1. Local Plan

i. The OAN: will the council reflect the lower population projections?

The council’s Cabinet Planning and Parking Panel, (CPPP), (Chair, Councillor Stephen Boulton) is to meet on 12^th November to consider the outcome of the consultation on additional sites which took place earlier this year. Members will also have before them the interim report of the inspector with his view on the “soundness” of the Plan and further information from the council’s consultants, Turley, about the effect on the Objectively Assessed Need (OAN) of the latest household formation projections from the Office of National Statistics (ONS) that were published in the summer.

In his report the inspector states his preliminary conclusion that “exceptional circumstances exist for the release of sites from the Green Belt sufficient to meet the housing requirement”. (https://www.welhat.gov.uk/local-plan/new/examination/inspector)

This would be a stark consequence for our local Green Belt.

The inspector is quite blunt that the Council must propose additional housing sites sufficient to meet the full OAN or withdraw the Plan from examination.

ii. Why should the OAN be so high?

In the Proposed Submission document on which the council consulted us in August 2016, (https://www.welhat.gov.uk/new-local-plan) the OAN was in a range of 12,616 -13,433 and the adopted housing target was 12,000 equating to 637 dwellings per year over the period 2013-2032. Following new ONS projections in 2014, the OAN was understood to have increased and is currently considered to be 16,000 over the revised plan period of 2016-2036. This equates to 800 dwellings per year.

Under the guidelines for preparing the plan, the starting point for establishing the OAN should be the most recent population and household projections. These are then “uplifted” to reflect local factors. For example the original OAN in 2016 included an uplift of 10% which “included a positive allowance to help improve household formation rates among younger people” (whatever that meant!).

The ONS projections published this summer show a dramatic 60 per cent slowdown in the projected increase in the growth of the number of households over the plan period and therefore a much lower starting point from which to calculate the OAN. Turley was asked by the Council to review the OAN in the light of the latest projections.

In their review, Turley chose not to use the latest figures as a new starting point but treated the slowdown as a “blip”. They said that 16,000 was still an appropriate figure, though at the top of a range of 715 – 800 dwellings per annum over the 20 years 2016-2036. However they recommended an OAN towards the bottom of the range, namely 775 dwellings per annum giving a total of 14,300.

Several councillors questioned the evidence for this recommendation and the application of uplifts in excess of 50% above the starting point implied by the new projections. Turley was to be asked to take account of their comments and that response should be available to councillors for the CPPP meeting on 12^th November.

iii. An independent review

The NMDGBS has commissioned an independent professional review of the Turley report by Alan Wenban Smith which we have submitted in response to the inspector’s consultation and which we are sending to councillors with our comment.

The report is quite clear that Turley’s latest recommendation is unduly high and has not been substantiated; that the starting point based on the latest ONS projections should be 309 households per annum; that all “uplifts” to take account of other factors should be transparent and fully evidenced.

Our planning consultant Jed Griffiths has also prepared a commentary on Turley’s review.

Both reports can be accessed on our website.

iv. Other Reviews

And we are not alone in showing that the OAN proposed by Turley is unduly high.

The campaign “Save Symonshyde” have calculated an OAN of 387 dwellings per year (7,740 for the Plan period).

Future Housing Need – Hertfordshire 2020-2036, published by CPREHerts, compares the projected housing need based on the latest ONS projections with that based on the ONS projections made in 2014. For Welwyn Hatfield this shows a reduction of 51% in the estimated need over the period.

The survey concludes: “Annual housing must reflect local factors and would be no less than 314 dwellings a year. The standard method isn’t applied for the current local plan, but as a guideline it would indicate up to 432 dwellings a year (a total for the borough over 15 years of between 4,710 and 6,480) 9,500 dwellings fewer than the inspector recommended.” https://www.cpreherts.org.uk/

v. How much Growth?

The council’s consultation document of August 2016 includes a chapter, “How Much Growth” which sets out the targets for housing and employment. It is the employment and economic growth ambitions particularly which influence the OAN and provide the uplifts from the ONS projections.

