We write as one-voice to Hertfordshire County Council Highways & Environment Division with our concerns about the impact the social distancing measures placed in Welwyn High Street is having and will continue to have on the ability of many of us to survive as businesses at this extremely difficult time.
In particular, the imposition of a one-way system in the High Street is extremely damaging in terms of footfall to the village. This is something we have experienced before, in 2009, with the effect of pushing some traders to the edge of survival.
The SAGE advice on the Government’s website regarding environmental transmission of coronavirus points to an extremely low risk of catching Covid-19 by passing someone on a pavement or in a shop for a short period of time.
For the first 9 weeks following lockdown when essential shops were open, the Great Welwyn Public largely behaved with courtesy, common-sense, and personal obligation to follow social distancing rules without needing barriers to help them do this. These are the only traders that are ever likely to have queues on the pavement, such is the nature of the others that opened after 15th June, and those planning to open from 4th July onwards. Most of the latter will be operating a booking/ appointment system to avoid queues.
Whilst whole-heartedly supporting the need for people to follow social distancing guidelines, we believe it is perfectly possible in the context of Welwyn Village for customers and staff to do this in a safe way without imposing restrictions that may lead to the demise of yet another High Street in this country. We are all making our businesses Covid-19 secure and will promote social distancing amongst our customers and outside.
Welwyn Village is fairly unique in its make-up of shops, pubs, restaurants, estate agents, hair, beauty and specialist businesses. The cross-fertilisation of footfall from one business to another has always been one of the main reasons for its ability to survive. We know from previous experience that reduction in parking and the necessity to negotiate the bypass for some journeys means that potential customers often simply decide to go elsewhere and footfall is lost, leading to a downturn in revenue which in these difficult times will be catastrophic.
We ask you to think again and support us in trying to get back on our feet.
Belinda Walsingham, Box of Delights, 24 High Street Susan Bull, SuSu, 21 High Street Mick Leto, The Barbers Room, 30 High Street Howard Hill, Hill & Co Violin Shop, 5 High Street Matheus Gomes, Vita Ristorante, 12 High Street Wendy Rowley, Welwyn Florist, 29 High Street Dennis, Katie, Chris & Phill Dinsdale, Katie’s Bakery, 3 High Street Tricia Conroy Smith, Off Broadway Travel, 18/20 Prospect Place Filippo Mazzarella, Aqua Restaurant, 28 High Street Adam Richardson, The White Horse, 30 Mill Lane Dan Tubbs, The Wellington, 1 High Street Steven Hastings & Jenny Havill, Lemon Plaice, 21 Church Street Gill Ewing, Simmons Bakers, 34 High Street Peter Morgan, Peter Morgan Hairdressing, 4 Codicote Road Martin Bishop, Bryan Bishop Estate Agent, 6a High Street
Dawn Somerville, Essie & Betsy, 12 Church Street Tanya Thanyaphon East, Thai Legacy Therapy, 27 High Street Morwenna McDonald, Welwyn Osteopathy, 27 High Street Gill Buszmanning, Comfy Soles Chiropody , 27 High Street Kelvin Dean, Old Welwyn Clinic, 27 High Street Deniz Gentle, Headmistress Hairdressing, 10 Church Street Jay Miah, Taj Mahal Restaurant, 2 High Street Claire Austin, Austin’s Funerals, 16 High Street Laura Moyes, Laura Kate, 15 High Street James Bainbridge, The White Hart, 2 Prospect Place Lisa Green, Belvoir Estate & Lettings Agents, 9 High Street Marianne Hawes, Danesbury & QVM Charity Shop, 4 High Street Gobind Singh Lidhar, XO Wine Merchants, 6 High Street
I am writing as the Rector of St Mary’s Welwyn and on behalf of nearly all of the traders in Welwyn village who have signed the attached letter (Ed. see separate Post) about the COVID19 restrictions. I should also add that after the final draft, Austin’s funeral directors, another important local business, wrote to say that they would wish to be included.
Whilst we understand that there was pressure to make quick decisions and that public safety was paramount, we also know that now you are looking to revise arrangements on a semi-permanent basis. As the photograph demonstrates, footfall is now so low in the village that the present measures in place are clearly disproportionate. Therefore as the letter states, we would like to see full consultation with local stakeholders including traders, and a major scaling back of the measures.
If I might add by own alliterative contribution, there are three other concerns: buses, beer and bicycles.
Whichever way the one way system goes, many people, including most of our elderly residents, rely on buses to access the village and its services. They cannot be dropped off half a mile from the doctors surgery, for instance – this needs to be thought through.
Brewery lorries need to access the village (historically Welwyn owes its existence to the coaching inns). In particular a south bound one-way along Mill Lane would mean beer could simply not get to the White Horse, and would make it difficult for other pubs.
