The situation with regard to SODC’s continuing ownership of its Local Plan could be easily solved by SODC. All it needs to do is allow the Plan to continue to examination in public before a Planning Inspector and for the Council to add potentially significant amendments and modifications for the Inspector to consider. That is the only place that one will get a definitive statement on whether, for example, the allocation of housing to the Green Belt is acceptable and proportionate and establishes a right balance or not.
Some have raised the current situation at SODC in relation to their emerging Local Plan with me. Firstly, let me be clear that I have had no part to play in the discussions between SODC and the Ministry of Housing, Communities, and Local Government (MHCLG) and was not party to the decision made by the Secretary of State. However, I do have a strong interest in planning.
The situation is well documented on SODCs website. Early in the work of the council elected in May 2019 there was an indication that they would withdraw the emerging Local Plan and the then Housing Minister wrote to the Leader expressing his concerns at the implications for wider Oxfordshire especially in relation to commitments already made. It is a shame that a promise to withdraw the Plan was not explicitly part of the election. Senior Officers in MHCLG had worked with SODC Planning Officers in the following months. The paper from SODC Officers to Cabinet on 3rd October set out three possible options and recommended the option to allow the emerging Local Plan to continue through its examination in public. Cabinet rejected this option in favour of withdrawing the emerging Local Plan and embarking on a new one. This would take adoption of a new Plan to February 2024. It was as a result of this decision that the Secretary of State intervened to put a hold on further progress.
MHCLG had recognised the ambitions of the new council and had been clear that they did not believe that continuing with the existing plan would undermine these ambitions. However, they had set out the negative implications for both SODC and for other local Oxfordshire councils in the event of withdrawal. The actions of the Secretary of State have given time for further consideration. I am committed to a local democratic process in producing Local Plans but Oxfordshire councils have to remember that they signed up to a Growth Deal as part of their commitments which came with money for new infrastructure and for affordable housing. Many of the plans containing this have themselves already been through a democratic process which needs to be balanced with that of SODC. It was, for example, as a result of my work on the Local Plan Expert Group that a new methodology for calculating housing need was established which is stronger than the previous Strategic Housing Market Assessment (SHMA) approach and takes away the potential of excessive legal wrangling over the figures. However, it produces only the starting point for calculations of final need to which councils have the choice to agree or not.
I do have concerns at the level of proposed building in the Green Belt and having campaigned for over 25 years for the protection of the Green Belt across the country, and particularly around Oxford, made my views on this known over some time. I also have concern for the many communities who have produced their own Neighbourhood Plan and who could now be in a period of uncertainty.
I wholly agree with SODC Planning Officer’s that the best approach would be to allow the emerging Local Plan to continue to public examination and for there to be put forward amendments as part of this process.
I have every confidence in a Planning Inspector taking a line on issues such as the Green Belt which helps to protect it and establish a balance between the need for homes close to hubs in Oxford with respect for the Green Belt. I believe this will be the quickest way of getting a Local Plan in place and avoiding what has been described as a developer free-for-all in South Oxfordshire in the long run-up to a new Plan being put together. Benson and Chinnor are both good examples of the scale of development that could take place in the absence of a Local Plan. There is nothing I wish to see less than such a situation happening across the district. It would produce thousands of new houses and without infrastructure to support them. The consequences are all too imaginable and all too horrendous.
I do not believe that the production of our Local Plan should be in the hands of the County Council and that is not what is proposed. What is proposed is for the Plan to go before a Planning Inspector in public examination and then for the County Council to implement the approved plan in the absence of SODCs willingness to do so. This would be preferable to effectively allowing developers a free reign. In the meantime, the administration at SODC can move quickly to prevent this happening by agreeing not to withdraw the Plan and to proceed with it to Public Examination, taking the opportunity to make and explain their amendments.
The HH projections hack doesn’t work. It is not supported by Government policy- as upheld by a recent court decision. Besides he has no power as the West Midlands Spatial Plan is non-statutory, unlike that for Greater Manchester. The mostly labour led leaders who form the Combined Authority board wouldnt agree to it.
No green belt land needs to be built on over the next decade in the Black Country despite the huge level of demand for housing, Mayor Andy Street declared today.
Mr Street said he believed the thousands of homes needed by 2031 could be provided by exclusively building on previously developed sites.
Launching his ‘Green Belt Pledge’, the Mayor said he would do everything in his power to ensure the countryside is protected.
Mr Street said following a review of the latest population projections he believes it is possible to “close the gap” between the number of houses needed and the total which can be built on brownfield sites, “so no green belt development should be required in the Black Country between now and at least 2031”.