In his interim report to the council the inspector is clear that if WHBC maintain their targets for employment growth, they have to find the housing.

But targets for growth need to be realistic and reflect current circumstances.

Councillors need to be confident that the original aspirations are still appropriate for changed economic circumstances and will not lead to unnecessary over appropriation of sites for housing in the local Green Belt.

Notwithstanding the confident assertion of the Prime Minister quoted below, in Welwyn Hatfield, the consequence of “build build build” will be the sacrifice of our local green belt.

vi. Remember Remember the 12^th of November (and the 23^rd too)

So there is much riding on the CPPP meeting on 12^th November (and of course the full Council meeting on the 23^rd .

In other circumstances we would have organised a demonstration outside the Council Offices but on zoom it doesn’t have the same impact. So if you haven’t already done so, write to your local councillors and urge them to approve an OAN that fully reflects the changes in the population projections and changed economic circumstances.

2. Local planning applications

The society has submitted objections to two recent planning applications.

Details of the applications at https://planning.welhat.gov.uk/Planning

• (Reference 6/2020/2379/MAJ)for development at The Firs Park, Woodside Lane, Bell Bar AL9 6DG. The application is for “the use of land as an extension to the existing caravan park for the provision of an additional 25 caravans.

• An application, (reference 6/2020/2248/OUTLINE) for outline permission for the erection of up to 100 dwellings, with all matters reserved except access, at Roundhouse Farm, off Bullens Green Lane, Colney Heath. A parallel application has been made to St Albans BC as this site straddles the local authority boundary with St Albans. The site has not been proposed for the local plans for either council.

3.The White Paper: Planning for the Future

The Society has responded to the government’s consultation on the White Paper, Planning for the Future with a submission prepared by our Planning Consultant Jed Griffiths which argues that we need a system which takes account of local interests, and is transparent in its operation.

Specifically on the Green Belt, the paper notes that whilst the list of proposed protected areas includes Green Belt, it is simply not enough to state that policy will remain unchanged. Given the current pressures on the Green Belt, there needs to be a positive affirmation of the policy to protect the Green Belt and the open countryside.

You can see the full response on our website.

4. Quotes of the month

• “There is abundant brownfield space across the whole UK, and I speak as someone who used to be the planning authority for London, and I know whereof I speak. The opportunity is there.”

Boris Johnson, responding to Coventry North West MP, Ms Taino Owatemi MP at Prime Minister’s Questions. Hansard 7.10.20

• “Panshanger is a great example of how Homes England is focussing its expertise on preparing land for the development of new homes. The site has long been recognised for its potential to deliver homes for Hertfordshire and the wider East of England.”

Dan Wheatley, Senior development Manager at Homes England. (Homes England is the non-departmental public body that funds new affordable housing in England.)

Welwyn Hatfield Times 14.10 20

Read the response from Jed Griffiths MA DipTP FRTPI On Behalf of North Mymms District Green Belt Society

Final Report to North Mymms District Green Belt Society – Read the full document

Local Plan.

It’s been a long summer for the local Plan and much has happened but there is still a long way to go.

The Hearing Sessions.

The “virtual” hearing sessions on the North Mymms sites took place in August with NMDGBS represented at all of them by our planning consultant Jed Griffiths.

Note that these hearings were only concerned with sites already included in the current draft. Those sites included in the council’s consultation in February 2020 will not be examined by the inspector until the council has decided which ones to put forward for the plan. More on that below, but meanwhile it left the inspector conducting hearings on sites in Brookmans Park and Little Heath which the council is proposing to withdraw from the plan.

What did we learn?

The hearings provide the inspector with the opportunity to listen to local views and to explore issues on which he wants further clarification. The inspector clearly has some misgivings but what he thinks will have to await his report.

Nevertheless, some things did emerge.

On Marshmoor:

i. the promoters made it clear that they were only interested in promoting the site for employment use, specifically for a science park with some residential accommodation. They were not interested in promoting the site generally for residential development.

ii. It was said that both the Royal Vet College and the University of Hertfordshire supported the proposal. Yet at an earlier hearing about UH, its representative said that UH would be bringing forward an application for additional science facilities at their site at Angerland Common.