Perhaps more personally, any one-way system should make proper provision for cyclists. At the moment I can ride from the church to my house and church school at the other end of the High Street – 200 yards on a village road. Without proper provision this would become nearly a mile along the incredibly busy by pass, three roundabouts, including a ¾ turn at the ‘Clock’ roundabout entrance to the A1M. Hundreds of commuting cyclists use this route, and the risk of a rush hour accident would be very high.
Thank you for reading this. We understand that there are difficult decisions to make, but do be in touch if we can help with on the ground meetings. We are in touch with all the traders and could easily pull a consultation meeting together to help you with your planning.
The Welwyn Planning & Amenity Group has been in regular conversation with Cllr Richard Smith with regard to the current and proposed COVID-19 restrictions in Welwyn village.
It has been our understanding that the current, unsatisfactory, arrangements would be amended as soon as possible. We appreciate that this has had to wait for clarification of central government decisions.
The truly draconian measures in place are destructive to the community, its lifestyle and its operation.
The High Street traders and shops, as well as residents, are seriously affected by what has been imposed on the village. In order to allow Welwyn to survive at all, the current restrictions need to be reversed and, if another scheme must be introduced, replaced with something as minimally invasive as possible. Residents have coped until now with social distancing and really the only precaution that is necessary is for everyone to wear a face covering when inside a shop and to queue one metre apart where necessary.
The WPAG Position
The Welwyn Planning & Amenity Group fully supports:
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.
Fish were rescued as the River Mimram dried up last autumn. Now, with the very wet February and March, the river is full and flowing faster than it has done for years. Clear water bubbling along and clearing some of the silt which has built up over time starting to reveal the gravel bed of a chalk stream. The river is fed by the underground aquifer and the chart shows the highest level of groundwater for several years. (On the chart, the Green band is Average)
However, all the ‘river life’ was either rescued or died last autumn, so it looks pretty dead. The Environment Agency (EA) expect it to take three or four years for ‘river life’ to return to normal. (Does this sound familiar?) The hope is that fish will migrate downstream from parts of the river that did not dry out, such as the mill pond towards Kimpton.
So the plan is to conduct a series of ‘electro’ fish surveys throughout the year to see if the fish do return. To do this they hold a ‘wand’ with a low electric current in the water, which stuns the fish long enough for them to be counted and measured without doing them any harm.
The first of these surveys was done recently and, while they didn’t find much, they did find several bullhead fish – a start. And some tadpoles!
If the fish population does not recover over the next few years, they will restock the river with breeding fish.
However, in 2020 it seems to be one extreme or the other, in April we only got 24% of the average effective rainfall and May looks likely to be the driest May on record. Already the river level is starting to drop……
THE WELWYN PLANNING & AMENITY GROUP ARE AWARE OF YOUR CONCERNS
OUR SHOPS ARE COMING BACK. PLEASE SUPPORT THEM – OR WE MAY LOSE THEM, AND THE VIBRANT ECONOMY OF OUR VILLAGE.
WITH REGARD TO THE CHANGES TO THE TRAFFIC FLOW IN THE HIGH STREET, WPAG IS AWARE THAT “ONE SIZE DOESN’T FIT ALL” and is concerned at the effect these changes will make on residents and businesses.
WPAG will be closely monitoring the situation. We will liaise with Herts CC and WPC and try to ensure arising issues are resolved.
Please note that the changes are temporary. The initial trial is for 21 days from 25th May. This is, however, likely to be extended, dependent upon government guidelines.
RESIDENTS PLEASE LET US KNOW:
What problems you are directly experiencing due to the changes
Whether the changes have made you feel safer on the High Street
Any modifications that you feel would improve the situation
BUSINESSES – PLEASE LET US KNOW
If you are currently operating, has footfall in your business dropped since the changes were implemented? By approximately how much?
If you are due to open, how you feel the changes might affect your business?
Any modifications that you feel would improve the situation
WPAG feels that this temporary scheme can work if there is adequateco-operation, consultation and communication from those running it.
Indeed, the village has coped admirably until now and the few shops that will reopen may not affect the footfall in the village enough to warrant the current amount of disruption.
WHY ARE THESE CHANGES HAPPENING?
In preparation for the reopening of some of our shops and businesses, Central Government has provided funds to local councils to deploy measures that will:
Provide space to pedestrians
Allow people to use our high streets safely
Queue safely outside shops
Pass each other at a suitable distance.
Such measures have been actioned throughout the UK where the existing footway width does not allow people to keep 2 metres apart.
The measures now temporarily in place have taken space away from vehicular traffic in order to enable people to keep 2m apart, in line with official guidelines.
Traffic flows are currently lower than historic trends, whilst both pedestrian and cycle usage have increased, many people are continuing to work from home and public transport usage patterns have all changed. The new measures will be kept under review to check they are operating as intended and, as necessary, adapted to a changing situation.
FOR GENERAL INFORMATION
The following extract is from Public Health England’s statement on the Gov.UK website:
Coronaviruses can be spread when people with the virus have close, sustained contact with people who are not infected. This typically means spending more than 15 minutes within two metres of an infected person, such as talking to someone for instance.
