Land North & East of Ware, Hertfordshire
Ref: 3/22/2406/FUL
January 2023
Prepared by Nicholas Cox
The Green Belt was established in 1955 to contain urban sprawl, to maintain the separation of settlements, to protect prime agricultural land around settlements, and to encourage urban regeneration and compact towns and cities. It now covers 13% of England; but increasing development in Hertfordshire’s green belt risks suburbanising the London to Cambridge corridor, swallowing East Hertfordshire into a massive conurbation.
The farmland and woods to the north and east of Ware are a beautiful part of our green and pleasant land. The woods, hills, rivers, and meadows are a resource for all. Generations of Ware residents have enjoyed walking across these fields, have played there as children, and watched crops grow and wildlife thrive as the seasons came and went. Now that’s all under threat from an assault driven by investors and developers putting profit before people and the places they love.
EHDC’s District Plan includes two greenbelt developments of some 18,485 new homes. Northeast Ware and Harlow North (Gilston Area Applications) are planned on the largest release of green belt land in England, representing over 6% of our green belt. It is important to appreciate that the two developments are two sides of the same coin and should be considered as one development when considering infrastructure and services, to avoid the risk of massive under provision.
The Northeast Ware development proposes 1,800 homes, up 20% from the 1,500 detailed in the WARE2 master planning policy. In 2018, the East Herts District Plan allocated 1,000 new homes to the site by 2033 with potential for a further 500 homes, subject to suitable highway mitigation measures. No highway measures that mitigate an additional 500 homes have been proposed, let alone a further 300 on top of that. This latest increase is an opportunist profiteering attempt by the developer which must be resisted.
There are four (4) main reasons why this development should not proceed:
1) Traffic
There should be no access from roads in the new development to Fanhams Hall Road as neither Wareside, nor the roads in Ware into which it feeds – High Oak Road and Musley Hill – can cope with the increased volume of traffic. Nor should there be access from the new development to the B1004 at Widbury Hill as neither Stansted Abbotts nor Star Street or King Edwards Road in Ware can cope with the increased volume of traffic that would result. This is, without doubt, the Achilles heel of a poor plan, as the introduction of thousands of extra cars into Ware is far beyond the possibility of the infrastructure of a medieval market town to absorb. Talk of a modal shift is just that, talk. The fact of the matter is that these houses will not be within walking distance of the High Street or railway station, each house will have at least two cars and the residents will use them. The delay in completing the spine road till 1000th home is built will lead to years during which traffic is forced onto the High Street, with rolling queues becoming stationary traffic in the afternoon peak, as shown by the applicants own traffic assessment. The data also shows that construction traffic building phase 1C will generate 80 HGVs journeys per day along Ware High Street which is totally unacceptable, with traffic taking 12 minutes to travel from the A602/A10 junction to the Fire Station roundabout.
How can you create a "sustainable" transport corridor that simply runs from a main road (A1170) to a minor road the (B1004), without offering any sustainable travel options at each end of this corridor? This is just greenwash! The proposals for improved walkability and cyclability are
dominated by adding tactile paving at crossings, adding signs and repairing the footway surface. This should be done through HCC Highways maintenance, not using funds for sustainable travel. Instead proper cycle lanes, widened footways and rerouted traffic should be put in place. The idea of the cycle hire scheme is positive but 70 bikes for the whole of Ware is not ambitious enough and the majority should be electric as the town is hilly. Car clubs are also an excellent proposal, but Enterprise is only suggesting 1 per 90 homes – the town needs the higher CoMo recommended rate of 1 per 50 homes from the start to get residents into the habit of using car club vehicles rather than buying private cars. Again the majority of the car club vehicles should be electric to reduce air pollution locally.
Overall this development will burden Ware with significant increases in traffic levels and congestion, increasing air pollution and road traffic accidents. The model suggests a doubling of traffic journey times through the town by 2029 with bus journey times taking anything between 10 and 50 minutes - with such huge delays, commuters won’t be able to trust the bus to deliver them to the station on time and will revert to commuting by car, and the modal shift plans assumed by the developer will not be achieved. These issues breach EHDC District Plan policies WARE2(ii), TRA2 and EQ4(iv).