On BrP4/HS22 Brookmans Park:

i. One of the alleged advantages of developing this site had been the safety benefit arising from improvements to the Station Road approach to the railway bridge. The proposers made it clear that they had no plans for any substantial changes to Station Road.

ii. Although this is one of the sites that the Council has said it wishes to withdraw from the plan the inspector has indicated that consideration should be given to increasing the dwelling numbers on the site (currently 250).

On BrP7/HS25 Little Heath:

i. It was acknowledged that development of this site, at the southern boundary of Welwyn Hatfield Borough, would put additional pressure on Potters Bar infrastructure. There was a lively debate about the availability of school places which led to the inspector to ask the County Council for a detailed report on their assumptions and the reality of filled capacity.

ii. The boundary between the two boroughs was itself recognised as a matter of concern for the Green Belt as NMDGBS has long argued because developments are proposed on both sides of the border. We were pleased that the inspector asked WHBC to discuss an agreed position with Hertsmere BC and to report to him.

The Objectively Assessed Number (OAN)

• Notwithstanding that the O stands for “objectively” the OAN, the target number for dwellings in the Plan and currently standing at 16,000, (800 dwellings per year) might more readily seem like the white rabbit from the conjurer’s hat.

• The basis of the OAN is the projection for the growth of new households over the plan period (2021-2036) calculated by the Office of National Statistics (ONS). At the end of June, ONS published new projections showing a much slower anticipated growth than that which underpins the current OAN of 16,000.

• The council’s consultants, Turley, were asked to review the OAN in the light of the new projections and have reported that the revised OAN is 14,300 (715 dwellings per year). This is conveniently close to the figure of 14,011 which the council included in its public consultation of February 2020, but it is a great deal higher than the slower growth would justify and depends on the methodology used in the calculation. So much for objectivity!

• Turley’s report was considered by the Cabinet Planning and Parking Panel (CPPP) on 10^th September and was severely criticised by Labour and Lib Dem members. Glynn Hayes said he had no confidence in Turley’s report that to him read more like a sales document than a justification of need. Paul Zukowskji could see no justification for an OAN that was 50% higher than the ONS projection. Chairman Stephen Boulton noted the disquiet and deferred discussion of the report. Meanwhile Turley would be asked to respond to the comments.

• The inspector has been sent a copy of Turley’s report and is asking the council for its decision on the number. He is also asked for comments on the report before 30^th October. NMDGBS will be responding in support of an OAN that takes full account of the slower rate of growth.

The timetable

• After a review by the inspector with council officials to take stock, it was agreed that

the inspector is to submit an interim report to the council in early October setting out his interim conclusions on what needs to be done if the plan is to be found “sound”.

• This is to be considered by CPPP and Cabinet and the council’s response agreed at a full Council Meeting on 23rd November. It is at this point that any changes to the sites proposed will be made new sites in or existing sites out as per the council’s consultation in February this year. These “main modifications” will then be the subject of consultations and hearings by the inspector sometime in the new year.

• It is not clear how sensible conclusions can be reached until such time as the CPPP has made up its mind about a revised OAN. CPPP is scheduled to meet next on 29th October and the Cabinet on 3rd November. As noted above, the inspector’s consultation is open until 30th October.

Can you do anything?

• Write to your local councillors urging them to take full account of the slower rate of growth projected by the ONS when setting the target OAN for the plan. Otherwise they will be sacrificing Green Belt in the borough for dwellings that are not required for local people. The time is short.

Planning White Paper

At the beginning of August, Communities Secretary, Robert Jenrick, issued a White Paper proposing “radical Reforms” to the planning system you can view it here.

CPRE London’s latest Bulletin has a helpful summary here.

The proposals include “simplifying the role of Local Plans, to focus on identifying land under three categories

Growth areas suitable for substantial development, and where outline approval for development specified in the Plan.

