitat. This has not been recognised by the core strategy or by

potentially flawed environmental assessments carried out so far by the Council. The development sites currently identified for achieving Policies CS2 and CS3

conflict with the assertion in Policy CS11 that growth will be directed to the poorer qualities of agricultural land. Other suitable sites on lower grades of agricultural land could be provided to meet the housing delivery target.

How is the policy of seeking to protect mineral resources compatible with the plan to carry out gravel extraction at the Panshanger site?

The aerodrome at Panshanger is already demonstrably a large green open space that while allowing flying to take place, is also the habitat of many species of wild flora and fauna. This has not been recognised by the Strategy, nor by the potentially flawed environmental assessments so far carried out by the Council.

Preservation of mineral resources needs to be respected in this strategy. No gravel extraction should be allowed at the Panshanger site as this has been challenged previously.

Any development at Panshanger would threaten the quality and capacity of the River Mimram. Surface water would potentially pollute the river. Panshanger airfield is a natural soak away.

Flooding has occurred in Hertford where the Mimram meets the Lee, development at Panshanger would make this worse due to increase surface run off.

Smaller developments would be less environmentally damaging. Acknowledge the environmental and historic significance of the area referred to

as BLG 1 to protect it from development. Farmland at Stanboroughbury is some of the richest in the county, yet the council

plan to build 2000 houses on it. How does that fit with their aspiration to keep good farming land?



Natural England Strongly welcomes this policy which outlines the council’s commitment to

protecting and enhancing the natural environment including new green infrastructure and resisting fragmentation of the existing network.

Support policies CS5-CS12 which together reinforce the sustainable development ethos set out within the borough-wide objectives.

Hertsmere Borough Council Welcome paragraph 12.15 which states that Welwyn Hatfield will aim to achieve

major environmental improvements to Watling Chase Community Forest.

Hertfordshire Biological Records Centre The Green Infrastructure map is supported in providing a clear presentation of

the broad corridors and major sites. 12.16 not only provides a range of aquatic habitats, its ecological quality is also very high.

Herts & Middlesex Wildlife Trust Supports the incorporation of green infrastructure proposals into Area Action

Plans as well as designation of Local Wildlife Sites.



Support approach. Agree that we should protect existing assets in the Borough.



Herts & Middlesex Wildlife Trust Welcomes policy CS11 although it needs improvement i.e. resisted is not strong

enough. Development resulting in loss of or damage to assets such as Local Wildlife Sites of LWS standard, ancient woodland, SSSIs, Local Nature Reserves should be refused.

Should consider changing the name of the section to Protection and Enhancement of Critical Assets to follow NPPF (paragraphs 7,109,114) and include where possible enhancing in paragraph 12.7.

Term ‘Local Wildlife Site’ should be used throughout the documents as this is the term used by central government.

Policy text in CS11 will benefit from being more specific to what are the council’s expectations and response to development proposals and for which type of asset. Text is unclear and therefore may be found unsound.

Aviva Investors Suggest amendment to paragraph 1 of policy by referencing presumption in

favour of sustainable development and that fragmentation of GI to be resisted unless it can be demonstrated that the function of GI is not compromised or adequate compensation can be made.

English Heritage In line with proactive tone of NPPF suggest the word ‘supported’ in the 2nd

sentence be substituted with ‘pursued’.

Environment Agency This policy needs to be much more direct and comprehensive to ensure

adequate protection of critical assets in Welwyn Hatfield. This is particularly the case with the deletion of a number of saved policies. It is not clear if Policy R8 on Flood Risk is to be deleted or saved. This should be clarified.

Suggested change to read ‘developments must be located, designed and laid out to ensure the risk of flooding is reduced whilst not increasing the risk of flooding elsewhere. See full consultation response for full wording suggestion.

Text should be changed to include:o All new development shall seek to make space for water and shall maintain

a minimum 8 metre buffer zone to designated main rivers and a 5 metre buffer zone to all ordinary water courses.

o Where proposals are considered to effect nearby watercourses or sites that are close to a river, the council will seek river enhancement and/or restoration as part of the proposal. See full response for more detail on suggested changes.

Text should be changed to read ‘all land previously used for industrial, commercial or utility or land which is considered to be contaminated will require a Preliminary Contaminated Land Risk Assessment to be submitted as part of the planning application. See full response for more detail on suggested changes.

Herts Garden Trust The protection and enhancement of heritage assets should also include the

setting of those assets as detailed in NPPF section 12 'Conserving and enhancing the historic environment.

Hertfordshire Biological Records Centre Implementation of CS11 – could also include supporting local food and forestry

enterprises where the LPA has a planning role. This may help to maintain a rural infrastructure (i.e. farm shop) which can be important in enhancing ecology and the countryside in a functional way

Brocket Trustees Green Infrastructure Map should be amended to reflect the opportunity of part of

the northern area of our land to secure open space enhancement and provide new green infrastructure. The map should exclude the southern portion which is suitable for housing.

Comments by individuals and other bodies Para 12.4 could include ‘habitats, species and features…’


Section 13 Infrastructure

Consultation Point 12 – Infrastructure Delivery


Hertfordshire County Council (Transport)

The County Council has provided a table to identify large increases in flow or stress on the road network.

Transport comments on WGC1 South of Welwyn Garden City:o Boundary Lane appears too narrow to serve any significant proportion of

the development. Opportunities to provide a high standard pedestrian/cycling link from the existing residential area.

o Hollybush Lane is a narrow rural lane, currently not wide enough to allow two cars to pass easily. Without a significant upgrade the route will also be unsuitable to serve any significant proportion of the proposal.

o Ascots Lane is a busy route, the junction with the A1000 chequers frequently suffer from congestion at peak times. The adjacent junction with the A414 access also suffers from congestion.

o There is a high quality cycling route adjacent to the A1000, it will be necessary for a development of this scale to ensure high quality connections are introduced to provide high quality sustainable transport links to facilities in Hatfield. It will also be necessary for a proposal in this area to contribute towards wider connections to the existing cycling network, such as the Cole Green Way.

o Main public transport provision for the site is buses and access to these would be at Howlands. Presently there are three main routes one of which (the 301) is an inter urban route. A high proportion of the site is

currently outside normal access criteria of 400 metres. In order to improve this it is likely that new bus stops will be necessary on Chequers and an appropriate crossing facility to be provided. As part of any application, possible diversion of some local services via Ascots Lane should also be considered.

Transport comments on WGC 4 North East of Welwyn Garden City:o It would appear feasible to integrate the proposal with the existing

residential road network by serving sections of the site through extensions to the existing road network. An additional point of access could be taken from its boundary with Herns Lane.

o Consideration should be given to the capacity and operation of Mundels roundabout. Also, improvements may be required to the priority junction with the B1000.

o In terms of sustainable transport, the same level of connection and improvement to the existing cycling network will be required.

o Any application will need to include good pedestrian links into Bericot Way, Westcott, Chelveston in order to access local bus services (the 401). Other services are located on Hertford Road (Tewin Mill) but access to these is likely to involve improvements to an existing ROW. Various ROW 'issues' also exist within the area.

Transport comments on Hat 1 North West of Hatfield:o The scale of development being proposed will generate a significant level

of traffic on the local and strategic road network. The local road network in the surrounding area is generally of a lower hierarchy to accommodate the level of development being promoted.

o Extensive improvements will be required, particular attention to the B197 and the A6129 Stanborough Lane link to Welwyn Garden City. The assumption is the site will also be served by an upgraded Hatfield Avenue as well as the other existing road network in the former BAe site. It should be noted that several recent planning applications have indicated that some junctions within the BAe site are at or close to capacity and there may be a need for highway improvements in these areas.

o A high quality cycling and pedestrian network will be incorporated into an internal layout ensuring full integration with the existing network within the adjacent former BAe development. Also, in the other direction, significant improvements will be required to link the site to the existing cycling network in Stanborough Lane.

o It is agreed that a transport strategy will be necessary for this site. Development is likely to require a new bus route and/or possible realignment of an existing service. Evening and weekend provisions will be a key factor and will need to form an integral part of the sites travel plan.

Transport comments on Hat 2 West of Hatfield:o No access proposals have been included with the proposals.o Similar to Hat 1, a development of this scale will generate a significant

level of traffic on the local road network. The surrounding network is generally of a lower hierarchy to accommodate the level of traffic the development being promoted will generate.

o The assumption is the site will also be served by an upgraded Hatfield Avenue as well as the other existing road network in the former BAe site. It should be noted that several recent planning applications have indicated that some junctions within the BAe site are at or close to capacity and there may be a need for highway improvements in these areas.

o A high quality cycling and pedestrian network will be incorporated into an internal layout ensuring full integration with the existing network within the adjacent former BAe development. Also, significant improvements

will be required to link the site to the existing off road Alban Way cycling route and the rights of way networks to the west.

o Any development will pose significant long term access issues to public transport as the site is remote from existing provision. A Transport Strategy linked to an effective Travel Plan would need to be firstly put in place.

Transport comments on Hat 3 West of Ellenbrook:o Assumed the main access to the site will be from the A1057 Hatfield

Road.o The A1057 Hatfield Road is the primary route between Hatfield and the

centre of St Albans. The route is extremely busy and as a result it suffers from significant congestion.

o In the vicinity of the site the road could be considered as rural in character. In fact this section of the Hatfield road is the point where the character changes. This change of environment is reinforced with an increase in the speed limit to 40mph that terminates at the eastern boundary of the site.

o In terms of vehicular access, the neighbouring development to the east is a similar scale and features two simple priority style junctions linked together with a service road allowing a forward facing development giving the impression of a residential area. The proposed site is likely to also likely to require two accesses, although depending on the scale, the second may be designed for emergency use.

o Due to the strategic importance of Hatfield Road both at a local level and to wider road network it will be necessary to ensure any access arrangement does not cause an obstruction and lead to further delays to the priority traffic. It is reasonable to expect a junction of this scale to require some realignment and widening of the Hatfield Road in the vicinity of the site. The introduction of another access introduces an additional point of conflict in an area where safety cameras have been

Hertfordshire County Council (Waste)

The key strategic waste objectives that are of particular relevance to individual Local Planning Authorities contained within the document are: SO1, SO2, SO4, SO6

The county council encourages districts and boroughs to promote the sustainable management of waste generated. This is by encouraging the re-use of unavoidable waste where possible, and the use of recycled materials where appropriate during construction

Methods of waste minimisation should be in keeping with the county council’s strategic objectives for the reduction of waste and its environmental impact, as stated in Chapter 2 of the adopted Waste Core Strategy and Development Management Policies document.

Immediately north of WGC5 is an operational inert waste recycling and soil washing facility, which is run by Eco Aggregates Ltd. Although this is operating under a temporary planning permission, an extension to this permission is currently under consideration. It should also be noted that this site is identified as an allocated site (ref: AS008) in the Waste Site Allocations Proposed Submission document, as it may have potential for further waste development.

Hertfordshire County Council (Education) The County Council would wish to assist and be represented as a stakeholder

and as a potential beneficiary of CIL monies. It is essential that the Borough and the County Council work closely together to ensure that the apportionment of future CIL revenues is realistic, appropriate and proportionate to the infrastructure needs of the Borough.

A logical approach is making appropriate provision for additional education provision a key consideration in Green Belt releases, rather than leaving a service provider with the uncertainty of having to lay claim to part of a more general housing release in the Green Belt., (If a school provider, whether that be HCC or the Department for Education, has to acquire a site as part of a general green belt housing release there would be an argument that residential alternative development value would need to be paid for the site to acquire land with a commensurate increase on the demand for monies in the CIL pot). Very early thinking is that above a threshold of 500 houses, a development should provide for a new primary school site via a Section 106 agreement, and below that threshold the CIL levy would apply.

The authority has a duty to ensure there are sufficient childcare places for 0-14 year olds (19 with disabilities) to enable parents to return or remain in work, as part of of the Child Poverty agenda HCC would require 1 childcare place for every 6 children aged 0-2, 1 place for every child aged 3-5 and1 place for every ten children aged 6-14. Childcare for the under 5's is ideally based in and around children’s centres and care for school aged children is based mainly in and around extended schools

The December 2012 changes to CIL Guidance will need to be factored into the final document. The detailed operation of CIL/S106 and the vision for implementation will be a key issue for HCC Services with regard to the future iterations of the CS and the IDP and naturally HCC would wish to have further discussions on the detail.

The deliverability of the land in East Herts is crucial to the soundness of the plan. Cross boundary growth is also crucial to HCC with regard to ensuring the appropriate and timely delivery of infrastructure – particularly Education sites. HCC would welcome further tri-partite discussions on this matter which may need to look at the potential for cross boundary flows of S106/CIL contributions

13.40 – The acknowledgement of the need for new schools sites to support the Hatfield Broad Location for Growth 2 (BLG2) is supported and welcomed

13.41 – The need for new school sites to support the WGC BLG1 is supported and welcomed.

For both the BLGs at Hatfield and Welwyn Garden City the acknowledgment of the need for new schools is supported and welcomed. HCC would wish to be an active participant in the development of any emerging AAPs and in the case of potential development east of WGC would need to be part of any joint working arrangements with East Herts.

HCC Development Services have now appraised all the primary schools in the District for expansion. Many of the simple sites have already been expanded. It should be noted that there has to be a level of uncertainty regarding the practical implications of expansion with town planning being but one factor. Other factors include changing school space standards, free schools, academies and faith issues. What remains is the statutory duty on HCC to ensure there are sufficient school places within the Local Authority area for every child who wants one.

Highways Agency Unless improvement schemes to the Strategic Road Network are already

committed it should not be assumed that the Highways Agency will be able to fund any improvements to the Strategic Road Network. It is likely that developers will be the main source of funding for the mitigation measures required to ensure that the Strategic Road Network is left no worse off. Potentially these could be funded through the Section 106 Contributions or the Community Infrastructure

Levy. In the event Community Infrastructure Levy funding is to be used, it is important that the schemes required are identified at an early stage such the level of contributions required to fund the schemes are known.

Encouraged by the emphasis which has been given to sustainability and sustainable transport measures in the plan. The BLGs have the potential to generate significant trips and sustainable transport measures will be required to mitigate this. HA should be involved in development of AAPs and future discussions concerning development sites which have the potential to impact upon the Strategic Road Network.

There is a need to provide sustainable transport links between all proposed development sites and public transport hubs, town centres and employment areas to be of critical importance to ensure traffic generation on the surrounding road network is minimised.

Advise that there is insufficient capacity in the strategic road network to accommodate housing numbers over and above the 7,200 currently being proposed.

DIAMOND does not fully assess in detail how the development proposals will impact on the operation of the Strategic Road Network. Provides a broad indication that a material impact could occur at a number of critical locations on the Strategic Road Network which could also have an impact on the local road network.

A 1 (M) Junction 4: Proposed development is predicted to result in high levels of impact in both the AM and PM peaks. The Highways Agency therefore recommends that more detailed assessments outlined above are undertaken to predict the impact to this interchange, the potential for capacity issues to occur and that the need and feasibility of any potential mitigation measures is tested.

A1(M) Junction 6: Proposed development is predicted to result in significant impact in both the AM and PM peaks. This junction already suffers capacity issues particularly where northbound carriageway reduces from 3 to 2 lanes and the northbound onslip joins. The report indicates a material impact to both slip road and mainline flows. The Highways Agency therefore recommends that more detailed assessments are undertaken to predict the impact to this interchange, the potential for capacity issues to occur and that the need and feasibility of any potential mitigation measures is tested. The Agency is currently developing a scheme (Department for Transport Pinch Point Scheme) to ease congestion in the northbound direction for delivery by March 2015 but will not.

A1 (M) Junction 3: Despite the relatively modest levels of impact predicted, this junction is currently heavily used and has the potential to become a greater issue based upon the level of development being proposed. The Highways Agency recommends that detailed assessments are undertaken to predict the impact to this interchange, the potential for capacity issues to occur and that the need and feasibility of any potential mitigation measures are tested.

The modelling undertaken also suggests that the stress levels for the dual two lane section A1(M) south of Junction 3 will increase. Any increase in traffic levels for the dual two lane section A1(M) north of Junction 6 would increase existing stress levels. Widening of the A 1 (M) would be out of scale and very likely beyond the gift of the proposed developments

Whilst fairly remote from the developments proposed, there is also a risk that the A1(M) Junction 1 I M25 Junction 23 would be adversely affected.

Stanborough School We note the suggestion that a new Secondary School may be needed if the

development in Hatfield goes ahead. However, given the proximity of new development in Hatfield to Stanborough School, it may be possible to expand Stanborough instead of providing a new school.

Mobile Operators Association

We consider it important that there remains in place a telecommunications policy within the emerging Local Plan.

Welwyn Hatfield Cycle Forum WHBC should work with HCC to develop key inter-urban cycling routes to and

from other towns and the borough villages The three of the four main cycle paths to the borough are former railways that are

away from roads and are mostly unlit. This makes them unusable for all year commuting.

Off road cycle paths parallel to existing roads are essential, even where they duplicate existing greenway routes.

