Here is the submission made by the StopNUtown Action Group Steering Committee to the pre-submission Uttlesford Local Plan. Rather than try to cover everything we focussed on key issues that strike at the credibility of the decision-making process of the Local Plan, question how North Uttlesford Garden Community came to be in the plan, and point to some of the more important reasons why it should not be in the plan. Other respondents, notably Great Chesterford Parish Council and Hinxton Parish Council, have made very detailed responses on traffic, landscape, archeology, flood risk, water and other topics.
The information below starts at section 3. The first two sections are the usual preliminaries so we have excluded them here.
RESPONSE TO REGULATION 19 PRE-SUBMISSION LOCAL PLAN
StopNUtown action group of residents in the area of the proposed North Uttlesford Garden Community
3. Our position on the Uttlesford Local Plan – in summary
A new community on the site of the proposed North Uttlesford Garden Community is not adequately justified and has not been shown to have a reasonable prospect of being viably developed. For this and other reasons given below we consider the Local Plan to be unsound.
3.1) the plan as a whole fails because:
- It has not been positively prepared (see 5 of this response).
- UDC did not undertake a district-wide landscape, environmental capacity and comparable transport assessment, which brings into question the selection of sites (see 6.1 of this response).
3.2) A new community at the proposed NUGC site presents so many challenges there is little prospect of it being viable or deliverable within provisions of the NPPF and NPPG:
- Landscape issues, mitigation of flood risk in the Cam valley, avoidance of damage to heritage assets and mitigation of risk to underlying aquifers will result in a significantly reduced build area. It is unlikely the build scale required to unlock full infrastructure funding can be achieved.
- Adequate public transport and improvements to the road network and site access in order to make this a sustainable development will involve very substantial sums, for which there is no identified funding, no timescale and no guarantee of delivery. It is questionable whether the necessary works could be delivered within the lifetime of the plan.
- Impacts on surrounding communities will be considerable, especially on roads around and through villages and the town of Saffron Walden, the nearest primary shopping centre.
- Important questions remain unanswered in respect of water and electricity supply to a new settlement of this scale in this location. Significant and costly upgrading of supply infrastructure is likely.
- UDC states the new community will adhere to TCPA Garden City Principles however there are inherent contradictions between the viability challenges of the site and the TCPA requirement for (among other considerations) 60% of housing to be “affordable” (social rent, shared equity, low cost or discounted ownership).
Housing on such a large scale is not needed in the north of the Uttlesford. Even if it were, the factors outlined above combine to make NUGC undeliverable. Simply stating a grandiose ambition is no substitute for a proper and detailed assessment of the realities.
4. Omissions, contradictions and misleading statements in the draft plan
We would draw the Inspector’s attention to the following in the context of the proposed North Uttlesford Garden Community (NUGC):
4.1) Chesterford Research Park
Nowhere in the plan is it stated that Uttlesford District Council owns 50% of Chesterford Research Park (CRP). Since CRP forms a significant part of UDC’s justification for NUGC we consider this a serious omission.
Further, the council says:
Ref. 2.10 “ The District is central to the London Stansted Cambridge Corridor economic growth area and in particular the importance of London Stansted Airport and its role within the South Cambridgeshire research and bio-technology cluster focused on Chesterford Research Park.” By no stretch of the imagination can CRP be considered to be the “focus” of the South Cambridgeshire research and bio-technology cluster. This is misleading.
Ref. 2.11 “ …… There is one major employment centre in the south of the District at London Stansted Airport. Chesterford Research Park is also a key employment area in the north…” Chesterford Research Park does not compare in any way with Stansted Airport as a source of employment. The council’s own forecast indicates that 90% of all new employment in the district will occur in or around Stansted Airport. Emphasising CRP in this way is highly misleading. CRP will at best contribute a further 900 new jobs during the balance of the plan period, which if achieved would represent just 6% of the district’s total employment growth.