His insistence that no green belt land should be built on goes against the views of housing experts who have said it is inevitable some sites will have to be released to fulfil the massive demand for housing over the next two decades, and may raise eyebrows among council planners. Some 70,000 homes must be built by 2038 to keep pace with the rising population.
Seven Cornfields in Penn, Wolverhampton, and Foxcote Farm in Wollescote, Stourbridge, are among high-profile green belt sites currently at risk from developers.
Another 26 green belt sites were classed as “low harm” in a recent green belt study, suggesting they could potentially be let go for housing.
The Mayor, who is up for re-election in May, has no direct control over planning policy but has pledged to work with councils and seek Government funding in an attempt to make it as difficult as possible for developers to get permission to build in the countryside.
He vowed to fight the controversial Seven Cornfields development, where 1,300 homes could be built on 240 acres between Wolverhampton and Dudley, which has sparked a backlash locally.
Mr Street said he would push the Government for an initial £200 million of further funding to clean up derelict and contaminated sites across the Black Country. A barrier to building on derelict sites is often the costs involved for developers to prepare them.
He also said he would “block the use of any West Midlands Combined Authority (WMCA) funds for unacceptable green belt development” and create a team of “urban density specialists” to help councils and developers increase the number of homes they can build on brownfield sites and in town centres.
Mr Street said: “Across the Black Country, at much-loved places like the Seven Cornfields, Foxcote Farm in Wollescote, and Tack Farm in Halesowen, residents are fighting to stop developers taking away their valued open spaces.
“The Black Country is leading the way in reclaiming derelict brownfield areas to build new homes and the fact is we have plenty of such sites. For this reason, and having looked at population projections, I do not believe there should be any new green belt development in the Black Country between now and at least 2031.
“I would rather see new family homes built on cleaned-up brownfield sites in the Black Country, or new apartments built in Birmingham city centre, than diggers tearing apart our green belt.
“My Green Belt Pledge lets the people of the Black Country know that the Mayor will be on their side when it comes to fighting unwanted proposals from developers.”
He has been totally unable to articulate what is wrong with the scheme and how to change it. He is just pandering to silly Nimbyism, such as opposition that it will be noisy, when it will be almost silent. The Ely Mafia holding up growth in Cambridgeshire again.
The Cambridgeshire and Peterborough Combined Authority has taken control of public transport improvements in the Cambourne to Cambridge area, it has been announced today (Monday, February 17).
Mayor James Palmer made the announcement in response to “significant concerns” raised by residents.
He has called for the Greater Cambridge Partnership’s Cambourne to Cambridge busway scheme as it stands to be “immediately halted”.
Mr Palmer has told the GCP that the scheme’s proposals do not fit with the Combined Authority’s aims for the Cambridgeshire Autonomous Metro.
The GCP says it is astonished by the mayor’s announcement and says the Combined Authority has confirmed that their work is consistent with the CAM plans.
Mr Palmer said: “I hoped that by bringing the GCP in to help implement our transport strategy, including the delivery the CAM Metro, we would gain real input from residents of one of our region’s most congested transport corridors, and proposals for the future that would be supported by the businesses, commuters and workers of Cambridge.
“But it has become clear to me that GCP lack the vision, strategic thinking and the ability necessary to deliver any of the transport priorities for the Cambridge area. Local communities deserve better and this failed C2C consultation, which has ignored concerns raised by myself and so many residents, is the final straw.
“The combined authority will now take direct responsibility for delivery of additional public transport solutions for the Cambridge to Cambourne corridor, and I will be bringing forward proposals at the March meeting of the CA transport committee for implementation as soon as possible.”
A decision on the final route for the Cambourne to Cambridge busway scheme was due to be made at the GCP’s executive board on Wednesday (February 19).
A GCP spokesperson said: “We are astonished that the mayor has made this announcement without any attempt to discuss our proposals with us. We have worked with the Combined Authority on this scheme and the route to Granta Park – and at all points the Combined Authority has confirmed that our work has been consistent with the mayor’s plans for the Cambridgeshire Autonomous Metro.
“It is simply wrong to say our proposals have been developed without input from the Combined Authority. We paused this scheme in 2018 at the Mayor’s request when he wanted to ensure it aligned with his vision for a future metro – and his review concluded that our approach was robust. At no point have the Combined Authority raised any concerns about our proposals, which are an integral part of delivering the mayor’s wider CAM network.
