Comments and Response to the Consultation on the proposed changes to the submitted Draft Local Plan 2016 (site allocations) 2020, submitted on behalf of the Welwyn Planning and Amenity Group
WPAG’s comments fall into three parts.
Part 1 – Comments on the overall Draft Local Plan
We agree with the approach taken in revising the Draft Local Plan at the end of January 2020. The consistent application of this approach’s guiding principles across all proposed developments in the borough is welcomed by WPAG.
We note that the nature of the Local Plan process is such that the development merits or drawbacks of individual sites are considered in detail, whereas the wider implications of a development site on surrounding areas (such as the ability to deliver supporting infrastructure by agencies other than WHBC) are only assessed in broad terms. It is vital, therefore, that these wider implications are assessed realistically and sufficiently as part of the assessment for each site in the Local Plan.
Those sites for which it is feasible to provide adequate and sustainable infrastructure, as well as passing the other tests inherent in assessing the Local Plan, should be taken forward into the Plan. Such infrastructure should be deliverable by all its various agencies in keeping with the growing needs of the site as it develops – ie not retrospectively after the end of the development, leaving new residents waiting for it to be delivered. It should be sympathetic to the needs of its community, both existing and new – WHBC communities are well established and often steeped in history, with strong community identities too, and they should not be provided with inappropriate, insensitive new infrastructure.
Where supporting infrastructure cannot be delivered in a timely manner, or in a form that is relevant to the existing community style and ethos, then that should be a strong reason to reject any new site advanced into the Draft Local Plan.
Part 2a – Sites Wel1, Wel2, Wel6 and Wel15 in Welwyn – Direct comments
These four sites (Wel1, Wel2, Wel6 and Wel15) were not selected for the revised Draft Local Plan, but they were originally offered in the Call for Sites and were considered suitable for allocation by WHBC officers, and so they were submitted to the CPPP meetings in January 2020. They are still mentioned in Appendix 1 of the submitted Draft Local Plan, and we wish to note several points of concern regarding how these sites are still regarded positively within the process.
We consider the original selection of these four sites to have been inappropriate, and that the assessments of these sites were neither sound nor legal for the following reasons. The assessment makes it clear that these four sites are only viable if taken together as a bloc. We have objections both to each site individually (this section), and together (next section).
Looked at individually, the Sustainability Appraisals in the Site Selection assessment (2019) for these four sites contain substantial errors.
For Wel1 and Wel2, under “Significant positives” in the Sustainability Appraisal, it is claimed that issues 4.2 (“Reduction of greenhouse gas emissions from transport”) and 4.3 (“Helping to avoid/reduce air pollution”) are both addressed by the sites being “within 400m of four bus stops providing a six day a week service.” We believe that there are no such bus stops within 400m of any point on these sites. It appears that this assessment may have incorrectly copied its assertions from other promoted development sites for which they are true (eg Wel 6 and Wel15 are within 400m of bus stops on nearby Codicote Road). Alternatively, they may be referring to ad hoc bus stops within the Hawbush area of the village which provide small-scale shopping transport to Welwyn Garden City only three times each week – the roads around these bus stops cannot accommodate a full-size bus, and there are not even any physical bus stops in Hawbush. If so, what the assessment fails to mention is that these bus stops have a total of three timetabled services over the course of an entire week, and this is not a bus service that could be used to ease private car traffic from these developments. Hence it is incorrect to state that this constitutes a “significantly positive” contribution to these promoted sites’ sustainability.
For each of Wel1, Wel2 and Wel15, issue 6.6 (“Provision of training, skills development and lifelong learning”) in the site selection assessment’s sustainability appraisal is supported by stating that each site “is within walking distance of education establishments”. The only such establishment (in the singular) is Welwyn St Mary’s Primary School, which provides children’s primary education but neither training, skills development nor lifelong learning in any obvious sense.
For Wel15, the response under “Significant negatives” issue 4.5 (“Conservation/enhancement of the borough’s character, historic environment, and heritage/cultural assets”) fails to make any mention of the major archaeological significance of this site. Hertfordshire County Council’s experts and the professional archaeological community agree that this location is the likely heart of the original Roman and pre-Roman (Iron Age) settlement that underpins Welwyn’s 2000+ years of history and continual settlement. The Site Selection assessment makes no mention of this very significant factor against development of Wel15.
WPAG believes that these errors and omissions should be recorded for these four locations, and should be fully considered if the sites are ever brought forward again for development consideration.
Part 2b – Sites Wel1, Wel2, Wel6 and Wel15 in Welwyn – Combined effect on Singlers Marsh
These four sites were considered together as a bloc in the 8th January 2020 WHBC proposals when justifying the proposed changes to the nearby road network to support the additional vehicle traffic arising from these sites. In the 2019 consultation process, submissions were requested from various statutory, advisory and voluntary bodies about the direct effect of developing each individual site on its own natural environment. The proposed Draft Local Plan (8th January 2020) assessed these four sites together when considering road network capacity. Together, it was felt that they warranted widening a stretch of Fulling Mill Lane and replacing the existing Singlers Bridge. As well as losing the bridge’s charming period character, widening the bridge and the road would have had to be made at the expense of the neighbouring Singlers Marsh, which it was confirmed would yield up some land to accommodate the widened infrastructure.
