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Another Great Example of a Persuasive Objection Letter

If you are looking for ideas of what to include in your response to UDC’s consultation on the Draft Local plan, check out our new Template Letter for you to download or copy and paste from the site.

Here’s a persuasive response from Great Chesterford resident Russell Pope:

 

Planning Policy Team,
Uttlesford District Council,
Council Offices,
London Road,
Saffron Walden,
Essex, CB11 4ER

 

22 August 2017

 

Dear Sirs

 

Local Plan – Regulation 18 Consultation – Proposed North Uttlesford Housing Development at Great Chesterford

 

As part of the Regulation 18 consultation I wish to submit the following observations.

 

I believe the Local Plan that incorporates the proposal for a new housing development close to Great Chesterford has been hastily prepared by a beleaguered Local Authority without the inclination or capability to undertake a thorough evidence based assessment of the accurate number of new houses that will be required over the next 15-20 years – whilst taking account of the most ideal size of community, the most appropriate site locations within the district and with due regard to the policies and criteria set out in the National Planning Policy Framework (NPPF).

 

Instead, UDC has rashly invited landowners – typically farmers of large expanses of prime agricultural land – to offer up their land for development and thereby obtain a windfall of many millions of pounds. This lazy approach is poor stewardship of valuable resources, detrimental to the wellbeing of North Uttlesford residents and contrary to most principles of sustainable development. Given the windfall that will benefit local farmers it is also contrary to what the vast majority of rate payers will perceive as just and fair.

 

I submit below the most significant effects that the proposed development (referred to in the Local Plan as ‘North Uttlesford Garden Village’ or NUGV) will have on land, resources, and local community where they relate to the policies set out in the National Planning Policy Framework (NPPF) and the Core Planning Principles (CPP) contained in paragraph 17 of the NPPF. In each case I have referred to the CPP’s and NPPF paragraphs that would be contravened by this development:

 

  1. Loss of Agricultural Land – Contrary to CPP 7 and NPPF paras 110 – 112

The Agricultural Land Classification map of the Eastern Region (ALC008) indicates the site is Grade 2 and 3a agricultural land – officially described as “best and most versatile”. The consequent loss of 466 hectares (1152 acres) of prime agricultural land would result in a decline in wheat production (for example) of 3700 tonnes per annum.

 

This is at a time when the NFU has reported that home grown food production has declined in the UK from 80% 30 years ago to 60% today and is likely to reduce further to 50% within the next 10 years. The NFU says that this would put the UK in a very insecure position as far as food production is concerned and that an over reliance on other countries for food is a risk to national security.

 

  1. Threat to the chalk aquifer (as catchment for the Cam/Ouse) and the Chalk Stream Environment – Contrary to CCPs 5, 7 & 10 and NPPF paras 109 – 113, 117,118,123,156,157 and 165

The proposed development land is within part of a unique chalk stream environment that feeds into the Cam and Ouse as defined and referred to by the Rivers Trust and the Catchment Based Approach Partnership. In its report, ‘The State of England’s Chalk Streams,’ the WWF-UK highlighted that the English chalk stream environment was unique and could be found nowhere else in the world. It reported that more than 77% are failing to meet the required good status; only 12 out of 224 chalk streams are protected and of these; only 15% are classed as adequately protected and meeting conservation objectives.

 

The proposed NUGV development is wholly sited on chalk aquifer, which the WWF report describes as, “the engine room of the chalk stream”. This is already classed as being “in Poor Quantitative status,” hence also creating, “a risk to drinking water supplies.”

The WWF report finds that the key pressures causing failure are, “physical modification (e.g. for land drainage and industry), over abstraction (particularly for public water supply), and pollution (e.g. from sewage works).” It further states that ensuring no further deterioration from the current meagre baseline will be challenging without a step change in management.

 

Contrary to this necessary ‘step change’ the proposed NUGV will significantly add to the pressures on the Combined Essex/Cam Ouse basin and thereby seriously deplete the aquifer even further and substantially increase the threat to these unique chalk stream environments.