4.2) Wellcome Genome Campus
The draft plan ignores the prospect of a submission by the Wellcome Trust of a 1,500 dwelling proposal at the Wellcome Genome Campus immediately the other side of the county boundary and 600m from the northern edge of NUGC. The expansion of this world-renowned facility is of national importance and is likely to be endorsed by South Cambs District Council even though it falls outside their Local Plan. Wellcome intends to meet its own housing need so will not be a source of jobs for NUGC and unlike NUGC, this development is not reliant upon third party agreements so will most likely build-out before NUGC. The Wellcome Campus lies on the A1301, the same road as residents of NUGC will use to access Cambridge and the M11 northbound.
4.3) TCPA Garden City principles
Ref. 3.78: The garden communities will be developed in accordance with Garden City Principles developed by the Town and Country Planning Association. However:
(i) the council has reworded one of the most important principles to suit its own objectives. TCPA states: A wide range of local jobs in the Garden City within easy commuting distance of homes; whereas UDC says (SP4, 3.78 and SP5): A wide range of local jobs within easy commuting distance from homes (note the omission of “in the Garden City”). The Possible availability of jobs at places of employment outside the community (including CRP, 50% owned by UDC) does not meet TCPA principles.
(ii) Additionally, the council seems intent upon substantially under-providing housing that is “affordable.” TCPA states: At least 30% of homes in a new Garden City should be for social rent. Other forms of affordable housing such as shared equity, low cost or discounted ownership should form at least a further 30% of homes. Thus 60% of the entire provision would fall into an affordable category. However UDC states (SP7.1) there will be an affordable & social provision of only 40%.
4.4) Access to NUGC
SP7.8 states “the primary southern access into the site will be via Field Farm Drive, access via Park Road will be limited to ensure the character of Park Road is protected.” However, 3.1.4 of the Infrastructure Delivery Plan (June 2018) states the promoters have proposed: “…. a new roundabout/signalized junction onto the BI84 near Park Road.” This would suggest an intention to make Park Road a primary access point.
5) Has the plan been positively prepared? NO –
While the plan paints a visionary picture of growth to give the appearance of having been “positively prepared” the reality is years of incompetent management of the plan process and no genuine engagement with communities.
5.1) The late addition of a new settlement in north Uttlesford (which resulted in a 12 month delay in publishing the local plan), has been widely criticised as a political construct to avoid further housing in the south of the district, where Conservatives are in the majority unlike the north of the district where they are not.
5.2 The Uttlesford Local Plan as presented at Reg 19 is entirely based on The West Essex and East Hertfordshire Strategic Housing Market and Functional Economic Market. No analysis has been made in the context of the adjoining South Cambridgeshire market and yet 13% of the entire proposed housing allocation in the plan (and 30% of the housing yet to be built), is alongside the district/county border with South Cambs.
5.3) Behind the supposed need for three new settlements is an OAN that has been repeatedly questioned. Requests for UDC to recognise a potential major flaw in methodology and to disclose the precise method of calculation used by its consultants, ORS, have been ignored. The council continues to obfuscate. An early review of the OAN might have suggested a need for only two new settlements. A detailed critique of the OAN is provided in the reg19 response by Michael Young, who has spent several years tracking the evolution of the OAN used by UDC and for that reason we do not go into detail here.
6) Is the plan justified, effective and sustainable? NO –
6.1) The council’s process of site selection is inadequate. The council’s Identification of Reasonable Alternatives paper of April 2017 makes clear that seven potential new settlement sites were submitted by promoters and that “it has not been necessary to identify any additional potential growth locations.” Why was such an important decision not informed by a district-wide landscape, environmental capacity and comparable transport assessment? How is the council’s process for site selection likely to meet the soundness requirements of paragraph 182 of the NPPF that a Plan should be “the most appropriate strategy when considered against reasonable alternatives.”
