Confirmation of No Prior Consultation Regarding Development of Singlers Marsh

Since 2019, WPAG has been actively involved with minimising the effects of the Welwyn Hatfield Local Plan on Welwyn, Digswell, Oaklands and Mardley Heath.  In particular, it has campaigned to preserve Singlers Marsh from the consequences of possible development on the land surrounding it.

In January 2020, a WHBC council officer stated in a public meeting that there had been consultations about the consequences of using part of Singlers Marsh itself for development, and that there had been no concerns raised in those consultations.  WPAG believed that this was said in error, and it has been working ever since to have the record corrected.  After several attempts, the answer we seek will be made public at a meeting of the WHBC Cabinet on 9th February 2021.  As it often takes a few days for the paperwork to be published after these meetings, WPAG has been given an advance copy of the council’s response, which we are publishing here below.  (Details about the WHBC committee meetings can be found at https://www.welhat.gov.uk/committees)

We will follow up with a separate post that comments on how this might be relevant to the ongoing Local Plan deliberations.

Question from Russell Haggar, Vice Chair, Welwyn Planning and Amenity Group.

In the CPPP session held on 23rd January last year, there was discussion about whether or not sites Wel1, Wel2, Wel6 and Wel15 should be included in the WHBC Local Plan. They were up for discussion as a result of having passed the site selection process during 2019, despite no consideration having been taken during that process of the consequences of building the external road infrastructure required to service and access these development sites.

As a consequence of this, much of that CPPP discussion related to how the infrastructure necessary to support those sites would affect amenities throughout Welwyn, particularly in regard to the area of Singlers Marsh. Singlers Marsh is formally recognised for its wildlife, natural environment and archaeological status, including playing host to a fragile and rare river system.

The earlier 2019 Call for Sites consultation had focussed on environmental issues relating only to development work at each individual site. That consultation made no effort to seek opinions about the environmental or other consequences of any consequent development work away from the sites themselves. In particular, the 2019 Call for Sites consultation made no mention of any possibility of building on Singlers Marsh itself as part of the Wel1/Wel2/Wel6/Wel15 proposals, and hence no opinions about this were solicited from either the public or any of the usual interested voluntary/statutory organisations.

In discussion with one of the councillors during that January 2020 CPPP session, a council officer seemed to say that – in proposing those four sites at that time for inclusion in the Local Plan – there had already been a consultation about the possibility of building on part of the Singlers Marsh land, with no adverse responses. Following that CPPP session, WPAG submitted a Freedom of Information request to ascertain what consultations, if any, had actually been made about developing on Singlers Marsh itself. The FOI response demonstrated that there had been no such consultations; no opinions had been sought, nor had had any been received unsolicited. There had only ever been consultations (as part of the Call for Sites process) about the effects on Singlers Marsh of development at each individual site. No consultation has ever been disclosed about development of Singlers Marsh itself, and we believe that no such consultation has ever been undertaken.

Since last January, comprehensive plans for expanding the road network surrounding these four sites have emerged, drawn up by their development advocates and submitted to WHBC and HCC for consideration. These plans propose the remodelling of Codicote Road (south of the roundabout), substantially upgrading the Link Road/Fulling Mill Lane/Codicote Road junction, creating an extra bridge across the river (at the expense of Singlers Marsh land) and widening Fulling Mill Lane (also at the expense of Singlers Marsh land). These plans were prepared in readiness for adding these four sites to the Local Plan, but were not disclosed publicly as part of the Call for Sites consultation. It is clear that a lot of effort went into planning for the necessary infrastructure expansion to support development at these sites. None of this was included in the Call for Sites consultation. Can the council now confirm, unequivocally and unambiguously, whether or not any consultation ever actually took place about any development on Singlers Marsh land itself? If it did, please indicate where such information can be found. If it did not, please update the official public record to indicate this. Furthermore, if indeed it did not, can WHBC confirm that no development of any of the land at Singlers Marsh would ever be proposed, let alone occur, without a meaningful and comprehensive public consultation, to include informed contributions regarding its standing and official designations as to its wildlife, natural environment and archaeological heritage status?