Renewal areas suitable for some development such as gentle desensification Protected areas where, as the name suggests – development – is restricted. “

Green Belt would be included within the Protected Areas.

The White Paper has received a mixed reception.

• The strap line in the Economist Magazine declared: “ Boris Johnson’s grand planning reform is not the big deal it is cracked up to be.” while the Chairman of the Local Government Association, quoted in the Financial Times, said that the loss of local control over decisions “would deprive communities of the ability to define the area they live in and know best and risk giving developers the freedom to ride roughshod over local areas.” He also refuted the “myth” that the existing system is a barrier to building more homes: “Nine in 10 applications are approved by councils, with more than a million homes given planning permission over the past decade yet to be built.”

• Alongside the White Paper, Ministers are consulting on changes to the way that housing need in council areas is calculated. These changes will increase local plan targets across the country from a total of 270,000 dwellings to 337,000 –a 25% increase.

• So even if the new arrangements continue to include Green Belt within the protected area category, there is bound to be greater pressure on Local Authorities to re-designate Green Belt boundaries.

The consultation lasts until October 29th . NMDGBS will work with the London Green Belt Council and CPRE Herts to develop comments.

Other Green Belt News

• CPRE Herts has issued its annual review here.

• The publication of the new draft Local Plan for Hertsmere is now earmarked for Spring 2021. Following publication there will be a six-week consultation period. NMDGBS will be particularly interested on any proposals at the boundary with Welwyn Hatfield.

• Examination of the North Herts Local Plan has been postponed. It is understood that the council is considering reducing its OAN.

North Mymms District Green Belt Society Newsletter – July 2020

This July Newsletter is a little later than usual to include the start of the Hearings held at the end of the month on sites within our Parish.

The Objectively Assessed Number OAN – a recap:

The OAN reflects projections made by the Office of National Statistics (ONS) on household formation over the plan period.

The Draft Local Plan currently being examined by the Inspector provides for an OAN of 16,000 dwellings to be built over the plan period of 2021-2036.

Faced with this target the draft Local Plan being considered proposes only 12,000 dwellings. Challenged by the inspector to provide for the full OAN the Council has considered a proposal for 14,000 dwellings, but has not yet put this forward formally.

The OAN of 16,000 reflects the household projections made in 2014.  The ONS updates these projections every two years and the Plan is expected to take account of the latest information. But though projections in 2016 indicated that growth would be lower than previously predicted, the Council decided to stick with the 2014 projections and the Inspector agreed that this was not unreasonable. This left the OAN at 16,000.

The latest 2018-based household projection figures continue the trend of slower growth, and substantially so.

According to calculations done by CPRE Herts, (of which NMDGBS is a member) the latest projections for our borough for the period between 2018 and 2036 show that the number of projected households in 2036 is 7,000 fewer than in the 2014 projections on which the OAN of 16,000 is based.

The OAN is a complex calculation but the household projection figures are the starting point

Local ward councilor, Paul Zukowskyj, quoted in the Welwyn Hatfield Times, urges a reduction in the planned target from 16,000 to “under 10,000.”

Also in a letter in the WHT, the Chair of “Save Symonshyde” argues that “anything higher than 10,520 would be unjustifiable”.

And that is before taking account of the impact of Brexit  and the economic repercussions of Covid-19.

The Society asked the Cabinet Parking and Planning Panel (CPPP) to look at the economic growth assumptions in the Plan and confirm that they were “ realistic and sensible in the changed economic circumstances of the country post covid.” The Council confirmed that they had asked its consultants, Turley, to look at the latest ONS numbers but didn’t actually answer the question asked.

The Inspector wrote to the Council asking for a response on the latest ONS figures by 31st July, but at the CPPP  meeting on 30th July there was no mention of progress on the consultant’s report.

We shall have to wait and see for the outcome. The Inspector has said he would expect to seek comments on any proposed change so we shall have our say on whatever is proposed.

The ONS projections are excellent news. Please urge your Councillors to take them fully into account to reduce the pressure on the Green Belt.

