Local Plan and “BGS”

December 2018: It has just been announced by our Council that the Local Plan will now not be finalised and adopted until Spring 2020. This announcement represents yet another year of delay. Until last week the plan was behind by four years, now it is behind by at least five years. The implications of this for our area are hugely significant, but first let’s rewind the clock and get some context.

The process began almost 10 years ago in March 2009 with the first public consultation on the Emerging Core Strategy, which later became known as the Local Plan. That pubic consultation document contained the following on page 26:

“In 2001 there were approximately 40,678 dwellings in Welwyn Hatfield (9). The East of England Plan states that 10,000 additional dwellings must be built in the borough between 2001 and 2021, 4,155 of which had already been built by April 2008 (10) . Between 1998 and 2008, Welwyn Hatfield experienced a 165% increase in the average property price”

This 10,000 figure was set, effectively by government, under the planning regime of the previous government. You may recall the vigorous local “No way to 10k” campaign, spearheaded by our then prospective MP Grant Shapps.

When the new coalition government came to power in 2010 there followed  a root and branch reform of the planning system. In 2011 the Localism Act came into force, supposedly giving power back to local communities and letting them decide how their areas should develop. Hot on the heels of that in 2012 was the National Planning Policy Framework. A shiny new national planning policy that supposedly placed decisions about home building, employment land, and more back into the hands of local communities via their local councils. The theory being that WHBC would now decide how many homes were needed and where they would best fit, it was a fact of course that over three quarters of the Borough is and was under Green Belt protection.

What happened next?

A further public consultation took place in November 2012, this proposed that 7,200 new homes be built up to 2029. Very importantly, the date set for adopting the Local Plan would now be ‘Winter 2014’.

As we know this date came and went, no draft version of the plan was ready for inspection due to delays.

In January 2015 there another public consultation. This time a housing target of 10,152 was proposed, this included a change of location for some of the new homes, and a need to move the Green Belt boundary to enable building on some of the Green Belt. WHBC also attempted to respond to the many criticisms that it had chosen to exclude some potential housing sites in the southern part of the Borough, while increasing the number around WGC and Hatfield. They stated that “The council now proposes a more proportionate and more dispersed pattern of growth to meet the housing needs of the borough”. However, many parties remained unhappy that the locations chosen were still not representative of a fair distribution across the borough. We should remember that the council’s Planning Officers had recommended to the elected Housing Panel and Cabinet members (Elected ward Councillors) where all the homes should go. Those officers are of course lobbied by housing developers and others. The elected members who have the final say do not necessarily live in our town. Most unusually, on two occasions the elected members were asked, at the end of committee meetings to vote against the recommendation of the Planning Officers. This they did and despite advice, and lobbying to the contrary by residents, they approved a plan to  focus housing growth far more on Welwyn Garden City than on other areas. For example Brookmans Park, Cuffley and elsewhere. When they did this it caused a number of local groups and people to call foul, to no avail.

A further public consultation took place in September 2016, this included a new date for the final plan adoption of “Autumn 2017”. The housing target had also risen to 12,000 homes with a plan end date now of 2032.

Although the decisions on how many new homes and their location are now to be left to the council, in theory at least, the eventual plan has to pass a test of legal soundness by a government appointed inspector. Our government appointed Inspector, Mr Middleton, has now held several hearings to go through all this. This has been ongoing over the last year or so. Time and again he has heard objections from housing developers and bodies such as the CPRE, Gascoyne Cecil Estates, ourselves and many more. All questioning how the decisions to allocate housing in one area, and yet not in another which appears in some ways more sustainable, were arrived at (this to some extent harks back to those committee meeting votes above).  It was not clear to many why areas in the south of the borough were being excluded, while other areas around WGC were being expanded or added. The most recent hearing held, about the proposed loss of Green Belt on November 7th 2018 seemed to raise more questions than it answered. It asked whether the WHBC report on the comparative risk of harm in developing one Green Belt site over another had been done fairly and consistently.

This observation links directly back to the other concerns about how fairly the proposed sites for housing have been chosen in the first place. Another complicating factor is that although our council is left to make its decisions about how many new homes need to be built, it must follow a formula set out by central government to work out its Objectively Assessed Housing need figure (OAN). This figure rises annually as the population rises. Meaning of course the figure today is higher than it would have been four years ago when this plan was supposed to be finalised.

The Inspector now advises that the current WHBC plan would be unsound as it only plans for 12,000 new homes, when according to the latest OAN calculations it should now be over 16,000. It’s a moving target, and so adding on another year of delay now probably means it will have to rise again, above 16,000 before it is adopted.

If the Local Plan process had been executed in such a way that it did not give rise to so many valid objections, for example on the lack of technical detail (Birchall Garden Suburb and Panshanger Airfield to name but two), and if the site allocations had been truly better balanced and more fairly dispersed across the borough then much of this now five years plus of delay could have been avoided. The Planning Inspector wrote to the head of WHBC planning on 24th October, in his letter he covered some points we have long raised,  he stated:

“A number of valid points concerning the methodology appear to have been made and if they stand up to scrutiny at the Hearing, I hope that you will take them on board when assessing the representations yourselves and taking the study forward. Additionally, I have noticed numerous objections to the assessments of particular areas of land. Whilst some of these may be partisan, not all appear to be and having heard the evidence, I may well ask you to undertake a reality check of the alleged inconsistencies”.