6.2) The council proceeded to add a third new community to the draft local plan in the north of Uttlesford alongside the Cambridgeshire border and the border with South Cambs District Council, despite:
i) there being no unmet housing need in the South Cambs authority area;
ii) 90% of Uttlesford’s projected employment growth being in the south of the district around Stansted Airport, a 36-mile roundtrip by car from NUGC and with limited prospects of reasonable public transport options;
6.3) The council’s late addition of NUGC to the Local Plan coincided with its purchase of 50% of Chesterford Research Park, less than 2 miles from the site of the proposed new community. Local communities have justifiable concerns about a conflict of interest between UDC as 50% owner of CRP and its role as prime mover of the Local Plan and as the planning authority. At a 2018 planning meeting to consider an application from CRP a councillor (on record) stated that a vote in favour would protect the council’s investment.
This is significant when read together with:
(i) the council’s rewording of Garden City Principles in which the council has removed the obligation to provide employment within the new community, and:
(ii) the absence of any estimate for total employment space to be provided within NUGC. Are we later to be told that employment space within the new community is not needed because there is plenty of space at Chesterford Research Park?
iii) Ref. 5.9 Chesterford Research Park (CRP) is projected to contribute no more than an additional 900 jobs to 2033 and conditional upon an additional 35,300 sq.m. of space being built during the plan period. This is not justification for creating a new settlement (NUGC),
6.4) The NUGC site was previously discounted as unsuitable in an earlier iteration of the Local Plan. Nothing has since changed about the site or its surrounding area except for the council’s acquisition of 50% of Chesterford Research Park.
6.5) UDC’s own landscape officer in a report of May 2017 says: “I am of the view that this Site cannot accommodate the development shown in the illustrative masterplan ….. without causing significant and unacceptable harm to the important visual qualities of the site and the wider landscape.” This was identified in the Reg18 consultation since when neither UDC in its Reg19 pre-submission draft nor the developers (Grosvenor) following their “vision” presentation, has made any new proposals. This would suggest they accept the scope to mitigate “unacceptable harm” is very limited and thus choose to ignore the importance of this aspect of the NPPF. The Reg19 submission by Great Chesterford Parish Council provides a fuller response together with independent opinion.
6.6) The transport rationale for NUGC relies on flimsy arguments based on the simple proximity of NUGC to the M11, A11 and a railway line. None of these provide workable routes to employment, shopping or leisure without damage to surrounding communities or requiring very substantial expenditure on new infrastructure, for which there are no funding proposals. Specifically:
i) M11 junction 9, which is close to the proposed NUGC site, only provides access in a southerly direction. To access the motorway northbound or to exit the M11 from the north to reach the new settlement requires driving via junction 10 of the motorway and involves a notorious intersection of the A1301 and A505 – the latter road is already rated one of the most congested roads in Cambridgeshire and results in rat-running through Ickleton, Hinxton and Duxford. Any increase in congestion and rat-running would have very serious impacts on those communities to the point of making it intolerable to live in the village centres.
ii) Consequently, the potential impact of NUGC on the road network either side of the county boundary is substantial, involving not only the A1301/A505 but also the A1307 and the B184, the latter being a principle road linking Saffron Walden to the M11. The Reg19 submission by Great Chesterford Parish Council provides a fuller response by an independent transport planning consultant.
(iii) The transport ‘solutions’ proposed are purely speculative and not based on either valid evidence or agreed cross-boundary co-operation (SP7: 6-8). Before improvement can be relied upon in plan making there needs to be commitment from the highway authority to delivery of a scheme, assuming that funding can be secured. Furthermore, the relevant highways authority for the A1301 and A505 is Cambridge whereas the development is in Essex, so there can be no certainty about improvements. The lengthy process of gaining development consent and carrying out major improvements puts this some years into the future.
(iv) The UDC “Infrastructure Delivery Plan/Garden Communities and Settlements” dated June 2018 is woefully short of detail. The frequency of “unknown amounts” and “Unknown delivery date” make this nothing more than an aide memoire to what needs to be done. How can this be considered a document upon which meaningful consultation is invited?
6.7) The expectation of a “step change” in traveling habits with 60% of trips by walking/cycling or public transport is totally unrealistic for a community in a rural location such as the proposed NUGC. There is absolutely no evidence this achievable.