“The recently agreed Combined Authority local transport plan confirmed that GCP is delivering phase one of the CAM, including out to Cambourne, Waterbeach, Granta Park, and to the east towards Newmarket – so this decision is completely at odds with recent CA Board decisions.
“Our GCP Board are demanding an urgent meeting with the mayor to discuss this in an effort to avoid further delay to improving public transport in Greater Cambridge.”
No MP should ever oppose plans for homes in a local plan without saying where else they should go. Otherwise they are bucking government policy. Worst of all they shouldn’t run sham fake consultations on their website that don”t allow for answers in line with government policy. The issue is not whether you support A plan for a 5,000 home community but where you think they should go. If you can”t say where – well your never going to get promoted to housing minister are you.
’Ive called on Swale Borough Council to reject plans to build 5,000 new houses at North Street.
The development is being considered for inclusion in Swale’s new Local Plan, which will set out where new homes should be built in the borough between 2022-2038.
The North Street development is one of four ‘garden villages’ being considered by Swale’s Local Plan Panel as a way of delivering new homes in our area.
I’m not against the idea of garden communities in general, but extra care needs to be taken when going ahead with such large developments because of the impact they have on the landscape and nearby communities.
The proposed development at North Street would be completely inappropriate for inclusion in the Local Plan. It’s hugely unpopular and would do enormous damage to an area of high landscape value as well as putting further pressure on local roads.
I’ve written to the Chair of the Local Plan Panel, Cllr Mike Baldock, to call for the North Street development to be rejected at the next opportunity.
Lenham Heath and the surrounding area are under threat.
Maidstone Borough Council has revealed plans for a new ‘garden village’ around Lenham Heath which could see 5,000 – or more – new homes built in this area.
The development would destroy an area of farmland at the foot of the North Downs and put huge pressure on local roads and services.
I’m working closely with the parish council, the “Save Lenham Heath” campaign, and Borough and County councillors, to oppose this development.
Both of these proposals would be rail based, outside the Green Belt and would protect the North Downs AONB by developing outside of them, as well as being well located to existing settlements and railway stations. It always shows a true blood Nimby will oppose good planning anywhere.
In response to a letter from the SoS Sue Cooper Leader of South Oxfordshire sends him a speech. That will go down well. As well as the following letter.
On the understanding that you continue to view eLP2034 proceeding to inspection as the only possible way forward, it would help us if your officials could list some examples of the kinds of significant changes which would address our concerns that can be made as modifications during inspection, and also an indication of how we could go further on sustainability and climate change policies.
There is obviously a lot more detail that I could give you. But it would be very much better if we could meet so that I can explain how and where we wish to plan for really good, affordable, well designed, energy-efficient housing in sustainable locations, rather than the depressing, sprawling housing estates of over-priced units remote from locations where the occupants work which make such poor use of our very
restricted land supply.
Here how you can do it Sue. its easy:
- Stop arguing about housing numbers. They are fixed in the standard OAN method. Building less than this will simply mean people having to drive further to work to work locations in South Oxfordshire.
- Start with south of Grenoble Road. By far the most sustainable new location for a strategic site in the whole of Oxfordshire, which can be linked by transit to Central Oxford and the Oxford Business Park/BMW-Mini. Other sites you might suggest will involve driving. If you want to start with a clocation close to where people work this should be top of the pile.
- Scrap Chalgrove. A silly unsustainable site car dependent and accessed via country lanes. Instead make one of the East of Oxford sites in the Green Belt larger. Clearly an SEA would support that. By the way with the overly tight Oxford Green Belt you support it should be renamed the Black Belt after all of the extra exhaust emissions from the extra driving it causes.
- Relocate Oxford Airport to Chalgrove. Work with Homes England to CPO the site. This would create a huge brownfield site for 1000s of homes on Oxfords doorstep.
- Work with the County Council on a strategic plan for Oxfordshire. Rather than scattering large estates on the edge of South Oxfordshires many pretty villages they should be concentrated in a few places served by rail and Bus Rapid Transit. For example such a plan could see less scattered rural housing in South Oxfordshire and concentration at strategic locations – such as South of Grenoble, east of Oxford, and potentially a new Garden City at Grove – the size of Oxford.
- Work with Grant Shapps to restore the whole of the Wycombe Line, not just the Cowley Branch, and four track Swindon to Didcot. Debeechingification should be prioritised, paid for by land value capture at places like South of Thame’and South of Grenoble Road.
- Positively masterplan new Garden Communities, avoid the mistake made by Uttlesford, who didnt even know their size, footprints, ‘viability, affordability or deliverability.
