Lets take this to the examination. That’s why we have them. Those calling for ‘no more money to be wasted’ are concerned about losing in my view. It is however essential to get the SEA right, as it will be this that addresses distribution options, now that the number is fixed by the inspector. So why not hire a neutral third part to intermediate on the SEA consultation and options, and evidence feeding into it, like Kevin Murray Associates, taking account, after the AVLP decision, that PINS and MCHLG expect plans to progress with contingencies in the face of transport infrastructure uncertainties. This is no reason to wait too long to commence the SEA, the only issue is at what point and following which evidence does the SEA conclude and what options should it consider. The ball is equally in CAUSE’s court in preparing an alternative option with the same numbers.
The Council Leaders
Over the last few months there has been a great deal of speculation about the North Essex Garden Community proposals following the Planning Inspector’s letters published in June.
Since that point, it has been important for us to both understand in more detail the Planning Inspector’s findings and to take independent legal advice on the options available.
It is critical that we have a Local Plan in place. This is the document and set of policies which effectively set out where and what type of development will be permitted in North Essex. Without it we open ourselves to speculative and piecemeal development.
But, it is also important that we do not rush into adopting a Local Plan which does not address current and future needs in the most sustainable way possible.
Within the Local Plan collectively in North Essex we need to build 2,186 homes a year – a figure agreed by the Planning Inspector based on our population need over the coming years.
The easiest way of getting a Local Plan over the line would be to tack homes onto existing towns and villages. But we know that this strains infrastructure and services. To people who are sat in traffic along the A120, stuck driving into Colchester or trying to get a place in oversubscribed schools or doctors’ surgeries, the idea of more homes adding to this would be madness. This is what has been done in the past, and you can see the results today.
And yet the need for homes remains. That is why we must look at a different way of approaching housing, ensuring that any new development is delivered with the required physical and social infrastructure and services to support it.
This is a promise often made but seldom realised – so how does it become a reality? The best way of ensuring this happens is through the creation of sustainable new communities created at a scale which creates the critical mass needed to provide the infrastructure they need to work.
The last thing any of us want to see is large scale housing estates or soulless bland commuter entities which will never provide the strategic infrastructure North Essex needs. If we are to build at scale to accommodate current and future generations – our children and grandchildren – we need to create vibrant, green and healthy communities.
We want to see cutting edge design both in building and layout, with a focus on walking and cycling. We want to see the affordability issue tackled through a mixture of high quality affordable and social homes. We want to see innovation in services such as waste and energy and ultimately, we want to see jobs, so that people can live, work and spend time here in North Essex.
This is why the creation of developments built to a specific set of community and design-based principles and developed over many decades is the best approach.
It’s also why we, as councils, want to take an active role in their delivery, working alongside the private sector and with local people to ensure they are delivered to these principles in a way that is achievable.
For these reasons, continuing to develop the Garden Community proposals is the right approach for the benefit of our communities, and current and future generations.
Cllr Graham Butland, Leader, Braintree District Council (Conservative)
Cllr Mark Cory, Leader, Colchester Borough Council (Lib Dem)
Cllr Tim Young, Deputy Leader, Colchester Borough Council (Labour)
Cllr Neil Stock OBE, Leader, Tendring District Council (Conservative)
The Campaign against Urban Sprawl in Essex
Local Plan Section 1 Timetable
CAUSE, advised by Michael Robson of CERDA Planning, writes to raise serious concerns about the preparation of the revised Section 1 Local Plan following conclusion of the EiP Hearing sessions, the
Inspector’s “Advice on the next steps in the Examination”
dated 8th June 2018 and “Clarification of Options in my advice letter of 8th June 2018” dated 2nd August 2018.
The letter from the Authorities to the inspector dated 19 October sets out what we believe is an extremely unrealistic timetable for the further work required by the Inspector.Although we understand that the NEA’s feel the pressure of the local election cycle, with a desire to
ensure that a revised Plan is submitted before May, and that noises from government about garden communities in principle are supportive,
due process must be followed4
. The Inspector, in
paragraph 157 of the letter dated 8 June noted the importance that: ‘adequate time and care are
taken now to ensure that any proposals are realistic and robust.”
The timetable submitted is likely to cause a number of problems which go to the heart of the
soundness of the Plan. We believe that any Plan submitted to the Planning Inspectorate in March
2019 will be extremely unlikely to be sound. The result will be yet another wasted examination at which CAUSE, and other groups, who share our concerns, will participate.