6.8) Ref 3.101 “a cap of 3,300 new homes on any allocation at NUGC to ensure that development over this figure does not take place until strategic highway improvements have been implemented.” However –
(i) If Genome campus (600m away from NUGC) proceeds with its 1,500 housing development the cap at NUGC will need to be 1,800 since both sites will use the same road infrastructure.
(ii) what implications will a cap have on the provision of a secondary school? Essex County Council states 3,500 dwellings as the trigger for a secondary school in which case any building cap below this threshold could indefinitely postpone the provision of a secondary school in an area where secondary education is under severe pressure.
6.9) The proposed new settlement lies in the watershed of the River Cam and could have serious implications for the speed and volume of water running into the river and it’s flood plain, which is already a high risk zone. No evidence is offered to support the assertion by developers Grosvenor that “NUGC has the potential to reduce the risk of flooding.” This apparently would be by means of absorbent surfaces and holding ponds. No explanation is given as to how and by whom these mitigations would be maintained long term and how future householders could be required to maintain absorbent surfaces. National Planning Practice Guidance indicates that development should not be permitted if the effect is to increase the risk of flooding.
6.10) There is woefully inadequate appraisal of: (a) Impact on aquifers, and (b) sewerage. An evidenced and detailed explanation of these factors is provided by the Hinxton Parish council in their response to the pre-submission local plan.
6.11) The area over which the new town will be built has considerable historic significance, including an important Roman Temple (a Scheduled Monument) and other artefacts. Recent archaeological excavations for the new Crematorium on the perimeter of the site suggest that there is a wide area of undesignated assets. The Reg19 submission by Great Chesterford Parish Council provides a fuller response in this respect.
6.12) We believe there are important considerations of deliverability, which seriously compromise the likely outcome of NUGC:
i) It is dependent upon land availability from four landowners. The developer will only deliver against draw-down options that will be market-led and cannot be guaranteed;
ii) Landscaping issues and Infrastructure costs within and outside the site are of such a scale that when fully calculated will almost certainly result in non-viable assessments;
iii) Control of housing delivery will be twice removed from UDC – the developer will be selling parcels of land to house builders, and it will be the house builders dictating the delivery. UDC will find it near impossible to enforce S106 obligations and/or TCPA Garden City Principles when market conditions change.
In conclusion, we restate some of the key reasons why NUGC should not have been included in the local plan:
7.1) Attempting to justify a new settlement on the grounds of Chesterford Research Park and the south Cambs research and bio-science cluster doesn’t work.
- At best, CRP will create 900 jobs to 2033 and that is entirely dependent on building more facilities and assumes there will be demand from science/R&D businesses to locate at CRP, which is far from certain. To date CRP has under performed. UDC’s acquisition of 50% of CRP in 2016 clouds what should be an arms length and objective decision-making process.
- Forecast growth in the South Cambs science cluster and the housing required to match this is already catered for in the South Cambs Local plan. There is no unmet housing need in south Cambs.
- To build beyond South Cambs’ OAN in expectation that the new settlement will be occupied by commuters to the south of Uttlesford, Cambridge, London or elsewhere will seriously upset a delicate sustainability balance in the North Uttlesford/South Cambs region. The roads and public transport facilities in North Uttlesford and South Cambs are not able to support a new settlement at NUGC without very substantial expenditure for which there appears to be little appetite.
7.2) The expectation stated by developer Grosvenor in their vision statement that the new community will provide 4,300 jobs within the community appears to be based on nothing more than guesswork and wishful thinking.
7.3) It is not acceptable to wait until a planning application is submitted before providing detail of the highways improvements required to avoid severe adverse impacts. If the work requires land outside the control of the developer or the works are simply too costly to be realistically born by the development, then the site will not be deliverable and should not be allocated for development.
7.4) It is evident that UDC has not met its duty to cooperate with South Cambs before adding NUGC to the local plan.