- Set world beating Zero/Negative Carbon Plan standards, including 60% plus active travel/modal share targets for strategic sites and built in design and transport infrastructure to make this happen
- Stop listening to Nimbys and Psuedo-Greens, start listening to experts. Nicholas Falk for starters.
- Stop chasing Unicorn Plans, start delivering a real one.
By the way the answer to your question is in paras 3.17, 6.1 and 6.2 of the local plan procedures guide.
With the forthcoming Planning White Paper there will of course be calls for a formal National Plan, or a return to a tier of Statutory Strategic Plans.
This issue will be highlighted by the One Powerhouse initiative , which will publish its vision of a non statutory national plan combined of compatible non statutory regional plans, which will launch shortly.
Our proposal is to develop large-scale regional plans which are NOT statutory in nature but instead provide an over-arching vision and framework within which local statutory planning can take place.
This approach to regional spatial planning of major infrastructure, promoting economic regeneration and development and securing the future of the environment requires effort, but has been very successful in other countries.
Notably in Germany with the Rhine/Ruhr, in The Netherlands with the Randstad and in The New York Metropolitan area through the Regional Plan Association.
Similarly some counties are pursuing non statutory strategic plans, such as Surrey and Leicestershire, egged on by Catriona Riddle, following the disillusionment of the progress of new style strategic plans (such as West of England and NEGC) and local plans making strategic allocations (such as Uttlesford).
This issue is a difficult one. There is no doubt that non statutory very large scale spatial plans have been successful. Government support and backing of these through endorsing the One Powerhouse initiative would be a very easy step to take, could easily be done through the remit of the NIC, and would begin to make sense of key issues such as for example the linkage between HS2 and Northern powerhouse Rail. We effectively already have a national ‘levelling up’ plan; It just isn’t written down, just intimated in speeches. One remembers the Richard Wakeford rule – never write national planning policy through speeches.
Non Statutory plans can also be material considerations as government policy. As the former RPGs were. The trouble is that they would be covered by the SEA directive (still law), as ‘plans or programmes which set the framework for future development consent‘ or require habitats assessment. It does not matter if they are non-statutory. If they are covered by an administrative process they would be. Consultation and consideration of options would be such a process. Failure to consult on options, if used to provide a framework for consents, would also be contrary to common law – see here.
If a spatial plan provided no framework for consents, either T&CPA or DCO, well what would be the use of that it would be no plan at all?
Even so there would be great advantages in not embodying regional/national planning in Law. The precedents for this have not ended well. I have doubts whether making the London Plan statutory has been a great success. It seems much easier all round for them to be non statutory but formally pursued through an SEA directive compliant consultative process with options.
Of course the reason why strategic plans have been so fraught is the issue of distribution of housing numbers. Whomever has pulled the levers of these has taken the blame for “imposing’ housing on the countryside”. Taking out the housing numbers ought makes them less fraught and simple to prepare, yes, and there is great merit in consulting on an early draft of strategic plans with spatial and infrastructure principles before the final housing numbers per strategic location are decided (of course this doesn’t dodge the SEA requirement). But the issue of strategic distribution can never be ducked. Remember strategic plan exist because some planning decisions have to be larger than local. Under-bounded authorities and other land constrained areas mean that there will always need to be distribute housing need beyond local authority boundaries. Discussions about this under the DTC are always fraught and in many cases held up by ‘awkward squad’ authorities who just won’t play ball; or in the very worst case, as in West Kent, where local authorities conspire to avoid asking each other to allocate for overspill.
At the very least then we need a more formalised system to deal with overspill. Lack of a system has arguably led to a 9 year delay, which looks likely to be nearer a 15 year delay, since the Localism Act, of answering key questions of where strategic sites should go. Given that RPG9 the South East Plan effectively deferred these decisions this extends to a 20-25 year delay. We wonder why we have a housing crisis.
There are two aspects of the overspill issue. The first is between a HMA, the second is from one strategic planning area (such as a major conurbation such as London or Birmingham to its surrounds). For the former I hope ive demonstrated it doesn’t matter if its a local plan, SDS or non statutory regional plan, the requirement for SEA (and to consider options even without the SEA directive) apply. For the latter I see no alternative for the government to issue a broad distribution between regions as national policy, as as policy as opposed to a plan or programme it would not be subject to SEA. I”ve suggested in the past a simple GIS based technique to calculate how to do this.
There is no technical reason this cant be done now, or in stages, as the overspill numbers for London and Birmingham have now been fixed and should be fixed for Greater Manchester by this time next year.