Stage Eight Hearing Sessions
The Inspector’s examination of the Plan recommenced with virtual hearings in the last week of July.
At the outset, the Inspector made it plain that he was only dealing with the sites that have been included in the current draft as submitted to him. He was not concerned with other sites which may be submitted by the Council at a later stage or with sites being promoted by developers that had not been accepted by the Council. He was not, he said, “conducting a beauty parade”.
The Hearings are the Inspector’s opportunity to hear and probe the various views of interested parties as he assesses the “soundness” of the proposed sites. He may declare his thoughts but does not pronounce any decision.
You can follow the sessions at the time through the live feed or later; the written arguments are published through the council’s web-site here.

Our planning consultant, Jed Griffiths, represented the Society at hearings on the 30th July about the sites in Welham Green :  Sites HS11 (Hat 11) Land at South Way,  Site SDS7 (WeG4b) Marshmoor, and  Site HS35 (GTLAA01)Foxes Lane, Dixons Hill Road.

The hearings on the other sites within the parish will be on 18th,19th and 20th August.

As a reminder, these are:
In Brookmans Park  –  Site HS22 (BrP4) Land West of Brookmans Park Railway Station, Site HS21 (BrP13) Land West of Golf Club Road, Site HS23 (BrP14) Land East of Golf Club Road
In Little Heath –   Site HS24 (BRP7) Land South of Hawkshead Road,  Site HS25 (LHe1) Land North of Hawkshead Road.
Our views on these sites have already been submitted and can be seen on the web site.

Elsewhere in the Green Belt

London Green Belt Council (LGBC) reports on the announcement by Robert Jenrick, the Secretary of State for Housing, Communities  and Local Government, to launch a policy paper setting out a new approach to planning. For more on this and a general round-up of developments affecting the London Metropolitan Green Belt, see the latest monthly report here.

The LGBC is also working with West Herts MP, Gagan Mohindra, to restart the All-Party Parliamentary Group for London’s Green Belt.  In past sessions of Parliament, our local MPs have been members of this valuable group.

CPRE the Countryside Charity has launched its “Manifesto for a resilient countryside after Coronavirus” calling on the government, amongst other things, to enhance and protect the countryside around our towns and cities, including the Green Belt, delivering better quality green spaces near to where people live. CPRE Website.

Our Committee

Our committee is losing one of its long serving stalwarts, Philip Elgar is leaving for the beauties of the Chilterns. We are very sorry to be losing him and thank him for all his support.  Is there anyone out there interested in joining us? We would be delighted to welcome reinforcements to our committee especially if you have a feeling for websites and social media.

We lack up to date email addresses for quite a number of our members so please share this news letter with your friends and neighbours. If they are not members , encourage them to join us.

More on the Local Plan.

Stage 8 Hearing Sessions.

The Inspector is now seeking to rearrange the hearings on the remaining sites in the Draft Plan that have not been considered to date. These include HS22(BrP4) in Brookmans Park, HS24 and HS25(BrP7) in Little Heath and the Marshmoor site in Welham Green.

The hearing sessions will be held “virtually” and the dates that are under consideration are the last two weeks of July and all of August.

NMDGBS will be represented by our planning consultant Jed Griffiths.

Given that the council’s recent public consultation proposed to withdraw HS22 and Hs 25 from the Plan it will be interesting to see how the council approaches these hearings.

Note: none of the new sites included in the recent consultation are involved in these hearings.

Response to the Public Consultation

Head of Planning, Colin Haigh reported to the Cabinet Planning and Parking Panel (CPPP) at its meeting on 4^th June.

• There had been 780 representations/ responses to the consultation. These were being reviewed by officers and a report will be submitted to the CPPP in due course.

• The Stage 8 hearings were being re-arranged(see above) After these hearings the Inspector intends to write an interim report.