NHS Hertfordshire The East & North Herts Clinical Commissioning will be taking responsibility for

the commissioning of services from 1st April 2013. The National Commissioning Board will be responsible for commissioning GPs and other primary care services such as Dentists, Pharmacists etc. East & North Herts CCG has a locality structure and the Welwyn & Hatfield locality will be focused on commissioning services locally.

We recognise the issues that are raised in the strategy and fully endorse the vision of sustainable communities. Meeting the needs of an aging population within the current financial climate will be challenging and therefore it is important that we enable and encourage communities to be active and supporting of their residents.

The New QEII will be open by early 2015 and therefore the majority of hospital outpatient, therapy diagnostic appointments will continue to be provided

Thames Water Upgrades to sewerage and sewage treatment infrastructure should be

anticipated and the timing of infrastructure upgrades should not be underestimated. It can take 18 months to three years to deliver local upgrades with more strategic upgrades taking 3 to 5 years to deliver from the point of certainty about development occurring.

As the requirement for sewerage and sewage treatment upgrades is dependent on variables including the scale, location and timing of development and the relationship with other developments within the same catchment it is not possible to identify all upgrades that may be required to support growth. Consequently Thames Water rely on the use of Grampian conditions to ensure that any necessary upgrades required to support growth are delivered ahead of the occupation of development. Failure to provide the upgrades required could result in adverse impacts such as sewer flooding and pollution of water courses.

North Herts District Council With regard to transport infrastructure it is noted that your Infrastructure Delivery

Plan (IDP) acknowledges existing capacity issues and deficiencies with the A1(M). However, whilst this issue is acknowledged in the section on existing need, it is surprising that your highway modelling for future need does not include consideration of impacts on capacity at junction 6 and the knock-on effects for areas to the north of your Borough.

Broxbourne Borough Council Broxbourne is about to commission a new transport study to understand the

impacts of preferred development sites on the local road network and identify improvement options. We would welcome the opportunity to share transport

evidence in order to take account of any cross-border issues that may arise and to work with Herts County Council as the local highway authority and the Highways Agency in respect of the M25 to lobby for any desired improvements.

St Albans District Council The Welwyn Hatfield Infrastructure Delivery Plan identifies junction

improvements. However it is unclear whether impacts on the local roads have been modelled. In particular impacts upon the A414, A1057, Coopers Green Lane, B653 will need to be considered and identified to comply with the NPPF. Furthermore the cumulative impact of the recent announcement of the rail freight interchange in St Albans and the Welwyn Hatfield proposals on the transport network in St Albans and the wider area needs to be taken into account.

The NPPF outlines the importance attached to ensuring that a sufficient choice of school places is available to meet needs of existing and new communities and the local planning authorities should take a proactive, positive and collaborative approach to meeting this requirement. Together with the emphasis on provision and coordination of infrastructure with development (Paragraph 7 of the NPPF) it is expected that there will be prompt and timely delivery of the school needs, and other infrastructure, identified in the IDP.

Affinity Water We note Welwyn Hatfield Borough Council's understanding that no major

constraints to supplying Welwyn Hatfield with potable water are predicted, provided the Environment Agency do not enforce further Sustainability Reductions. We endorse this understanding and are confident we are able to maintain this position alongside your plans to support future growth in Welwyn Hatfield.

Welwyn Parish Council The southbound A1M will also be impacted by the growth in population. This will

in turn impact on the roads around Welwyn - B197 and B656 and Welwyn Bypass feeding into the Clock roundabout. Concern that nothing is being done to ease congestion between WGC and Stevenage.

Welwyn Village and Oaklands/Mardley Heath, by virtue of being on the route from Stevenage to WGC, are well served by buses during the week up to early evening. There is little or no provision for Digswell but this could be considered acceptable for the time being in view of the all day half-hourly train service to WGC and Hatfield.

The draft plan acknowledges (anecdotally) that there are already capacity issues in GP practices outside the major towns, especially in the northern villages. We consider this to be more than anecdote. This is an NHS responsibility that HCC and the borough must require it to address.

From the HCC Green Infrastructure Plan 2011 the key areas for Welwyn Hatfield are the Mimram Valley Greenway primarily focused on Panshanger Park but stretching back into Welwyn at Singlers Marsh and the Lee, where it runs between WGC and Hatfield,. Both of these are important to the borough. There are indicative costs in the ECS. These projects should be supported strongly by the borough

Cycling is becoming a mode for commuting and thought should be given to cycle-ways that enable this.

Welwyn Parish Council (and Hertfordshire County Council - Education) The ECS does not specify where new primary and secondary schools should be

sited. With the Frythe expansion and the Tudor Road site an assessment of primary capacity needs in the parish is important.

David Lock Associates (for Lafarge Tarmac) Local sewerage network would need upgrading for Birchall Garden Suburb.

There are two different options that could help to deliver large-scale development. Would ensure that impacts caused by development would be mitigated through new supporting infrastructure or through S106 or CIL payments to the local authority

Birchall Garden Suburb has the capacity to provide two new primary schools of 1.5 to 2 FE and demand for a 4FE secondary school.

The council should publish its transport evidence to support the Core Strategy and explain the reasons why one option was selected over the reasonable alternatives (i.e. Hat1 over Hat2).

Hatfield Town Council Infrastructure should be in place (and adopted by the local authority) before

development commences. Would also like to see allotments and community orchard. Play facilities for teenagers should be provided in new developments and

installed prior to occupation. These facilities could be provided next to any new schools that are planned. The play areas for younger children have worked well on the Salisbury Village & de Havilland sites except for the hand over of the sites.

Welwyn Garden City Society The Draft document proposals appear to be totally reliant on third party providers

to provide the necessary infrastructure. The concentration of new development at the major conurbations would probably

require new facilities rather than being able to develop the existing to accommodate the increased numbers. This could lead in the future to schools etc. being closed in the event that pupil numbers drop with a changing demographic. Existing facilities expanded could be reduced in capacity or usage without significant expense.

The concentration in development, particularly WGC 4 at Panshanger, could affect the Mimram and the settlements downstream and the Lea valley and lead to flooding.

Hertfordshire Biological Records Association Growth locations will put pressure on Ellenbrook Fields and Panshanger Country

Parks – CIL money needs to be sought to support the management of these spaces

Local Woodlands must not become isolated in this area as a result of new development and should be linked and enhanced as wildlife corridors.

GI doesn't stop at LPA boundaries, an issue which must be considered as part of a broader approach to cross-boundary planning and environmental functionality - representing the delivery of ecosystem services.

Welwyn Hatfield Borough Council Client Services In addition to the need for more burial space, there is a need for a crematorium,

which should be recognised in the infrastructure delivery plan.

Comments by individuals and other bodies More funding is required from Central Government to deliver essential

infrastructure items, particularly transport infrastructure. Would recommend the installation of peak hour traffic lights in a number of

locations but in particular the set of junctions on the Great North Road between The Frythe and The Clock Roundabout.

Bus services will need to be improved and the provision of a real time information system displaying destinations and expected arrival times should be a demand placed on HCC.



Oshwal Association Whilst we fully support the sentiment expressed at 13.51 to the effect that the

council will work with landowners, developers and service providers to ensure that new developments are well served by cultural and leisure facilities, the statement should be extended to acknowledge support for the extension, expansion and development of existing facilities wherever they occur which can benefit the present community as well as that arising from planned growth.

Stevenage Borough Council The Highways Agency has identified capacity constraints on the two-lane section

of the A1(M) between Junctions 6 and 8 (from Welwyn to Stevenage north) ~ particularly on the southbound carriageway in the morning peak and the northbound carriageway in the evening peak. Notwithstanding the recent announcement of Pinch Point funding for the northbound slip road at Junction 6, there is no larger scheme which addresses capacity concerns nor is there any funding identified for any scheme.

The last detailed travel to work data is from the 2001 Census. This identifies significant car-based flows originating from Stevenage, Letchworth and other settlements in northern Hertfordshire and Bedfordshire with destinations in Welwyn Garden City, Hatfield and further south.

It is assumed that data from the 2011 Census will re-confirm this trend and that any future employment development in Welwyn Hatfield Borough will continue to drive this phenomenon over the plan period.

Any proposals by WHBC which further ‘eats into’ the small amount of remaining capacity on the A1(M) between Junctions 6 and 8 will diminish the ability of other authorities, including Stevenage Borough Council, to produce credible plans and / or demonstrate their deliverability.

General Aviation Awareness Council The decision to develop Panshanger airfield is contrary to Policy CS 12. Panshanger is an important leisure asset which should be protected. Panshanger is an important transport facility.

Veolia Environmental Services Policy CS 12 should be open and positive to all proposals for new low carbon or

renewable energy infrastructure in the Borough, particularly where such infrastructure is provided by others as part of a wider initiative to achieve greater self sufficiency in Hertfordshire. In this context, the Policy should also be positive to the provision of new strategic waste management facilities where they can come forward in advance of, or in parallel with, strategic housing growth. Such an approach places less reliance upon developer contributions alone to deliver the

strategic scale waste and energy infrastructure, necessary to support strategic growth.

Friends of the Mimram Concern about the current health of the Mimram as a result of abstraction by

Affinity Water. Putting this number of new houses into the area will mean greater water demand still. Even if water meters are installed, the 10% saving (Affinity) will not achieve the water volume required. Water needs to be brought in from outside the area, which will increase water costs. Currently Affinity has to provide the piping to the outside of all households and not the developer. But this cost will be passed on to all Affinity customers via their water bill. The developer should bear this cost.

Light Aircraft Association Section 13 must recognise the aviation infrastructure facility at Panshanger which

is the only such facility in the Council's area and is one of only 2 licensed aerodromes in Hertfordshire.

Sport England Sport England is concerned that appropriate contributions from developments

towards sports facilities may not be secured and the opportunity to deliver key projects that would address the needs through the use of such contributions may be missed.

Welwyn Garden City Society Whilst it is positive that new green spaces are to be provided, existing green

spaces in the borough are being eroded due to poor maintenance and management.

Concern about the potential impact of growth on the road network in terms of capacity. Transport modelling work should look at the impact on Junctions 5 and 6 of the A1M. More development should be located in closer proximity to the boroughs existing stations (including those in the villages).

A more proportionate approach to housing growth would benefit existing services by giving them the critical mass to continue. The use of commercial buildings for religious purposes seems to work well.

The increased number of households will generate substantial waste either for landfill or recycling. This problem is unlikely to be solved without the case for disposal being given urgent attention by the County Council.

The council should support energy saving and generation in both new housing projects and existing dwellings.

Any new development should be to SUDS standards. The existing sewerage facilities appear to operating at near capacity and will require major infrastructure investment and installation to meet the ongoing needs

Comments by individuals and other bodies There is not sufficient infrastructure in place for the development of housing at

Panshanger airfield Concerns about sewage treatment capacity, water supplies, road and rail

infrastructure, lack of car parking spaces, lack of burial space, lack of schools, doctors’ surgeries

Infrastructure should be put in place before the development goes ahead. Infrastructure should be planned before deciding where to put new houses.



Sport England Policy CS12 is supported as it makes provision for the delivery of infrastructure

that includes sports facilities for meeting the growth in the district. The need for new development to make provision for sports facilities is fully justified by the Council's evidence base (principally the Sports Facilities Study and Sports Facilities Strategy) which identifies a range of existing and future sports facility needs which have been identified through a sound assessment endorsed by Sport England.

The requirement in the policy for developers to contribute towards the costs of new or enhanced sports facility provision is justified.

Herts and Middlesex Wildlife Trust Welcomes this policy and in particular it is positive that green infrastructure is

recognised and included. Although it is yet to be seen how it will be achieved, HMWT is pleased that the council intends to use all the mechanisms available to secure this (Planning Obligations SPD, section 106, unilateral undertaking, planning conditions and CIL).

It is positive that the Council gives clear recognition to the necessity for green infrastructure to support growth. It is welcome also that the council acknowledges the particular need to improve the green infrastructure networks and provision as a core part of development in the broad locations.

HMWT is pleased that new developments are expected to provide green infrastructure on site.

HMWT strongly supports para 13.57. It is critical that the council is confident that funding or a funding mechanism is in place to deliver any needed enhancements or new provision of infrastructure (including GI) for all planning applications. HMWT welcomes the use of conditions and legal agreements to ensure needed infrastructure (including GI) is provided to support development and growth. This relates to paragraphs 176 and 203-206.

HMWT is pleased to see a range of studies, including studies focussing on open space, green infrastructure and water resources, feeding into the Infrastructure Delivery Plan. The council should ensure that future iterations of the IDP and related plans reflect new information on infrastructure needs, deficiencies and priorities.

Tesco Stores Ltd We strongly support the principle that ‘suitable provision is made for new or

improved infrastructure, required to meet the levels of growth identified in the strategy'

We support the principle that improvements to the highway network will be crucial to delivering the level of development that is set out in the Core Strategy, alongside the need to improve Public Transport in the borough in order to reduce the pressure on the highways network and parking issues in the area.

We would support the proposed ‘part replacement and/or enhancement' of the pedestrian bridge over the railway at Welwyn Garden City Station.

Theatres Trust We support this policy.

Hertfordshire Biological Records Centre Para 13.32 Urban greening, river valley, woodland, heathland and grassland

projects are supported. They will also require support of land management initiatives to succeed.

Para 13.34 The delivery of Ellenbrook Country Park is supported. Support for the management of Panshanger is also required given the increased pressure this site will be subject to; this is in addition to improved links. This relates primarily to access opportunities to that resource and not support of the resource itself.

Lafarge Tarmac Aggregates Lafarge Tarmac supports the objectives set out by Policy CS12 and would apply

the same high standards to the development of Birchall Garden Suburb.


Environment Agency We support the inclusion of River Valleys project, Thames Tributaries and

Mimram Valley Green Space projects.

Natural England Natural England welcomes the range of policies within the Emerging Core

Strategy that reinforce the sustainable development ethos as set out within the Borough-wide objectives.

Comments by individuals and other bodies Support the recommendations in relation to the provision of sewerage

infrastructure. Support the provision of a bus station in WGC town centre. Support efforts to improve or replace the existing footbridge linking the east and

west of the town.

We strongly support the development of the new QEII but pressure to include on the site a facility providing Intermediate Beds must be continued.

We support the inclusion of River Valleys project, Thames Tributaries and Mimram Valley Green Space projects.


CHANGES suggested

Stevenage Borough Council We would request that the issue of capacity on the A1M is given due

consideration and reflected in future iterations of your plan. Co-ordinated action under the Duty to Co-operate would be a useful way forward on the issue of how to relieve capacity constraints on the A1(M) between junctions 6 and 8. We wish to continue working with you, the County Council, the Highways Agency, the Local Enterprise Partnership and other relevant parties to identify a practicable, funded long-term solution that will allow all plan-making authorities affected by

this issue to proceed.

Herts and Middlesex Wildlife Trust Significantly more detail is required on proposed green infrastructure projects, in

terms of what the particular needs and opportunities are for each location and whether this will be deliverable and sufficient to mitigate and compensate for adverse impacts. It is presumed details will come forward in Area Action Plans.

With regards to the provision of green infrastructure as part of new developments, it is felt that more guidance on the expectations of the council is needed, to provide clarity to developers and ensure that development delivers as highly as possible in sustainability terms.

General Aviation Awareness Council Remove Panshanger as a potential development site.

Veolia Environmental Services Propose the following change to Policy CS12: ‘Furthermore the Council will

continue to work with its partners to address existing deficiencies and secure appropriate levels of funding. The Council will also proactively support proposals for new strategic infrastructure in the Borough, including new energy and waste facilities, even if not directly related to the growth identified in the strategy, provided that the infrastructure proposed is beneficial or complementary to the growth identified or serves the wider needs of Hertfordshire, in terms of helping to achieve greater self sufficiency and sustainability'.

Propose the following change to para 13.30: ‘In addition, where considered necessary in planning for the broad locations identified in the Core Strategy, the Council will proactively engage with its partners to facilitate opportunities for the provision of sustainable waste management facilities, both to meet the needs of the growth identified and to facilitate greater self sufficiency and sustainability in Hertfordshire.'

Friends of the Mimram Developers should pay for installing the water mains pipework, not Affinity, in

order to avoid costs being passed on to all residents.. Any new housing uses water harvesting systems and water meters to reduce the

demand on the aquifer feeding the River Mimram

Consideration should be taken to ensure water supply is from outside the region and not local groundwater

Mobile Operators Association We suggest that a clear and flexible telecommunications policy be introduced in

one of the main LDDs. This should be a short paragraph outlining the development pressures and the authority’s aims. We have suggested text for both. In keeping with the aims and objectives of the legislation any background information should be contained within a separate non-statutory LDD which would not need to go through the same consultation process.

Theatres Trust We suggest that theatres are included in the examples of cultural facilities in

para.13.51 as you have three, according to the Draft Infrastructure Delivery Plan document which lists them as key cultural and arts facilities.

Thames Water

The physical infrastructure section should refer to sewerage networks and sewage treatment works.

