Appendix A

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

Key Points raised during November 2012 – January 2013 consultation

Document: Emerging Core Strategy

Section Foreword
Consultation Point
GENERAL comments raising the following points / Number of comments
Hertfordshire County Council
There are a number of areas where it is considered that there is a need for either additional wording or for further work to be undertaken
  • the need for the IDP to be supported by a comprehensive assessment of the necessary infrastructure required to support growth over the plan period;
  • the need for greater clarity relating to, and safeguarding of potential mineral reserves within the locations identified as ‘possible broad locations’ and ‘possible urban extensions;
  • the need to ensure that future iterations of the Core Strategy accurately reflect recent changes/forthcoming changes relating to the statutory functions of the county council (e.g. in its capacity as Lead Local Flood Authority) and emergence of other bodies (e.g. Local Nature Partnership);
  • where necessary update the supporting evidence base to ensure that the growth set out within the emerging core Strategy is deliverable (particularly in relation to transport modelling), and update the Sustainability Appraisal where necessary;
  • the need to take into account potential constraints relating to growth areas which may come forward on land outside of Welwyn Hatfield

Comments by individuals and other bodies
  • Regarding first bullet point – sites for housing should be selected throughout the borough in a fair and balanced manner without influence or bias.

Total No. of GENERALcomments / 2
OBJECTIONS raised on the following grounds / Number of comments
Consultation Process
Hatfield Town Council
  • Concerned that we are only being given one option to consider. Believe that there must have been other options which we and the community should have been consulted on.
  • Endorse the charrette approach to building new communities with the tolerance or approval of the existing community that will be affected.
  • The consultation timetable has not been convenient, having been postponed many times
  • Some residents believe that this has been done deliberately to stifle healthy debate and is contrary to localism.
  • Some of the community perceives to be the only option is "a done deal". More work needs to be done to change that perception.

Welwyn Garden City Society
  • It would appear that the end product has been chosen and the facts cherry picked to support the decision. It is not very convincing
  • The NPPF lists the core planning principles that should underpin planning. The first is that planning should be genuinely plan led empowering local people to shape their surroundings

CPRE
  • The Core Strategy and the Land for Housing outside Urban Areas have to be read together to fully understand the council's intentions
  • Both documents as inextricably linked and none of the questions online allow CPRE to cover the concerns the documents raise
  • Consider therefore that the consultation is flawedand if the Core Strategy is based on this may be unsound.

Comments by individuals and other bodies
  • Opportunities for responding are too complicated.
  • Consultation was very opaque.
  • Consultation not well advertised.
  • The requirement to use a separate paper response form to comment on each part of the document is discouraging.
  • There has been no public meeting to allow people to ask questions, which would go a long way towards a clearer understanding.
  • The glossy brochure is very good as far as it goes, but it only provides an overview. Readers should be directed to learn more from the website.
  • Lack of options being consulted on.
  • Important decisions seem to be already made (‘a done deal’).
  • Many of the concerns raised at Issues and Options 2009 consultation are again reflected in the comments made on this document.

The Document
Welwyn Garden City Society
  • The suite of documents covering the Emerging Core Strategy is complex and boring, difficult to navigate and cluttered by a large amount of irrelevant detail obscuring the main issues.
  • Garden cities concept is being revisited and should be reflected in the Core Strategy.
  • Difficult to see how Core Strategy can be delivered when responsibility for so many aspects rest with other organisations.
  • Core Strategy does not take account of current social and economic trends.
  • WGC has already reached optimum size and the size that the infrastructure of the town was designed for.
  • There is no mention of the option of building a new separate town/village to meet the Housing Target along the lines of the suggestion made at the University of Hertfordshire Charrette in December 2008.
  • The Emerging Core Strategy talks endlessly about sustainability, but the Society could find very few places where the principles were properly addressed.
  • Concerned about the economic strategy to support these developments: there is the assumption that the private sector will jump into the breach. Given the current global economic crisis, this does not seem likely and we need a clearer, more definite economic policy to link to housing developments otherwise we could end up with a housing situation similar to Spain, Ireland or parts of China.