Response:

Consultation has taken place with a number of statutory consultees relating to the assessment of the suitability, availability and achievability of sites for allocation. This includes sites Wel1, Wel2, Wel6 and Wel15.

When considering the deliverability of these sites it has been established that delivery is dependent upon significant highway upgrades; as the current access via Singlers Bridge is inadequate to accommodate additional vehicular/pedestrian access. The promoter of the site provided indicative drawings which were made available to statutory consultees as part of the consultation on the HELAA.

The FOI response from the Council has forwarded the responses received on these sites. This includes a response from Herts Ecology in 2016 regarding the potential impact of highway upgrades around Singlers Bridge and Fulling Mill Lane road involving the loss of a small section of land at Singlers Marsh.

There are no proposals which result in the loss of Singlers Marsh as a nature reserve, as an archaeological site, as a wildlife site or its ability to continue function as all of these things. Nor has the Council proposed these sites for inclusion in the Local Plan.

However, it seems likely that the Inspector will examine the potential of these sites to contribute to meeting the need for housing, any potential impact on biodiversity and whether or not this could be mitigated. He may consider their allocation is required to make the plan sound and if that is the case there would need to be consultation on modifications to the Plan. Local Plans do not however contain detailed proposals for accessing sites which are detailed matters considered at the planning application stage and which would be subject to consultation at that point.

Analysis of WHBC response to WPAG regarding Singlers Marsh and Local Plan

During 2019, Welwyn Hatfield Borough Council (WHBC) ran a consultation process about all the sites that were being promoted for inclusion in the new Local Plan.  This Local Plan will indicate where 16,000 new homes can be built across the whole borough over a twenty-year period.  Several sites were promoted within/around Welwyn village by various developers, all of which were met with fierce resistance by local residents due to the major damage they would have on the character of the community were they to proceed.

Four of these sites (Wel 1, Wel 2, Wel 6 and Wel 15) survived the consultation process and were included in the draft proposal by the council’s officers that was published on 8th January 2020.  At that stage in the process, this proposal had not been considered by our elected councillors.

These four sites are on green belt land and would amount to around 250 new homes, running in an anticlockwise arc from Singlers Marsh to Hawbush.  The rural feel of that side of the village, not to mention the tranquil and countryside setting of the village cemetery, would be utterly changed if these sites were to be developed.  There would be knock-on effects of substantial extra traffic and noise on the whole area, as well as damaging consequences for the remaining open spaces and natural environment, including Singlers Marsh.

An even bigger shock to the community was the comment buried within the proposed plan, seemingly as a mere aside, about using part of Singlers Marsh itself to provide better road access to these new housing sites.

It was always obvious that these sites would need improved road access, both for the construction traffic and for their future residents (approximately 500 extra cars) to drive in and out of the area.  However, at no point during the 2019 consultation was any mention made of using anything other than the existing road network, let alone of using Singlers Marsh itself.  What was worse, it then became known that exploratory discussions about the possibility of buying the required chunk of Singlers Marsh from its landowner had already started.  The landowner in question is WHBC itself.

Had this possibility been included in the 2019 consultation, then arguments against developing on Singlers Marsh could have been put forward.  Singlers Marsh is a hugely popular and much used piece of open, semi-rural countryside.  It hosts a rare chalk stream (the Mimram), is designated both as an official wildlife site and a nature reserve, and contains significant archaeological remains relating to Welwyn’s Roman and pre-Roman history.  It is the focus of many of the community’s regular events throughout the year.