• Once the Inspector has produced his interim report, and when they are ready to do so, Officers will present the report to the CPPP with the results of the consultation and the review of the OAN (see below). This is the point at which the CPPP may wish to select additional sites for inclusion in the Plan. The Inspector will hold hearings on any additional sites and submit a final report. There will then be a period of public consultation on “Major Modifications” to the original Draft before the Council finally approves the Plan.

The Objectively Assessed Number (OAN)

NMDGBS has consistently argued that the target number of dwellings (the OAN) for the Borough currently 16000 is too high. It is an arithmetic calculation driven in part by an aggressive assumption of employment growth which pays scant attention to the fact that this will require land from the Green Belt. The Inspector has several times commented that the employment assumptions have housing consequences.

Recently, new population growth projections have been published by the Office of National Statistics(ONS), which show a lower growth in population than that implied by the OAN; additionally, new Household Growth projection figures are to be published on 29^th June.

In reporting to the CPPP, Colin Haigh said that once the household growth projection figures were available the Council’s will ask its consultants whether a review of the OAN is necessary. The consultants will also be asked if they can make any assessment about the impact of Brexit and the Coronavirus pandemic.

Irrespective of lower population growth estimates, it seems to us a matter of common sense that ambitious economic expansion figures adopted several years ago, which will cost land from the Green Belt (for example Marshmoor), need to be reviewed to see if they are sensible and realistic in the light of the changed economic circumstances resulting from the coronavirus pandemic. This is a responsibility that the councilors must take themselves, not just shuffle off to consultants. If you agree with this view, please contact your local Councillors to tell them so.

NMDGBS has put down a question to this effect for answer at the next CPPP on 3^rd July. We will report on the response in July’s newsletter.

Meantime keep safe.

Enjoying our local countryside.

This time of tension and lock down provides us with a timely reminder of the importance of the countryside for mental and physical health and well-being. One of the five purposes of the Green Belt laid down in the NPPF is “to assist in safeguarding the countryside from encroachment.” Without the protection of the Green Belt planning policies we can’t assume that our countryside will continue to be there.

 Local Plan consultation.

The submissions and comments are still being listed on the consultation portal, so it is not yet possible to see just how many responses there have been, but it is a goodly response. Thank you all for your contributions.

The Society’s comments prepared by Jed Griffiths our planning consultant will be listed in due course. We have objected on Green Belt grounds to all the proposed sites in the parish.

Coronavirus has delayed an already stretched out process. At some point the council officers will present a report on the consultation to the Cabinet Planning and Parking Panel (CPPP) with recommendations as to the way forward. The next meeting of the CPPP is scheduled for Thursday 4^th June.

The Inspector’s Stage 8 hearing sessions into the sites already in the Draft Plan will continue but no decision has been taken yet on when they are likely to be held, whether they are likely to be virtual hearing sessions or to take place in the same way as the previous hearings did.

NMDGBS will be represented by Jed Griffiths and our written comments were submitted prior to the deadline last month.

 ??16,000 dwellings??

NMDGBS has consistently argued that the target of 16000 dwellings (known as the Objectively Assessed Number) in the Draft Local Plan is far too high. In part the OAN figure is calculated on assumptions about the strong economic expansion that the Council desired to see over the plan period. These assumptions were highly aspirational when they were made several years ago but now, with the Chancellor of the Exchequer predicting a severe recession “the likes of which we have not seen”, they are totally unrealistic and surely must be reviewed.

Please let your local councilors know if you agree with this argument.

Green Belt beyond North Mymms.

NMDGBS is a long-standing member of the Countryside Charity (CPRE) through CPRE (Herts) as indeed are many of our members. CPRE nationally sends out a regular campaigns newsletter which you can access at https://www.cpre.org.uk

We also belong to the London Green Belt Council which brings together over 100 organisations including councils, residents & environmental groups with a shared concern for London’s Green Belt. Their latest newsletter deals with the emergency change to planning law that permits Councils to hold virtual planning committee meetings. It also includes a round-up of recent developments within the London Metropolitan Green Belt of which we are a part. Our problems are shared throughout the area and we can learn from what is happening in other planning authorities. Check out the details at http://londongreenbeltcouncil.org.uk