Click here to read the letter.

Our council now has to rather embarrassingly make a fresh call for new housing sites so that it can make up the 4,000 home shortfall that now exists, due in no small part to the protracted process and ongoing delays due to the way things have been done thus far.  This has been ordered by the Planning Inspector. Worse still, developers are at liberty to put in planning applications to build whatever they want in the interim, if the council has not been able to protect against unwanted developments through its own Local Plan. There are already such planning applications for about 2000 new homes around WGC, on land not yet zoned for housing.

On 7th December WHBC released the following statement in a press release:

“A call for sites in the New Year will give us the best chance of producing a sound plan, a plan that balances the protection of our green belt with the need to deliver the new homes, jobs, services and infrastructure our children and grandchildren will rely on. Members will also agree a new timetable, which would see a four week call for new sites in January 2019, followed by sites being published for six weeks of public comment in February and March. It is hoped the plan will now be adopted in spring 2020”.

This further slippage leaves the Borough open to another year of potentially unwanted speculative planning applications. The Local Plan has now slipped from Winter 2014 to Spring 2020. Things are now about five and half years behind schedule and the housing target has had to rise accordingly as a consequence. In our view much of this slippage was avoidable,  we also feel the current plan with so much emphasis on major extensions to our town increases urbanisation and poses a threat to the ethos and sustainability of the town going forward.

The full report on the latest delay to the plan can be read on the WHBC website here:

http://democracy.welhat.gov.uk/documents/s9162/07%20-%2018-12-13%20CPPP%20Local%20Plan%20Next%20Steps%20Amend.pdf

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October 2017 update: The WHBC Local Plan  is currently being examined by the government appointed Inspector. The plan includes a joint proposal between WHBC and East Herts council to place 2,550 homes and other amenities beside, or perhaps on, the former Cole Green landfill waste site. Our paper “What Lies Beneath?” looked into the history of the 70 years of waste dumping on that site, it is available on this website. We have now done further research of the archive material, such that exists. Previously waste dumping was poorly regulated so not that much can be found, but what we have found is very concerning, we also have testimony from local people who remember operations at the site as far back as the 1950’s.

Domestic waste dumping at Cole Green tip in 1979

All of this is captured in a 15 page letter we have sent to WHBC and the other neighbouring authorities, we have also produced a press release on the matter which you can read below. The government Inspector has not yet looked in any detail at the proposals for this site, we hope that he will give our findings some weight and be as concerned about the Birchall Garden Suburb as we are.  The final paragraph of our letter follows, we urge residents to read it in it’s entirety to understand the many questions it poses to the Local Authorities.

Welwyn Garden City was founded as a town “designed for healthy living”. It was set up to attract people from cities who wanted to escape their contaminated and polluted living conditions. Now, here we are less than a century since the first brick was laid and WHBC is unable to find a better site for a large housing development than by a hill largely composed of 70 years of the last century’s rubbish, much of it waste from London. The very thing the original townsfolk came here to get away from is now seemingly a good location for new residents to live beside and enjoy. We think that this is an affront to the town, its heritage and its founder, Ebenezer Howard.”

Our full letter can be downloaded here: Letter to WHBC opposing the current plan for Birchall Garden Suburb

The Press Release we have issued on the matter can be read below:

Welwyn Garden City Society calls for Birchall Garden Suburb to be abandoned

Announcing that the Welwyn Garden City Society had written to the Welwyn Hatfield Borough Council, Will Davis, Society Chairman, said “We are surprised the Council has persisted with its proposal for Birchall Garden Suburb when, so far as we are aware, it has failed to look into the site properly. So we are today publishing our own research that we think proves the site should now be abandoned as a proposed site for 2,550 new homes.

Information supplied to the Council had made the claim that housing was to be built on “virgin land”. The Society disputes this and provides supporting evidence that supports its point of view. It references copies of planning submissions, approvals given, work specifications, relevant maps, aerial photographs and testimony from local residents that suggest that claims for the site are incorrect.

Accordingly, the assumptions proposing the site can support many thousands of homes are flawed, this alters the financial basis of the entire development and the length of time it would require to bring the site to a starting point for building. Its development on any timescale that fits with the Draft Local Plan is likely to be incorrect. The Society considers that all this should have been identified much earlier in the planning process and concludes the site should never have been included as one that is appropriate for housing.

The Society has not been able to find any evidence that the Council itself has been able to verify that the site would be safe housing. On the contrary, the Society has cited central government information that there may be increased health risks to communities living close to landfill sites. For these health reasons alone and, as central government has signed up to the “Precautionary Principle”, it believes that the development should be withdrawn from the Draft Local Plan, at least until a far more detailed and independent analysis of the proposed site has been carried out by WHBC.

Key reports submitted to the Council as to the safety of the site are deeply flawed, are inadequate and, by their own admission, are partly incomplete. They fail to identify both one authorised tip and another that was unauthorised. They fail to give any explanation how come a large area marked “Filled area 250m buffer 45.0ha” on a submitted map is reconcilable against a claim to be building on “virgin land”.

The areas that the Society believes have been excavated for sand include areas that fall within the East Herts District Council area, suggesting that the area in East Herts should now closely examined by them, before this proposal goes any further.

27th October 2017.

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