So, passing someone quickly in the street would not appear to pose any risk, whereas chatting in a queue less than 2metres apart would.
NHS advice posted on 26/05/2020 was that masks/face coverings should be worn in shops, crowded areas and on public transport.
We can also take encouragement from the fact that, in terms of risk, the infection rate in the East of England is very low in comparison with other areas.
(Ed. In David Cheek’s Post of 22nd March 2020 you were briefed on the Hertfordshire County Council’s (HCC) Consultation on future transport plans, which was scheduled to close on 31st March 2020).
Working with the Welwyn Parish Council, and the Welwyn Parish Plan Group, your Committee studied those sections relevant to Welwyn and we contributed to the submission produced by the WPC.
We re-produce below the Introduction to the WPC Submission for your convenience.
We expect that the full WPC submission on this Consultation, which is very lengthy, will be published shortly on the WPC website.
Welwyn Parish Council
Welwyn Parish Council is pleased to offer comment within the consultation process, on this important piece of strategic planning.
Welwyn civil parish has three main settlements, separated from each other by fields and woodlands of the green belt: the settlement of Oaklands & Mardley Heath and the villages of Digswell and Welwyn. The parish is largely residential but small businesses and farmsteads are scattered throughout. Residents and businesses benefit from post office facilities and a mix of shops in all three areas and a wide range of amenities: a primary school in each area (the secondary schools are in WGC or further afield); the Welwyn Community Library; Welwyn has 3 churches, Digswell has 2 and both have Village Halls used for recreation, sport and social events.
Soccer and cricket pitches in Welwyn, owned and maintained by the parish council, are used by clubs from within the Parish and further afield; there are tennis clubs at Welwyn and Digswell, a bowls club at Welwyn and children’s play areas in Welwyn and Digswell. There are many open spaces and local nature reserves with rural footpaths, providing for informal recreation as well as local wildlife. With a population of over 9000, our Parish is relatively large; it is highly regarded as a place for families to live and house prices and the buoyant property market reflect that.
Comments on the GTP have been co-ordinated under the aegis of the which included:
• Welwyn Planning and Amenity Group – WPAG – formed over 60 years ago, to encourage, and coordinate public interest in all issues concerning Planning and Amenities in and around Welwyn)
• Welwyn Parish Plan Group – WPPG – who compiled the current Parish Plan in 2008 which sought to represent the wishes and ideas of the community in Digswell, Oaklands & Mardley Heath and Welwyn, propose a strategy to show what we should aim to achieve. It has been used to help drive change and as a reference to influence policy
• Individual residents.
The Working Group has also encouraged residents to make their own responses to this consultation.
The majority of the detail relating to Welwyn Parish is contained in the South Central Growth & Transport Plan; only one project (PR27) in the North Central GTP is relevant to Welwyn but it should be noted that SM93 (in the NC Plan) duplicates the detail of SM98 (in the SC Plan), albeit with a different and arguably misleading title. The following sections offer comments on the various schemes that impact upon our parish area.
Welwyn Parish Council (WPC) is pleased to comment on the 2020 Site Allocation that revised the Local Plan (2016) and was approved by the Welwyn Hatfield Borough Council (WHBC) Cabinet and issued for consultation. We have restricted our comments to those aspects of the Plan that affect our area of responsibility as far as possible.
We have reviewed the sustainability and legality aspects and consider that the portion of the Local Plan (as approved by WHBC Cabinet) relating to this Parish, meets these requirements. We therefore largely welcome and agree with the Plan. We support WHBC’s decisions regarding the sites to be allocated in Welwyn, Oaklands and Mardley Heath (there were none proposed for Digswell) with the exception of one site (HS32) for which we maintain our original objection on soundness grounds. We are concerned that WHBC have not yet announced the formulation of the “gap policy” as recommended by LUC as settlement coalescence is a major issue for us.
This Council was very concerned that some additional sites proposed by prospective developers would have meant great harm to our parish. Our concerns were regarding green belt harm and boundary sustainability, unsuitable ground e.g. partial flood plain or too close to the River Mimram (the important chalk stream that runs through much of the parish) or necessitating major infrastructure implementation for feasibility or sustainability.
All of the sites originally proposed following the 2019 Call for Sites for Digswell and most of those proposed for Oaklands, Mardley Heath and Welwyn, had major suitability, access or green belt boundary implications. The Welwyn sites in particular, if they had been selected for allocation, would have had a massive negative impact on the village: traffic; unsuitable road infrastructure; visually intrusive, marring currently open rural views; impinging upon local open spaces.
We strongly believe the WHBC assessment of the 4 Welwyn sites rejected under the CPPP and Cabinet decisions, included arguments and conclusions that were seriously flawed. When considered collectively (which part of the argument for their original inclusion maintained: to support infrastructure improvement) the harm to the green belt would be very great, almost catastrophic and not merely the “medium-high” of each individual site (with which we also disagree). Accordingly we were pleased that WHBC decided to exclude from site allocation, all sites which would cause medium-high or worse harm to the Green Belt, which encompassed those 4 sites. We fully support that decision.