These are our main areas of concern:
Sustainability Appraisal before evidence: The assessment of individual sites by Land Use Consultants (LUC) in the Sustainability Appraisal is being done separately from the work to
create the evidence to drive a revised Plan.
Here a note of caution is advisable. Nothing of substance has been promised by government to north Essex, particularly when compared with the ‘Arc’ where funding for the East-West Rail network and the ‘Expressway’ has been committed, and the authorities involved in the preparation of the spatial plan have been allowed
exemption from the ‘presumption in favour of development’, thus lessening the impact of five year supply shortages. In north Essex, no such deal has been agreed and Braintree & Tendring in particular are at the
mercy of speculative developers while the authorities prepare the Section
Crucially, the background evidence is incomplete or unavailable for:
Land holding / purchase / control
There is no framework for LUC to assess sites against. The ‘work streams’, submitted to the Inspector, are substantive, the site assessment cannot be carried out beforehand. The sustainability appraisal must follow afterwards.
The Inspector’s 8 June letter stated, in paragraph 122:“Before [our emphasis] embarking on further SA work the NEA’s will need to re-examine the evidence base for any GC proposals they wish to assess, especially with regard to viability,the provision of transport infrastructure and employment opportunities, in order to ensure they have a sound basis on which to score them against SA objectives.”
We therefore seek to understand why (and how) the SA work on individual sites has commenced.
How is it possible to select alternatives, assess alternatives, explain choices and choose the most appropriate alternative in the absence of evidence of viability, employment and transport provision?
A particular example is the Metro Plan. It comes with a £1bn nfrastructure/viability headstart
because the basis for a mass rapid transit solution is already in place. How can it be adequately assessed against other alternatives, such as variants of West Tey, when there is no plan for transport, no funding, and no viability work for north Essex as a whole?
Trunk roads: By February there will be no confirmation that HIF bids have been successful or otherwise. The A12 route will not be known and we understand that the consultation
has slipped again, into the New Year. It will not be known if the A120 dualling is included in RIS 2. Therefore, the NEA’s intend to make decisions about the sustainability, deliverabilityand viability of sites in a vacuum. These were cited as crucial in paragraphs 34-36 of the 8
Mass Rapid Transit: It seems highly unlikely that a Mass Rapid Transit system can be costed, proven feasible, and funded in time to inform the SA. This was cited in paragraphs 41 & 42 of the 8
th June letter. The same goes for a new station at West Tey.
Effective consultation: An SA requires effective consultation. Before then, there must also be consultation on LUC’s methodology
. Results of the SA, and consultation responses, must
be taken into account in the ongoing preparation of the Plan. It seems that there will be a consultation on the Plan but that findings will be submitted straight to the Inspector, rather
Land Use Consultants confirmed, at a meeting with CAUSE on 31 October, that they aim for a five week consultation on the methodology
than informing the Plan. We seek to understand how your timetable submitted to the Inspector can incorporate effective consultation and allow for changes to be made to the Plan. On the face of it, the consultation is simply a tick box exercise with no meaningful
input or role in the process.
Timetable: Finally, LUC’s timetable differs from yours. LUC’s timetable shows a minimum of six months work (on the SA alone) from the time when the Inspector gives the go ahead.
This would mean that LUC’s work will not be complete until end April should the Inspector respond positively in early November.
Proportionate development: There is scant evidence that proportionate development at
and around existing settlements will be given a full and proper assessment as an alternative.
Finally, we are ever more concerned that the public behaviour of the NEA’s points to closed minds and a lack of objective thinking. The view presented to the public is that the same three garden community proposals submitted previously will ‘make the grade’ with a little tweaking of the evidence. We draw your attention to three particular examples:
1. Officer packs accompanying meetings / Leader announcements at council meetings have used words to the effect that ‘Option 2’ is simply a continuation of work on the same three GC proposals;
2. Press releases and a Braintree public magazine have consistently demonstrated that the NEA’s believe that they are continuing work on the same proposals. BBC Essex just last week was told, in a press release, by the authorities that three GC’s would be examined by an Inspector in June 2019;
3. A north Essex promotional website prepared for Mipim UK, held in October:
http://www.north-essex-opportunity.com/c/map.php shows the same three GC’s and makes it clear that the intention is to move full steam ahead with these proposals.
We seek to assist in the preparation of the revised Plan, and we endeavour to prevent the premature submission of an unsound Plan. In light of our various concerns, this letter has been copied to the Inspector, whom we note you have asked to comment on, amongst other matters,
your proposed timetable.