So overall i’d recommend:
- Compatible Corridor and Region Based Non Statutory but SEA directive compliant plans on the One Powerhouse model
- The government endorsing these through an overarching National Policy Statement, including an appendix on overspill housing number per region from land constrained areas
- Functional Region/sub regional plans, whether as local plans statutory policies or SEA directive compliant non statutory plans.
All of the above not requiring one line of legislation. Roll on the White Paper.
Apologies for not havong on time to comment on this before.
are not persuaded that there is sufficient evidence to demonstrate that the Garden Communities, and thus the overall spatial strategy, have been justified. We therefore cannot conclude that these fundamental aspects of the plan are sound.es no time to blog on this before.
This of course is the second time a local plan here, based on a Garden Community, has been found unsound. And is a bitter blow to them. After all they decided tio carry on with the plan despite electoral changes and rise of indpendents calling for it to be scrapped. These voices of, lets face it, psudo-green numbyism must seem vindicated. However in a district without ANY large towns and numeroud small villages, and including Stansted, any viable plan must surely include Garden Communities. The acid these ten of Garden Communities being capable of being built within the current local plan and non strategic no centrally led development coroprations has shifted to Essex.
The plan contains three Garden Communities which are known as, Easton
Park, North Uttlesford and West of Braintree. They are relied upon for the
delivery of much of the new housing in the remainder of the plan period,
and well beyond. In total they are expected to deliver around 18,500 new
market and affordable homes.
In general terms we are concerned about the lack of evidence before us to enable us to conclude these parts of the plan are sound. Whilst we realise it is the Council’s intention to lay down much of the detail of the proposed Garden Communities in further Development Plan Documents (DPDs),
following the adoption of the plan, it is this examination which must
determine whether the Garden Community proposals are properly justified
and realistically developable. This is of major importance in this case given
the large scale and long-term nature of the Garden Community
developments, combined with the fact that they would be the primary
source of housing in the district for the next 30 to 40 years.
Lets not forget that Uttlesford is a small and poorly funded rural authority. The three garden communities are all consortium led. and one only accepted at the last possible moment by Cllrs. There was no democrically and techncially led process or methodology for examing locations, options and alternative for Garden Communities and the sometimes radical infrastructure measures to make them happen.
Landsecs bone headed greed and stupidity, arguding against an LLDC. didnt help.
Furthermore, whilst it is understood that the Delivery Board for North
Uttlesford has already been established, ED66 also highlights disagreementbetween the Council and the site promoter at Easton Park in relation to the terms of the Delivery Board that will oversee the plan making, delivery and implementation of that Garden Community. All these matters cast some doubt as to whether these vital Garden Community Principles would be met in Uttlesford. Without assurances that the necessary mechanisms outside the plan would be put in place, we cannot be content in principle that the new proposed settlements would be true Garden Communities, or that the plan’s stated vision for these new settlements would be met. This is aserious concern.
We are concerned that the boundaries of the Garden Community site
allocations are not shown on the Policies Map. This is not a matter to be
left to DPDs. We cannot find the plan sound based on vague blurred
annotations of broad locations, especially for something as significant as
three large new communities.
Spot on, as with NEGC, you cant allocate Garden Communities with furry vague blobs, you need lines on maps. The Sine-qua-non of planning.
The proposed trajectory is even more optimistic if the promoters of the
Garden Communities do not intend to submit planning applications until the DPDs have been adopted (as indicated by the promoter for Easton Park). The Council’s timetable assumes promoters would twin track outline planning applications alongside the DPD preparation and examination process.
This is a problem we know how to fix. For example at Rugby Radio Mask (Houlton) the masterplanning and DPD were wisely combined into a single process, with outline application/S106/parameter planning work running in paralell. Rather than throwing objections at large scale site delivery PINs should be more proactive, learn from best practice, and promote it at examinations. A task for Homes England and PINS to work on together I think.
The promoters of Easton Park argue for the details of the Garden
Communities to be dealt with by Supplementary Planning Documents
(SPDs) rather than DPDs, to speed up the process. However, since SPDs
cannot set policies and are not subject to independent examination,
proceeding down the route of SPDs would require the plan to contain far
more detail than it does at present. Additionally, SPDs carry less weight in
future decision making as they are not part of the development plan. With
something so fundamental as large new Garden Communities it is our firm
view that the key details need to be committed to DPDs which would be
examined and adopted.
It would also be unlawful for an non stsutory doument to define a policy boundary such as a Garden Community Boundary. The relevent caselaw is in the very long judgement of Lord Scarmen in Great Portland Estates V Westminster.  AC 661,  3 WLR 1035
Overall, we strongly believe that the Garden Communities will not deliver
the quantum of housing in the plan period that the Council’s housing
trajectory shows. Consequently, the housing requirement for the plan
period would not be met.
