This letter has been sent by Great Chesterford resident Neil Paterson to the Planning Policy Team at Uttlesford District Council.
9th August 2017
Dear Sirs, Regulation 18 Consultation, North Uttlesford New Town
I submit the following observations for your consideration as part of the Reg 18 consultation process.
Validity of Population Growth
There is little transparency on the analysis of housing numbers included in the draft local plan. Growth in the district has been mainly a consequence of the expansion of Stansted airport, which presumably reached saturation point some time ago, with east Herts absorbing most of the housing demand.
UDC need to demonstrate that the growth projections in the draft local plan are based on current and realistic analysis, and not on inflated historic data based on peak growth from airport expansion.
Choice of sites
The location of the three large settlements is not based on demographic need, but on three groups of landowners wanting to capitalise on the £950,000 per acre value uplift on £10,000 per acre agricultural land. In the case of the North Uttlesford new town this equates to a value uplift of nearly £1bn for four farmers.
The call for sites process has resulted in three examples of opportunistic exploitation which coincidentally happens to solve the acreage required to deliver UDC’s housing need. The whole basis of the local plan is fundamentally flawed as it is based on a quick and dirty solution rather than detailed evidence based analysis, which is fundamental to the Reg 18 consultation process.
As Professor Brown, the chairman of Hinxton PC observed in correspondence with the leader of UDC – “ It would appear that UDC has given less thought to the site for what is intended to be one of it’s two largest towns than it would give to a planning application for a barn or a bus shelter.”
I would surmise that the local plan process is beyond the capability of the local planning department to resolve; what should be a forensic analysis has simply become an administrative exercise to abrogate the fate of one of Essex’s historic villages to the Planning Inspectorate. Pilate used as similar strategy.
Assumption of Need
Demand for houses on the Great Chesterford site will be from people currently living outside UDC, particularly London and Cambridge and not locals as suggested in the Local Plan. Cllr Rolfe confirms this in his letter to The Chair of Hinxton PC dated 7th July, he states ……” “the average house price in Uttlesford at £396,511 (2016) is beyond the reach of those on mean annual earnings (£38,397 in 2015) and would require a salary of £90,631.”
So where is the justification to provide 5,000 unaffordable homes where there is no demonstrable need, other than as an overspill supply for South Cambs and London. Average house sale price equates to around £265/ft2; current sales values in Gt Chesterford exceed this considerably; and housebuilder sales value expectations will be north of £350/ft2 … draw your own conclusion.
Affordable homes can be supplied locally as demonstrated by the imminent development adjacent to the recently completed Heritage Enterprise development in Gt Chesterford.
Transparency and Due Process
UDC have been opaque about their discussions with South Cambs, the outcome and content of which are highly relevant to the viability and sustainability of the proposed new town.
Following an FOI request from the Parish Council on the content and status of these discussions, UDC have determined that visibility of this information would not be in the public interest. (Ref Richard Fox’s undated letter to the Chair of Gt Chesterford PC).
The Reg 18 Consultation is meant to be open and transparent, hopefully the Planning Inspector will regard this as what it is – an abuse of process.
The report produced by the landowner’s consultant Bidwell’s provides little information on what is proposed, the report includes a fluffy aspirational plan with no tangible economic evidence to demonstrate viable and sustainable delivery.
Clearly the landowners didn’t want to spend money on a speculative punt and are waiting for a developer to fund an appropriate level of consultancy work, which should have been in place for proper Reg 18 consultation to proceed.
The infrastructure report takes no account of proposed schemes, including Genome, Wellcome, Sawston Business Park and the new Crematorium and is therefore based on flawed information. It also takes no account of the impact of significant biomed campus and associated housing development in South Cambridgeshire.
Peter Brett Associates transportation report is meaningless and ignores the fact that local highways are already at capacity, and could not absorb thousands of additional vehicles onto the B148 whose only route from the proposed site is either south towards Saffron Walden or north to Cambridge via the A1301 and A11.
A detailed and robust trip analysis should be submitted to determine what infrastructure improvements are required and the associated investment to address the impact of the new town and other local developments.
Infrastructure improvements should be funded by the landowners/Developer as a Grampian condition before any potential development commences. As a development proposal, the Landowners submission is neither viable, sustainable or deliverable.
It does however provide UDC with a quick and easy response to housing need, which will ruin rather than “enhance the natural environment” and destroy rather than “safeguard the high quality of life and character of this very special district”
An intelligent answer to both the housing and infrastructure problem would be to build a bypass around Saffron Walden which would ease congestion, improve air quality, dissipate environmental impact and facilitate ribbon development where it is most needed.
Air Quality Impact – Saffron Walden and Gt Chesterford
Additional trip generation will seriously impact the air quality in Saffron Walden. An analysis should also be submitted to demonstrate the impact of several thousand additional cars from the new town – irrespective of the additional traffic congestion resulting from newly completed and proposed commercial and residential developments in the town.