Any infrastructure implementation would involve considerable investment, but we recognise that this is largely a matter of will and prioritisation and not an absolute barrier to development. This Council has consistently asked for infrastructure such as roads, bus routes, schools and health facilities to be established commensurate with the timescales of developments (ideally in advance) and not months or even years behind with resulting congestion, noise, pollution, inconvenience and destruction of the rural nature of much of the parish (especially the historic centres of Digswell and Welwyn villages).
(Ed. The following analysis was prepared by Ian Skidmore for the Welwyn Parish Plan Group, who worked with WPAG and the WPC as members of a Local Plan Working Group, formed for this purpose. Maps have been added to refresh memories.)
This document is a response to the Consultation on Proposed Changes to the submitted Draft Local Plan 2016 (Site Allocations) 2020. It is submitted by the Welwyn Parish Plan Group.
The Draft Local Plan was submitted in May 2017 and has been
reviewed for soundness and legality in several stages by the Inspector. His
analysis noted that the Plan as submitted did not meet the full objectively
assessed need (OAN) for housing. He was, among other things, concerned that if
housing growth did not keep pace with projected growth of employment in the
Borough there would be excessive inward commuting. (WH is already a significant
The housing numbers on which the Plan was based were out of
date at 12000 and based on further analysis the target figure should be 16000.
There have been arguments and counter-arguments about the accuracy of this
figure, which leads to an annual building rate of 800pa, but the borough’s
independent consultants believe it to be the right figure within the accuracy
limits that forward projections carry..
On the basis of this the Planning Department created a
series of options for the Council to consider, with their recommended strategy delivering
15952 houses, 48 under target, and a shortfall of 1.63Ha in employment land. This
included all the sites from the 2016 submission plus 36 additional sites none
of which, with the exception of a school site in Welham Green was considered to
be high harm to the Green Belt.
The Council Cabinet Planning and Parking Panel (CPPP) did
not accept this option nor any of the other 3 options presented and recommended
to Council a reduction to a lower figure of 14206 units. Cabinet approved this
figure. The changes to the original Draft that this figure represents is the
subject of this consultation.
The primary basis for the lower figure is the removal of
sites from the original Plan that were considered to be moderate to high or
high harm to the Green Belt and ensuring that none of the added sites fell into
these categories. There is no technical justification for this lower figure and
it clearly falls significantly short of the OAN
As with previous consultations our understanding is that the
focus of this consultation is on Soundness and Legality alone.
Soundness: There are four tests of soundness:
Has the Plan been positively prepared, is it based on a
strategy which seeks to meet the objectively assessed development and
infrastructure requirements and is it consistent with achieving sustainable
(The revised NPPF, 2019, says the target should be as a minimum the OAN but this may not
apply strictly to WH which started its Plan process several years ago under
NPPF 2012) that states that it should meet
Is the Plan justified, is it an appropriate strategy based
on proportionate evidence?
Is it effective, can it be delivered over the Plan period?
Is it consistent with national policy, enabling sustainable
development consistent with NPPF?
This covers Community Involvement, Compliance with the Local
Development Scheme, Duty to cooperate with adjoining authorities, conformity
with Town and Country planning regulations, Sustainability and Habitat
Welwyn Parish: Comments on the 2016 Draft Plan.
The Parish Council commented on the soundness of the
proposals in 2016 for inclusion and exclusion of sites in the Parish for the
Draft Plan. The Parish Plan Group was involved in formulating these comments
and endorsed them. They are summarised as follows:
Of the 5 sites proposed none was included in the Plan, it
was our opinion then and remains now that the rejection of all Digswell sites
was legal and based on sound reasoning. No Digswell sites appear in the 2020
Our view was then and remains that, with the exception of
the Traveller site, GTLAA04 the decisions taken were sound and legal . Thus
OMH6, and OMH7 were rejected for sound NPPF reasons relating to the Green Belt.
OMH 5 and OMH 8 passed the HELAA stages and were proposed in the Plan. They
remain in the revised Plan in 2020 and we agree with this.
In 2016 we considered that the Plan was legally compliant
The following summarises our comments then and we have no
reason to change our view.
Wel1 The Borough
rejected this site and the adjacent Wel 2 and Wel15 sites for several reasons
although they passed the HELAA Phases. They should be considered together
(Housing Site Selection-Background Paper Appendix E). Most importantly the
expansion of the green belt boundary would lead to ribbon development between
Welwyn and Codicote; one of the prime purposes of the green belt is to prevent
such coalescence (NPPF 2012 para 80). There are serious issues with access,
requiring a new bridge and widening of a rural road with effects on a
designated wildlife site (WS5) and an LNR and there is potential for flooding.
The site topography is open and housing on this site would dominate the
Wel5, the “school
reserve site” was rejected at HELAA Phase 1 as it was impossible to achieve
access. HELAA 2016, Appendix D).