The appropriate response of the inspectors here is to step the trajectory further not find the plan unsound. Of course the LPA can simple ask with main modifications are necessary to make the plan sound.
if the three Garden Communities allocated in the plan are
granted planning permission and then work is commenced on site, it would
be very difficult to deviate from this strategy. To do so, and to leave the
intended Garden Communities effectively uncompleted, could potentially
result in relatively small pockets of residential development in the open
countryside that would not have the sustainability credentials of Garden
Communities and would not ordinarily be supported. The Framework
recognises that it is crucial that Local Plans should ‘allocate new sites to
promote development and flexible use of land, bringing forward new land
where necessary…’ (paragraph 157). The current strategy which relies on
the Garden Communities to deliver 4190 dwellings in the period 2023/24 –
2032/33 (the end of the Plan period), against a target in this period of 7190
dwellings carries with it significant risks and a lack of flexibility.
Here I think the inspectors are mistaken. In a large plan area with several large towns it is good practice to have potential plan B sites. Here is rural essex the plan B would be large unsustainable estates car based around small villages increasing them potentially many times in size, Rather plan A has to be made to work.
With reference to ED13 (Bus Rapid Transport fornUttlesford Supplementary Technical Study), the Council confirms that in the early phases the Garden Communities would be served by a conventional bus service, with a RTS only coming online when there is population tosupport it, (2029–2033).
The Council also advises that it is not necessary to delay the housing
delivery to allow for the delivery of the RTS. Whilst appreciating the
difficulties in providing a full RTS service from the outset and recognising
the role of incremental improvements, in our view, the lack of a RTS until
towards the end of the plan period would mean the modal shifts anticipated
would not be realised. Moreover, the use of less sustainable modes of
travel could have become engrained in the habits of residents living in the
homes built within the early phases of the Garden Communities.
The inspectors were right here. The developers simply didnt want to pay for early years subsidy for frequent services and for dedicated off road paths. However government policy needs to shift to facilitate BRT at early phases as the single biggest contributer planning can make towards Zero Carbon and minimum impact development – such as tax breaks.
It should be noted that delivery and RTS concerns were also raised over NEGC, and were fixed (and west of Braintree is a shared project with this site.)
a revised VA based on the residual valuation appraisal method would need to be supplemented with a discounted cashflow assessment (a valuation method used to estimate the value of an investment based on its future cash flows), in order to provide a more complete and robust analysis.
How can you not do a DCF calculation (with financing and peak debt) these days. Its is standard and a simple spreadhseet (such as the HYAS model/AECOM Garden Communities Cost model as used at NEGC).
We are very conscious of the considerable work that has been undertaken
over several years by the Council and the promoters of the Garden
Communities in developing them as proposals. We are also aware of the
in-principle support afforded to them as a concept by the Government and the funding that has been provided. However, for the reasons given, the Garden Communities are insufficiently justified and have not been shown to have a reasonable prospect of being delivered as submitted. Moreover, the unsolicited documents referred to in paragraph 4 above do not deal with these matters.
. Consequently, as things stand the strategy set out in the plan is unsound.
In summary, our main concerns are:
• The lack of clear mechanisms to ensure the Garden Community
Principles will be met;
• The need to define precise boundaries and to show these on the
• The proposed housing delivery trajectory is overly optimistic;
• There is unlikely to be a 5 year HLS on adoption;
• The stepped trajectory unreasonably delays addressing the housing
• The Garden Community approach predetermines the strategy long
beyond the plan period and so is unduly inflexible;
• As part of the assessment of reasonable alternatives the SA does not
consider a smaller number of garden communities, in combination
with more housing in existing sustainable settlements, nor does it
have regard to the evidence in the HIA;
• The lack of certainty about the delivery of employment uses
undermines the potential for the Garden Communities to be
• The costs, viability and deliverability of the RTS are uncertain and
any benefits would be realised too late to help ensure the Garden
Communities at Easton Park and West of Braintree would be
• Realistic infrastructure costs have not been established meaning it is
uncertain whether the Garden Communities will be viable and
• The North Uttlesford Garden Community is flawed in terms of
landscape and heritage impacts and the potential for the A505
improvements and public transport infrastructure are uncertain,
undermining the potential for this Garden Community to be a
• The Easton Park Garden Community is flawed in terms of heritage
impacts, the potential for highway improvements to M11 junction 8
and the M11 between junctions 8 and 13 are uncertain pending
further investigations by Highways England and the unknown
implications of the gas pipeline crossing the site on its capacity for
• The West of Braintree Garden Community is flawed since the
sustainability appraisal and viability assessment only considers the
part of the site within Uttlesford despite it being dependent of the
delivery of the larger proposed site allocation in Braintree District.