Within Section 13.4 it is considered that the strategic level infrastructure requirements should be revised to refer to new or upgraded facilities being required to facilitate growth across the borough and the wider area. For example it may be that growth can be accommodated by upgrading existing sewage treatment works rather than by constructing new treatment works.

Sections 13.11 to 13.14 relate to sewerage and sewage treatment works. References within this section to ‘sewerage treatment works' be revised to read ‘sewage treatment works'.

With regard to the potential upgrades identified in sections 13.11 to 13.14 it should be made clear that these are options to support growth and not necessarily defined schemes as the exact location and scale of upgrades to both sewerage and sewage treatment infrastructure will be determined based on the location, scale and phasing of development within Welwyn Hatfield and adjoining local authorities. It may also be necessary to undertake infrastructure upgrades in order to deliver environmental improvements in addition to upgrades to support growth.

Thames Water would welcome the Councils support in securing the provision of necessary upgrades through the use of Grampian conditions were off-site upgrades are required. To assist with the provision of sewerage and sewage treatment upgrades in a timely manner it is considered that the text within Policy CS 12 should be strengthened as set out below: "Supporting infrastructure , including sewerage infrastructure, should be provided in advance of, or prior to occupation of , the development unless there is sufficient existing capacity. The appropriate phasing for the provision of infrastructure will however be determined on a case by case basis. Where necessary planning conditions will be used to ensure that the necessary infrastructure is provided ahead of the occupation of development. "

The following supporting text should be included following section 3.14: The Council will seek to ensure that there is adequate surface water, foul drainage and sewage treatment capacity to serve all new developments. Developers will be required to demonstrate that there is adequate capacity both on and off the site to serve the development and that it would not lead to problems for existing users. In some circumstances this may make it necessary for developers to carry out appropriate studies to ascertain whether the proposed development will lead to overloading of existing infrastructure. Where there is a capacity problem and no improvements are programmed by statutory undertaker, the Council will require the developer to fund appropriate improvements which must be completed prior to occupation of the development.

North Herts District Council This Council would request that full consideration is given to the impacts of the

proposed levels of growth on the operation of the A1 (M) (particularly junction 6) both within your Borough and to the north.

Hertfordshire County Council Repetition between IDP and Chapter 13. Move the background information and

evidence across to the IDP and the Core Strategy should just cross refer and simply set out the implications in spatial planning terms.

Any key infrastructure projects that are attributable to specific growth locations should be included in the relevant policies and implementation sections in the core strategy.

Hertfordshire County Council (Transport) More detailed transport assessments are required to supplement the existing

DIAMOND transport modeling work. These also need to identify mitigation

measures and potential funding/ delivery mechanisms. This will enable the identification of ‘show stoppers’. The county council also needs to be confident that any mitigation measures can be delivered.

Hertfordshire County Council (Waste)

Ref should be made to the Waste Core Strategy & Development Management Policies Development Plan Document 2011-2026, November 2012 and Waste Site Allocations Proposed Submission, November 2012.

The following sentence should be included in each of the broad locations policies: "provision should be made for the storage and collection of waste and recyclables, including recycling boxes, wheelie bins and compost bins and be positioned in a way that it enables refuse trucks to gain access easily."

Sufficient land should be made available for the provision of a neighbourhood recycling centre, particularly in the broad locations for growth.

Hertfordshire County Council (Green Infrastructure)

Page 95: The text for green infrastructure would be helped by adding "networks of structural planting " to the beginning of the list and " SuDS " within it.

The following examples could be added to the scales of infrastructure required, to complement the more urban elements: Local: open space and structural landscaping; Neighbourhood: Local links, urban greening, SuDS; Strategic: Contributions to relevant green infrastructure projects [as shown in the GI plans]

Paragraphs 13.8: If WH agrees that it should co-operate with neighbouring authorities over GI provision, then the Green Infrastructure Plan reference should be to Plan s ( to include the Strategic Highlights Plan for Hertfordshire referred to in Para 13.33, which for example critically describes a joint initiative with East Herts concerning the Mimram Valley)

Paragraph 13.35: Suggest delete "some elements of green infrastructure" since the standard for green infrastructure, where spatial considerations and linkages are crucial, is effectively set by the GI plans.

Omission (possibly 13.51): Panshanger Country Park, in East Herts but immediately adjacent to the borough, currently in the ownership of Lafarge Tarmac but with need of a longer-term plan, provides an opportunity for satisfy some of the requirements for leisure for WHBC residents. Consideration could usefully be given to giving it a mention, e.g. by adding " For example, the council will seek to support the development of Panshanger Country Park, in East Hertfordshire, but adjacent to the borough, as an outdoor leisure and heritage destination " to the end of 13.51. Supporting this will complement CS19.

Hertfordshire County Council (Education) If the land take requirements for new schools which are required to meet the

needs arising out of new development, are made key to the relevant allocation, then this will assist the economics of delivery. It will also ensure that any funding gap which might be identified when considering your Charging Schedule, will be minimised.

Given that primary and secondary schools are identified as social infrastructure it would be helpful if the bullet points at 2.3 could be expanded to make clear “the great importance” Government attaches to the need to ensure appropriate school places and need to “give great weight to the need to create, expand or alter schools….” As outlined at paragraph 72 of the NPPF.

As an example later stages of the CS outline that spatially 2 new secondary and up to 4 new primary schools may be required. Whilst school space standards are currently open to interpretation the amount of land required for new and reserve school sites is still likely to be considerable.

2 x Secondary approx. 15 ha each = 30 ha4 x primary approx 2.5 ha each = 10 ha= 40 hectares

It would therefore be helpful if the next iteration of the ECS sets out how many hectares of land it is estimated is required for education purposes or which areas of potential release for growth might contribute to meeting the need for education land.

13.36 The wording of this paragraph should be adjusted. It is more appropriate to say that many existing schools have been expanded and whilst there may be opportunities at certain schools for additional expansion this is largely likely to cater for natural growth and migration from existing populations. Large scale edge of urban growth as put forward within the Broad Locations for Growth will require specific new education facilities for the large number of houses proposed.

13.37 The inclusion of the form of words that covers the County Council’s current approach to child yield is supported and welcomed. However it should be noted that this approach could well change as demography and migration issues vary over time. It is therefore questionable whether this text should be included in the final Core Strategy Document or would it be better placed within the Infrastructure Delivery Plan given that this document will be updated on a more regular basis.

The very precise wordings contained at these paragraphs (13.41) will need to be adjusted in accordance with the scale of housing delivery that ultimately is to come forward. For example it is more appropriate to say “prudent to plan for” rather than “will be provided”.

Land should be allocated within future DPDs for new and reserve school sites. An Education allocation should be made within/alongside the growth areas where it is explicit that the land is for Education and no other purpose.

13.42 The wording that land will need to be made available is imprecise and again does not recognise the fact that Welwyn Hatfield will need to allocate land for education purposes only.

It would be helpful if there can be formal education allocations as part of any subsequent Site Allocations document, with those explicit education allocations or reserves being sewn into the process. If the education allocation is merely being considered as part of a wider housing or other release from the Green Belt or other allocation site acquisition will be prohibitively expensive1.

1 Part III of the Land Compensation Act 1961 provides a mechanism for indicating the kind of development (if any) for which planning permission can be assumed by means of a ‘certificate of appropriate alternative development’. The permissions indicated in a certificate can briefly be described as those with which an owner might reasonably have expected to sell his land in the open market if it had not been publicly acquired. Therefore, if X number sites are identified as being educational sites in the development plan and they are located in the Green Belt, then the alternative use is limited to those uses which are appropriate in the Green Belt. If however, the identification is simply as a school as part of a wider housing release, then one might argue that the alternative development would be residential and the site acquisition will be prohibitively more expensive.

Highways Agency The role of the Highways Agency is to facilitate sustainable development and be

supportive of measures which reduce the level of traffic impact on to the strategic highway network. Therefore the Emerging Core Strategy should incorporate a policy statement to that effect

A more detailed transport assessment is required to identify any potential ‘show stoppers’ that could prevent the adverse impacts to the Strategic Road Network from being mitigated. Also needs to show that any mitigated measures can be delivered.

M25 Junction 23 - the ECS states: " In the AM peak, the west bound on slip at junction 23 of the M25/ junction 1 of the A 1 M) is already at capacity, even without additional development, which could affect its operation " Table 5 of the DIAMOND report suggests however that the M25 westbound onslip does not suffer any impact and should operate within capacity.

A 11M) Junction 2 - the ECS states: " Junction 2 of the A 1 M would also be affected in the north bound direction, with additional movements bringing it close to capacity “Table 13 of the DIAMOND report confirms that in the PM peak the A 1 (M) Northbound carriageway would be approaching capacity, but suggests that there would not be an impact from the proposed development.

A 11M) Junction 3 - the ECS states: " Further to this, due to traffic generated by new development in the borough both the southbound off slip and north bound on slip at junction 3 of the A 1 (M) would reach capacity, meaning that development traffic would need to be routed away from these junctions to minimise the impact on the highways network." Table 7 of the DIAMOND report confirms that at Junction 3 in the AM peak the A 1 (M) southbound off slip and northbound on slip would be operating at high stress levels. The report indicates however that only the A 1 southbound off slip would suffer a material impact

A1(M) Junction 3 - the ECS also states: "In the PM peak , the north bound on slip at junction 3 of the A 1 (M) would be affected, as it is already at capacity , even without additional development , meaning that development traffic would need to be routed away from this junction to minimise the impact on the highways network. " Table 14 of the DIAMOND report confirms that at Junction 3 in the PM peak the A1(M) northbound on slip would be operating at high stress levels. The report also indicates however that the proposed development would not result in a material impact.

St Albans District Council More detailed transport modeling is required to assess the impact of growth on

local roads. This should also take into account the proposed Rail Freight Interchange in St Albans.

Welwyn Hatfield Cycle Forum

Key inter-urban routes should be from Hatfield to St Albans, Potters Bar and Hertford and from WGC to Hertford, Knebworth and Stevenage and Wheathampstead. The existing inter-urban routes between WGC and Hatfield would then create a cohesive network for central Hertfordshire. Much of this network could be achieved by allowing cycling along low use pavements out of town, so the cost can be contained

The borough villages should also have cycle routes to their centres, the schools and the stations. Where practical these routes should be off road, but it may be that lower traffic density may allow some on road routes on speed limited calmer streets. For example, there is significant suppressed demand for cycling to and from Chancellors School due to the lack of off road cycling between Hatfield, Welham Green and Brookmans Park. This could be provided by making local inter urban pavements dual use as part of a Potters Bar to Hatfield route.

NHS Hertfordshire

We would ask that accessibility and transport issues are taken account of when agreeing where housing growth should take place.

Wherever the growth in housing takes place there will be a potential impact on primary care services such as GP Practices, pharmacies, dental surgeries etc. These proposals and the timing/phasing of such developments will need to be discussed as they are planned to agree the best way to ensure that there are appropriate local primary health care resources. This additional capacity can be delivered in a number of ways and we would wish to discuss these with the Council on a case by case basis.

Environment Agency

With regards to water infrastructure, consideration must be given to how Welwyn Hatfield's growth plans fit in with the growth plans of neighbouring areas, who are all proposing growth in their area and have shared infrastructure. Also, what are the cumulative effects of growth on infrastructure? What timescales and phasing of development needs to be considered? How will capacity and consent standards be addressed on a larger than Borough scale?

We would like to see the actions proposed in the Beane and Mimram Rivers Partnership included in the existing and future need for Welwyn Hatfield. The website can be found http://www.beaneandmimrampartnership.org.uk/ . In addition, we would also like to see the actions for waterbodies as proposed in the Thames River Basin Management Plan included as an existing and future need. Specific actions for waterbodies will be published throughout 2013 by the Environment Agency.

There are potential flood defence schemes within Welwyn Hatfield that will be identified under the Environment Agency’s ‘Communities at Risk’ project. The project is ongoing and in the near future we will have some schemes/ locations that could be put forward for inclusion in the Infrastructure plan.

In the summary of Welwyn Hatfield green assets, it would be helpful to provide the number and length of rivers and their tributaries included. This would help provide a clearer picture of Welwyn Hatfield’s assets.

Sport England

Sport England would recommend that a small number of priority sports facility projects are identified in the IDP for which developer contributions together with funding from other sources will be prioritised. These projects should then be fully costed and include a delivery timeline. A further consideration is that there may be a need for a spatial approach in order to meet the CIL/planning obligation tests.

Welwyn Hatfield Borough Council Client Services

The need for a crematorium needs to be recognised in the Infrastructure Delivery Plan. Technical analysis is currently being undertaken to establish the proof of need.

Hertfordshire Biological Records Association

Refer to the Hertfordshire's Biodiversity Action Plan. The 1998 Biodiversity Action Plan date was updated and re-published in 2006 In any event the author should be HMWT on behalf of HEF, not HCC

http://www.beaneandmimrampartnership.org.uk/

Tewinbury SSSI should be in the Mimram Valley, given its proximity to the District boundary and proposed BLG 1.

HBRC are not highlighted as a responsible delivery body What about the emerging LNP? or the NIA proposals within the Lee catchment

etc? Comments on current provision section of IDP

o should mention 'Wildlife Sites' and Grasslandso Broxbourne SAC is not within borough but immediately adjacent to it. o It is not clear as to what the 24 areas of natural and semi-natural

greenspace refers. o The 6.29 ha per 100 population is resource related rather than equating

to publicly accessible areaso There is also an issue regarding definition of Green corridors, unless

these have been defined and identified within the District - in which case there is no map of these within the DIDP.

Comments on existing and future need section of IDP:o Urban greening in WH should also refer to management to help improve

local biodiversity and the character of the greenspace o River valleys project – should also mention Living Landscapes project

and the NIA proposalso The woodland heathland/grassland projects will need appropriate

management to achieve anything of value o Where good management is taking place this needs to be encouraged

and supported o Similarly the County GI plan is laudable but requires a mechanism to

deliver and maintain most of the physical management improvements. o The Thames Tributaries and Mimram Valley projects are also to be

however increasing public access is likely to compromise management and wildlife opportunities unless carefully provided.

o The Woodland Arc project is also to be supported although it will require the same sorts of drivers to be achieved.

o Suitable delivery mechanisms must be identified to deliver these projects

Comments on planned provision section of IDP:o Extra land and subsequent management would be required to provide

new GI, however this approach has not yet been taken in the county.Such areas must also be managed; the functionality of management must therefore also be a primary consideration if this is to be achieved . If a robust approach to such countryside management is not taken, the quality of that countryside and its GI role is likely to degrade.

o No mention of biodiversity offsetting (ecological compensation) o Rural economy should be mentioned, including farmers markets.


Smaller developments across more areas of the borough could leverage existing infrastructure, with only capacity upgrades where needed. This is a more sustainable solution that is more likely to actually materialise.


Section 15 Welwyn Garden City

Consultation Point - Vision and Objectives for Welwyn Garden City


HCC Landscape Officer The green infrastructure shown on the diagrams could relate better to the GI

plans - in particular links need to be better shown.

Comments by individuals and other bodies The Welwyn Garden City Key Diagram does not show key green spaces which

affect or abut the settlement. Why show important green spaces on the Villages and Rural Areas maps - some of these are important resources for both, and several are obviously missing. This approach would appear to be inconsistent at least.

The map shows an area called Structural Landscape Area – where is the definition of what that actually is in reality?

The map shows Black Fan Valley Park – this is an unknown place name. Objective WGC4 – what is ‘strategic healthcare’ and where is this defined? What

exactly is it you are proposing to retain? ‘To provide for housing including affordable housing’ - where is ‘affordable

housing’ defined.





Tesco Stores Ltd

Support objective WGC3 to 'maintain a balanced supply of employment land to fulfil the town's role as a key centre for employment' . However, we would propose that Welwyn Garden City strives to improve existing employment land for the needs and requirements of existing employers in the area as well as for potential future employers.

Support the wider objectives of the Strategy to promote Welwyn as a main centre for employment in the Borough.

Comments by individuals and other bodies This is a far-sighted and important strategy for the development of our local area

that will create additional housing opportunities for those of us who do not currently own our own homes and would very much like to.

This proposal represents a sensible strategy to provide work and accommodation opportunities for a growing population. The alternative to embracing this is that Welwyn Hatfield ossifies and declines.

1


CHANGES suggested for Vision and Objectives for Welwyn Garden City Number of comments

Tesco Stores Ltd Make specific reference to acknowledging the needs of existing employers as

well as potential new employers.

Comments by individuals and other bodies Remove the jargon and clarify the terms/names Define exactly what and where Black Fan Valley Park is.


Section 15.2 Heritage of Welwyn Garden City

Consultation Point CS13 The Historic Environment of Welwyn Garden City


English Heritage Welcome the protection afforded by this policy to the New Town heritage. It is

important to ensure other aspects of the settlements heritage are conserved and enhanced e.g. archaeological record and relationship of the town to historic parkland.

The 2nd&3rd paras should not imply that careful analysis of historic character for smaller developments is not required.

It is not clear here or in LFHOUA the extent to which development sites have been evaluated where potential archaeological interest has been identified.