 

  1. Adverse effect on landscape – Contrary to CPPs 5 & 7 and NPPF paras 109 – 113,156 and 157

In its own Landscape Character Assessment of the locality being proposed for the NUGV site UDC has lauded the following visual characteristics:

Attractive panoramic views from the eastern slopes to western valley slopes framed by distant blocks of trees; Views of towns and villages from higher ground; Valley sides descend quite steeply from rolling arable fields to the river and dramatic views are possible from the ridges; Intimate views on the lower slopes of wooded river valley floor; Intimate scale of villages and towns that contrasts with large-scale modern agriculture.

 

The report emphasises that key characteristics and landscape elements within this area are visually sensitive and are highly sensitive to change. These characteristics are stated as: the open skyline of the valley slopes “with new development potentially being highly visible within panoramic inter and cross-valley views”; Intimate views from lower slopes to the wooded river valley floor; views to the valley sides from adjacent Landscape Character Areas; a dispersed historic settlement pattern.

 

The UDC report warns against the following:

Potential for erection of new buildings, which would be conspicuous on the skyline; Potential pressure for increased use of narrow and minor roads; Potential pressure from urban expansions on the edges of Great Chesterford and Saffron Waldon; Pressure from potential expansion of villages within adjacent character areas infringing upon the generally open character of the area; Visual intrusion of potential road expansion linked to pressure of traffic on minor roads.

 

The single Landscape Strategy Objective of UDC is to, “protect and enhance positive features that are essential in contributing to local distinctiveness and sense of place.”

 

To achieve this the report states that the following Landscape Planning Guidelines should be followed: Conserve and enhance the landscape setting of settlements; Maintain cross-valley views; Ensure any new development on valley sides is small-scale and responds to the historic settlement pattern.

 

In the Landscape Appraisal by Chris Blandford Associates dated June 2017 commissioned by UDC for the Local Plan the compelling conclusion is that:

“The land at Great Chesterford is of high landscape and visual sensitivity, considering: its steeply sloping landform and elevated position; its open fields and limited vegetation structure; and the potential for long distance cross-valley views into the Site.  Furthermore, given the settlement pattern within the area of Great Chesterford – where settlements and road and rail infrastructure largely follow the valley floor/lower valley sides – development cutting across the upper valley sides and the ridgeline of the Site would be uncharacteristic of the local settlement pattern.“

 

It is clear from the evidence above that, from a landscape perspective alone, any development on the site proposed for the NUGV would be wholly inappropriate and contrary to all national, regional and local guidelines and recommendations, including those of UDC itself. In proposing this site for development UDC has flagrantly ignored its own conservation policies and objectives.

 

  1. Present a serious threat to important and historically significant Heritage Assets – Contrary to CCP 10 and NPPF paras 110,126,129,132,133,156,157 and 169

The excavations documented in East Anglian Archaeological Report no 137 2011 are extremely important in the context of the history of Roman Britain and they evidence that Great Chesterford was a significant strategic Roman settlement. The remains of the Romano-Celtic temple 400m south of Dell’s Farm – a Scheduled Ancient Monument – is of particular importance.

 

There is also evidence of Anglo-Saxon remains around Great Chesterford, including a recently unearthed Anglo-Saxon burial ground. There is widespread agreement, both current and historic, that there will be many more ancient remains and heritage assets in the close vicinity of Great Chesterford that is preserved in its buried condition. These would be substantially harmed or even totally lost if excavations for the NUGV were to proceed.

 

The Heritage Impact Assessment within the Local Plan describes the potential damage thus, “Excavation of surrounding land may cause irreversible harm to buried Archaeology, which could inhibit future interpretation of the site.”

 

The concluding recommendation of the Heritage Impact Assessment is categoric,

“I must advise however, that based on the information available at present, it is unlikely that the proposed scheme could be achieved without causing significant harm to the significance of the numerous heritage assets detailed above, most notably…the Romano-Celtic Temple (Scheduled Ancient Monument). The resulting impact of the development as proposed, upon the setting of the heritage assets would compromise their overall significance. In response to this, the ‘heritage’ benefits arising from the scheme……are unlikely in my view to mitigate this harm.

In light of the above, whilst there would be a significant public benefit arising from the scheme in terms of new housing, my recommendation would be that alternative sites are considered, in order to achieve this benefit elsewhere, without compromising the heritage assets within what is considered a highly sensitive site.”