Lets be clear the inspectors are not saying scrapp all three Garden Communities and start again. Indeed the conclusion is much clearer than the NEGC report. An SEA may find an alternative more small sites replacement for North Utllesford less sustainable than a North Uttlesfiord awith proper RTS connections to Cambridge.
Overall not enough local authority led planning had been done. Like several small authorities in Essex proactive planning was underfunded and they drowned. I think the solution in Essex, given the South Essex Plan is floundering, is for the County to take over, and do a proper methodological nstudy of alternative locations for Garden Communities, test them, concept mastrerplan them, and lead on a Countywide delivery body that would oversee quite a number of LLDCs. This also requires a proper methodology for assessing and testing alternive locations for Garden Communities and other strategic sites. Something im lectoring on at several places last week and this whilst im in England (book coming later on this year I hope).
Grant Shapps was on Marr this morning answering a question about China’s offer to build HS2 in 5 years. Shapps was sceptical quoting the different planning, legal and land aquisition systems. All of which are correct, but they dont address the fundmental area in which the Chinese are demonstraebly faster – construction. After all on many very complex projects such as the Macua-Kuhai-Hing Kong Bridge and Tunnel they still relay on international consultancies (such as my own AECOM) to do the design work.
I have seen first hand on site all over Africa and Asia chinese funded Megaprojects under construction. They are very impressive. Undoubedly they have made great strides on improving safety and reducing corruption which has held so many emerging econiomies back. Now if you fake concrete tests to keep a project ón track’you are more likley to go to jail than get a promotion. Certainly it also helps that national, regional and local projects are ruthlessly aligned around a single vision.
The key differences though are that they do things differently.
This starts with the design to be implemented. They have fully shifted from design through sheets and drawings to design via models. There simply arnt enough CAD technicians in the world to draw up sheets for even one of some of their megaprojects. That means that they basically design to the schamtic (30%) stage, based on a model, and then start building. Of course many emerging economies are notorious for just designing to the (sub) 10% stage and then ‘sort it out during construction”, often with horribly badly trained construction managers. The chinese are not like this. They break projects into sections of model – based on terrain and engineering solutions to that terrain, then have design teams sort things out as they go. All they are worried about before starting is that problems are solvable, and because they break projects into sections they work on them in paralell not series. This represents a different non risk averse culture. They dont fell they have to solve every small detailed design problem before starting.
They also use on site techniques roman engineers would recognise. Pegging sites out by eye, and laying out peg to peg using gps and other surveying equipment on wheelbarrows etc. This is aided by a modular prototype basis for there designs. For example railway embankments, using a standard (deliberately slightly overengineered) grade to each so they dont have to redesign and recalculate slope stability for every point on the track. Using this approach they, knowing the model and prototype design works, simply peg out and build by eye using total stations to main consistency of the built levels with the model. They also take every engineering step to shorten the later stages of construction. For example on railways using pre-built steel tracks and bases, and building all of the electricity infrastructure at the same time.
Can HS2 be built in 5 years using chinese techniques, and safely, yes.
Number 10 has instigated what amounts to a reboot of Blairs delivery unit. In the new centralisation of policy memos have gone out to all ministry’s in the last few days setting out delivery targets, including tellingly on what each is doing to meet the net zero 2050 target.
Of course this is the law with regards to the Climate Change Act. Ed Milliband when SoS set carbon budgets for each department. What is new in the central determination to drive it through and track results.
This presents a dilemma for town planning. Already many Green and Independent groups are expressing the new Green Nimbyism. Only last week for example in the London Assembly calling for scrapping of the London Plan latest version. Many local authorities are declaring climate emergencies.
Of course what individual local authorities can do by themselves is limited. Major decisions on decarbonising energy and transport networks are out of the power of local authorities as is a long delayed shift to zero carbon homes. Moreover the failure to properly model elements of carbon emissions as part of an overall system has led to many national policy misteps when translated into planning of places. How will residual emissions be handled? For a while it was assumed to be via gas powered CHP as a transition technology, but the fall in the price of renewables has transformed that.
What is the response of the planning profession and of wider engineering and design consultancies of which many planning consultancies form a part? So far there has not been a clear and transferable ‘model’ of what a zero or even negative carbon (one that sucks in Carbon through soil biochar and or new carbon sinks) looks like. Certainly many of the new style regional plans that are emerging look very car based.
