BSCF's comments on Uttlesford District Council's Local Plan Consultation Form New!
This email was sent on 29 November 2015
The Planning Policy Team
|29 November 2015|
Dear Sir or Madam
LOCAL PLAN ISSUES AND OPTIONS
I am writing on behalf of the Bishop's Stortford Civic Federation with comments on a number of the issues raised in your Consultation Form.
Question 1 – Vision and Development Strategy
You quote from the vision in the previous draft Local Plan
‘The district’s high quality natural and historic environment will have been maintained and the settlements will continue to be separate entities with green space between them.’
We believe that this should remain as part of your vision and indeed that it should go further. It appears that the metropolitan Green Belt has been designated only in the most southern part of the district, in the areas bordering East Herts and Epping District Councils and reference to it does not feature greatly in your planning policies. Indeed the sustainability report, to which you refer consultees, does not identify it at all as a key issue. However, in the context of the National Planning Policy Framework (NPPF), preservation of the Green Belt is one of the few policy considerations to which more weight should be attached than the general presumption in favour of so-called ‘sustainable’ development.
Four of the five purposes of the Green Belt listed in the NPPF are relevant to the land designated as Green Belt in the southern part of the district Map . They are
- To check the unrestricted sprawl of large built up areas
- To prevent neighbouring towns from merging into one another
- To assist in safeguarding the countryside from encroachment
- To preserve the setting and special character of historic towns
We suggest that the vision and development strategy to be included in the next version of your draft local plan should make explicit reference to safeguarding the Green Belt from any threat of development in the future. While the open rural nature of Uttlesford gives pleasure to many, the need for protection is greatest where it is potentially most at risk, and this was the rationale for creating the Green Belt in the first place.
Questions 2 and 10 – Cross boundary Strategic Planning
Amongst the development options reviewed you have raised the possibility of a new free standing settlement to meet the housing needs of the district. Given the development pressures facing East Herts and Epping Councils in the south and South Cambridgeshire in the north we suggest that this is a strategic issue which goes beyond simply meeting the identified housing demand in Uttlesford over the next 20 years.
Questions 11 and 13 – Edge of Bishop's Stortford
We strongly object to the inclusion of sites 11a and b in the areas of search to provide 500 homes to meet Uttlesford’s housing target. Our reasons are as follows
- Both sites are within the Green Belt and no case has been advanced as to why either site should be redesignated. All the purposes of the Green Belt which I have listed above apply to these sites. In the case of 11a preventing urban sprawl and the merger of settlements are particularly important. In the case of 11b preventing urban sprawl and safeguarding the countryside from encroachment are particularly important.
- Over the last 20 years Bishop's Stortford has had to absorb some 40% of all the new housing within East Herts. This expansion has been accompanied by no improvements in physical infrastructure – in particular the highway network – while much of the supporting social infrastructure has been relocated elsewhere – for example, the district general hospital, the Magistrates Court, the Police Station and the job centre.
- Planning permission has now been granted for over 2500 homes in the area known as Bishop's Stortford North (BSN), which will bring the built up area of the town to the boundary formed by the A120 bypass. This development will also add greatly to the pressures the physical and remaining social infrastructure will face.
- The last version of East Herts draft district plan envisaged another 2000 dwellings for the town in addition to those at BSN. The town would have no capability to support the further urban extensions which 11a and b would comprise. Indeed the sustainability appraisal rather gives the game away by suggesting as a ‘benefit’ how conveniently they would be placed for Bishop's Stortford railway station. Access to the station causes chronic traffic congestion at the moment and locating more dormitory suburbs on the edge of town for occupation by rail commuters can scarcely be regarded as a sustainable form of development.
- In the case of site 11b, Beldams Lane is used as a rat run to avoid Hockerill traffic lights, since there is no south eastern quadrant to the bypass. It would therefore be especially unsuitable as a site for further traffic generating development. It would also suffer severely from aircraft noise because of proximity to one of Stansted’s main take off paths and traffic noise from the M11.
- In the case of education, the sustainability appraisal refers only to JMI schools and acknowledges doubts about the capacity of Thorn Grove school to admit additional pupils arising from development at 11b. But both developments would also give rise to extra demand for secondary school places. Bishop's Stortford’s schools are successful and are all full. Herts County Council uses as a rule of thumb a metric of 500 dwellings adding 1 form of entry of demand at both primary and secondary levels. As urban extensions to Bishop's Stortford, parents on developments at 11a and b would expect to send their children to Bishop's Stortford schools regardless of where the administrative boundaries are drawn, even though there would be no capacity to absorb that additional demand.
- Development of these sites would thus leave East Herts council’s tax payers meeting all the costs and disbenefits of additional development purely to enable Uttlesford to reduce the rigour of its search for new housing within its own very ample boundaries. The same objections are generally applicable to areas of search 4 and 5 amongst the new settlement options.
Questions 16 and 17 – Development Scenarios
All scenarios should have 500 dwellings on the edge of Bishop's Stortford removed from them with the number being reallocated to other settlements.
Question 19 – Other Points
We came across this consultation document purely by chance. While not residents of Uttlesford, our members could clearly be severely adversely affected by the possible development to be included in your local plan. I should therefore be obliged if you would ensure that I am included in any further rounds of consultation or decision making so that we may have the chance to make representations about matters which may affect us.
I am copying this letter to Cllr Gary Jones (Deputy Leader of East Herts Council and a Bishop's Stortford councillor), Kevin Steptoe (Head of Planning and Building Control at East Herts Council), James Parker (Chief Executive of Bishop's Stortford Town council) and Kevin Fitzgerald (Honorary Director of CPREHerts).
President, Bishop's Stortford Civic Federation