 

It is important to note that the Heritage Impact Assessments for the two other sites proposed for development within the Local Plan do not carry this recommendation; instead they advise that, subject to certain measures, the two schemes could be achieved on their respective sites without causing substantial harm to the significance of their heritage assets.

 

The site proposed for NUGV at Great Chesterford is unique in respect of the irreversible harm that would be caused to significant Heritage Assets.

 

  1. Create a significant risk of flooding – Contrary to CPP 6 and NPPF paras 111,156 and 162

Downstream flood risks at the bottom of the proposed NUGC site are already well known – even for existing ground and below ground conditions. There have been occasions during the last 15 years when run off from fields during heavy rainfall has caused serious flooding in Great Chesterford particularly along the High Street, Manor Lane and South Street towards the river.

It is the statutory responsibility of the Environment Agency to avoid the potential for flooding and I trust they will give careful and honest consideration to flood risk in their comments on NUGV. It is highly likely that the findings of the Environment Agency will be that hard surfaces created by the NUGV will significantly increase the risk of flooding unless robust (and no doubt expensive) mitigation measures are engineered into the scheme. The Economic Viability Study prepared by UDC does not appear to have allowed for the cost of measures necessary to mitigate the risk of flooding.

  1. Take the road transportation network beyond capacity with no adequate funding identified for mitigation – Contrary to CPPs 2,3,11 and 12 and NPPF paras 152,156,157,162,177 and 179

Assessments of projected transportation modes and movements have been based upon incorrect/inadequate reference data and hence the conclusions are substantially flawed.

Traffic Assignment Evidence prepared by Peter Brett Associates for Bidwells, and apparently accepted by UDC, shows that 32% of work commutes would be to Cambridge, 17% to London, 4.79% to Granta Park and 2.75% to the Babraham Research Campus. UDC has also commissioned a study titled ‘South Cambridgeshire Junction Assessments, which has been prepared by WYG Transport Planning.

 

No consideration has been given to employment areas west of the A505/M11 junction towards the A1 (Royston, Baldock, Letchworth, Hitchin, Stevenage and Hatfield) or North of the M11 towards the A14 (West Cambridge).

Furthermore, neither the district wide Transport Study or the South Cambridgeshire Junction Study have taken any account of planned growth in West Suffolk – an additional 5,000 homes, much of which will rely on the A1307 to access jobs in the Cambridge area – nor have they taken account of 20,000 planned extra jobs in Cambridge and South Cambridgeshire.

 

The conclusion of the PBA report that the A505 west of the MacDonalds Roundabout would account for 7% of traffic is therefore incorrect. All transport by car to/from the locations referred to above will utilise the A505 between M11 junction 10 at Duxford and the MacDonalds roundabout. This is already at capacity during peak periods and even significant and costly improvement (dualling this length of the A505) would only be sufficient to ease existing congestion – such improvements would not adequately cope with the additional transport movements created by 5,000 dwellings at the NUGV.

 

The inevitable outcome is that to avoid the serious congestion that would occur on the A505 a significant amount of traffic will take the locally familiar ‘rat run’ route through the villages of Duxford, Ickleton and Great Chesterford. Therefore, the notable conclusion within the PBA report that, “local routes through adjacent villages are not forecast to be impacted by development in this location,” is fundamentally wrong.

 

It is also significant that the Economic Viability Study prepared by UDC only allows for an expenditure of £1m on road transport mitigations, whereas the South Cambridgeshire Junction Assessment advises that the actual cost of road transport mitigation measures that will be required (although still not adequate for the reasons stated above) will be £7.5m to £11m. Considering that Essex County Council have already made it clear that they will not contribute anything to road improvement costs and Cambridge County Council will only do so when taking account of developments within SCDC the inevitable conclusion is that UDC must make a further allowance of about £10m within its Economic Viability Study. With other costs that have also not been accounted for this would very likely make the whole scheme commercially unviable. (See point 8.)