This is disappointing as many of the larger consultancies certainly have the expertise to produce integrated solutions for energy, infrastructure, building fabric and landscape scale carbon sinks. This is the great advantage of planning. To do these together through design. So far in the UK there just hasnt been a commission that asks for such as a holistic design as an output.
Of course it is entirely possible to produce a zero carbon plan with unnecessary driving by an all electric fleet. The issue then is efficiency. Unnecessary deprecation, the impact of producing more batteries, more energy etc. So I would say that a plan cant just be zero/negative carbon, it must be I would suggest as a test negative carbon and minimum impact.
Negative carbon is important; as it is the only provable geoengineering solution to climate change reversal we have. The scale of rapid urbanisation on a planet of 5 billion humans by 2040 is such that we have to transform urbanisation, quite literally town planning saves the world. Its that important. Greta says ‘listen to the scientists’ but they will only tell you the problem not the solution. Perhaps she should have said ‘listen to the planners’ but so far they have not made their voices heard or had clear solutions worth listening to.
So what might such a negative carbon/minimum impact plan look like?
Certainly not a build little, infill only approach which many pseudo-green local groups propose. This would mean simply make people share more and drive further to get to work. It would be a selfish and wholly counterproductive climate detroying approach.
A starting point would be achieving the kind of high public transport /high cycle use modal splits we see in many of the best example of integrated city and regional planning on the continent, Where car use is 20% or lower, and where we can assume it will be all electric by the time many strategic scale developments are at their peak delivery. This means I would contend rejecting patterns and locations of development that cannot achieve this, such as linear cities along motorways and expressways or scattered small Garden Villages. It means planning strategic developments as integrated regional wholes as part of a network. If an existing or reused railine doesn’t have capacity, either give it capacity through digital signalling, acceleration/deceleration lanes, new Chords, 4 tracking or new termini, or if that isnt possible sub-regional scale BRT networks. No compromises on locations means having to plan locations, high level design of settlements and transport networks as one.
Every part of the profession has a part to play. Local and regional planners have to demand it and integrate the technical work. For example looking at how landscape scale biodiversity offsetting can create new carbon sinks. by treating energy as a key topic, and not treating regional transport planning as a Cinderella underfunded one man and a dog operation (as it is in Essex for example). The consultancies have a role to play. At the consultancy where I work iv’e initiated a project under their global innovation project, and iv’e been lecturing on how we can model spatial patterns or zero carbon development in London last week (at Aecom) and next (at Nat Litch and David Lock Ass), The offer is open till Sat 22nd when I fly back to the Middle East. Central Government can play a role by making it much more central to its scattered corridor and regional projects. Above all Councillors have a role in promoting and championing this new wave of planning, by chasing away unicorn solutions and supporting working with communities on exciting possible solutions.
it is not possible to escape the conclusion that, had the Council properly engaged with and heeded Natural England’s advice and had the Council properly involved itself in a constructive discussion with neighbouring authorities about both the impacts of the plan and the ability to help in meeting Eastbourne’s unmet housing need, the overarching development strategy of the submitted LP – the planned quantum and distribution of development, and whether the Council considers itself to be in a position to be able to take any of Eastbourne’s unmet housing needs – could have been
different. As has been shown, the Council chose not to accept the advice ofNatural England in respect of emissions modelling but selected a model which failed to take into account known factors influencing future emissions. This approach, by overstating future emissions and hence likely effects on the Ashdown Forest and potentially other SACs, has had the potential to magnify constraints, constrain development potential and so inappropriately influence possible development scenarios. The Council has not been transparent when presenting these constraints to Eastbourne Council and other authorities. It has not actively shared its evidence base and addressed key cross-boundary issues with other authorities in a timely manner (including contributing meaningfully to SoCGs) and has not worked collaboratively in jointly addressing the implicationsof the reduction of its plan period and has not engaged in constructive discussion in respect of the distribution of development and the accommodation of Eastbourne’s unmet needs.
What it should have done is simple
- Work proactively with Eastbourne to identify sites that met their unmet need
- Consulted on them
- Tested them with Appropriate Assessment
- Taken Natural England’s advice
- Then decided at submission, based on that advice, whether or not their inclusion would breach the Habitats Directive.
After all scientif opionion can vary and change, and exclusion of sites because of HD reasons can only really be taken at the last step before submission. By stating something as a scientific fact when it was disputed Wealden took a foolhardy line. By the way the head of policy at Weladen is a scientist.