The first opportunity to raise residents’ strong concerns about the unadvertised possibility of developing on Singlers Marsh was at a public meeting of the WHBC Cabinet Planning and Parking Panel (CPPP), held on 23rd January 2020 for the councillors to consider the officers’ proposals for the Local Plan.  During a Q&A session at this CPPP meeting, a Welwyn councillor raised local residents’ concerns with WHBC’s head of planning about the proposal to provide better access to these four sites by using part of Singlers Marsh.  Mindful of Singlers Marsh’s natural environment, the question asked about what (if any) consultation had taken place with wildlife bodies prior to making this proposal.

Taking this question on the fly, without having prepared for it, the head of planning replied: “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 uscause that something couldn’t be done in that regard.

(If anyone is interested to see this exchange, a video recording of the entire meeting is available on the WHBC website.  The question is asked at 1 hour, 39 minutes into the recording; the answer starts at 1 hour, 42 minutes.)

WPAG, along with many others involved in the process, were not aware of any such consultations ever having occurred.  It seems likely that this was an accidental statement, an example of someone “mis-speaking”.  However, this statement was made on the public record, and created a real risk that it could influence future deliberations inappropriately.

In the short term, the various council meetings in January 2020 decided not to include these four sites in the new version of the Local Plan.  However, for various reasons they are currently now back in the mix, as the process has entered a new phase of its review.

WPAG’s first attempt to correct the public record was treated as a Freedom of Information request, leading to an unhelpful reply that merely directed us to the website that collated all the responses to previous consultations.  This we already knew well, and we learned little from the response.  The second attempt was to raise this concern as part of our contribution to the next consultation process later in 2020.  Sadly, WHBC chose to ignore this part of our contribution, simply offering no reply to it at all.  The third attempt has resulted in a response this week – it is a written question to another WHBC committee meeting, with a written response.  WHBC have kindly provided us advance notice of the response from their head of planning, and we have published it in a separate post here on our website.

This response is timely, as responses to the next phase of the review of the Local Plan are due by the end of this week.  The response is pretty long, and seems to make all sorts of justifications for the process that has been followed.  However, in the context of the original question and the answer that was given to it, this is a very clear retraction of the previous statement.

The original question asked about the consultations that WHBC had made regarding the use of part of Singlers Marsh to provide a new road access for these new housing sites.  It particularly asked about any consultations that had taken place with any wildlife bodies.  Let’s dissect the answer in the light of the new statement that has finally emerged:

“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.”

They now confirm that the only consultation about using Singlers Marsh land took place with Hertfordshire Ecology, not with any of these other bodies.  Moreover, this consultation took place not in 2019 when these four sites were being assessed, but in 2016 when there was no mention of using Singlers Marsh land in this way.

“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.”

There was indeed “nothing particular said that gave cause” for concern, because nothing was said at all by these bodies, because they were not asked about it, ever.

To conclude:

WHBC has now confirmed that the proposal to use Singlers Marsh land to build a new access road to service these four housing developments has never been consulted upon, particularly by any of the key ecological or environmental bodies that have a specific interest in maintaining its current status.

Singlers Marsh is a registered wildlife site, nature reserve and archaeological area.  It is host to a rare natural chalk stream, and is the only place along the Mimram’s length where it can be easily and freely accessed by the public.  It is also a heavily used and widely loved public amenity, host to many of the community’s events during its normal yearly cycle.

Any proposals to build on this land must take full account of the simple fact that no consultation about this has ever taken place.

River Management Consultation Responses

Last year WPAG responded to the Environment Agency’s ‘Challenges and Choices’ consultation to help the next determine key issues for the next River Basin Management Plan. The River Mimram is part of their Thames region

They have now published a summary of the responses and here are the key themes:

• Nature based solutions that can deliver multiple benefits, including:
o flood risk reduction through natural flood management
o enhancements for habitats and biodiversity through actions such as rewilding
• The need for the Environment Agency to address storm water overflows, particularly to:
o improve their operation and reduce their frequency of use
o penalise water companies when they are used too frequently
• The need to tackle over abstraction, particularly the:
o importance of sustainable abstraction on chalk
o need to maintain a minimum flow target
o need to value water appropriately and encourage water meter usage
• Importance of protecting chalk streams:
o from over abstraction, pollution and physical modification
o to have additional protections for these globally unique water environments
• The importance of catchment planning and partnerships:
o to deliver education and citizen campaigns
o to be sufficiently funded for the long term
• The need for the Environment Agency to enforce existing regulations more.
• The importance of the proposed Environmental Land Management (ELM) schemes to
the future of agriculture, including:
o getting the new agricultural policy right is crucial to achieving a shift to more
sustainable land use and improve soil health
o supporting their implementation with greater enforcement of existing
regulations
• Chemicals and plastics in the environment, including the:
o need to have campaigns to educate the public in sustainable usage
o government to use of bans and restrictions, where appropriate
• Securing future funding for the environment, including:
o central government to use additional taxation to support environmental
improvements
o securing additional funding to support enforcement of existing regulations
(for example, farm inspections)

If you want to read the full summary (103 pages long), click here.

In your hands – the Future for Singlers Marsh

What is the future for Singlers Marsh?

Singlers Marsh was formed during the Ice Age. The glaciers more or less stopped at the Bedfordshire/Hertfordshire borders. But the rocks, soil and sediment they pushed before them created the chalk hills of the Chilterns, from which the River Mimram flows, and the Mimram valley.

The Past

1904 Postcard from Singlers Bridge along the Codicote Road

The Mimram was a much wider, deeper river than it is now and Singlers Marsh was part of the flood plain, where the river could expand into several channels when the water levels rose – helping to protect Welwyn from flooding.

The marshy, fertile meadows or ‘medes’ were excellent for grazing animals, but not surprisingly marked on old maps as ‘Likely to flood’. There are tales of swimming and boating on the Mimram, skating on the marsh when it iced over and tug of war matches ‘across the Mimram’ – when the losers got wet.

The Drain flooded

The Present

When the Link Road was built in the 60’s, sadly the resulting clay spoil was allowed to be tipped onto the Marsh, creating a domed effect, thus removing its effectiveness as a flood plain! However, it was then seeded. 1969 saw Welwyn Rural District Council buying the marsh from Three Valleys Water and in 1973 they made the historic decision to create Singlers Marsh into a nature reserve, with the lovely quote, reported in the Welwyn Hatfield Times: “We sincerely hope this spot will become a restful retreat for those who want to spend a few hours away from the crowds”.

A Hot Spell June 2020

Welwyn RDC then handed ownership on to Welwyn Hatfield Borough Council (WHBC), who have registered it as a ‘Local Nature Reserve’. Now much used as a safe place by walkers, the Guides, school, dog walkers, family picnics and of course the Welwyn Festival Fun Runs and Fun Day. During the Covid lockdown it has been used very regularly for everyone’s exercise and, during the hot weather, loads of socially-distanced’ picnics.

Welwyn Fun Day 2013 & the Duck Race

The Future

But despite the classification as a ‘Local Nature Reserve’ this gives little protection from development. Last year WHBC readily gave permission for part of the Marsh to be used in a road and bridge widening scheme to support the proposed housing developments around the cemetery. 959 people signed a petition to stop this being done and, at the moment, this proposal has not been included in the latest Local Plan submission, but we have yet to hear the Inspector’s final decision.

So how can we protect this beautiful space for us and generations to come?

Well, there are two possibilities:

  1. We can try to get it ‘Village Green’ status, which has a much higher level of protection. This was tried a few years ago but was stymied by the landowner WHBC. Anyone can make this application and one is currently underway at https://www.protectthemarsh.co.uk/. However, it usually needs the support of the landowner to be successful. So could we persuade Welwyn Parish Council to buy the land? And then there is a vested interest to get this greater level of protection.