It is our belief that the possibility of developing part of Singlers Marsh and replacing Singlers Bridge (in order to widen Fulling Mill Lane to provide access to these four sites) was not consulted upon. We have seen no evidence that Opinions from the various organisations that would have a view about the effect of such development were either sought out, or otherwise provided.
In the CPPP session held on 23rd January 2020, during the Q&A session with the borough councillors, Cllr Thusu asked Colin Haigh (WHBC Head of Planning) about residents’ concerns regarding the proposal to widen the lane at the expense of the marsh and the bridge, and whether there had been any consultation with wildlife bodies about it (this question can be seen at 1 hour 39 minutes into the webcast recording of the session, as available on the WHBC website). Mr Haigh responded (at 1 hour 42 minutes into the recording), saying “We would have consulted key ecological bodies – the Environment Agency, Natural England, and various others: Herts & Middlesex Wildlife Trust, Hertfordshire Ecology and other local bodies on our database. And in terms of the regulatory and the statutory bodies (Environment Agency, Natural England side of things) there was nothing particular said that gave us cause that something couldn’t be done in that regard.”
The proposal to widen the lane was not included in the 2019 consultation, and was only revealed when the Draft Local Plan was published on 8th January of this year. It is not obvious how those bodies’ opinions about a January 2020 proposal could have been sought during the 2019 consultation. Following Mr Haigh’s statement, WPAG made a Freedom of Information request of WHBC to reveal any consultations that had taken place about the proposed widening of the lane at the expense of the marsh and bridge. WHBC’s response to this FOI request referred only to the responses to the 2019 consultation.
On this evidence, WPAG feels it must therefore conclude that no such consultation actually took place.
Singlers Marsh is formally designated as both a Wildlife Site and a Local Nature Reserve. The Mimram river which flows through it is a globally rare chalk stream which is known to host an increasingly precarious ecological system. In fact, the river has dried up twice in the past fifteen years, and is currently still recovering from the most recent such event – we understand that the Environment Agency are not planning to restore rescued fish to the river until 2021 to allow sufficient time to recover from that 2019 drought. Singlers Marsh also borders the presumed centre of the Roman-era settlement from which the village of Welwyn has grown over the past 2,000 years. It is therefore of interest to the archaeological community in its own right. In addition, it received a substantial amount of land spoil from the cutting that was made when nearby Link Road was built – archaeologists now recognise that this spoil will have contained a large amount of archaeological remains from Roman Welwyn, and possibly the Iron Age era that preceded the Roman settlement.
On Fulling Mill Lane itself, by the road junction with Riverside at OS grid reference TL 2294 1643, is a piece of World War 2 archaeology, in the form of a partially buried concrete mortar emplacement (as described on the Archaeology Data Service’s website at https://archaeologydataservice.ac.uk/archives/view/dob/ai_full_r.cfm?refno=13405). The ADS is a key UK agency concerned with the preservation of digital records of the historic environment, and its records are referenced internationally by the heritage community.
It appears that none of this rich natural, environmental, archaeological and historical heritage has been considered at all in preparing the 8th January 2020 proposal to widen Fulling Mill Lane in order to provide access to these four possible development sites.
In WPAG’s opinion, it is imperative that all of this be noted on the record, and that it be fully taken into account before any future attempt is made to revive any development possibilities for any site near to Singlers Marsh. In the absence of any consultations about these matters, it seems clear that any proposal to develop any part of Singlers Marsh or Singlers Bridge, or to modify Fulling Mill Lane, would be neither sound nor legally compliant with the planning process.
Moreover, the entirety of Singlers Marsh is a much loved public amenity enjoyed by a great many local residents, and it plays host to popular community events every year. During the current coronavirus lockdown, access to its open land surrounded by fields and low density housing has never been more enjoyed in living memory. Singlers Marsh is also the only place along the entire course of the Mimram where it flows through public land – nowhere else can the members of the public enjoy its riverside setting for themselves. The immense value and pleasure that the local community gains from having Singlers Marsh at its heart in its current extensive form in a tranquil and peaceful location must not be lightly discounted.
Many residents in Welwyn have expressed their concern at WHBC’s proposal to develop Singlers Marsh without consultation, and several petitions have been successfully raised against this possibility. A good way to restore residents’ confidence in the future of their public land would be for WHBC to transfer both ownership and stewardship of it to Welwyn Parish Council, and to seek to protect it for the future by supporting an application for it to receive Village Green status.
We trust that all the points in this submission will be recorded against the current promoted development sites around Singlers Marsh, and also be readily available for consideration against any future proposals that might arise in this area.
In WPAG’s opinion, for all the reasons stated in this document, development of none of these sites around Singlers Marsh would be either sound or legally compliant.
Russell Haggar
Vice Chair, Welwyn Planning and Amenity Group