Wel 6, 8, 9, 10,12,13
were all rejected at HELAA Phase 1. They were all in the green belt and neither
in, nor contiguous with, a settlement bounded by the green belt boundary (HELAA
2016, Appendix D) and thus were contrary to NPPF (para 80 2012 version).
Wel14. Because of
access issues this site would only be viable in conjunction with Wel 1 and Wel
2 and the reasons for rejecting it mirror those for the other two sites (HELAA 2016,
Wel16. Access to this
site is via a village road that is mainly single lane with poor pedestrian
provision and with a pinch point that cannot be modified. (See Highways comment
in HELAA 2016, Appendix G). Emergency access via single-track roads would be problematic.
The connection with the existing settlement of Welwyn is tenuous.
We considered these
decisions to be sound and legally compliant..
Wel3; Previously developed land, (Affinity Water
Site). Three houses have already been built on this site and the plan was for 7
more, a total of 10. Assessment suggests there are no unmanageable constraints
to developing this site. (HELAA2016, Appendix E)
Wel 4. This partially-developed site would
extend the green belt boundary to the A1(M) junction 6 northbound exit slip
road, which is a good permanent boundary. The borough resisted extending the
site further to the southwest to maintain a significant and defendable gap
between Welwyn and Welwyn Garden City. (HELAA2016, Appendix E). There is
excellent public transport connectivity.
Wel 11. This site, part previously developed
land, would have moderate to strong green belt boundaries. There would be some
loss of openness. Good access to public transport. (HELAA2016, Appendix E).
Traffic sightlines would need to be managed.
We considered these decisions to be sound and
Call for sites.
Following the Call for Sites in 2019 WHBC employed a four-stage
process to determine which sites could be considered suitable for development.
HELAA stage 1, HELAA stage 2 and for those sites passing
HELAA stage 2, and therefore comprising a shortlist, a detailed assessment of
suitability using a variety of criteria. This shortlist was then examined first
in a detailed analysis of the individual sites and then assessed at the
settlement level, that is the effect on the overall settlement of those sites
that were still under consideration.
HELAA provides information on the range of sites that are, in principle, suitable, availableand
achievable to meet development needs. It is for the subsequent development
plan process to determine which of those sites are the most suitable to meet those
needs. Green Belt policy and other considerations are not dealt with during
4 sites were reintroduced from the 2016 list all of which
had been rejected at that time. In 2019 Dig 3 and Dig 5 failed at stage 1 of
HELAA, Dig 1 and Dig 4 at stage 2. Thus no sites progressed to further
assessment. We consider these decisions to be sound.
3 sites were assessed; OMH 6 failed at stage 2, OMH7 and OMH
9 passed stage 2 and so were taken forward to site assessment.
The sites considered were Wel 1, 2, 6,14, 14a, 14b, 15, 15a,
16 and 17, plus an unnumbered site north of Tudor Road. This last was rejected
outright as being below the size for consideration. Of these Wel1, 2, 6, 14,
15, and 16 were sites previously rejected in the 2016 analysis 14a, 14b, 15a
and 17 were new proposals.
HELAA stage 1:
All sites with the exception of Wel17 passed HELAA stage 1.
Wel17 failed this stage because it is not contiguous with a Green Belt boundary.
While it adjoins the Frythe, also outside the Green Belt boundary, development
of that site was permitted as the site was brownfield. It is still washed over
by the green belt and does not at any point adjoin a green belt boundary. This
decision therefore is consistent with NPPF and therefore sound and legal.
HELAA Stage 2:
Wel 14, 14a and 15a failed stage 2.
Wel14: This site
was assessed as unsuitable for development in 2016 due to the negative impact
on nearby Heritage Sites, ie Grade 2 listed buildings at Linces farm. There was
also uncertainty about the availability of at least part of the site and
achievability was uncertain because of access problems. The new proposal in
2019 reduced the size of the site and this part does not have availability
problems and could be developed immediately. However the heritage issues remain
and WHBC conservation advisors agree with Historic England. Primarily because
of the heritage aspects WH consider the site unsuitable for development. We concur with this view and consider
the decision to be sound.
Wel14a: The WH
analysis notes that the physical constraints on this site are primarily access.
Without the development of Wel14, rejected as above, or 14b, see later, access
would be impossible. Highways noted that in any case Kimpton Road is too narrow
for pedestrian access and expressed concern about access via School Lane.
Thames Water indicated that upgrades to drainage would be needed in advance of
any development. The heritage issues for
14 also apply here. WH determined this site to be unsuitable for development. We agree with this decision and
consider it to be sound.
Wel15a: This is
land at Fulling Mill Lane, south of Riverside. This is at risk of flooding. Highways point
out that on its own it is not viable given the necessary improvements at
Singlers Bridge that would be needed. Thames Water notes that waste-water
capacity would need an upgrade. There are serious heritage concerns, Guessens
and the Manor House, and the site is in AAS7 about which there is currently very
WH considers 15a to be unsuitable
for development. We agree with this opinion and believe it to be sound
Wel 1, 2, 6, 14b, 15
and 16 passed HELAA stage 2 and went forward to detailed assessment.