  1. Take other local Infrastructure beyond capacity with no adequate funding identified for mitigation – Contrary to CCPs 1,2,3,4 and 12 and NPPF paras 152,156,157,162,171,177 and 180

The current situation in the Great Chesterford area in respect of infrastructure and services is as follows:

Education

All local schools are oversubscribed and have class sizes well in excess of 30. They are incapable of absorbing any additional demand whatsoever, let alone the increase that will derive from a new town of 5,000 houses. Note – the housing thresholds for providing a new primary and secondary school are 700 and 3,500 respectively. Assuming delivery of 150 units per year (which is optimistic) this won’t occur until 5 years and 23 years after post infrastructure development commences. Existing schools will not cope with any additional intake in the meantime.

 

Health

Local GP surgeries are already at full capacity and appointment waiting times are several weeks. There is no provision within the Economic Viability Study for a new medical centre;

Addenbrookes hospital is currently running at a critical level and has been for some time. The only prospect is for this situation to worsen even without the additional demand that a new town of approximately 15,000 residents will create. It is likely that Addenbrookes will not accept this additional demand and Essex residents will be required to attend Princess Alexandra hospital in Harlow. The extra distance would put resident’s health, and even lives, at risk, particularly in respect of accident and emergency services.

 

Railway and local station

Great Chesterford railway station has a number of issues of concern. The land around the station and the station building were sold off for private development, leaving on street parking with capacity for just 15 cars, hence parking spills onto the main road and blocks public footpaths. The only access to the station is along Station Road, which is extremely narrow. The road also serves several businesses – including a removals company whose HGV’s require constant access to their premises. There is no public footpath and to access the station pedestrians must walk in the road alongside parked cars.

There are no opportunities to provide additional parking on the Essex side of Great Chesterford station as the land is currently being developed by Enterprise Heritage for additional housing. The land to the west of the station is within SCDC jurisdiction.

Audley End carpark has already been extended and adjacent office buildings have been demolished to provide additional carpark space. Even local pubs provide carparking for commuters. Despite this parking at Audley End station is at full capacity with no prospect of this being increased.

 

Trains comprise 12 carriages during peak periods yet this is insufficient for current passenger numbers and a large number are forced to stand on. The number of carriages cannot be increased without significant platform extension at both Audley End and Great Chesterford. Trains are often delayed and cancelled and Abelio Greater Anglia Railway was recently voted 4th from bottom of all rail operators in a recent Which? Survey (January 2017). As such, the rail service cannot be described as “good” as stated in UDC local plan.

Introducing thousands of additional commuters is not viable or sustainable without a significant increase to station parking. Due to unavailability of land and no funding being identified such provision will never materialise.

  1. The proposals for NUGV are not Commercially Viable – Contrary to CCP 3 and NPPF paras 159,173 and 177

The NUGV proposals lack any degree of commercial analysis. At the very least the Local Plan, where it relates to NUGV, should include a considered business plan incorporating a detailed masterplan, development strategy, funding strategy, delivery and sales program, logistical assumptions and market risk analysis to prove that the development is viable and deliverable over the medium and long term.

 

The business plan should take account of all ancillary and infrastructure costs associated with the scheme where no alternative funding source has been identified. Such costs should include those referred to above: additional class rooms and teachers, additional health services including a medical centre and greater A&E provision; railway and station infrastructure; road transport mitigations (£7.5m – £11m); flood risk mitigations; the cost of extensive archaeological investigations and the measures they recommend for the protection of Historic Assets.

 

When all these costs are incorporated within the Economic Viability Study, as they should be, the NUGV will almost certainly prove to be commercially unviable.

 

Conclusion

It should be clear to anyone, lay person or professional, that any one of the points referred to above should be sufficient, by itself, to warrant a more suitable site, or number of smaller sites, being found to accommodate the additional housing that is needed in Uttlesford over the next 15-20 years.

 

The contravention of so many central Government planning principles and policies renders the proposed development at Great Chesterford fundamentally untenable.

 

Yours sincerely

 

Russell Pope

Resident of Great Chesterford

1 Comment on "Another Great Example of a Persuasive Objection Letter"

  1. Packed with evidence, written objectively and illuminating various facets of the issues at hand, this letter proves convicingly why the “development” is untenable and should not go ahead. Thank you for the time and effort that you have expended on this, Mr Pope.

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