Comments by individuals and other bodies
  • Document does not meet the core planning principals of the NPPF and duty to cooperate.
  • Document is too long for residents to understand.
  • Does not meet the Sustainable Communities Framework.
  • Has ignored results of Charrette in 2009.
  • The whole method of planning is back to front. The council should be deciding what infrastructure is required to support expansion and deciding where those can be supplied, before deciding where to put the houses.
  • Strategy is a quick fix solution designed to create least amount of ‘pain’ for Councillors. How can responses from the 2009 consultation have been thoroughly considered if the plan is now just to focus on Hatfield and Panshanger and to ignore the other areas in the borough that were identified as suitable for housing?
  • Document is not really a developed core strategy and methodology is flawed. Proposals for development locations are based upon nothing more than a call to land owners to identify land they would be prepared to sell (to developers, not the council) for development. Whole process then hinges upon those locations offered by the land owners who have ultimately only one aim; to make money.

Total No. of OBJECTIONS / 7
SUPPORT / Number of comments
Comments by individuals and other bodies
  • Document is supported

Total No. of Expressions of SUPPORT / 1
CHANGES suggested / Number of comments
Hatfield Town Council
  • There should be more options and more consultation.

Comments by individuals and other bodies
  • The emerging core strategy should not be carried forward.
  • Review the process of the consultation and carry out full formal consultation
  • Charrette approach should be used for consultation
  • There is a major need to improve the consultation process and to involve more residents in it.
  • There should be a review of the 2009 consultation process that led to this strategy being formed. The public are not kept fully informed.
  • Re-think the whole planning process by cooperating with neighbouring boroughs to provide a plan for the region.
  • Need to provide further information and evidence as to why housing requirements are being focussed on Hatfield and Panshanger and not the other locations which may in fact be more suitable for the housing and potential traveller sites that are now in scope.
  • Strategy as proposed below would give the council more control of the process and prevent landowners driving the process.
1)Develop a proposal that allows the number of proposed dwellings to be challenged. It should question and challenge the evidence upon which this figure is arrived at and present a clear, comprehensive and defensible argument supporting the number of homes. This fundamental approach should be extended to all aspects of the strategy.
2)Identify where people want to live.
3)Identify where the existing infrastructure and geographic characteristics can best support some limited additional population increase with the aim of spreading the social burden and limiting costs associated with significant infrastructure change.
4)Model the effect of the population increases (in conjunction with neighbouring boroughs).
5)Having identified the zones that can support development land only then should land owners should be approached. They should be pressed to make land available where it is needed, where they want to sell it.
Total No. of CHANGES suggested / 15
Section 1 Introduction
Consultation Point 1 Introduction
GENERAL comments raising the following points / Number of comments
Hertsmere Borough Council
  • The document appears to be generally sound and consistent with national policy. The main spatial planning topics are suitably reviewed with comprehensive detail.

Total No. of GENERALcomments / 1
OBJECTIONS raised on the following grounds / Number of comments
Welwyn Garden City Society
  • Do not consider that the comments of residents from earlier consultations have been taken into account.
  • Some of the investigations in this report are superficial and lacking depth.
  • Too many assumptions have been made about economic recovery, led by the private sector.
  • There is also little acknowledgement of climate change threats to the community.

Comments by individuals and other bodies
  • Socially and sustainably unacceptable to continue to stuff as many houses as possible into the south-east.
  • Local residents’ views from previous consultations have not informed or directed this consultation.
  • The planning process is clearly politically motivated and has not been adequately justified. An inquiry into the way the options way this was decided should be conducted and the strategy suspended.
  • Concern that the opportunity to participate in this consultation was limited due to confusion between summary documents/full documents on objective and the section headings/reference points given.
  • Concern public consultation was limited and did not provide transparent and clear options.
  • Concern that widening of motorways is self defeating and my lead to more vehicle dependence.

Total No. of OBJECTIONS / 9
SUPPORT / Number of comments
  • No comments received.