Wel 1 and 2 were previously assessed in the HELAA in 2016
and the 2019 site selection provides an update but little new information.
Wel1. The 2016
HELAA noted the obvious physical constraints of access, the need to build a new
bridge and widen Fulling Mill Lane at the expense of Singlers Marsh owned by
WHBC. Proposed entry to the site would be from a new road parallel to Kimpton
Road. Waste-water capacity upgrade would be needed. Historic England is
concerned about effects on views out from the Conservation area. Nature Reserve
and wildlife sites( WS5 and WS19) would be affected. The site is within AAS7.
Site is located within a Groundwater Source Protection Zone.
Overall in 2016 this site was classified as available, with uncertain
achievability, deliverability 6-15 years. The 2019 HELAA adds nothing significant
Wel 2. Wel 2 has very similar issues to Wel 1. Access
to the site would be from Fulling Mill Lane. The document suggests that there
would be access to Wel1 from Wel 2 but there is no physical connection between
the sites to allow this. Access to Wel 15 is possible from Wel2 but there is
still no connectivity with Wel 1. Similar issues with road widening and Singlers
bridge. WS 5 and WS 19 and AAS 7 are also affected. Waste-water network would
Overall assessment: Available, achievability uncertain,
timescale 6-15 years.
The 2019 HELAA adds nothing of significance
Wel 6. Wel 6 was
not considered in 2016. The 2019 HELAA has a detailed assessment. Access would
be from Kimpton Road, this is too narrow for pedestrian access. Environmental
Health notes the potential for contamination issues within 200m (gravel
extraction and engine testing site?) Site is inside the inner Groundwater
Protection Zone. The area backs onto the garden of a grade 2 listed building on Fulling Mill
The adjacent land is in North Herts and is not proposed for
allocation in the North Herts Local Plan, currently under examination. That
area is not contiguous with a green belt boundary and so is not developable
This site is considered available but achievable only with
extensive highways upgrades associated with Wel 1 and 2 and if it is practical
to create access for pedestrians and cyclists which would require upgrades to
Kimpton Road. This site is not viable on
its own. Delivery timescale 6-10/11-15 years.
Wel14b: This was
also not considered in 2016 as it had not been brought forward. Access is
proposed via School Lane that has a pinch point at the High Street junction
with a listed building creating a single lane road. Alternative access is
proposed from Kimpton Road but this would require development of Wel 14 and
14a, both of which are considered by WH to be unsuitable for development. The
report is suggests that at this stage (HELAA) the potential for some
development in the southern part of the site might be feasible, ie not as far
up as Wel 14a.
They classify the site as: suitable (limited, lower part only),
available and achievable with a deliverability timescale of 1-5 years subject
to waste-water network upgrades. We challenge this assessment because of
fundamental access problems. These also apply to Wel16, see below.
Wel15a is considered in HELAA 2019 this site was reviewed in HELAA 2016. There is no access directly from Fulling Mill
lane owing to landownership issues so access would have to be via Wel 2 and Wel
1 with which it is being co-promoted. The same road and bridge issues arise
therefore for this site. The site is within AAS7 and there is evidence
suggesting that this was the site of the roman settlement. Detailed study would
be needed before submitting planning applications. Given that the southern part
of 15a was rejected because of historic buildings above ground we argue for a
detailed archaeological survey and a block on development if anything really
significant (cf Welwyn roman baths) is
found. The site also adjoins the Welwyn Conservation Area and WH thinks any
development should be limited to the eastern part of the site, between
Riverside and the Evangelical church, to minimise effects on this Area. This
would reduce capacity from 45 to 14 units.
WH rated the site, without 15a, as suitable, and available
but with uncertain achievability and an uncertain timescale 6-15 years.
Wel16: Wel16 was
in the 2016 HELAA as a much larger site with a capacity of 250 units. It was
assessed then as unsuitable and unachievable. Primary concerns were for access.
It was reintroduced as a smaller site in 2019 reduced from 10ha to 3.3 ha and
95 units. There are still serious access issues via School Lane/Ayot St Peters
Road and Whitehill.
The topography of the site is difficult, steep and with the
risk of water run-off.
The site is in a groundwater protection zone. Waste-water
network will need upgrading. (timescale 1-3 years.
The archaeological significance of the area is high and
assessment would be needed in advance of any planning application.
WH considered Wel16 to be suitable, available and achievable
in a 1-5 year timescale. We challenge this assessment of suitability as we
consider access for a further 95 dwellings via a single-lane pinch point and
single-lane rural roads to be impractical . This of course would be exacerbated
by any development of Wel14b.
The HELAA exercises
are solely about suitability of the sites, their achievability and their
deliverability. They do not consider any
other factors, perhaps most importantly the Green Belt or their overall effects
on the settlements to which they would belong if developed.