Welwyn Garden City Society Policy is unclear. Current council policy fails to enforce almost any planning,

Estate Management Scheme rules or legislation. Such policy and or detailed planning guidance must be enforceable and the council must be willing to enforce or else the documents will not be worth the paper they are written on.

Comments by individuals and other bodies The development of the historic Panshanger aerodrome (WW2 heritage assets)

is inconsistent with this policy and contradictory to the vision and objectives for Welwyn Garden City – particularly objective WGC1.

The historic environment of the Garden City as it is now would be destroyed by the development at Panshanger.

The only heritage currently remaining in the Panshanger area is the airfield itself and its buildings, together with the open space adjoining it on its western boundary. The heritage, character and original concept of the Garden City Company has been lost and the council is "a dog without any teeth". If the local authority is concerned with retaining heritage it should consider putting a Listed Building Notice on the Airfield and its buildings.

The exclusion of Panshanger Airfield as an area of historical interest and therefore part of the heritage of Welwyn Garden City needs to be reviewed. Panshanger aerodrome should be preserved for historical and cultural reasons. There is open land beyond the aerodrome that could be used.

Query why is there no policy to protect and promote Hatfield's history and heritage? Its aviation aspect alone is worthy of world heritage status while WGC wasn't even built until after World War One.

No effort has been made to exploit the town’s importance in urban planning despite the regular flow of UK and foreign visitors and forming a closer link with Letchworth to promote both venues should be a key objective.

Much is made of the need to conserve the historic environment but this has demonstrably failed due to a lack of enforcement of both planning permissions within the Conservation Area and the Estate Management Scheme. Current ambivalence over the Estate Management Scheme needs to stop.

A method to protect grass verges which are such a feature of the town must be built into any plan.



Natural England Welcomes the references within both policy CS13 and CS14 to enhance the

quality of Welwyn Garden City's environment, open spaces and public realm and

to improve movement and access within the centre by giving priority to cyclists and public transport



HCC Landscape Officer It would be good to add either " and garden " or " and landscape" after 'enhance

its heritage'. Otherwise there will be few prompts in successive text to ensure that these elements will be incorporated into thinking.

Comments by individuals and other bodies Panshanger has a real local historic significance. Any redevelopment of this

aerodrome for housing purposes would mean the loss of a local historical and community asset. Retain Panshanger airfield and choose another location for development.

Panshanger Aerodrome should not be built upon as it is a site of national importance, not just local.

The heritage centre that was planned for the former Hatfield Aerodrome, did not transpire, and it is not considered that a similar one for Panshanger Aerodrome will transpire either.

Panshanger Airfield needs to be incorporated as a site of special historical interest and therefore protected from any potential future development.

At least equal attention should be paid to Hatfield's heritage and culture - especially protection for the few remaining buildings that date back to the New Town of the 1850s (built after the arrival of the railways).

The council’s approach to the heritage of the original concept of the town should change.

Remove area WGC4 and instead review the housing numbers suggested, and spread any development evenly throughout the borough. Including in the areas that your own SLHAA survey highlighted as available and suitable, but were left out entirely in the current Core Strategy proposal.

Why not make this policy apply to any development proposal, from 1 dwelling upwards?

Clarify what is meant by "Mark One New Town". Subject all development proposals to close examination and implement an effective enforcement regime.


Section 15.3 Welwyn Garden City Town Centre

Consultation Point CS14 Welwyn Garden City Town Centre


Homes and Communities Agency The HCA has landownership interests within the town centre and will continue to

work with the council to bring forward new retail opportunities in line with its local

investment plan.

Comments by individuals and other bodies Considerable care will be needed to ensure that the character of the area is not

diminished or destroyed in the drive for more retail. The town centre is characterised by open spaces and large areas of green space and that must be maintained.

The town centre is dominated by national chains with very few small local businesses. A vibrant town centre needs a number of small local providers.

A means by which the council can enforce proper maintenance of both retail, commercial and residential properties by owners is needed.

It is essential that the Town Centre Streetscape Design Manual is not simply a piece of paper but is adhered to and the Shopfront and Advertisement Guide are enforced.

CIL should be used to provide funding to improve or provide community buildings operated by non-government bodies to offer affordable community facilities for residents and local voluntary groups.



Welwyn Garden City Society The entire approach is flawed and should be rethought, starting with a SWOT

analysis rather than using historical ratios of retail floorspace to households. Table 9 – why does ‘Comparison Floorspace’ start at 2019? Policy appears to be

predicated on a ten-fold increase in comparison retail floorspace which would result in a massive over-supply of retail in the town centre.

The night time economy if it is to be enhanced would not include comparison shops.

Given the increase in online retail, is a ten-fold increase in ‘Comparison Floorspace’ desirable or possible?

Query why is there no consideration of the revolution in retailing which is changing the face of retail centres throughout the country.

Comments by individuals and other bodies Concern at suggestion of retail expansion given the number of empty premises in

the town centre and neighbourhood shopping areas as well as the impacts resulting from increased internet sales.

As a retail centre, Welwyn Garden City has to recognise that in recent years we have seen the emergence of changing buying patterns - particularly with the advent of internet retails sales. Moreover, the development of larger retail/entertainment centres such as Westfield Stratford represent a serious and credible alternative to the nearer Stevenage. Is this likely to change and if not where will new retail jobs come from?

Welwyn Garden City is an established commuter city with very good rail links to both Kings Cross and Moorgate. To infer it can create employment for the inhabitants of proposed new dwellings appears very optimistic. As such, to proposed large scale developments so far away from the rail stations would appear a very misjudged option. The result would be increased car volumes into the town centre as existing public transport links are very limited.


SUPPORT Number of

comments

Natural England Welcomes the reference to enhancing the quality of the environment, open

spaces and public realm and the improvement of movement and access by giving priority to cyclists and public transport.

Welwyn Hatfield Chamber of Commerce Supports most of the comments made in this section, but considers the statement

that there is an identified need for an increase in gross retail footage needs to be reviewed. The retail market has changed radically in the last two years and most projections of future retail requirements are unlikely to reflect this.

John Lewis Generally supportive of CS14 and its objectives. Any ‘associated uses’ must

complement the existing offer and provide a mix of services and leisure uses that increase the dwell time within the centre and create a town centre which will attract people to visit.

Welwyn Garden City Chamber of Commerce

supports most of the comments made in this section, but considers the statement that there is an identified need for an increase in gross retail footage needs to be reviewed. The retail market has changed radically in the last two years and most projections of future retail requirements are unlikely to reflect this.

Comments by individuals and other bodies If it is shown there is a genuine need to increase the retail offer within the town

centre, despite the major increase in on-line shopping that has taken place in the last 12-18 months, and that this necessitates further development then sensitive expansion would be supported.



Welwyn Garden City Society Revise down the figure for comparison retail in Welwyn Garden City town centre

to reflect the current trend in retail.

English Heritage The importance of the re-use and regeneration of important buildings (whether of

local or national interest) should be covered in this policy. The Shredded Wheat Factory deserves a reference in this section.

HCC Landscape Officer Under 4th bullet point add “trees” before “open spaces and public realm”.

Welwyn Garden City Chamber of Commerce

In light of the changing pattern of retailing, with more sales being made on line and less in retail stores, it is unrealistic to expect all the vacant units to be re let even when the economy recovers. In addition those retailers that are looking for

new outlets are generally seeking larger units, because they are more cost effective to operate than smaller ones. Therefore the Council needs to look again at future projections for retail footage and to consider alternative uses for surplus retail space. If new retail development is taking place unit size needs to be tailored to meet the current market needs and the new space needs to be pre-let.

Comments by individuals and other bodies Focus new dwellings nearer to existing stations within the Borough to assist the

loads on public transport and traffic to town centres.

In light of the changing pattern of retailing, the Council needs to look again at future projections for retail footage and to consider alternative uses for surplus retail space. If new retail development is taking place unit size needs to be tailored to meet the current market needs and the new space needs to be pre-let.


Section 15 Welwyn Garden City

Consultation Point Policy CS15 Broad Location for Growth 1 – Neighbourhood Extension North East of Welwyn Garden City


Part 1: 700 dwellings in this location

Sport England Panshanger Aerodrome is a regionally important facility. Panshanger only one of 3 aerodromes suitable for sport and leisure in the limited

airspace between Stansted and Heathrow. Aerodrome home to North London Flying School – the aerodrome is a Significant

Area for Sport.

Herts and Middlesex Wildlife Trust Pleased to note that an Area Action Plan will be produced and that there will be

comprehensive approach to master planning development in Broad Locations.

Hertfordshire County Council (Minerals and Waste) Site located within sand and gravel belt which is a safeguarded area within the

Herts Minerals Local Plan. Prior to examination evidence must be forthcoming on how it will be possible to extract minerals and prepare land so that it is suitable for development. If Core Strategy proposes that minerals are not removed it must be clear as to how the tests in Policy MP5 can be met.

Additional wording is required to ensure that developers and land owners are fully aware of these requirements (similar to wording in CS19).

In the event that the issue is not resolved as part of the Core Strategy it is likely that HCC would object to any development proposals should they prevent or prejudice future mineral extraction.

Comments by individuals and other bodies Where will new residents work? Do not like the proposal for further development in Panshanger but consider the

area can sustain such growth.

Part 3: Structural landscaping area minimise visual impact and long distance views across the Mimram valley. Wildlife. Leisure.

Herts Biological Record Centre Structural landscaping approach is supported. However, no amount of on-site

landscaping/ecological enhancement would effectively compensate for the loss of at least some of the existing habitat characteristics. This is inevitable if development has to be found in this general area.

There is some local evidence of bird interest on at least some of the site although it is not recognised as a key bird site in Hertfordshire by Herts Bird Club and is not recognised as a wildlife site.

The adjacent Mimram Valley is ecologically very sensitive with a wildlife site and SSSI and already has to withstand significant disturbance.

To help deflect pressure, CIL resources should also be made available for the management of Panshanger which should take account of potential compensation for any bird interest affected by future development.

Natural England Tewinbury SSSI is located in close proximity, CS should acknowledge this

together with the requirement for any proposal to satisfactorily demonstrate no adverse effects on the statutory site.

Environment Agency do not object to proposed location for development, but a number of issues need

to be considered The site is source protection zone 2 and 3. Site is in Flood Zone 1 but due to size of site a FRA is required. Furthermore a

full drainage assessment of existing and future capacity is required via Water Framework Directive

Range of SUDS should be used. Geology of site means it is reasonably sensitive to pollution Protection required for any water course crossing the site. Support comments in Green Infrastructure Plan and opportunities for structural

landscaping and GI measures in river valleys. Essential no adverse impact on habitats assoc with River Mimram and SSSI at

Tewinbury.

Part 4: Green infrastructure – open space, sports facilities, allotments, play areas, green chains.

Herts and Middlesex Wildlife Trust Policy CS15 point 4 as well as ecological restoration and enhancement in the

surrounding area supports the need of creating GI & habitats areas & links within around and through new development.

Natural England the site provides an important area of accessible natural green space, this should

be retained and enhanced as far as possible.

Other comments

English Heritage The site is located in an elevated position in the context of the Mimram river valley. As the policy acknowledges, this gives rise to constraints in order to avoid a significant intrusion into the valley landscape. Note the potential for development to affect the setting of the adjoining registered historic park and garden, Panshanger Park. Note the intention for a convenience store at the eastern end of the site which has the potential for visual intrusion in relation to the historic parkland, including through night-time lighting, depending on the nature and scale of the development. The local heritage of the aerodrome is acknowledged in the policy and should be thoroughly assessed before decisions on this site are taken.


What is to stop Luton or Stansted airports stacking planes over the area? Who will build the homes at Panshanger?



Paragraph 15.26

Robin Bretherick (for Mr and Mrs Ferry) Panshanger is not a sustainable opportunity for development because of its

remoteness from facilities, the resulting loss of recreational, leisure, bio-diversity, employment and heritage functions and the potential landscape impact. The proposal conflicts with NPPF and other CS objectives in this regard. Development would not need to go ahead at Panshanger if sufficient sites around the larger villages can be identified through a Green Belt review.

Comments by individuals and other bodies Delivery of large urban extensions and neighbourhoods requires a long lead in

time and therefore more, smaller sites are needed to provide the growth needs of the settlement of Welwyn Garden City in the short term.

Much of WGC green areas have been lost in the last 19 years. Houses do not need to be built on Green Belt or Panshanger.

Part 1: 700 dwellings in this location

Hertfordshire Gardens Trust Loss of Green Belt here is unacceptable and will blur the distinctive identity of

Welwyn Garden City, Hatfield and surrounding villages.

Robin Bretherick (for Mr and Mrs Ferry) This location is inappropriate for development because it is not in a sustainable

location, it would result in the loss of an important and historic airfield facility and related public recreational, leisure and employment uses, and would have a potential impact on landscape, wildlife and amenity. In any event, it is unlikely to provide the number of dwellings suggested if it is to be sensitive to the views and character of the Mimram Valley, is to make some allowance for its present employment, leisure and heritage functions and is to provide adequate residential support facilities

Metropolis PD Housing development at this location, alongside development north west of

Hatfield, will be insufficient to meet the needs of Welwyn Hatfield. Their adoption alone, without other appropriate growth points elsewhere will be unsustainable and will put undue strain on those areas. Because they are complex sites to deliver housing delivery will be “backloaded” and the authority will be exposed in the short term. The allocation of housing sites should be informed by a comprehensive Green Belt review of the whole borough. If not, the BLGs should be deleted as the overall strategy will be unsound in failing to meet the requirement for a five year supply of housing land (NPPF para 47).

HJ Brosnan Inspector at the previous District Plan Inquiry concluded that there were more

suitable locations, e.g. sites around the large villages.

AWD Perkins Inspector at the previous District Plan Inquiry concluded that there were more

suitable locations, e.g. sites around the large villages. Mineral reserves have not yet been extracted. Panshanger is a well-established and valued airfield and flying club for light aircraft. Its loss is unlikely to be provided for elsewhere placing a heavy burden on Elstree, the busiest private aerodrome in the UK.

Nathaniel Lichfield and Partners (for Mariposa)An AAP will unacceptably delay the delivery of housing. The Green Belt boundary could be defined and settled through the Core Strategy, allowing for a (non-statutory) masterplan to be progressed allowing for consultation.

The council’s housing supply will be under stress before 2019. Land at this location should come forward in parallel with urban sites. If the overall housing target is raised, the tipping point for the 5 year land supply will occur earlier and the BLGs will be needed in the 1st 5 years of the plan period.Light Aircraft Association

Concerned that the proposal to create a housing development on Panshanger Aerodrome would seriously damage the recreational and sporting facilities in the region and destroy a small but important set of businesses that rely on it. The Local Plan and Core Strategy do not have regard to the requirements of the National Planning Policy Framework nor with other national and EU policy related to sports facilities and aerodromes. Closing Panshanger Aerodrome would remove the air sports and associated leisure facilities available to local communities as well as destroying employment and business opportunities from this important national asset that serves the whole area north of London.

General Aviation Awareness Council

The proposal to reclassify this land, currently used as an active local airfield, leisure amenity and flying school, is inappropriate and runs contrary both to the Council’s responsibilities as outlined in the National Planning Policy Framework and its own Planning Strategy; as outlined in policy CS11, Protection of Critical Assets (environmental and heritage) and Policy CS 12, Infrastructure; which includes maintaining Physical Infrastructure such as transport, social Infrastructure including leisure amenities and Green Infrastructure, which includes formal and informal green space, green corridors and open spaces.

In addition there are a number of significant unanswered questions about the processes carried out thus far. This includes the process and methodology employed for the landscape and visual character assessment of the site.

This important assessment, which is regarded as a specialist discipline and usually outsourced to professionals in that field, appears to have been carried out

in-house. British Aerobatic Association

Loss of aerodrome would be contrary to government aviation policy. It would also result in the loss of a valuable training facility. The council should carry out an analysis of future requirements for airfields. This aerodrome should not be lost unless a replacement facility has been identified.

Comments by individuals and other bodies Loss of airfield:

Loss of the aerodrome as an historic, community, business etc asset. Loss of wildlife. Training new pilots. Proposal does not have regard to the National Planning Policy Framework

para 33 and para 74. It also does not have regard to the Framework for UK Aviation Policy Framework and other national and EU policy related to sports facilities and aerodromes. This includes EU Special Resolution ‘Sustainable Future for General Aviation and Business Aviation’ which encourages member states, regional and local authorities, to invest in the modernisation and establishment of small and medium sized airports (Special Resolution of 3rd Feb 2009).

Provides employment. Popular and well run local amenity, café etc. Sports facility. No provision for a replacement facility has been made and it is unlikely one

would be provided. [Includes RAF Air Cadets at Haileybury and RAF Hertford and District.]

