Further to our telephone conversation on Monday 4 th April 2007 I enclose an electronic copy of our representation on behalf of our client TAM815.

Transcription

1 2 nd April 2007 Our ref: AAH/YS/SWO Let073 Ms Sarah Nicholas Senior Planning Officer Uttlesford District Council Council Offices London Road Saffron Walden CB11 4ER Dear Sarah Re: Representations on Uttlesford Core Strategy Further to our telephone conversation on Monday 4 th April 2007 I enclose an electronic copy of our representation on behalf of our client TAM815. Yours sincerely A A Hudson Direct angus.hudson@sworders-agri.co.uk Attachment TAM815Rep

2 Representations in Response to The Uttlesford Core Strategy Policy Choices And Options For Growth Due By March 9 th Client Ref: 815 Vision Statement 1 Employment Growth It is important for companies to be able to grow without leaving Uttlesford and employment growth should be the key economic driver for the region. Substantial opportunities will arise as a result of the expansion of Stansted Airport and Uttlesford is the District best placed to benefit therefrom. Strategic Objective 1 Employment Growth Uttlesford should support the local economy which retains and encourages growth of existing and new employers by providing enough land and premises of the right type and in locations that will meet the anticipated needs and aspirations of businesses. In particular, Uttlesford should recognise the importance of the expanding Stansted Airport and new employment generated by both existing and new employers and the need to release land close to the airport that is close to major strategic routes to provide sustainable growth and seek retention of those business uses within Uttlesford District. Core Strategy Policy E 1 Employment Land Provision Support Core Strategy Policy E 2 Safeguarding Existing Employment Sites Of the two options put forward by Uttlesford - clearly allowing the market to decide which sites are appropriate and releasing sites where there is not commercial interest for other uses - has to the most appropriate and sustainable Policy.

3 Trying to protect employment sites for non commercial reasons risks those sites becoming run down, vacant, vandalised and, as a result, the loss of sustainability. Releasing former commercial sites for other uses where there is demand for such uses will actually facilitate enhancement of the District overall. Core Strategy Policy E 3 Employment Growth The two alternatives put forward to allow existing companies to grow within the District are both potentially feasible and need not be mutually exclusive and both could have a useful role within a Local Development Framework Document. Strategic Objective 2 Working from Home We support reduction in travel to work by encouraging development which gives people the opportunity to work from home. This can be done through a number of means by encouraging live/work units. Strategic Objective 3 Renewable Energy Strategic Objective 4 Biomass and Biofuels Core Strategy Policy E 5 Renewable Energy

4 Core Strategy Policy E 6 Biofuels Core Strategy Policy E 7 Biomass Core Strategy Policy GA 1 Public Transport Whilst the principle of ensuring new development is accessible by public transport is a good one, any Policy based on this needs to reflect the practicalities of a limited bus network. Whilst clearly it is a key and essential Policy for large scale housing developments, there will be wide spread smaller developments throughout the District, including in some of the larger sustainable villages where there are appropriate facilities, schools, etc., but where public transport may not be available specifically to the site. Whilst the principle of the Policy is supported, care should be taken in the wording and exceptions should be allowed for sites that could otherwise form a sustainable contribution to housing development and should not be vetoed purely on the grounds of lack of an existing public transport link. Core Strategy Policy GA 2 Travel Plans Whilst travel plans are a laudable aim particularly for schools and larger businesses, they can place an undue burden upon smaller businesses and therefore any Policy needs to include flexibility and take into account scale and have an appropriate exceptions provision where other circumstances justify such. Strategic Objective 7

5 Housing Provision Strategic Objective 8 Infrastructure Core Strategy Policy DC 1 Housing Needs Core Strategy Policy DC 2 Affordable Housing Whilst the principle of encouraging affordable housing within given schemes is supported, the current drafting suggests an element of affordable housing at 40% of the total provision of housing. Bearing in mind that the shortly to be adopted PPS3 will allow sites of less than 15 units not to provide any affordable housing, by setting an overall target of 40% for the entire District such would place immediate pressure on all sites above the PPS threshold to provide a total greater than 40%. Bearing in mind also that National Government are consulting on a Supplemental Planning Gain (Development Land Tax) which could be implemented as early as April 2009, and bearing in mind the other increasing burdens on developers to deliver Section 106 contributions on larger sites, it would be prudent to include a degree of flexibility within the affordable housing provision. The importance of this is underlined by the fact that if a site does not come forward at all (because it is unviable due to a disproportionate affordable housing requirement), then no affordable houses would be delivered from that site.