For this process only those sites that passed stage 2 of the
HELAA 2019 were considered. The HELAA findings are summarised but the focus is
on six things:
Green Belt Study Review
Green belt Boundary Appraisal
Strategic Advantages and
Green Gap policies
Green Belt Review:
The fundamental aim of Green Belt policy is to prevent urban
sprawl by keeping land permanently open. The essential characteristics of Green
Belts are their openness and their permanence. (NPPF para 133).
As far as Welwyn Parish is concerned purposes 3 and 4 are
key. NPPF refers to towns but in fact it means any settlement that is excluded
from the Green Belt, be it town or village.
While neither OMH7 or OMH9 is of high harm their
geographical location to the west of the A1(M) would mean a breach of the very
strong green belt boundary that the motorway creates and the additional 14
units in total that these two sites would deliver does not represent
exceptional circumstances that that resetting the boundary would entail. Thus
these sites were rejected at this stage. We concur and agree that exceptional
circumstances do not exist.
The site is contiguous with the green belt boundary at
Hawbush and Glebe Road so this is not a barrier to development under NPPF. The
site as a single unit does not contribute to preventing the merging of towns
(WGC and Harpenden). It does however make a significant contribution to
preventing encroachment on the countryside. In particular it would destroy the
countryside vista from this boundary. In addition it would enclose in the
Assessment of the whole parcel of which this is part (P7) is moderate /high harm. Similarly,
development of P7a, (Wel 1, 2 and 15 ) is considered moderate/high harm. The
report concludes that these three Stage 2 sites in combination or isolation
would lead to encroachment of the countryside to the south east and south west
Any new green belt boundary would be significantly weaker than
the current one. As noted above this is defined by the perimeter of Hawbush and
Glebe Road and was drawn tightly round the existing village when the boundary
was established. Wel 2 is not contiguous with the current boundary but is
linked via Wel15. This would mean that if Wel15 was not developed Wel 2 could not be developed. This emphasises
the focus of developers on all three sites and
on our contention that the overall harm to the green belt of the three
sites (4 with Wel6) combined should be assessed rather than assessing them for
possible effect as single sites.
The Sustainability Appraisal is slightly in favour but it is
difficult determine what leads to this assessment.
A circular argument is presented that developing Wel 1, 2
and 15 would enable the highways improvements and bridge building that developing
these sites would require. The Council
needs to look carefully at the logic of this argument..
The overall conclusion is that development of the whole
parcel P7a taking it out of the green belt would cause moderate /high harm. However, they use the circular argument above
to say it would be a good thing and that the new green belt boundary would be similar
in strength to the existing one. Thus the site is suitable for allocation on green belt grounds. We strongly disagree
with this and suggest that the three
sites together would cause high harm to the green belt. Implications for
any Green Gap Policies must also be taken into consideration, see below.
Much of what applies to Wel 1 applies here but as it is not
contiguous with the green belt boundary it would depend on the development of
Wel15 to proceed, see above. The borough note that Wel 15 makes a significant
contribution to two national green belt policies, P3, safeguarding from
encroachment and P4 preserving the setting and special character of historic
towns (and villages!). In addition it is noted that currently the physical
openness of the site is high. The assessment of harm to the green belt is assessed
as moderate /high, we consider the potential harm to be high. The same circular
argument is used in relation to
development and road widening.
There is also a statement in the Overall Conclusion as
“ It is assumed that
the site would only be allocated in combination with Wel 1 and Wel15 due to the need to provide highways upgrades
and this would enclose Wel2 to the south and west with Fulling Mill Lane to the
east. The existing village extends further west and north than this site and so
development would not significantly extend the urban area of Welwyn”
This is, with respect, nonsense. The westward extension of
Welwyn is indeed the corner of Hawbush, further to the west and any northern
extension relates to Danesbury across the Mimram valley beyond Singlers Marsh. However,
the urban area of the village would be increased by at least 15% if Wel 1,2 and
15 were developed, hardly insignificant!
Overall they consider this site on balance to be suitable for allocation and the green
belt boundary should be extended while ensuring that Green Gap policies are
considered (see later). In relation to this it is very difficult to see how a
Green Gap can be maintained if developing these sites goes ahead.
We disagree strongly with their assessment.
This is considered out of sequence as it is key to the
WH note that this site has two major green belt
contributions, preserving the countryside from encroachment and preserving the
setting and special character of historic towns ie P3 and P4, They note it is
directly adjacent to the Conservation Area. Its harm is assessed as being moderate/high. We think this is a site of
high harm. The key strategic advantage of this site to developers is that,
while there is no direct access to it from Fulling Mill Lane it unlocks both
Wel 2 and Wel 6 as it is contiguous with the green belt boundary.
WH considers the site suitable
for development. We strongly disagree.
This is also out of sequence as it is being seen as related
to both Wel 1 and Wel 2 and could only be developed in association with them as
it is not contiguous with a green belt boundary.Thus its effect on the Green
Belt is considered moderate/high.