Total No. of Expressions of SUPPORT / 0
CHANGES suggested / Number of comments
Welwyn Garden City Society
  • Refer to results of previous consultations and amend accordingly.

Comments by individuals and other bodies
  • Initiate a more effective awareness programme for residents and involve the people affected at a much earlier stage when their input can be effective.
  • Do not allow political influences to prevent other alternatives to be considered e.g. development within the current 'excluded villages' surrounding Welwyn and Hatfield.
  • Create greater balance of the proposals to be taken forward, not just concentrating the new (as opposed to brownfield development) housing to the two key sites.
  • Shift policy to take account nationally of the number of ‘brown field’ sites, which should be fully utilised and developed before any other land developed. The number of unoccupied houses should be mapped nationally and used to accommodate people with the aid of a policy taxation promoting full occupation.
  • National road and rail network should be developed with the idea of inclusively expanding trade and business throughout Great Britain.
  • Make it easier to participate.

Total No. of CHANGES suggested / 7

Document: Emerging Core Strategy

Section 2 Welwyn Hatfield Now
Consultation Point 2 Welwyn Hatfield Now
GENERAL comments raising the following points / Number of comments
Oshwal Association
  • In relation to the reference to cultural heritage, this includes the Oshwal Centre which aside from being the headquarters of the Oshwal Association is also the site of the largest Jain Temple or Derasar in Europe.

English Heritage
  • Suggest that all designated heritage assets should be referred to i.e. scheduled monuments, along with references to the undesignated heritage assets of the district, including undesignated archaeological remains

Herts Biological Records
  • Should reflect the role agriculture plays in managing countryside and food production.
  • Should also include grasslands as a habitat type.
  • References to chalk stream and river habitats are welcomed.
  • The serious water stress in the district is noted and should be fully considered in other policies reducing the environmental impacts of development.
  • References to the issues noted in para 2.64 is welcomed.

WHBC Environmental Health
  • The new public health agenda is changing current roles and introducing new roles for the various agencies dealing with public health. It is recommended that the strategy uses current available data over the ensuing years of the life of the document and should aim to engage with stakeholders throughout the life of the document.
  • Another important document that should be given due regard is a Department of Health "A toolkit for supporting engagement with local business". This provides principles for businesses to engage with the concept of improving the health and wellbeing of its staff and customers and implementing that at a local level. For example the Core Strategy should aspire to enable the resident of every new development to have easy access to affordable and healthy food.

Comments by individuals and other bodies
  • Para 2.13 refers to the carbon footprint per person compared with the UK average. The University of Hertfordshire was highlighted in an ENDS special report in December 2011 as being No.14 out of 20 of the highest carbon emitting universities in the country.

Total No. of GENERAL comments / 10
OBJECTIONS raised on the following grounds / Number of comments
Oshwal Association
  • The profile of the Borough should refer to the wider context of the area, in particular the relationship between southern parts of the Borough and Potters Bar.

Welwyn Garden City Society
  • Overall this section provides a reasonable analysis of the status quo. However, the Emerging Core Strategy fails to address many of the key issues identified in this section, relating to Green Belt, sustainability, housing, transport, the impact of climate change, the results of previous consultations, local history and heritage and the individual local character of the different settlements in the Borough.

Land Improvement Holdings
  • It is imperative that the population and household projections, used to inform the policies and proposals within the Core Strategy, are up-to-date and robust, particularly now that the Regional Strategy has been revoked. In the circumstances, Lands Improvement Holdings has decided that once the 2010 based household projections are published and further demographic and household data deriving from the Census is released, it will be commissioning its own assessment of the need for housing within the Borough.
  • LIH object to the perception that Cuffley is disconnected from the rest of the borough and is therefore a less sustainable location for new housing, as it has excellent connections to Enfield and Hertford.