Development of this site would be a great loss to the aviation industry. Used by private business aircraft, supports business and brings visitors Part of the identity of the area, it puts Welwyn Hatfield on the map Green area on the edge of town. Local people enjoy watching the planes. Support all comments made by the light aircraft association Development is contrary to policy CS6. Conflicts with policy protecting sports facilities. Unique facility. Used by University of Hertfordshire. Used by air cadets. Established nature reserve / Conflict with policy on protecting wildlife sites. Would affect commuting from Newport City Aerodrome. Aviation is the future. Would remove a diversion option for flights in the area, decreasing the safety

margin. Remote location, from town centre and services, will increase car dependency. Increase in crime, impact on policing, negative impact of quality of life Decrease value of existing houses There are covenants on the land preventing it from being built upon. Would result in coalescence between towns and reduce the 'green' gaps between

separate recognisable areas. ruin the countryside feel Strategy has ignored the 2009 consultation. Residents of Panshanger have been

ignored, while Welham Green, Brookmans Park and Cuffley all have had allocation of land for housing removed from the Strategy.

No response was received to 2009 consultation and none of these objections have been taken into account in this consultation. 2011 consultation was not publicised sufficiently.

Minerals - Site is in mineral belt and minerals would need to be extracted before development. This site is not suitable for a quarry as is too small.

Poor ground conditions in the area for building – potential for damage to occur to

existing homes. Number of homes is too small to create critical mass to support services etc Number of homes proposed is too high Conflicts with vision to protect areas of high environmental quality and raise

quality of life. Have all the potential uses of this land (BLG1) been considered? Does it have to

be housing. You mention schools, playing fields, shops, but what about turning the airfield into a private airport, surely this would generate an economy. Any of these options would be preferable to housing.

Loss of airfield is not necessary. There is no need to build new housing in the borough.

Proposed housing density is excessive. Development of proposed site in Panshanger to the north-east of Welwyn Garden

City (CS15) conflicts with Core Strategy Policies CS1, CS6, CS9, CS11 and CS12.

Core Strategy conflicts with the council’s vision to protect areas of high environmental value and to raise (maintain) the quality of life for existing residents.

Part 3: Structural landscaping area minimise visual impact and long distance views across the Mimram valley. Wildlife. Leisure.

Comments by individuals and other bodies Concern regarding over extraction and pollution of River Mimram. Proposed structural landscaping will obscure view of the Mimram valley for

Panshanger residents, whilst screening Tewin residents from the new development

Development will lead to the loss of wildlife and woodland decay Negative ecological impacts including increased water runoff to the Mimram which

has a delicate ecosystem and is a rare chalk stream. Runoff will introduce pollutants into the Mimram and the water table. It will cause Hertford to flood more often.

Site close to a Site of Special Scientific Interest at Tewinbury which will be threatened by this development.

Screen for the development (e.g. from the Mimram Valley) would be inadequate. It cannot work on the northern edge because the land falls away and the houses will be above the skyline and dominate the valley.

Loss of views. Loss of enjoyment of countryside (walking, cycling etc). Flood prevention methods have not been planned or budgeted for. Plan to save view from Tewin and from the railway but not from WGC Landscaping to the north of the housing site would have no benefit for existing

residents of Panshanger. Public footpaths are used extensively by walkers, cyclists etc. An area of Archaeological Significance could be adversely affected. Loss of environment and habitats. Proximity to SSSIs at Brookmans Park and Cuffley a disadvantage but not at

Panshanger. Will lead to development in the Mimram Valley. Landscape assessment carried out in-house, rather than by specialist

independent consultants. The land contributes to the surrounding Landscaping. What is structural landscaping? There is no definition Does this mean that Tewin is protected by a treeline from years of gravel

extraction and building, and Panshanger residents living yards away will not? A lot of residents enjoy having the views and the occasional light aircraft. Tewinbury SSSI is within 450m of the site, but this is not listed as a disadvantage

but the proximity of SSSIs to sites considered in Cuffley and Brookmans Park, much further away, is identified as a disadvantage – this is double standards

Part 4: Green infrastructure – open space, sports facilities, allotments, play areas, green chains.

Comments by individuals and other bodies The green space is a highly valued asset by existing residents; loss of such an

asset will reduce the quality of life within the community. Green infrastructure cannot be provided in the site, if it is used for 700 dwellings

there will be no space. Adequate green infrastructure exists nearby (e.g. Moneyhole playing fields).

Providing the proposed new green infrastructure within the development site would mean that the actual housing areas would have to be at higher density.

Lack of sports and community facilities to meet the needs of current residents, teenagers in particular.

Part 5: Traffic impacts on road network and environment, access, parking, improvements or alterations to road junctions and network.

Comments by individuals and other bodies Increase in traffic

Specifically traffic pressure on Panshanger Lane and the surrounding link roads into Hertford and Welwyn

B1000 A414 Would become a cut through between A414 and B1000

Development will bring increased pollution (increase in Co2 emissions) Increase in noise and other disruptions Not possible to increase capacity of existing roads Increase in accidents Proposed access to the new houses along Bericot way is not adequate for

carrying up to an additional 1400 cars. Access should be provided through Herns Lane.

Car parking at the local shopping centres is already at capacity Car parking poor, problems with visitor car parking. Road layout changes poor Concern over the length of time it may take to adopt roads in the new

development.

Part 6: Local and strategic infrastructure – General

Comments by individuals and other bodies Infrastructure in area is already at capacity. Sewage treatment is at full capacity and parts of the Rye Meads site and

surrounding area are designated as areas of acknowledged wildlife importance which restrict capacity for expansion.

Water – we are abstracting more water than nature is providing and our water table is slowly subsiding.

Inadequate healthcare capacity. Inadequate hospital capacity and access / emergency services. Doctors cannot cope with existing demand. Significant spending on infrastructure would be required to serve the new

development and the funding is not available. Inadequate capacity of utilities (gas, electricity etc). Panshanger is not well served via broadband. Stress on the land drainage with unpredictable heavy rainfall in future. No mention of strain on local recycling centre. Roads are in poor condition in this area already.

Inadequate facilities for children and young people. No thought has been given to the provision of infrastructure for this new

development. There is no funding for upgrades to infrastructure.

Part 6a: Local and strategic infrastructure – Primary and secondary education

Comments by individuals and other bodies Existing primary and secondary schools are already close to or at capacity. How

will provision be made for Primary and secondary education when no space has been allocated as part of the proposal to build a new school? Springmead is already accommodating children in portacabins due to capacity issues.

Requirement for new secondary school is ironic given that Heronswood, Howard, Mater Dei and St Josephs have all been closed.

Part 6b: Local and strategic infrastructure – Small convenience shop

John Lewis Partnership Would not be supportive of any major retail development as part of this

development, other than a local convenience shop.

Comments by individuals and other bodies Local shops and services are already at capacity, new development will put

immense strain on existing services. A sole corner shop will be insufficient.

Part 6c: Local and strategic infrastructure – Walking, cycling and public transport, public transport links, walking and cycling links to Panshanger Park

Welwyn Hatfield Cycle Forum Cycle routes must be constructed at the same time as new housing. All new flats

and houses must have access to secure cycle parking. Map page 108 shows more cycle/walking routes than currently exist. Map should

clearly show existing and planned route

Comments by individuals and other bodies Panshanger is poorly served by public transport. Public transport is also already working to maximum capacity. Trains into London are already overcrowded. Car parking at the station will not cope. Access to station is poor with walkway over to Broadwater Road.

Part 7: Gypsy and Traveller accommodation

Nathaniel Lichfield and Partners (for Mariposa) The provision of 15 pitches is not clear in terms of type of provision, their

management and delivery. Further consideration should be given in terms of type and design of provision, location and delivery to conclude whether Panshanger is best placed to contribute towards meeting need.

Comments by individuals and other bodies A Gypsy and Traveller site alongside a housing estate is undesirable. It would

have a significant impact on the existing community and on the new housing. The area is too small to accommodate 15 pitches. The Gypsy and Traveller community would prefer a more rural site. There has not been enough thought given to how this proposal would work.

Expand existing Gypsy and Traveller sites.

Part 8: Design, layout, public realm

Comments by individuals and other bodies Not in keeping with the Garden City ethos. Concern new development will not respect the design, character and identity of

Panshanger. No information on access, layout, design Density would be out of keeping with existing area. Development will change the character of Welwyn Garden City

Part 9: Affordable housing. Housing size, type and tenure

Nathaniel Lichfield and Partners (for Mariposa) Not appropriate to set a lower target of 30% given duration of delivery when

market conditions could change significantly. Should be subject to market conditions and development viability.

Comments by individuals and other bodies Developers no longer have to provide as much affordable housing. How will 35%

be guaranteed? New homes unlikely to be affordable to the local population No affordable housing will be provided More information needed on the size and mix of housing

Other - Jobs

Comments by individuals and other bodies Inadequate number of local jobs / problems with the economy – would result in

more commuters attracted to site.

Other / Miscellaneous

Comments by individuals and other bodies The housing immediately next to this land has a blanket ban of 'No permitted right

of development'. It is understood that ground conditions are very poor for building on, existing foundations were far in excess of 'the norm' and further development will surely have a negative impact on the safety of existing dwellings. Have these impacts been taken into account of potential building costs or damage to neighbouring housing?

Assuming building will go ahead regardless there needs to be a substantial 'gap' between current and new homes. Current residents could have the option to purchase such a strip of land.

Access should be via Bericot Way (not via Westcott, Chedburgh or Chelveston).

Paragraph 15.29

Hertfordshire County Council The comment that the ASR release at Panshanger would generate 1 FE of

primary need in isolation is unhelpful given the additional and more significant levels of growth envisaged for the immediate area. Previous evidence has been provided to WHBC that make clear the preferred delivery model of 2FE schools that are more robust educationally. If phasing did indicate that 1FE only is required at any one time HCC advice is that this should be provided but on a school site capable of being expanded to 2 or even possibly a 3 FE model.

Comments by individuals and other bodies Panshanger schools are already full and a new primary school would have to be

built. A new secondary school (or two) would be more likely to be built in West

Hatfield to cope with the Hatfield airfield development which is too far for Panshanger children to travel to and will cause more road congestion and CO2 emissions.

Paragraph 15.31

Comments by individuals and other bodies A statue of an aeroplane does not replace an active airfield and even if the

amenities in Panshanger are improved, the airfield site is still too far from the town centre and train station.



AECOM (for the Royal Veterinary College) Generally support this allocation subject to adequate access to facilities and

services within the site given the distance from WGC and the cumulative effects of development here plus land in East Herts need to be fully understood.

Herts and Middlesex Wildlife Trust Policy CS15 point 6 fully supports projects to create and improve sustainable links

to Panshanger Park to encourage residents to explore the countryside and key wildlife areas like Panshanger Park.

Welcome Policy CS15 point 2 to ensure best practice in sustainable design, but should make clear that this must be comprehensive not just relating to fabric and form of buildings. Significant new development especially in Green Belt or green field land must keep adverse ecological impacts to a minimum.

Welcome CS15 Point 3 and support in principle a GI/habitat project as a way of delivering a significant net gain for biodiversity. Scheme should be suitable to local conditions and context important council works with other authorities HMWT and Local Nature Partnership to ensure consistency with strategic GI and Living Landscape Plans.

Any development of this scale should deliver a substantial biodiversity gain.

Hertfordshire County Council The fact that BLG1 will be master planned through the progression of an AAP is

supported and welcomed and HCC would wish to participate in this process given the wider implications on HCC services.

Support policy regarding primary and secondary education.

Nathaniel Lichfield and Partners (for Mariposa) Supports identification of this broad location for growth. Will constitute a

sustainable location for housing development to meet the needs of the borough and WGC. Clearly, existing housing was designed with more housing in mind.

Homes and Communities Agency Has land ownership in this area and welcomes the identification of this location for

residential development


Support the proposal for housing on this site as the noise and disturbance from the airfield has a negative impact on the surrounding area.

The airfield in its current state is a possible danger to residents.

This is a far-sighted and important strategy for the development of our local area that will create additional housing opportunities for those of us who do not currently own our own homes and would very much like to. The lack of affordable housing in this area is undoubtedly a result of excessively restrictive historic planning regulations, driven by an implacable and vocal minority of residents who put their self interest ahead of those of us who aspire to own a home of our own. We need to prepare our town for the future and this proposal represents a sensible strategy to provide work and accommodation opportunities for a growing population. The alternative to embracing this is that Welwyn Hatfield ossifies and declines.


CHANGES Number of comments

Herts CC Landscape Officer Reference needed in bullet point 4 to Project 5 in the Strategic Green

Infrastructure Plan for Hertfordshire “Mimram Valley Greenspace”. Under 4th bullet point add “trees” before “open spaces and public realm”

Various, including Robin Bretherick (for Mr and Mrs Ferry), General Aviation Awareness Council and Light Aircraft Association

Remove Panshanger as a housing site.

Strutt and Parker (for Trustees of Brocket Estate and Barratt Strategic) As an alternative to development here, should consider growth at Stanborough

as an extension to WGC.

Hertfordshire County Council Add “10. Make provision for supported accommodation in line with needs

identified by Hertfordshire County Council”

Comments by individuals and other bodies Use sites closer to Welwyn Garden City town centre making it more vibrant. Allocate smaller sites with the existing or at the edge of the urban fringe of

Welwyn Garden City, to provide Welwyn Garden City with a flexible housing supply

Designate the airfield as a community asset. Reduce housing target for Welwyn Garden City. Uplift in land value from developing this land should be retained by the

community of Welwyn Hatfield. Development should be based on the Garden City principles, with housing,

industry and agricultural land provided. Exploit the brownfield / in fill opportunities that exist inside the main

towns/population centres. There are many of these that do not appear in the plan or have been ignored

Spread housing provision requirements more evenly across the borough. This provides more sustainable development. Explain what happened to the other sites considered at issues and options stage. Explain why other SHLAA sites have been discounted.

Building should take place preferably in the larger southern villages of Brookmans Park, Cuffley and Welham Green as recommended in the Sustainability Appraisal. Welham Green and Cuffley have better transport links.

Amend proposals to retain the airfield. Consultation with the local community. Review proposal to take account of issues on water, sewage and drainage. Reduce the size of the development. Convert unused office spaces to residential.

Heritage centre / museum built at the aerodrome to recognise its past. Remove Gypsy & Traveller pitches as part of the proposal Ensure that Broadband speed is considered Give land to the community. Use empty field rather than displace an active use. Use other sites instead. Suggestions include:

Brownfield site at Broadwater Road, Welwyn Garden City. Suggest the fields adjacent to A414 on the south side of town – Council

could create a new community in this area which could expand its services as the population grows.

Suitable sites just outside the boundary by A414/B195. WGC1 – better local road network. WGC5 – large open area with excellent road networks. Eddington Crescent – adj to Chequersfield. Area to west/south Chequersfield. Area to south of WGC/Mill Green. Area between Digswell and Welwyn village. Use Warrengate farm land southeast of Tewin which has been sold for

that purpose


Section 16 Hatfield

Consultation Point – Vision and Objectives for Hatfield


Herts and Middlesex Wildlife Trust Pleased to see that Ellenbrook Country Park is included within the vision for

Hatfield. The old Hatfield Aerodrome site (now Ellenbrook Fields), part of which has been allocated as Safeguarded Land in this document (recognised in the report ‘Land for Housing Outside Urban Areas' as Hat2 West of Hatfield), is known as a good site for rare and protected bird species. The area is valued by members of the local community as well as enthusiasts from further afield in Hertfordshire as a great resource for wildlife and recreation. The Council should work through its local plan to ensure that this site is managed, enhanced and maintained in the long term for its wildlife and recreation interest. Allocation as Safeguarded Land seems inappropriate and inconsistent with past land use and planning decisions taken by the council, and the ramifications of this allocation should be given strong consideration.

Herts Biological Records Centre Hatfield Key diagram does not show important wetlands to the north (i.e.

Stanborough) or smaller green spaces within the urban area. Some definition of these areas or a more comprehensive depiction may be required.



Comments by individuals and other bodies Paragraph 16.2 which opens with the words ‘By 2029 a more positive image of

Hatfield…’ does nothing to counteract the view of many Hatfield residents that it is being thoroughly neglected. To propose that it will take another 16 years before anything really worthwhile will be done is absolutely unacceptable.

All developments within Hatfield, as for WGC, should be based on Garden City principles and this must be made explicit within any plan proposed by the authority.

In addition to the Neighbourhood shopping centres of High View and Old Hatfield the smaller centres, such as that to the west of the A1M including Parkhouse Court, should be examined to determine how they can be improved. The minor shopping locations, Birchwood, Hatfield Garden Village, St Albans Road East and Harpsfield Broadway Parade could all be improved at relatively little cost.

Many of the issues identified in the WGC section apply equally to Hatfield e.g. the issue of verge damage, insufficient rigour over enforcing adherence to planning consents and streetscene maintenance.



University of Hertfordshire The University is supportive of the local objectives for Hatfield (HAT1-5). These

are important in recognising the specific needs of Hatfield; particularly the upgrades to Hatfield train station (HAT2) and maximizing the benefits of the university whilst balancing accommodation needs of students with the needs of the wider community.