    OR
  2. Welwyn Parish has voted to develop a Neighbourhood Plan which is your vision of what Welwyn should be like in the next 15-20 years, primarily in terms of house planning and infrastructure. When approved, it has some ‘teeth’ with planning decisions.  Part of the Plan is what should be protected both in terms of architecture, green belt, open spaces – and our three nature reserves. Developing this Plan will start with a questionnaire which everyone will receive. This will be your chance to say how important Singlers Marsh is to you.

Your WPAG is involved with both these projects, but we will need your support when the time comes.

Enjoy Singlers Marsh now. And let’s do our best to protect it for years to come.

Mimram – where are the fish?

All the rain gives us the River Mimram back, but where are the fish?

The River Mimram is one of the world’s rare chalk streams. (There are only 220 of them.) And they are fed by underground aquifers which are replenished by steady, winter rains. However, after three very dry winters, our aquifer was almost empty and the river dried up. (Affinity Water had already reduced the amount they abstract from Singlers Marsh and have not increased it since.)

The Environment Agency (EA) measure the groundwater levels of the Mimram at Lilley Bottom and you can see from their chart below that the groundwater was exceptionally low in September. But now, after all the rain this Autumn and Winter, it has now risen but it is still below average. Provided we get an average rainfall fall for the next two months, this should be enough to keep the river running through the summer.

One other aspect of the dry winters was that by last Spring we were in an official drought and Affinity Water were expecting to have to introduce a hosepipe ban (Temporary Use Ban) this April. That will no longer be necessary, but their Drought Committee will continue to monitor the situation.

And what about the fish in the Mimram? Last September, as the river levels dropped dramatically, the EA rescued the fish and rehoused them downstream. Now we have to wait for the riverflies to return, who are the bottom of the food chain. Once they are back then we hope the fish will return and be sustainable. However, due to the large weirs at Tewinbury and Mill Lane, the fish cannot migrate upstream as they would do naturally.

So there are three options. Some fish did survive upstream above Codicote and they might come down stream to Welwyn. The EA could restock the Welwyn stretch with breeding fish. Or the EA could bring some of the fish stock back from Panshanger. The EA plan to monitor the situation closely and make the decision, but don’t expect to see anything much for three to four years.

In the meantime, enjoy the Mimram Mimram at Singlers Marsh. Or, if you fancy a walk, there is a very good stretch at Panshanger Park, near Hertford.

Pavements and Pathways – a Response

Further to my recent post on Nextdoor, I’ve received a lot of replies complaining about pavements and pathways. I spoke with County Councillor Richard Smith today and he will be happy to help in any way he can. He also suggests that you go onto the Herts CC website: and lodge your complaint, or phone them on 0300 123 4047.

County Councillor Smith also asks that you let him know so that he can push for action where it is needed. I will be passing all the complaints I have received on to him, but many of them do not have full contact addresses and names so it would be helpful for him if you could email him or phone him. Many thanks. Sandra Kyriakides,

Welwyn Planning & Amenity Group29 Jan · Welwyn in General

Pavements and Pathways

The Welwyn Planning & Amenity Group is compiling a list of pavements and pathways in our Parish that are in need of repair/attention. You can help by letting me know if there are any such issues in your area. We hope to then bring the matter to the attention of the appropriate local authorities and will do all we can to get action where it is needed.

Many thanks for your assistance. Sandra Kyriakides

Please email me at

The poor State of our Local Pavements/Pathways

The following Report was drafted by Sandra Kyriakides

CONDITION OF LOCAL PAVEMENTS/PATHWAYS

WPAG is conducting a survey of local pavements and pathways that are in bad or poor condition.

If you know of any problem locations – please tell us.

Input from you is vital so, if there are any in your area, please email the location details to 

We will record all reported details in our dossier, and WPAG will then raise the matter with those responsible for their maintenance.

 

London Luton Airport – Expansion Consultation

Luton Airport is planning a major expansion.

A Consultation Paper did not reach the Welwyn Parish Council (WPC) until 25th June 2018 with responses required by 31st August, leaving precious little time to study the associated papers and to respond.