Environment Agency
  • Welwyn Hatfield's Chalk Streams are a habitat of internationalimportanceand not just regional importance; identified as a habitat of Principle Importance for England in the Natural Environment and Rural Communities Act (NERC) 2006, section 41. They are a globally scarce habitat and their importance should be reflected here.
  • Under the section on 'Climate change and sustainable development', the second bullet point, should be amended to note that the inclusion of sustainable features will ensure development is more sustainable and to ensure that it is in line with the NPPF.
  • Two challenges for Welwyn Hatfield are missing and should be included – 1) to manage and reduce flood risk and 2) for Welwyn Hatfield's water bodies to reach good ecological status in line with the Water Framework Directive.

Comments by individuals and other bodies
  • Town heritage also includes Panshanger aerodrome which is an historic and present day community resource and amenity for Welwyn Garden City.
  • The allotments are vital and are part of the character of the community. They encourage wildlife.
  • Many on the housing waiting list won’t be able to afford housing even it were available because the banks aren't lending, not because it’s not available.
  • Growth forecasts have not included the2011 census results which show a lower growth estimate than previously predicted.
  • The council acknowledge that it doesn’t know what will happen to the population because you used trend data.
  • Job increase in the 2000s are unlikely to be repeated in the next 20 years so local jobs may not be available for new residents.
  • No explanation is given for the housing targets numbers 4 and 5 referred to. Do we have to read yet another document to understand this one?
  • Brookmans Park, Cuffley and Welham Green are supported by local boreholes in to the aquifer and reasonable development here would therefore not impact on the sensitive rivers Lea or Mimram.
  • The natural resources of the river Mimram are already being stretched to the disadvantage of the water course. Additional demands will make the situation worse.
  • You have identified the areas considerable natural resources that shape the area and in addition mentioned the dryness of the region. How does the Council justify eroding the Greenbelt or take measures to supply water all the new homes to be built without contributing to further environmental issues.
  • Do not agree that Welwyn Garden City is served well by rail.
  • Strong links to London would suggest that new housing would mean more people wanting to travel to London. Building homes about 3 miles from the town centre will increase the amount of traffic and the demand for parking in the town centre.
  • Creating another large housing estate adjacent to an existing large estate with inadequate services and infrastructure is not the way to create a ‘place where people want to live’.
  • Too much development in either of the two areas identified will lead to imbalance. This would lead to unnecessary pressure on local services and infrastructure. Smaller numbers in more locations would help keep the character of an existing area while promoting growth at manageable levels.
  • Concern that feedback and objections raised at Issues and Options stage as noted in this section has not been fully taken into consideration.
  • What happened to localism? Para 2.48 states that residents want minimal development. You might not like it, but you can’t ignore it. The council is elected to deliver what the residents want.
  • Question the statement ‘there was a good response in para 2.40 - 1400 responses from over 45000 houses and 80000 employees in the area is a drop in the ocean. Consider that consultations can be manipulated.
  • Consider that there are major biases towards selling these plans and the truth hasn't been told i.e. redundancies across the county at major employers, neighbourhoods destroyed due to high multiple occupancy and high investors not home owners are not providing strong community or quality neighbourhoods.
  • Para 2.3 states that the town centre is smaller and serves a smaller catchment area but this ignores the Galleria which with some improvements and marketing could attract people from a far wider area than Welwyn Garden City.
  • Para 2.7 refers to water stress but makes no mention of the water demands that the proposed incinerator.
  • Para 2.14 refers to the garden city but fails to mention the more important (in heritage and visitor terms) Hatfield House.
  • Para 2.22 reveals the cumulative effect of Hatfield town centre being used as a repository for social needs cases – possibly a deliberate tactic by the council to secure national or EU funding rather than spending its own funds.
  • The economic downturn is used as an excuse for Hatfield to play second fiddle to Welwyn Garden City.
  • It should be acknowledged that if the residents of Hatfield don’t bother to respond then it suggests they are either happy or have given up as the local authorities do as they please. The same authorities appear to have been congregating people who are unlikely or unable to voice effective opposition in Hatfield (short term residents, those with learning disabilities, new immigrants unfamiliar with UK standards or those with substance dependencies).