Objections to the East of England (Regional) Plan Policies

Letter from the BSCF to the Regional Planning Team

Regional Planning Team
Shaftesbury Road
6 February 2007

Respondent Number:8753


I am enclosing the Federation’s objections to policies SS7 (Green Belt north of Harlow), H1 (Housing), T1 (Transport), and HA1 (Harlow).



The proposed review of the Green Belt in East Herts north of Harlow arises only because the government has ignored its Inspectors’ recommendations and proposes to develop the area. If Green Belt protection can be sacrificed in such a cavalier manner, then creating a new, at present unnecessary, Green Belt outside the proposed new urban area may offer scant protection – it too might fall victim to the insatiable appetites of developers abetted by a compliant Government. Green Belts are supposed to provide protection against urban sprawl and coalescence. The Lee and Stort valleys have been developed almost without interruption from London to Harlow. This review makes it likely that Sawbridgeworth will be absorbed into the urban sprawl, and if that happens will Bishop's Stortford be far behind?

There is no need to review this Green Belt. It should be kept as it is.


Hertfordshire is being asked to provide a disproportionately high share of the housing in the region and this applies particularly to East Herts which, in addition to its allocation of 12000 dwellings will be expected to release the land for a further 10-20000 dwellings for Harlow North. The Inspectors recognised that water and sewerage facilities and transport infrastructure were quite inadequate to support development on this scale and that there were no plans to remedy this deficit. This regional plan ought to provide the means of ensuring that development takes place only at the rate that additional infrastructure can support it. Instead it adopts the approach of Mr Micawber by imposing an unrealistic housing total on the area on the basis that ‘something will turn up’ to enable the existing communities to remain habitable and support such growth.

Our experience in Bishop’s Stortford is that ‘nothing turns up’ to remedy our physical and social infrastructure deficit. Our general hospital has closed. We have a shortage of secondary school places. Our highway network cannot support more development. Water is in short supply and the sewage treatment works is full. This policy repeats all these shortcomings on a larger scale. The housing figures for East Herts should be scaled back to existing commitments until such time as it has been demonstrated how and when the water, sewerage and transport infrastructure will be in place to support any further growth in a sustainable manner.


The regional plan envisages a substantial increase in the emissions of greenhouse gases from the Eastern Region. The government has a national objective of reducing emissions by 60% by 2050. It is unrealistic to expect all of this to happen in later decades or for the Eastern Region to carry on polluting while the rest of the country closes down to achieve the target. Transport, especially road transport, is a major contributor to greenhouse gas emissions and its contribution is becoming more pronounced. The aim of achieving an absolute reduction in traffic on the region’s road system, endorsed by the Inspectors, is an entirely appropriate contribution to the government’s national climate change objective. The proposed watering down of the traffic reduction objective suggests that the government is not yet serious about climate change and that it has no appropriate policy instruments in place to achieve a reduction in road traffic. Since the region is likely to be the most adversely affected by global warming – increased risks of both flooding and water shortages – the plan should be trying to mitigate these risks. Transport is perhaps only the most obvious way in which it fails to do so. The road traffic reduction objective should be reinstated.


We support the objective of regenerating Harlow. However, the policy proposed by the government will fail to achieve that objective while putting unsustainable pressure on the transport, water and sewerage infrastructure in the area and destroying a valued area of open landscape.

The draft plan included developments at both Harlow North and North Weald, which would have depended for their successful implementation on a major new traffic management and public transport system. The inspectors rightly concluded that a large new settlement north of Harlow but separated from it by the major physical barrier of the Stort flood plain would not contribute to but detract from the regeneration of Harlow. It would create another new town on Harlow’s doorstep which would require its own shopping, education and health facilities and would be more likely to attract new investment than the more challenging task of regenerating the existing town. They rejected development at North Weald for similar reasons.

The government has reinstated the Harlow north proposal using the specious argument that similar considerations led the Inspectors to a different conclusion elsewhere. That is irrelevant. What matters to Harlow is their application in this location. The Inspectors’ conclusions still apply, particularly as the government has omitted to reinstate the transport improvements on which any such development would depend.

The Inspectors also noted in connection with Harlow North that there were insufficient water and sewerage facilities to support such development and that a new link with the M11 was both essential and unacceptable to the Highways Agency.

The purpose of a plan ought to be to ensure that new development is sustained by the infrastructure needed to support it. With this proposal the government has negated the whole purpose of the planning system. Instead it has imposed an arbitrary housing target on an area without the slightest regard as to whether that number or any other is capable of being supported by essential infrastructure within the time frame of the plan.

Our particular concern is with the likely adverse consequences of such a development on Bishop’s Stortford. Our hosepipe ban has only just been lifted and there are no new sources of water supply likely to become available in the near future. With no improvements planned for roads either, the traffic problems of Harlow North are bound to spill over into our town. And the destruction Green Belt provides a most unwelcome precedent for our efforts to protect our own. This proposal should be removed from the plan and the housing total for the region should be reduced to such a number as can support the regeneration of Harlow within the current urban area. The Green Belt should remain in place.