6 Furthermore, it is also important to identify that the Policy should require developers to make land available for affordable housing rather than actually having to provide the housing itself, as clearly this isn t the intention of PPS3 and ambiguity in Policies of this nature should be avoided where possible. Similarly, the word negotiating ought not to be included within a Policy. Core Strategy Policy DC 3 Providing Services Core Strategy Policy DC 4 Site for Gypsies and Travellers Strategic Objective 9 Metropolitan Green Belt Supported in principle, other than where a Metropolitan Green Belt Review is appropriate, for example to consider an allocation for housing or employment land. Strategic Objective 10 District Character Core Strategy Policy DC 5

7 Metropolitan Green Belt In principle this has to be the starting point for the Metropolitan Green Belt to be unchanged from the current adopted version. Core Strategy Policy DC 6 Protecting the Countryside In principle the countryside should be protected with control on new development outside existing settlements and any land needed for development. However, this Policy should incorporate the provisions of PPS7 and the Good Practice Guide on Planning for Tourism. Both these documents give positive recognition that new development in the countryside can be appropriate in certain given circumstances. Core Strategy Policy DC 14 Requirements for New Development The principle of this supported, albeit the circumstances of a particular site should be taken into account and the Policy should be drafted to allow this. Core Strategy Policy DC 15 Retail Centres Strategic Objective 16 Reducing Greenhouse Gas Emissions The principle of this Policy is supported. However, different types of development produce levels of Green House gas emissions both in relation to construction and future use and ancillary (i.e. knock on) effects thereof.

8 A Policy of this type by its very nature has to be broadly worded to allow some flexibility. For example this Policy as drafted would conflict directly against further expansion of Stansted Airport which itself could provide key employment growth and other opportunities for the District and it should also be borne in mind that Stansted Airport provides a convenient departure and arrival point for many Uttlesford residents. Core Strategy Policy DC 17 Development and Flood Risk The principle of this proposal is supported, although the Policy could be more appropriately worded to recognise the inevitable inaccuracy of national data relating to flood plains provided by the Environment Agency compared with specific site surveys. 7 Options for Growth 8 Growth Strategy Option 1a Concentrate all development at Saffron Walden It is difficult to comment on the principle of such a proposal until a fuller assessment has been made as to the ability of Saffron Walden to deliver the additional 3,000 homes sought. However, given the level of development that went to Great Dunmow and Felstead on previous occasions, it would certainly be appropriate to carefully consider the opportunities for expanding Saffron Walden. 9 Growth Strategy Option 1b Concentrate all development at Great Dunmow A combination of Great Dunmow and Felstead have provided a disproportionate amount of Uttlesford s growth in the previous Plan period and just because the A120 provides a physical barrier to the south of the town does not automatically mean that further expansion of Dunmow at the current time on such a scale would be in the interests of either the current community or future residents. 10 Growth Strategy Option 1c Concentrate all development at Stansted Mountfitchet 3,000 homes would swamp Stansted Mountfitchet if entirely concentrated there and whilst there may be scope for some more modest

9 growth at Stansted, the scale of the development should take into account the ability of the existing village and infrastructure to provide an integrated settlement. 11 Growth Strategy Option 1d Concentrate development in the largest centres Great Dunmow has already taken a disproportionate amount of development in the previous Plan period but it may be appropriate for Saffron Walden and, to a lesser extent, Stansted Mountfitchet to take additional housing proportionate to their scale and reflecting the ability to integrate such to the existing development. It is extremely difficult to comment on the concept and principle of a single new settlement without knowing the location. However, given the regeneration opportunities provided by additional housing to those areas that have not had to take substantial housing numbers in previous Plan Reviews, a single new settlement may not be necessary. The East of England Plan Panel also had the opportunity to consider a new settlement for the current Plan period and decided against doing so, albeit they have reported that it may be a possibility for a further subsequent Plan Review. Therefore, at this stage, Uttlesford would be going beyond the remit of the anticipated Regional Spatial Strategy if they were to opt for a single new settlement at this stage. 13 Growth Strategy Option 2a Distribute development over a range of settlements Whilst a number of the growth strategies overlap to a significant degree, this growth strategy as a broad principle probably represents the most appropriate one for the District. However, if the basis of distribution were proportional to the scale of the towns and larger villages, then in addition to sustainability issues it would also be appropriate to take into account previous scale of development such as that at Great Dunmow and, to a lesser degree, Stansted Mountfitchet. 14 Growth Strategy Option 2b Distribute development along the West Anglia Rail Corridor

10 Again, whilst this Policy would be ambitious for the total 3,000 houses, there is certainly scope for significant contributions to a proportional distribution based spread for sustainable, modest extensions to villages along the Rail Corridor, such as Stansted Mountfitchet, Elsenham, Newport and Great Chesterford. Whilst employment land could be provided in Wendons Ambo close to Audley End railway station, it would be a less sustainable solution than providing employment land next to existing and new residential development. 15 Growth Strategy Option 1c Distribute all the development in villages around the District This gives two options. Clearly including all villages and seeking to allocate sites within those villages as part of a Local Development Framework Plan would be an ambitious project and many smaller villages would inevitably be inappropriate for such development with a very low sustainability score. Therefore including only villages with a certain level of facilities has to be a sensible principle but whether or not the village should have to have to have a primary school is probably too much of an assumption to make in a Policy Choices Statement. Certainly there are a significant number of larger villages that could make an important contribution to the delivery of houses for the District with places such as Newport, Elsenham and Hatfield Heath placed to provide a range of facilities. 16 Growth Strategy Option 2d Distribute development along the A120 Corridor and at Great Dunmow Given the amount of development that Great Dunmow has taken in the previous Plan period an extension to the south of Dunmow is considered inappropriate. The A120 should not provide the reason for developing to the south of Dunmow. TAM815