Comments by individuals and other bodies The Hat 1 - 5 objectives are sound and will help to regenerate the town centre. We support all the objectives outlined in Paragraph 16.3 as we have ever since

the initial redevelopment collapsed. While the first stage of the redevelopment will commence later this year efforts need to be redoubled to bring forward further phases. If the economic situation continues to make it impossible to proceed due to the unwillingness of retailer to commit effort needs to be directed to bring about completion of HAT 2 to HAT5.



Herts and Middlesex Wildlife Trust In relation to Ellenbrook Fields, the council should work through its local plan to

ensure that this site is managed, enhanced and maintained in the long term for its wildlife and recreation interest.

English Heritage

While we recognise the important regeneration work that is required in the town, the positive contribution of Hatfield House and its historic park should be acknowledged as a key asset in this section, including in the vision, and objectives (HAT5). The NPPF recommends a positive strategy for the historic environment and we hope that the plan can address the key assets of the settlement that contribute to its quality and local economy.

Comments by individuals and other bodies Hatfield has no clear town centre - a series of different areas offer shopping.

Transport links between these need to be improved, especially the corridor between the town centre and the galleria.

The identification of the Objectives is the same as those used to identify potential development sites on maps creating potential for confusion. Suggest adding TC-HAT1.


Section 16.2 Hatfield Town Centre

Consultation Point CS16 Hatfield Town Centre


Comments by individuals and other bodies Could services other than retail be encouraged to come into the town centre e.g.

osteopaths, solicitors, dentists; community groups or an extension to the Library, particularly IT facilities and study space, to replace facilities lost from New Barnfield.

Obvious facilities are needed for Hatfield such as local shops and a number of ‘anchor’ stores and services. Beyond that, there is a case for looking at building up a number of small specialist shops and services. Propose the council takes ownership of a number of small premised with a view to offering a sort of retail Weltech Centre.

Need for transport links between the town centre, University, West Neighbourhood Centre, The Galleria and the railway station

The aspirations for the town centre are generally admirable, what is need now is implementation of as many of them as can be afforded in the short-term with others specified and picked up immediately further council funds become available.



CGMS A more specific time scale should be referred to within the paragraph 6.14 where

it is proposed to review the strategy for the town centre if viability issues continue to impinge delivery. This would add certainty to deliver.

Concern at the inclusion of point 4 of the list of items that an Area Action Plan for the town centre would cover. The Galleria's present role in the Borough's defined retail hierarchy is that it pretends that it does not exist. The retail hierarchy should acknowledge now that the Galleria exists and that it performs as Hatfield's main durable goods and leisure centre as well as a sub-regional outlets destination. Hatfield town centre provides the town's main convenience shopping offer. This relationship is unlikely to change in the future even if the town centre shrinks in order to become more viable and vital.

Comments by individuals and other bodies Hatfield has been deteriorating in shopping mix and quality for many years. A

radical approach would be needed to develop it and even then the centres of Welwyn Garden City and St Albans would still be more attractive. Thought should be given to reverting to the original layout of the town and the provision of housing on land released.

Not enough money, time, interest or effort is going into the re-development of the town centre.

The regeneration planned is not nearly enough, especially when so much housing expansion is being considered.

Given the role of the Galleria and Oldings Corner the town centre is too large and needs to be reduced in size and the fringes developed e.g. for social housing or student halls of residence.

Document hints at plans to do away with Hatfield town centre. There needs to be more consideration of what might create a vibrant town centre in Hatfield even in times when retail is not flourishing.

Hatfield needs a website to publicise retail and other facilities available in Hatfield.



Home and Communities Agency Supports CS16. HCA will continue to work with its development partners to

pursue the regeneration of the eastern end of the town centre.

Natural England Welcomes the reference to enhancing the quality of the environment, open

spaces and public realm and the improvement of movement and access by giving priority to cyclists and public transport.

Strutt and Parker (for Mrs C Horton) This policy is supported and it is considered that the proposed increase in

population from the additional housing growth will support the regeneration of the town centre. Funding from new housing development will also support regeneration initiatives for the town centre. With specific relation to our client's site to the south of South Way, it is considered that provision of a residential lead development in this location will be particularly important in supporting the town centre of Hatfield. The proposed preferred growth locations to the west of the A1 (M) are in close proximity to St Albans. It is likely that a high number of residents

from the growth areas to the west of the A1 (M) will use St Albans as their local centre, rather than Hatfield. Our client's land being located to the east of the A1 (M) is more likely to support Hatfield town centre, due to the additional distance from St Albans.

CGMS Support improved links between the Galleria and the town centre.

Comments by individuals and other bodies The local community has been waiting years for a new town centre. A thriving town centre linking Old Hatfield, the Galleria, Oldings Corner, Hilltop,

the Business Park and UH is what the district needs. The shops in the town centre need to face outward not inward to attract those

that drive by. Parking should be kept free. The regeneration of the town centre is clearly vital.



CGMS Item 4 of para 16.14 should be deleted.

Comments by individuals and other bodies Would like to see reference to how Hatfield Town Centre is to be made more

attractive to business. Hatfield is desperate for a decent town centre but phase 1 of the town centre development is unlikely to turn the town centre into an inviting place to shop, work and live. Plans for a healthy and prosperous centre need to be addressed and implemented before town expansion is contemplated.

Traffic should be kept flowing. Works on Wellfield Road are dangerous and disrupt the traffic flow. This road

could and should have been made wider. Reduce bus fares to encourage more use of public transport Think bigger and invest more money in Hatfield. CS16 needs to be given the highest priority if Hatfield is to be expanded

successfully as is envisaged. By any standard, not least by comparison with WGC, the town centre is a depressed area and blights the whole of the town.

Build new shops with more choice.

Total No. of suggested CHANGES 8

Section 16: Hatfield

Consultation Point: CS17 – University of Hertfordshire (and relevant parts of Section 16)


Comments by individuals and other bodies Caution should be exercised to ensure that ordinary Hatfield residents take

priority over what is delivered. It is in the University’s interest for rent prices to stay low in Hatfield. Reduction in demand for accommodation off campus is likely to occur once

redevelopment of university halls is completed. This is an opportunity to reverse progress of HMOs and less scrupulous property speculators.

The development of closer links between the University and all aspects of life of the Borough must be encouraged. This will benefit all parties and requires some consideration by the council.



Hatfield Town Council

Student accommodation should be concentrated only on campusTurnberry (for University of Hertfordshire)

Supports the principle of this policy. However, it is felt that the first key principle of the policy overlooks the status of the University of Hertfordshire's 2020 Estates Vision which received formal Council endorsement on 261 h April 2012 and has emerged in response to the issues identified under the first principle


WHBC is proposing to promote university’s interests over that of local residents and businesses. There should be a policy of reducing links and the influence of the University until they show genuine community partnership.



Roehyde Consortium (Cemex and A1M Securities)

support to the approach to maximise the economic development and community benefits associated with the University. Roehyde Consortium supports the proposals for enhancement of the University's facilities and supports any future proposals for development by the University at Roehyde, Hatfield (the junction of the A1(M) and A414).

1



Turnberry (for University of Hertfordshire)

First key principle overlooks the status of the university’s 2020 Estates Vision, which was endorsed by the council. Accordingly, the first principle should be modified to read:“future major development to be brought forward in accordance with the 2020 Estates Vision or other such masterplan which satisfactorily address the impact on the surrounding area in terms of traffic, noise, pollution, car parking and visual appearance'.

The supporting text to this policy contained within paragraphs 16.24-16.26 is also outdated and needs substantially revised. This requires a rewording of paragraph 16.25 and the deletion of the key principles and paragraph 16.26:"Changes taking place within higher education and the wider economy mean that theuniversity has developed a new masterplan. referred to as the 2020 Estates Vision. The council approved the underlying principles in December 2011 and on the 261h April 201, the Vision was formally recognised as a material consideration in the determination of future planning applications."


Third bullet point needs amending to remove the words "wherever possible”. 1

Roehyde Consortium (Cemex and A1M Securities This policy should allow expansion onto Roehyde in terms of employment

opportunities and for its own uses. The University has had to expand onto sites well beyond walking distance when a pedestrian/cycle underpass connects Roehyde with the University where a ‘science type' employment park could be built

1

Comments by individuals and other bodies Carry out an independent investigation into the impact of the University of

Hertfordshire on Hatfield. Actively seek to curtail its influence in the borough until they show they are

genuinely partners with the community (for example restoring full public access to Angerland Common).

1


Section 16

Consultation Point CS18


Welwyn Hatfield BC Environmental Health

It is noted that BLG2 appears to be in close proximity to the A1M. Long term air quality monitoring will be necessary in advance of any development decision to ensure that the future inhabitants of the area are not adversely affected by poor air quality.

The Public Health and Protection Service will continue to liaise with the Planning Department on these matters.

Natural England

Natural England notes that the policy CS18 may support Biodiversity Action Plan (BAP) habitats. Whilst Natural England does not object to this Broad Location for development, we believe that the Core Strategy should recognise the multi-functional value of this area of green infrastructure and require that any proposal should demonstrate that it will not have an adverse effect on biodiversity, green infrastructure and landscape and will seek to retain and enhance these interests as far as possible.

Welwyn Hatfield Cycle Forum

Cycle routes must be constructed and completed in advance of or at worst at the same time as new housing.

This has not happened so far. For example, there is still no off road cycle path from Hatfield Garden Village or de Havilland Village to the railway station. The routes end at the edge of the town centre and then leave the cyclist to fend for themselves.

All new flats and houses without garages must have access to secure cycle

parking for one bike per member of the household, not one bike per property.

We are disappointed that the maps in the Emerging Core Strategy on pages 108 (WGC) and 120 (Hatfield) appear to show far more cycling and walking routes than currently exist. These maps should clearly show separately what exists for cycling and walking now, what is planned and the intended completion dates.

Hertfordshire Biological Records Centre (HBRC)

Hatfield BLG2 is largely open arable but may support some local bird interest. It is not yet clear whether this is focused around BLG2 or the Safeguarded land on the former airfield site itself. In any event the interest is likely to have exploited the current longer grassland which itself may not be a permanent feature of the site.

Consequently whilst this is not considered to be a fundamental constraint, any interest affected should be recognised and properly considered in any development proposal and compensation measures proposed as appropriate. In any event, the creation of new GI is to be supported.


The impacts of development of this site should be given strong consideration by the council relative to development need in the area, and the allocation should be subject to a comprehensive assessment of alternative sites.

If it is concluded that this site is the most appropriate available site for development, and that the impacts are acceptable to the council in policy terms, then the council should ensure that sufficient steps are taken to minimise ecological impact in the first instance, mitigate for adverse impact, and compensate for residual effects.

Any development of this scale should deliver a substantial biodiversity gain, through habitat enhancement and creation within the development and in the surrounding area

HMWT would welcome production of a draft Area Action Plan for this site, which must address ecological issues and opportunities as well as the Green Belt and urban separation issues.

Objective 2 (new green infrastructure) is generally welcomed. However, it must be ensured that any strategic landscape zone functions to increase ecological connectivity, habitat quality and biodiversity, as well as acting as a visual buffer. Objective 3 (sustainable design and construction) is welcome.

It should be made clear that this must be a comprehensive, holistic interpretation of sustainable design, and cannot simply relate to the fabric and form of buildings themselves.

English Heritage

The Land for Housing document refers to a number of heritage constraints which we note have been considered in assessing the capacity of this site. It would be appropriate to reflect the need to accommodate these constraints in policy CS18.


All new development in Hatfield should also be based on garden city principles 2,000 new homes is the maximum capacity


OBJECTIONS raised on the following grounds

Infrastructure

St Albans City and District Council

Having considered the assessment of this site contained in Land for Housing Outside Urban Areas document, the Area Action Plan for delivering this site should ensure that mechanisms are put in place to address the identified infrastructure issues, in particular the impacts on and the need for transport and school infrastructure.

Development in this location will have an affect on the transport infrastructure not only on the A1(M) but on roads in St Albans. Currently routes to and from Junction 4 of the A1(M) extending towards St Albans are already congested at rush hour times. This junction provides the main access to the A1(M) for Harpenden, Redbourn and Wheathampstead. Further development close to this A1(M) junction would exacerbate existing traffic issues.

Green Lanes Primary School

Already the school has undergone vast changes in the last 10 years as additional housing adjoining the school increased our pupil numbers.

We are currently oversubscribed and have had already 196 applications for 60 places.

The school feels that at this point it would be unable to expand to meet rising pupil numbers at its current site.

Comments by individuals and other bodies The area lacks the infrastructure to support 2,000 new homes

There is no guarantee that the necessary infrastructure will be provided for the new development

Existing road network is already at capacity and will not cope with further housing development

None of the infrastructure paid for by the developers of Hatfield garden Village has been realised

Extra traffic will increase risk of accidents, particularly around Green Lanes school.

The traffic impact on the local road network should be considered, including junctions 4 & 5 of the A(1M)

Limited capacity of the train service from Hatfield station to accommodate more commuters

Existing police resources will be inadequate to cope with increased population

Development is located too far from Hatfield train station

The cost of upgrading Hatfield train station will increase train fares.

Inadequate capacity of emergency services

Existing bus service is inadequate

There is a lack of community facilities, leisure, and shops in the area

Already existing infrastructure problems. Concern that infrastructure for additional housing would also be inadequate.

Insufficient secondary school places

Insufficient primary school places

Lack of health services – doctors, dentists, hospitals

QEII hospital –facilities have been reduced and will not have the capacity for additional patients from new housing

Lister Hospital, Stevenage is at capacity

Existing Council provided facilities e.g. street lighting, gritting are at capacity

Concerned that the High Court rejected the proposal for 10,000 new homes in the Borough, due to lack of infrastructure, yet ECS is recommending almost the same number

Infrastructure promises are never delivered

Environment

AECOM (for the Royal Veterinary College) - Loss of high quality agricultural land, contrary to policy CS11, has not been given appropriate weight. Coalescence between Hatfield and Stanborough contrary to the council’s strategic objective. Sustainability Appraisal highlights the negative impacts of development on this site.

Comments by individuals and other bodies Concern about increase in noise and pollution close to children’s playground at

Green Lanes School. Loss of open green fields and countryside Loss of recreational space Adverse impact on wildlife Increase in noise Agricultural land should be protected from development – needed for food

production Development would destroy some of the best agricultural land in Hertfordshire Increase in litter, which is already a problem in the area, exacerbated by fast food

outlets in the Galleria Development will reduce natural drainage and increase the risk of flooding Some areas described as “low risk” have recently flooded Development will increase the level of light pollution Development will lead to deterioration in air quality, due to extra traffic Loss of footpaths and bridleways The impact of the proposed development on hedgerows needs to be assessed; a

number of mature hedgerows will be affected which will impact on wildlife Development will increase the carbon footprint There are not enough playgrounds in this area for children

Green Belt

St Albans City and District Council

Para 83 of the NPPF states that authorities should consider Green Belt boundaries having regard to their intended permanence in the long term, so that they should be capable of enduring beyond the plan period.

The site boundary presented on the Key Diagram and in the Land for Housing Outside Urban Areas document does not provide for a boundary which will endure beyond the plan period.

This is primarily because the boundary does not meet the requirements set out in paragraph 85 of the NPPF. It is considered that green buffers will need to be implemented to the western and northern edge of the site to prevent development pressure beyond the boundaries defined.

Hatfield Town Council Oppose the coalescence of Lemsford with Hatfield. Hatfield needs as much

Green Belt as any other town.

Hertfordshire Gardens Trust The use of Green Belt land for housing as in policies CS15 and CS18 is

unacceptable. Further development between the settlements of Hatfield, WGC and surrounding villages will blur their distinctive identities and lead to further urbanisation.

Moult Walker Chartered Surveyors (Duncan Murdoch) for Bayard Developments Substantial buffers required to the A1(M) and to the north (owing to recognised

concerns about coalescence);


Loss of green belt land is unacceptable

The Government promised that the green belt would be protected under the new NPPF

Brownfield land should be developed first, before the release of green belt

NPPF states that Travellers’ sites are inappropriate in the green belt

Coalescence – the natural green division between WGC and Hatfield will be lost

The development will create a precedent which will lead to further erosion of the green belt

The development will lead to urban sprawl

Development on green belt is an easy option for developers

Questions why the green belt around Hatfield Garden Village is being treated differently from other villages in the Borough, in terms of criteria used for the selection of green belt sites for housing

Housing

Comments by individuals and other bodies Hatfield Garden Village has already accommodated additional housing

development and so should not be expanded further

The scale of the housing development proposed is too large

Development will lead to a loss in the value of houses

There is already sufficient housing available in the area

Priority should be given to the re-use of empty homes before new building

Vacant commercial space should be used for housing

Housing in Hatfield is already affordable

The proportion of affordable housing proposed is too high

Additional housing is needed St Albans, WGC, Hertford and Potters Bar which are less affordable than Hatfield and where there is more demand

The properties will be sold to social landlords and to investment buyers to be let out to students

The provision of social housing & student housing/HMOs will both take more out of the Borough’s resources than the put in

Hatfield will become a town of mass built housing

The development of student accommodation on campus will free up houses in Hatfield, currently rented out to students, so extra housing will not be necessary

Questions the reliability of evidence provided to support the need for this high number of additional dwellings

Council’s housing needs assessment does not accord with the Government’s projections

CPRE report states that the Government’s data used to calculate future housing requirements is out of date, and contains immigration anomalies

Hatfield is already large enough

Need to ensure that it is local families have access to the new housing

Challenge the view that 2000 dwellings and a Travellers site are actually required

Gypsy and Traveller Site

Comments by individuals and other bodies Objection to a Gypsy and Travellers site

A Traveller site in this location is not supported by residents or members of the Travelling community

There is already a Gypsy and Travellers site nearby

The area is not suitable for a G&T site; an isolated, more rural site may be more appropriate

Gypsies and Travellers require special provision

Questions the need for provision for Gypsies and Travellers

There are sufficient G&T sites; priority should be for housing for other sections of the community

The views of the G&T community, who may not want to live in this area, should be taken into account.