2) Water infrastructure issues
We have about 10% of the Earth’s chalk streams in Hertfordshire. Ware’s chalk streams – the Ash, Rib, and Lea are part of a globally rare and internationally important habitat. Ware’s domestic water supply is pumped from the chalk aquifer that feeds the chalk streams. Over-abstraction of water from the chalk aquifer has resulted in our chalk streams being reduced to dangerously low flows; the source of the River Rib has moved downstream to Buntingford, while the Ash is reduced to just 11% of long-term average flows. To proceed with this development without a new strategic water supply would be criminally negligent and verging on ecocide.
The sustainability plan linked to the East Herts district plan notes that our district is “one of the most water-stressed areas of the country” in a sub-region which “experiences water scarcity” and this issue will only get worse with climate change. The draft called for new strategic water resources to provide the 12 million litres / day of water that the 18,485 new homes will require. Yet this requirement was dropped when EHDC passed the sustainability plan without scrutiny or debate, despite the plan’s failure to explain how to provide the water from resources which do not exist! Affinity Water has recently launched a discussion on strategic resource options*, including pumping in water from as far away as Lincolnshire, but there is no firm plan or funding and it can’t be implemented within the timescale required for this development. This breaches EHDC Policy WAT3(i).
Similarly, a current lack of capacity in sewage treatment means that Thames Water cannot meet demand for WARE2. This breaches EHDC Policy WAT6(i) and (ii). Finally the increase in concrete, tarmac and solid materials proposed for the fields in Ware North will inevitably make flooding worse in an area of the town already susceptible to surface water flooding. This breaches EHDC Policy WAT1(ii).
3) Healthcare
East Hertfordshire has one of the worst healthcare provisions in the country, with no inpatient or emergency services provision at all. Hertford County Hospital and the Queen Elizabeth II Hospital in Welwyn Garden City were run down on the understanding that a university teaching hospital would be established in Hatfield. This was cancelled by the austerity coalition, with inpatient and emergency services transferred to the Lister Hospital at Stevenage in October 2014. No additional provision was made for East Herts residents, with no direct public transport links provided and no additional or allocated car parking facilities. What happened to the forty (40) new hospitals promised by central government? What happened to the £350m per week ‘Brexit dividend’ for the NHS? Clearly none of this has been allocated to East Herts! To get from Wodson Park to the Lister by public transport would take a fit healthy person over an hour.
The alternative, Princess Alexandra Hospital in Harlow, is not just overstretched, it's in permanent and terminal crisis. Although a new Harlow hospital is planned, its completion cannot happen within the timescales of the development of WARE2 and it is planned for the far Eastern side of Harlow, more than 12 miles away and difficult to reach by public transport. Similarly, local GP, dental facilities, and all the other aspects of healthcare in Ware are overloaded with registration for an NHS dentist in the area no longer possible.
To permit new housing in the knowledge that there will be an increase in demand for healthcare which cannot be met would potentially be a breach of the Councillor Code of Conduct requirement to "exercise reasonable care and diligence", and a breach of health and safety legislation with the risk of litigation, possibly including corporate manslaughter (Section 11(1) and Schedule 1 of the Act provide that specified government bodies can be prosecuted for Corporate Manslaughter.)†
4) Change of Central Government Policy
The expectations set out by Rt Hon Michael Gove MP, Secretary of State for Levelling Up, Housing and Communities in his letters of 1st and 5th December 2022 to Council Leaders and MPs, set out three very clear expectations for future development and housing:
1. Planning should be about delivering “enough of the right homes in the right places and will do that by promoting development that is beautiful, that comes with the right infrastructure, that is done democratically with local communities rather than to them, that protects and improves our environment, and that leaves us with better neighbourhoods than before”.
2. Councils should refuse planning permissions for development that is not well-designed and housing targets should not be used as justification to grant permission.
3. Local authorities will not be expected to build at densities wholly out of character with existing areas or which would lead to a significant change of character. The new Office for Place will support the Council and its community in achieving this goal.
Statements by Ministers are material considerations at the planning decision stage. Moreover, the district council elections are now only five months away and local residents may wish to take the opportunity to make the elections a defacto referendum on the district plan. In the interests of
democracy and accountability, all further decision making on this development should be suspended until after the elections.
In Conclusion:
The EHGP is of the view that the scheme is not policy compliant and cannot be considered acceptable in planning terms. We cannot support the proposals given the serious implications regarding the lack of essential environmental, social and community infrastructure provision proposed.
Submitted by Alex Daar on behalf of the East Herts Green Party
* https://affinitywater.uk.engagementhq.com/strategic-resource-options
† https://www.cps.gov.uk/legal-guidance/corporate-manslaughter