Development however would leave an odd enclave of NHerts land on the northern
side of Kimpton Road. Again the highways argument is applied to Fulling Mill
Lane and the bridge. On balance it is considered suitable for development. We disagree and argue that Kimpton Road
provides a permanent physical barrier that can serve as a strong green belt
boundary. Were this boundary to be breached it would put both Fulling Mill Lane
(Welwyn Hatfield) and Kimpton Road/Oakhill Drive ( N Herts) at risk of being
excluded from the Green Belt putting them at risk of further development. We
note that NHerts currently cannot develop
their part of this area as it is not contiguous with a green belt boundary in
Wel 14 b is part of a wider green belt parcel Parcel 8 the
totality of which makes a major contribution to preventing encroachment on the
countryside. The parcel is open and rural and any reduction of it would be very
difficult to defend with a new boundary and so it is rated high harm. On that
basis WH state that this site should not
be considered for allocation. We agree.
As noted above this site is much reduced from the original
proposal by the developer. It falls within a larger high harm parcel (P6c).The
green belt analysis notes that it makes
a significant contribution to safeguarding the countryside from encroachment.
They also note that the rising topography of this site above the low-lying
village would tend to dominate. There is
no physical boundary to the site that might serve as new green belt boundary.
They conclude that this
site should not be considered for allocation. We agree with this
Thus the final
position is that the sites in the original Plan Wel 3, 4 and 11, to which we
offered no opposition, remain as part of the 2020 proposal together with Wel 1, 2, 6, 15 as
assessed above were included in the package presented to the Cabinet Committee
for consideration in January.
As noted above we
believe that the effects on the Green Belt have been underestimated for Wel
1,2, 6 and 15. In assessing harm to the Green Belt each has been considered as
a separate entity. If it were feasible to develop perhaps one of them as such
that might be considered reasonable. However, as all the reports have made
clear these sites are only viable from a development infrastructure standpoint
if they are developed together allowing the financing of a new bridge over the
Mimram and the widening of Fulling Mill Lane and Kimpton Road. Developed
together they would enclose the western slopes of the Mimram valley and
Singlers Marsh completely and destroy the open vistas from the Hawbush and
Glebe road estates. We strongly contend
that this would represent high to very high harm to the Green Belt. See comment
below on Green Gap policy.
The Green Gap policy aims to ensure that that the current
gaps between settlements are maintained. This will of course work in tandem
with the Green Belt purposes but can be considered as operating on a larger
scale than potential changes to the green belt boundaries, looking at the
relationship between urban and rural landscape from above rather than at ground
The review carried out by LUC identified several key green
gaps both within the parish and between the parish and other areas. The Green
Gap considerations for Welwyn Parish relate to the spaces separating Welwyn
from Oaklands/Mardley Heath, ie Danesbury, separating Welwyn, Oaklands and Mardley
Heath from Digswell, ie Lockleys Farm and the area to its south , The Mimram
valley separating WCG and Digswell and the south-eastern side of the A1M (Monks
Walk school and Malms Wood). The other important one from the standpoint of the
Local Plan and the one at highest potential risk from the site assessments is
the gap between Welwyn and Codicote. Wel 1,2
6 and 15 are all contained within
and effectively are this green gap
and including these in the Plan would destroy the gap. This reinforces the need
to avoid development in this area.
The other key Green Gap is the small one between Mardley
Heath and Woolmer Green. We note that the two sites bordering Heath Road, WG7
and 7a, have been rejected and this will maintain this gap.
While the officers provided the Borough with options to
provide housing close to the OAN of 16000 these options were not accepted by the
Cabinet Planning and Parking Panel. A proposal
to remove from the recommended option all sites for which the green belt
assessment was moderate/high harm or greater from the draft 2017 Plan was
considered. This resulted in a shortfall of about 2000 houses. Key in this was
the removal of Symondshyde from the draft Plan. This proposal was voted through
and passed in Cabinet. As far as Welwyn Parish is concerned all four sites
assessed as suitable in the 2019 exercise, Wel 1, 2, 6 and 15 have been removed
from the draft leaving a total of 69 houses, close to the 67 in the original
Plan rejected by the inspector.
There is no doubt that this lower target is a high-risk
strategy for the Borough as a whole. Given that the Inspector found the 2017
Plan unsound because it fell short of the OAN it seem likely that this revised
Plan will suffer the same fate. Furthermore, when this revised Plan was communicated
to the Inspector in EX182 his response (EX183) made his concerns quite clear.
It is not permissible under Regulation 19 to remove sites from the Plan as
submitted unless they are Major Modifications intended to address matters of
unsoundness flagged up by the Inspector. In other words what the Council
proposes is not only numerically but also procedurally unsound.
This argues very strongly for the reintroduction of the five
sites removed from the recommended option. These are Symondshyde, Cuf 7 and 12,
and BrP 4 and 7. Adding these sites back to the reduced figure of 14206 would
give a total of 15886 close to the OAN target. Doing this may well avoid any
further sites being added to the Plan.
It is our opinion
that this is what the Borough should do.