As WPAG are co-opted members of the WPC Planning Committee we have been invited to contribute to their response.

However, the dates of scheduled WPC meetings puts pressure on the time left to respond, and the WPAG Committee will therefore prepare a separate WPAG group response.

The Consultation Documents

To read the Main Consultation Paper go to Consultation Paper and for a Summary go to Consultation Summary. Other associated documents include the Feedback Form

These are weighty papers and the WPC Briefing Paper (copied below), is recommended reading for its comparative brevity.

Individual WPAG members who would like to add thoughts and comments, are encouraged to respond directly to the Consultation.

Briefing Paper for the Welwyn Parish Council Planning Committee

The following Briefing Paper has been prepared by Cllr Bill Morris, Chair of WPC and is reproduced here as it provides a very helpful guide which will be of help to WPAG members.

Background

WPC first became aware of this consultation at their 25th June meeting.  Luton Borough Council (whose company – London Luton Airport Limited – own the airport) are consulting with those whose opinions they seek and who may be affected, about their proposals to expand the airport further and a series of public meetings has been drawn up.  The consultation runs until 31 August, with a series of 17 consultation events taking place in and around Luton between 9 July and 4 August. At these events everyone will have the opportunity to view the plans, speak to members of the expert project team, and provide feedback.  The meeting for our locality was to be held on 10 July at Oaklands College WGC from 1400 to 2000.  Given the lack of open advertisement or direct contact and our late discovery of the event, no WPC representative could attend.  Other venues and times are given on their website and members may wish to attend a more remote event.

The website contains a lot of information including proposals, consultation format and a response booklet:  https:/www.luton.gov.uk/news/Pages/Consultation-gets-under-way-on-potential-expansion-of-London-Luton-Airport.aspx

Given that much of the village, Digswell and Oaklands are under the flight paths, many residents (assuming they were aware) may have concerns.  In addition to the obvious air and noise pollution issues, there are also infrastructure questions concerning travelling both to and from the airport and the airport layout itself, when such an expansion is being considered.The Planning & Licensing Committee is invited to consider the issue and this outline reply, with regard to submission to WPC at their July meeting.  The consultation ends on 31 August, with a further round in 2019.

Proposals

Luton Airport is growing faster than predicted and is now the fifth busiest airport in the UK. At its current rate of growth, Luton is forecast to reach its existing permitted capacity of 18 million passengers per annum (mppa) in 2021.  The Council believe it may be possible to handle up to 36-38 mppa (i.e. doubling the throughput.  The major reasons for doing this, as given by the Council are:

  • There is an opportunity for Luton to play a substantially greater role in the UK aviation market, notwithstanding the proposal for a third runway at Heathrow and the proposed expansion at Stansted. (“Why not us”?)
  • Initial estimates are than there could be an increase of up to 800 new jobs for each additional million passengers per year travelling through Luton and an annual boost to the regional economy of £76m. (“Let’s see the calculations and if Herts and a village such as ours really benefits”)
  • The contribution of an expanded Luton to Beds, Bucks and Herts could reach up to £2.6bn and support up to 42,000 jobs. (as per previous statement).

Essentially this all boils down to developing the site to be able to handle a doubling in passenger numbers and presumably in aircraft numbers (large jets are the most significant, the extensive and lucrative private jet market is important but insignificant in these terms.)  This in turn means expansion or re-arranging of: runway(s), terminal building(s), aircraft hangers (servicing/repairs etc.), inter-communication within the airport and passenger transport infrastructure outside the airport and beyond.

[1] Prepared by Bill Morris, Chair WPC, following a request from Colin Hukin, Chair P&L Committee.  The author has lived in Welwyn (near QVM Hospital) for over 32 years, has flown in and out of Luton Airport on business and pleasure all of that time and still continues to do so for pleasure, twice a year.  His home is also under the westbound landing flight path.