Recent survey of Travellers stated that they would rather have existing sites extended than new sites

Gypsies and Travellers are hardly ever seen in the area so building a new site makes no sense

Economy

Comments by individuals and other bodies Housing development will lead to an increase in unemployment in the area, as

there are insufficient jobs available.

Not enough jobs in Hatfield

Hatfield Business Park is still not fully developed due to lack of demand and the

poor economic outlook will not deliver the jobs needed for the new houses.

Building new homes will not boost the economy

Need to encourage growth in regions other than the south-east

Hatfield Town Centre is inadequate to serve the existing population and the priority should be its regeneration, before any new housing development.

Questions the need for a new neighbourhood centre when Hatfield town centre needs regenerating.

Hatfield Town Centre regeneration has not taken place, 10 years after the original Garden Village expansion

ASDA in Hatfield is under utilised and Hatfield Town Centre is by-passed in favour of WGC.

Community/Quality of Life


Loss of school community which has already undergone huge changes both in size and rapid building expansion.

Loss of village status, identity and character Development will change the character from a family neighbourhood to one of

students and commuters Concern that development in the green belt will not only destroy existing village

community but will also create an unsatisfactory quality of development for the new residents

Families have left the Hatfield area due to lack of community services, facilities and amenities and safety concerns; new housing development will exacerbate this

Both Hatfield Garden Village and Salisbury Village consist of sprawling housing development, lacking a focus point and facilities

The development will lead to an increase in crime and anti-social behaviour Development will adversely affect the quality of life of existing residents Years of building work will create on going health hazards Number of HGVs currently using local roads, is unacceptable; weight restrictions

are not enforced Concern regarding the 33kv substation – e.g. noise A G&T site will not raise the quality of life There are serious implications for community segregation New housing so close to the A1 will have an adverse impact on the quality of

living for those in the new housing due to the impact of background noise.

Deliverability of site

Metropolis PD

BLGs 1 and 2 will be insufficient to meet the needs of Welwyn Hatfield. Their adoption alone, without other appropriate growth points elsewhere will be unsustainable and will put undue strain on those areas.

Because they are complex sites to deliver housing delivery will be “backloaded” and the authority will be exposed in the short term. The allocation of housing sites should be informed by a comprehensive Green Belt review of the whole borough.

If not, the BLGs should be deleted as the overall strategy will be unsound in

failing to meet the requirement for a five year supply of housing land (NPPF para 47).

Maddox (for Goodman) The council has failed to take account of evidence previously submitted. Should

not rely upon 25% of its housing delivery from one (this) site in varying ownership. Instead, should replace with land west of Hatfield (CS19) which is in single ownership. (See also comments on CS19).

Core Strategy has not demonstrated why Hat1 is the most appropriate site in relation to transport and the reasonable alternative at Hat1.

Miscellaneous


Given the above concerns (relating to infrastructure and the setting of permanent Green Belt boundaries - see relevant sections) and the absence of a comprehensive Green Belt boundary review and associated work, this council therefore has significant concerns about this allocation.

AWD Perkins Some merit in identifying the land west of Green Lanes as an extension to

Hatfield Garden Village but no justification (or merit) for development on land east of Green Lanes.

It is inconceivable that there are no better sites. High car dependency, access from the A1(M), access to town centres and railway stations will be slow by public transport. Highly visible site from the A1(M). Part of the site has AAS status and there is a Grade II listed building.

Moult Walker Chartered Surveyors (Duncan Murdoch) for Bayard Developments –

Bayard Developments object to the defined amount of growth proposed by this policy. Having regard to the constraints imposed by the location, the proposed 2000 dwellings is considered too high unless this can be properly shown from a comprehensive masterplanning exercise.

Given the masterplanning exercise has not yet been considered, it is considered premature to allocate such a defined number to this site.

Strutt and Parker (for Mrs C Horton)

Objection is raised to this policy on the basis that it is not considered to be the most appropriate location for the focus of growth in Hatfield.

Strutt and Parker (for Trustees of Brocket Estate and Barratt Strategic)

Not the most appropriate location for growth in Hatfield. Would result in coalescence between Hatfield and Stanborough / WGC unless housing number reduced. Number of houses here should be reduced to ease strain on infrastructure.


Hatfield has seen massive development in the last decade, it would be good to have a period of stability prior to creating another large community again. Under no circumstance will Hatfield bear any more housing than the 2,000, if the Panshanger option is not adopted another housing area will have to be found in Welwyn Garden City.


Hatfield has already seen significant development in recent years

The amount of development proposed is disproportionate, in relation to size of Hatfield Garden Village

Hatfield has already become place that people don’t want to live in

Plans are vague and lacking in detail

Questions whether the proposed housing development was previously considered and rejected at the time that the other additional housing in Hatfield Garden Village was approved?

Hatfield has already been subjected to the proposed incinerator development, which is unwanted.

Hatfield has become the dumping ground of Hertfordshire

Preferred Options 4 and 6 presented to CHPP on 27/09/12 should have been highlighted for public consultation

Public Opinion/Previous Consultation

Comments by individuals and other bodies Serious concerns that public opinion is being ignored

The Council are not representing their constituents – they are following party political lines.

Concern that Hatfield is seen as an easy option for the location of new housing development, due to the high numbers of students who do not vote in the area and a low turnout in elections

Why do councillors continually select Hatfield for expansion? Share the pain across the borough

Council should acknowledge that 800 names on a petition represents 80% of the village objecting to the Emerging Core Strategy.



Turnberry (for CEMEX and Gascoyne Cecil Estates) CEMEX and Gascoyne Cecil Estates are joint owners of the 129 hectare site, located to the south of Stanborough, which is identified as a broad location for Growth in the Emerging Core Strategy. This site provides a natural urban extension to Hatfield, rounding out the northern edge of the town, and we support the council's allocation of it as a new neighbourhood.


Support for Broad Location for Growth area in North West Hatfield



Infrastructure


The council is well aware of the major challenges facing churches in Hatfield regarding church buildings. There are no (none) places or buildings available for D1 use (place of worship). This has restricted the growth and effectiveness of church group like ours to carry out our responsibilities to the community.

We would suggest if we can be provided land (BLG2 AREA) to build a four hundred seater conference centre or if we can be provided with an empty building in the town centre


Use the “New Homes Bonus” to mitigate infrastructure issues for surrounding wards and improve Hatfield Town Centre

Traffic impacts should be reviewed

Ensure that Infrastructure is provided before the development commences

Provide infrastructure such as schools, health, now

Improve roads to reduce traffic

Green belt

Comments by individuals and other bodies No release of green belt – new housing should be developed on brownfield land

only

Develop brownfield sites before releasing green belt land

Strategy needs to clarify how coalescence between Hatfield Garden Village and Stanborough will be avoided.

Environment

Environment Agency

Do not object but there are a number of issues that need to be considered. The appropriate changes should be made to the supporting text.

The site is Source Protection Zone 3 (SPZ 3). These zones show the risk of contamination from any activities that might cause pollution in the area. The closer the activity, the greater the risk

The geology makes the site reasonably sensitive as the bedrock is chalk. Groundwater is reasonably shallow at 10 metres - this would need to be considered when foundations and piling are being considered.

The site is over the Mid-Chilterns Chalk Ground water body which is currently of poor status under the Water Framework Directive. The masterplanning should require developers to undertake phase 1 assessment of the site in order to remediate any areas of contamination and help improve the status of the Water Framework Directive groundwater body.

There are issues with capacity at waste water treatment works (WwTW). We would urge the Council to work closely with the water companies and the Environment Agency to ensure capacity and consent standards can be met.


More detail required to give assurance that development at this site will not have a significant adverse impact on wildlife and ecological network. Any development of this scale should deliver a substantial biodiversity gain, through habitat enhancement and creation within the development and in the surrounding area.

Comments by individuals and other bodies Delete the policy, except for the requirement to provide open space Consider alternative sites, which would not affect wildlife Allotments should be included as part of the strategy

Housing numbers


Reduce the number of new homes proposed No more homes should be built Review the need for more housing

Alternative sites/distribution

AECOM (for the Royal Veterinary College) RVC considers that land to the south of Brookmans Park would assist in avoiding

the extent of coalescence compared to other growth options, including that identified in Policy CS18.

See also RVC comments relating to a revision of Policy CS4 to include sites around the large excluded villages.

Comments by individuals and other bodies Alternative sites for housing development should be considered and consulted

on.

If no suitable alternative sites are available, then the scale of the proposed housing should be significantly reduced, to lessen its impact.

New housing development should be distributed more evenly throughout the Borough, including the villages

New housing development should be distributed throughout Hertfordshire, to reduce the impact on both residents and the environment

Consider locations near WGC, where there are a good road networks and no countryside

Re-use industrial/commercial sites for housing

Alternative sites – Brookmans Park, Cuffley, North Mymms, Welwyn and Welham Green – have good under used transport infrastructure e.g stations

Develop housing on the non-green belt land between WGC and Stevenage – it is closer to main regional employment centres and would have less traffic impact

Build a new village in the south of the Borough

Essendon and Potters Bar

Develop WGC5 as an alternative site

Broadwater Road, WGC

Locate new housing to create a new community, rather than expanding an existing community, unless the benefits of expanding an existing community outweigh the cons.

Redevelop Hatfield Town Centre for housing, rather than retail

Locate new housing in Hatfield Town Centre

Seek more windfall housing sites

Cooperate with neighbouring authorities to locate all housing requirements proposed for non-urban land in one Greenfield location, with sufficient infrastructure to be a self-contained neighbourhood

Cooperate with St Albans Council to develop part of the former British Aerospace site. This would require a new link road from the A1(M)

Look at land to north of the borough i.e. Tewin, Digswell etc

Housing type, size and tenure

Hertfordshire County Council Add ‘and people with disabilities’ to the first bullet point at the top of page 129 Add new criterion to Policy CS18 “1f. make provision for supported

accommodation in line with needs identified by Hertfordshire County Council”.

Comments by individuals and other bodies Remove the G&T site from the proposal and find a more suitable site

Extend the Essendon G&T site

Impose restrictions to prevent any more HMOs

Increase affordable housing to 49%

Build flats, not houses

Brookmans Park and Welham Green do not have sufficient affordable housing

Economy

Comments by individuals and other bodies Encourage sustainable business to locate to the Borough and work with

communities after development completed Regenerate Hatfield Town Centre before building new housing

Quality of Life/Community


Respect and reflect the local character Construct a new playground for children to play and people to meet Salisbury Garden Village needs a retail centre and more corner shops

Miscellaneous

Moult Walker Chartered Surveyors (Duncan Murdoch) for Bayard Developments

Given the masterplanning exercise has not yet been considered, it is considered premature to allocate such a defined number to this site.

Bayard Developments considers that reference to 2000 dwellings should be deleted until a proper masterplanning exercise has been carried out and fully consulted.


The consultation has not been fair. There is a political agenda to not build around the villages.

Revise the Plan and re-consult in a more timely and fully informed way, including fully researched impact assessments

Request that the development provides space to locate a building to be used as a place of worship (D1 use)

The consultation literature is misleading – the proposed site is larger than that shown


Section 16.6 Ellenbrook Fields Country Park

Consultation Point CS19 Ellenbrook Fields Country Park and Safeguarded Land

GENERAL comments raising the following points No of comments

Environment Agency do not object to the proposed location for future development but raise a number of

issues (impact on the chalk aquifer, contamination, impact on the Ellenbrook watercourse, capacity of the waste water treatment and the need for flood risk assessment) that need to be considered if this area is brought forward to the next stage of the plan and recommend that appropriate changes should be made to the supporting text.

Hertfordshire Biological Records Centre the long term importance of Ellenbrook Fields Country Park in providing a recreational

(and ecological) resource on the west side of Hatfield will be increasingly recognised. However it is important to ensure that its management is secured to ensure an informal recreational facility rather than a more formal amenity facility.

loss of the safeguarded land to development will significantly impact upon the current resource and area of the future country park. Gravel extraction, built development and the country park must therefore fully consider the ecological impacts these will have and

measures taken to compensate where possible i.e. provision of open grasslands for wildlife and landscape benefit.


OBJECTIONS raised on the following grounds No of comments

Hertfordshire and Middlesex Wildlife Trust raise some concern about the plans for this site, which is recognised as a good site for

birds and is highly valued by the community as a recreational and wildlife resource (although it is recognised that the site has been allocated as a minerals extraction site).

it seems inappropriate to allocate the site as Safeguarded Land for future development, given the vision for the Country Park and wildlife interest of the site. The council must be assured that there is a genuine need for development, that there are no other available sites that would be more appropriate, and that suitable avoidance and mitigation measures are available and can be secured.

it is important to bear in mind that the ecological context of the site may change over the plan period, which may have an impact on the suitability of the site for development.

St. Albans District Council Ellenbrook Fields Country Park is an important piece of strategic green infrastructure.

The identified Safeguarded Land forms part of the Country Park which forms part of a S106 agreement for the Hatfield Aerodrome redevelopment. St Albans, Welwyn Hatfield and the County Council have jointly signed up to improve the existing public access to the Country Park on this land as part of the agreement.

given the significant issues raised by Welwyn Hatfield Borough Council in the assessment of suitability for this site, namely creation of an artificial Green Belt boundary, the likely adverse effects on the quality, open character and value of the area, its poor relationship to Hatfield and existing development, this Council is unsure why this site has been taken forward to meet long term needs. Given the situation above and the absence of a comprehensive Green Belt boundary review and associated work, this Council therefore raises very significant concerns with regard to the Safeguarded Land allocation.

AECOM (for Royal Veterinary College) object to the allocation of this site for Safeguarded Land. The implications, e.g. impact on

transport and infrastructure, do not appear to have been adequately considered. Other issues noted include uncertain deliverability, loss of high grade agricultural land, future loss of Country Park and public open space.

Maddox Associates (for Goodman) object to the Safeguarded Land allocation and consider the land referred to in CS19

should be allocated in the plan period 2011 – 2029 for a minimum of 1,500 new homes to meet housing need and provide a flexible and deliverable supply of housing to ensure competition in the market.

Metropolis PD The Safeguarded Land identified is wholly inappropriate and unsuitable for longer term

development. It comprises a Country Park that provides the residents of Hatfield access to natural green space.

Strutt and Parker (for Brocket Trustees) objection raised to this policy as it is not considered the most appropriate location for

growth in Hatfield. May not be deliverable because the site is a preferred minerals site, but not yet subject to a planning consent. No guarantee that minerals will have been

worked before end of the plan period.

Bayard Developments

object to this policy. This long awaited Country Park should be respected. If minerals are extracted from this land it should be restored as a Country Park. In addition:

i. Although not proposed to be developed until the next plan period part of Ellenbrook Park is suggested as an adjustment to the Green Belt now.

ii. The history of this sites designation for a park, commenced 29th December 2000 with a Sec106 agreement signed by 7 parties including the Council. It appears its owner(s) failed to deliver this benefit which the Council had stated as necessary, hence a new Sec 106 still allocating the land for Ellenbrook Park.

iii. it is understood the park could be relocated which would defeat the raison d'etre for its zoning (as Ellenbrook Park) which was to protect the area to the West from further encroachment and to mitigate the environmental disbenefits of that employment scheme. It appears the Council are now proposing such an encroachment themselves.

iv. Minerals: This area is designated the preferred mineral extraction area by HCC. Developing for housing post-extraction is an extremely difficult building exercise. Viability may be quoted to reduce its contribution e.g. to affordable housing.

v. The land by now is supposed to be held in trust as Ellenbrook Park!

AWD Perkins the site has a list of obstacles; Green Belt, Country Park, Watling Chase Community

Forest, adjoins a Wildlife Site and ancient woodland, Grade 2 agricultural land and a preferred area for mineral extraction under the Minerals Local Plan. The defensibility of the Green Belt boundary is questioned. There is a suggestion of 2 new primary schools but these are needed now, not at 2029. There are no reasonable grounds for safeguarding this site in preference to more suitable sites.

Strutt and Parker (for Mrs C Horton) This is not the most appropriate location for the focus of growth in Hatfield. It has

potential significant deliverability problems.