The existing roads in both locations are simply not of sufficient capacity to accommodate additional vehicles without creating massive congestion problems which will seriously impacting resident’s rights to decent air quality.
Note that at Great Chesterford a few additional cars parking on the high street adjacent to the village surgery has created such a nuisance that double yellow lines have been introduced, the impact of hundreds of additional vehicles using the high street would be devastating on both the character and environment of the village.
Impact on local services
Local schools are at capacity and not capable of absorbing the additional demand from a new town of 5,000 houses.
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 – how can this possibly be a viable and sustainable solution to local need.
The same argument applies to primary health facilities, Addenbrookes and the cottage hospital in Saffron Walden are at capacity and will not cope with an increased catchment of between 12,000 to 20,000 people.
Impact on local railway stations
Audley End carpark has already been extended and adjacent office buildings have been demolished to provide additional carpark space – the local pubs also provide station carparking – ALL of which are at full capacity.
During rush hour, it is impossible to get a seat on the south bound service unless you catch a train at 7.04 or earlier. At peak, trains comprise of 12 carriages and cannot be increased without significant platform extension at both Audley End and Great Chesterford.
The station at Great Chesterford has on street parking with capacity for @ 15 cars, Station Road is the only access to the station and several businesses – including a removals company whose HGV’s require constant access to their premises.
There are no opportunities to provide additional parking on the Essex side Gt Chesterford station, the land is currently being developed by Enterprise Heritage for additional housing, and the land to the west of the station is in South Cambs jurisdiction. Introducing thousands of additional commuters is not viable or sustainable without massive increases to station parking, which is unlikely due to limited land availability and funding requirements.
The premise that the Great Chesterford new town will create jobs is a fantasy.
Twelve years after the start of development at Ebbsfleet (George Osborne’s exemplar for Garden Village Developments), the only jobs that have been created are for construction workers, the same will apply at Great Chesterford.
If the new town were to proceed it would be the antithesis of the charming rural village that UDC hope for, in any event north west Essex has several of those already, Gt Chesterford, Icketon, Hinxton etc. all which are currently being threatened by the imposition of a mini Harlow.
Conflict of Interest
UDC’s recent investment in the Gt Chesterford Science Park, creates a conflict of interest with the proposed adjacent new town – as such UDC have a vested financial interest to ensure that the North Uttlesford new town proceeds, which is in direct conflict with the impartial evidence based analysis required from the Reg 18 process.
To comply with national planning guidelines, potential sites need to demonstrate that they are viable, sustainable and deliverable. The North Uttlesford proposal is devoid of any commercial analysis, and should as a minimum include a considered business plan, incorporating a detailed masterplan, development strategy, funding strategy, delivery and sales program, logistics assumptions and market risk analysis to prove that the development is viable and deliverable over the medium and long term.
The business plan should also determine post Brexit market risk, and adjust unit delivery to suit.
It is commercial reality that if developers and house builders fail to make their margins, the whole process grinds to a halt, as experienced in 2009. If another economic downturn were to happen, housing delivery would stop and S.106 obligations would be renegotiated downwards before delivery recommences, and UDC could do nothing about it.
The wrong proposal in the wrong location
The Gt Chesterford new town is an easy but lazy political solution to housing need, it would not exist but for the blunt speculative opportunism of four farmers. It is simply the wrong proposal in the wrong location, with flimsy and questionable justification citing adjacent and adequate infrastructure, while ignoring known capacity issues and imminent adjacent development proposals.
UDC’s vision purports to:
“safeguard the high quality of life and character of this very special district;”
Provide “Quality homes local people can afford;”
“The community benefitting from part of the increase in land value;”
“Development that enhances the natural environment;”
Generation of “a wide range of local jobs.”
The proposed settlement satisfies none of the above aspirations, quite the opposite, it contradicts one of UDC’s principle aims to prevent … “unplanned development occurring in undesirable locations” Oh the irony !
If you haven’t guessed by now, I strongly object to the proposed new town adjacent to Great Chesterford. It is a quick and lazy response to the planning authorities housing dilemma, and lacks any detail or evidence based analysis expected of a credible development proposal.
The local villages, highways infrastructure and associated public services are simply not capable of absorbing a development of this size and the area would be utterly ruined if it proceeds. The impact of this development has not been fully considered by UDC as there is simply not enough detail to undertake evidence based analysis.
This proposal is being forced upon a historic village because of commercial opportunism on behalf of the landowners and the council, with insufficient due diligence to demonstrate that the proposal is viable, sustainable or deliverable.
It is evident that while trying to follow the spirit of Reg 18 consultation, UDC will railroad the draft local plan to a predetermined conclusion and leave the cerebral analysis to the Planning Inspectorate. Frankly it’s a disgrace and a crude abuse of the planning process.
Neil S Paterson, Resident
for the benefit of those not familiar with planning terminology, a “Grampian condition” is a planning condition that prevents the start of a development until off-site works have been completed on land not controlled by the applicant.