Comments by individuals and other bodies The term ‘safeguarded’ seems rather inappropriate as this land will simply be taken back

again in 2029 for further housing. Where is the long term landscaping/green space provision?

Confusion as the ‘Safeguarded Land’ appears to be HAT2 in the "Land for Housing Outside Urban Areas". It is unclear why it is being safeguarded when that document identifies it as less than suitable.

Ellenbrook Country Park, is an essential community facility and it must be protected and enhanced.

Ellenbrook Fields Country Park is an important area of open countryside which also serves as a break and defining area of land separating Hatfield from St. Albans.

Object to future mineral extraction and development of this site on ecological grounds due to loss of breeding/feeding habitat and the wider effect this could have on local wildlife (particularly rare species such as Barn Owls, Kestrels, Bats and other wildlife noted on conservation lists)

Strongly object to CS19 as the land was originally secured as green space as part of the planning permission granted for the development of Hatfield Business Park.

The ornithological biodiversity of this site is strong both actually and potentially. Hertfordshire Bird Atlas and British Trust for Ornithology’s Birdtrack confirms the site provides habitat for a wide range of species. Concern is raised at losing this habitat in the longer term.


SUPPORT No of comments

Natural England supports the policy as it provides Hatfield residents access to green natural space and

notes that a proportion of the 180Ha area will be safeguarded for future development. Only land that is of low environmental or biological value should be considered for potential development.

Comments by individuals and other bodies Support the importance of not building between Hatfield and Smallford, avoiding

coalescence and maintaining the Country Park but with reservations about its possible reduction by building post-2029.


CHANGES suggested No of comments

HMWT the council should reconsider the allocation and provide more clarity about the future

plans for the Ellenbrook Fields area (including mineral extraction, habitat restoration, enhancement and management for wildlife, and public access/recreation).

AECOM (for Royal Veterinary College) the Settlement Strategy should be revised to incorporate sites which are more appropriate

for development, including those within the excluded villages (see comments on Policy CS4). The number of safeguarded sites should also be increased should the Ellenbrook Fields site prove to be undeliverable.

Bayard Developments

delete Policy CS19

Comments by individuals and other bodies The entire plan should be scrapped - if there is a genuine need for more housing in the

area it absolutely should not be on the Green Belt. Remove the proposal to carry out development on the Ellenbrook Fields Country Park for

ecological reasons It should not be considered for housing or industrial development even in the long term. There should be a realistic strategic long term approach to the provision of greenspace

available to the public.


Sections 17 and 18

Consultation Point: Section 17 and 18 and CS20


English Heritage It would help to clarify the definition of strategic policies as those in the ECS

(para 18.20) at the beginning of the plan

Thames Water Policy CS20 refers to Major Developed Sites within the Green Belt and sets out

that such sites are identified on the Policy Map and are listed in Section 17.22. In representations at the issues and options consultation stage Thames Water promoted the Mill Green Sewage Treatment Works for designation as a Major Developed Site.

Comments by individuals and other bodies 17.10 and 17.11 - Cuffley and Brookmans Park are well able to absorb more

housing, which would add to the diversity of housing stock with the addition of more affordable housing as well as reducing the strain on overloaded Rye Meads WWTW. It has good transport links which would reduce CO2 emissions, and housing could be close to amenities. It is large enough to provide a centre for small start up businesses to provide jobs for the new occupants.

17.13 - Welham Green is well able to absorb more housing. Support for the community rep workshops discussed in this section but the same

should’ve been done for the towns. No guarantee that all new residents will avail themselves of the local services in

Cuffley. That’s why its best to develop a site close to the centre to promote accessibility



Mr and Mrs Ferry (landowners) In the second bullet point, the value of providing further local housing is

understated, especially as para 17.2 makes clear that “falling populations can affect the viability of maintaining [community] facilities”.

Limited expansion of the larger villages should be permitted, including land on the edges of such villages with some small-scale adjustment to GB boundaries where appropriate.

Development within the Excluded Villages is likely to be restricted by conservation objectives aimed at protecting the character and appearance of the village centres. Expansion onto suitable sites on the edges of these villages would provide more scope for additional housing without conflicting with conservation objectives.

Ayot St Peter Parish Meeting

Objects to the planning authority’s restrictive attitude to the reasonable extension of houses in green belt settlements, based on strict interpretation of floor area comparison with the original building. Most properties are located in large plots, located in a built up settlement and their extension would not have an adverse impact on the open aspect of the green belt landscape

Bidwells The policy does not make provision for sustainable development on the edge of

the settlements

Metropolis PD

Policy does not allow for appropriate growth in villages. Cuffley will have no opportunity to deliver the objectives set by Northaw and

Cuffley Parish (para 17.10). As such, the policy will not be successful in sustaining a vibrant and prosperous local community, services will decline, and residents will be forced, or choose, to move away.

Instead, this policy should be replaced with a proactive and positive approach to delivering sustainable growth in villages such as Cuffley, linked to a comprehensive Green Belt review

AWD Perkins Expand the policy to allow for residential infill within Green Belt villages and on

areas surrounding the specified settlements where it would harm local character and would not move the natural edge of settlements so as to cause coalescence

Barker Parry (for Mr Whitten and Hubert C Leach) Contrary to what is said in Policy CS3, the villages in the district are not the focus

for development; secondary or otherwise as this policy (CS20) makes quite clear and it is an understatement to say the least that the “majority of development” is directed to the main towns when it is almost wholly so directed.

Other than affordable rural exceptions housing, the proposed text of CS20 makes no mention of housing whatsoever, and includes a list of sometimes vague pledges to sustain the rural areas despite the identification elsewhere of a hierarchy of villages (CS3) the policy fails to recognise this.

The Plan should recognise the different types of villages and their differing potential to accommodate development either in or at the settlement.

Mark Rayner Very small numbers of new homes are allowed for in Brookmans Park and

Welham Green. How is this consistent with promoting village centres to improve social cohesion and improving the mix of housing types and tenures?

Comments by individuals and other bodies Housing should be built in the out laying villages regardless of their character,

because housing needs must be addressed

Villages should accommodate their fair share of housing growth

Housing/affordable housing should be built in the villages to meet housing needs

The core strategy fails to recognise that new development is the best way to achieve vital and viable village centres (NPPF para 28)

It is only possible to widen housing choice and provide a range of sizes and tenures as part of new residential development

Many of the objectives identified for the villages can only be achieved through development

Objection to any development in the villages



HBRC The protection, maintenance and enhancement of valuable landscapes and

waterscapes for their biodiversity/conversation value is welcomed.

Countryside Development Agency Support the inclusion of Rural Exception Sites in Policy CS7 and CS20.

Natural England Welcomes the policy which reinforces the commitment set out in policy CS3 to

focus development around those settlements which score higher within the settlement hierarchy (based on sustainability) and also because the policy states that development in rural areas needs to protect, maintain and enhance valuable landscapes, waterscapes and access to the countryside for recreation.

AECOM Royal Vet College

Support the retention of Major Developed Sites (MDS’s) and the policy relating to them. However, RVC seeks to redefine the MDS boundary through the Site Allocations document.



Barker Parry (for Mr Whitten and Hubert Leach Homes) The four larger excluded villages should be considered in a proper Green Belt

review and, as with Option 6 as considered in Autumn 2012 should be allowed development over and above the stagnation policy promoted in this draft plan.

Countryside Development Agency Some changes suggested to CS20 – remove word ‘existing’ from sentence “the

affordable housing addresses the identified existing needs of the local community” and also deletion of word ‘current’ and substituted with ‘identified’ from sentence “the development is small scale, no greater than required to meet the current need…” for consistency with CS7

May wish to consider adding a clarification to explain how need is identified for rural exception site to avoid doubt. Suggested additional text – see full comment.

English Heritage Would like to see mention in the policy of the local historic environment issues

that characterise the rural area

Oshwal Centre Would like to see the inclusion of a policy specific to the long term use and

management of the Oshwal Centre, Coopers Lane Road in the parish of Northaw and Cuffley through which the delivery of the exceptional development requirements of the Oshwal Centre can be managed.

Ayot St Peter Parish Meeting

Suggest that an additional paragraph is added to the Policy: “The sympathetic extension of existing houses in rural settlements where plot size merits it in order to sustain and improve the quality of the housing stock in terms of modern living space and energy efficiency so long as the Green Belt Landscape is not adversely affected.

HBRC

Villages and rural areas diagram north does not include Lemsford springs amongst other sites, although this may be because the site does not have

Villages and rural areas diagram south show some sites which are not open access and therefore which conflicts with the above. Criteria for identifying these green sites need to be more fully explained. The extent of Ellenbrook Country Park is misleading if this is to be developed – perhaps could be hatched.

Mr and Mrs Ferry (landowners)

The policy does not reflect the benefits of providing further market-sector housing within and on the edge of the larger villages including the value of ensuring the continued viability of community and retail facilities in the villages. Revise policy text to include support for the provision of further market sector housing within, and on the edge of, the larger inset villages.

Expand second bullet point to say “deliver housing that meets the needs of local people, that assists in achieving Boroughwide targets and which helps to ensure continued viability of village community facilities including shops, community halls, schools, healthcare facilities, pubs and places of worship”.

HCC Landscape Officer 17.1 could usefully add “and rural economic ventures” to the end of paragraph.

English Heritage The reference to the CAA is useful in relation to Digswell and suggest other

appraisals be referenced. Hope that the ECS can include further policies for the rural settlements and that

the significant historic interest of settlements such as Welwyn will be referred to in the policy framework and not just the text

Bidwells The wording should refer "These excluded villages are considered suitable for a

limited amount of sustainable development within and on the edge of defined urban areas where this is in keeping with the scale and character of the village."

HCC Landscape Officer Section 18 (Neighbourhood Planning)– If section is expanded it should

encourage neighbourhood plans to support the implementation of the GI plans.

Comments by individuals and other bodies Re-instate the houses that were originally allocated to these areas in the Green

Belt SHLAA October 2012 report, but which were removed from the November Core strategy document.

The Core Strategy should be rewritten to reflect the feedback from towns not just the community representative workshops discussed in this chapter.

Section 18 (Neighbourhood Planning) Unaware of plans by WHBC to promote or encourage neighbourhood plans or neighbourhood forums in WGC, will this be done in the future?


Section 19 Implementation

Consultation Point 19 Implementation






Hertsmere Borough Council Note paragraph 19.20 which sets out Welwyn Hatfield's commitment to

partnership working. This is fully supported. Hertsmere Borough Council recognises the importance of working in partnership with surrounding authorities to deliver our respective Local Plans and to ensure the duty to co-operate is met.

Herts & Middlesex Wildlife Trust Support



Hertfordshire County Council (landscape)

Alongside para. 19.22, reference needs to be made to working with the Local Nature Partnership (LNP)

Alongside para. 19.25 could usefully be added a paragraph regarding green infrastructure:" In seeking to provide green infrastructure the council will work with third-party providers and partners including landowners and managers, neighbouring district councils, parish and town councils, the Environment Agency, Hertfordshire County Council, the Herts & Middlesex Wildlife Trust, Groundwork Hertfordshire, and local community groups "

(This would include the jointly funded services such as CMS & HBRC, including if current discussions about alternative hosting arrangements for them proceed)

Para 19.28 needs bringing up to dateHerts and Middlesex Wildlife Trust

As well as working with the Hertfordshire LEP, Welwyn Hatfield council must include a paragraph on how it will work with and engage with the Hertfordshire Local Nature Partnership.


Section: 20 Monitoring

Consultation Point: 20 Monitoring


Herts Biological Records Centre (HBRC)

I39 – Environment is laudable as an indicator. However, it can be affected by development, losses or changes are most likely to be in response to changes in, or poor, management, usually beyond any form of planning control. This is particularly the case with wildlife sites which cannot be accessed for surveys without the owner’s permission, so recording changes is especially difficult.

These changes are important and need to be known if possible, however they are not a good indicator of the implementation or success of a CS policy. Perhaps would be better with “as a result of development” added. This would be consistent with I40

I40 – changes in agricultural practice are influenced by perhaps a global market and loss of grazing, or by neglect are outside the scope of the planning process. This is why broad support of the rural economy may, in planning terms; help deliver countryside conservation, although relating this to maintenance of biodiversity directly would not be so easy.


OBJECTIONS to Section 20 Monitoring raised on the following grounds Number of comments

Comments by individuals and other bodies Monitoring Table should be revised to reflect a suggested change in settlement

strategy to allow development in large villages


SUPPORT for Section 20 Monitoring Number of comments


CHANGES suggested for Section 20 Monitoring Number of comments

Welwyn Hatfield Cycle Forum I49 – ECS should set a target to monitor the % of journeys of 3 miles or less

undertaken by cycling and walking and set a target to increase every year as routes expand.

Herts and Middlesex Wildlife Trust (HMWT)

Would recommend addition of indicator reflecting the quality of biodiversity sites. Eg. number and area of SSSIs in favourable condition, and number and area of Local Wildlife Sites under positive conservation management (this measure is part of the Single Data Set reported by LAs to central government (previously NI 197).

HBRC Re: I39 - Perhaps would be better with “as a result of development” added. This

would be consistent with I40


Section: Appendices

Consultation Point: Appendix A Housing Trajectory


Total No. of GENERAL comments

OBJECTIONS to Appendix A raised on the following grounds Number of comments

East Herts District Council East Herts Council objects to the inclusion of dwellings within East Herts District

within Welwyn Hatfield Council’s proposed housing trajectory, and requests that the housing trajectory for Welwyn Hatfield Borough be amended to reflect removal of these numbers within East Herts District

1


Having objected to the inadequacy of the housing requirement to meet the needs of the area, and the approach which the Council is adopting to the provision of new homes particularly in other local authorities' administrative areas, it follows that Lands Improvement Holdings objects to the Housing Trajectory.

This clearly shows not only the Council's reliance on land in East Herts to meet its proposed housing target but also its heavy reliance on urban capacity sites in the first part of the plan period.

Accepts that many sites identified within the SHLAA as having potential for housing will be developed within the plan period. However, it cannot be assumed that all sites with potential for housing will in fact be (re)developed for residential purposes.

The need and demand for sites for other purposes, including retail, leisure and employment uses may limit the potential for residential development

1

Comments by individuals and other bodies 1

The figures here include East Herts territory. It is clear that they have not agreed to this at all and in fact object to this WHBC incursion on to their area.


SUPPORT for Appendix A Number of comments


CHANGES suggested for Appendix A Number of comments

East Herts District Council

Remove land in East Herts district from the trajectory1


It is requested that the Housing Trajectory is amended to accord with the increased requirement for new homes and sources of supply.

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Remove land in East Herts from the trajectory

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Section: Appendices

Consultation Point: Appendix B District Plan Policies to be replaced



OBJECTIONS to Appendix B raised on the following grounds Number of comments


Concern about list of policies to be replaced, especially those concerning Green Belt, environment and wildlife issues

1


SUPPORT for Appendix B Number of comments


CHANGES suggested for Appendix B Number of comments


Do not remove policies which make it easier to destroy natural environment and wildlife

1


Section: Appendices

Consultation Point: Appendix C District Plan Policies to be saved



OBJECTIONS to Appendix C raised on the following grounds Number of comments


SUPPORT for Appendix C Number of comments

Herts Biological Records Centre

The retention of the existing policy on Light pollution is welcomed. This topic does not appear to be otherwise covered within the Emerging Core Strategy.

1


CHANGES suggested for Appendix C Number of comments


Section: Appendices

Consultation Point: Appendix D Full Glossary


Herts Biological Records Centre (HBRC)

Significantly improved definitions should be used for accuracy as follows:

D.6 Biodiversity - the variety of life on earth, embracing the full diversity and complexity of terrestrial and aquatic animal and plant species, their habitats and ecosystems.

D.50 SSSIs - Optional: include …as amended 'by the CROW Act 2000 and NERC Act 2006.

D56. Wildlife Sites - Replace with: 'Non-statutory Local Sites of District / County importance which meet minimum biodiversity criteria as identified by the Wildlife Sites Partnership in accordance with DEFRA guidance.'

D?? Geodiversity The term 'Geodiversity' is not included or defined given that no references are made to it in the Core Strategy. However, Water End swallow holes at Water End S of Welham Green is an SSSI because of its geological (physiographic) features and function. If required, an appropriate definition is as follows:

'Geodiversity - the variety of rocks, minerals, fossils, soils, landforms and natural processes.'

Note – definitions summarised – see full response for further wording suggestions

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OBJECTIONS to Appendix D raised on the following grounds Number of comments


SUPPORT for Appendix D Number of comments


CHANGES suggested for Appendix D Number of comments

HBRC

Amend definitions as set out above1


Section: Appendices

Consultation Point: Appendix E Spatial Implications of other plans and strategies



OBJECTIONS to Appendix E raised on the following grounds Number of comments


SUPPORT for Appendix E Number of comments


CHANGES suggested for Appendix E Number of comments

Hertfordshire County Council (County Landscape Officer) - Table 15. Suggest that for consistency and completeness the GI Plans are included and assessed

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web viewconcerned about the economic strategy to support these developments: there is the assumption...

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