Chelmsford Council’s response to Basildon Borough Council’s Core Strategy
Preferred Options – March 2012
Option A
Whilst Chelmsford Council would support in principle the protection of the Green
Belt, it is considered that the proposed housing targets under Option A are
unrealistically low for the period up to 2031. Although Regional Spatial Strategies are
soon to be abolished, at present they remain part of the statutory development plan
and for Basildon an overall housing target of 10,700 dwelling between 2011 and 2031 has been identified (Draft Review March 2010). Accordingly, the provision of 6,500 dwellings in a period up to 2031 is significantly below RSS targets. Notwithstanding this, the level of housing provision for Option A does not appear to appropriately reflect population and household forecasts for the same plan period. There is a major concern, therefore, that Option A could prejudice Chelmsford Council’s own housing delivery if there is insufficient housing allocation within Basildon Borough to match its expected growth over the next 20 years.
Options B and C
Whilst Chelmsford Council acknowledges that Option A is the Preferred Option, it
would appear that Option B and the provision of 10,100 homes is more in line with
the predicted population growth for Basildon Borough over the plan period.
Nevertheless, the Council would have concerns regarding both Options B and C in
that there is a lack of evidence identifying the necessary infrastructure required to
either accommodate a growing population and economy (Option B) or maximise the
Borough’s growth potential (Option C) and the delivery of such infrastructure. This
Council considers that the emerging Core Strategy is potentially not Sound in this
regard. If, at submission stage, this Council continues to see a lack of robust evidence supporting the infrastructure requirements of planned growth in Basildon, it will maintain its objections to the Plan. Specifically, in terms of Option B, this seeks to maximise the use of existing services and infrastructure however at present it has not been identified how this could be reasonably achieved. In reference to Option C, the Council would have concerns regarding the infrastructure implications to support growth of this scale, particularly if any of the larger sites identified in the SHLAA that lie adjacent to the Chelmsford’s boundary (i.e. SS0012, SS0053, SS0054, SS0164 and SS00238) were to be allocated as part of Basildon’s emerging Local Development Plan. Chelmsford Council has its own adopted Development Plan Documents that have been through the formal processes and all have been found sound. These documents allocate major development sites within Chelmsford on the basis that there are suitable utilities and infrastructure to support such growth. Accordingly, the Council is concerned that any large scale development in close proximity to the Chelmsford boundary which is not appropriately supported by the necessary infrastructure could risk the deliverability of Chelmsford’s allocated sites and place added pressure on infrastructure that supports this authority’s communities.
Sustainability Appraisal
It is recognised that it is not the role of the SA to determine the option to be chosen as the basis for the preferred options and the draft plan. However, it does provide a
qualitative assessment of each option’s contribution towards the sustainability
objectives. The SA highlights that Options B and C consistently perform better than Option A in meeting the key sustainability issues yet Option A has been selected by the Council as its Preferred Option. The assessment findings for each of the Options do not seem to indicate that Option A is the most appropriate given the alternatives of Options B and C.However, it is noted that in many cases capacity of key services and facilities has notbeen explored such that it is not considered that the findings of the SA are not fullyinformed. Accordingly, there are concerns that the SA does not provide a soundevidence base for the Basildon Borough Core Strategy.
Basildon Borough Council –Strategic Housing Land Availability Assessment
Chelmsford Council strongly objects to the expansion of Wickford within the
proximity of Barn Hall and more notably the Chelmsford boundary. The SHLAA
identifies three sites, SS0053, SS0054 and SS0164 where up to 742 new dwellings
could be provided and it is felt that this would have considerable and detrimental
impacts upon Chelmsford. It is considered that the scale of development at the three
sites either individually or cumulatively, is entirely inappropriate and would
significantly impact upon Chelmsford’s infrastructure and facilities due to the
proximity of the sites to the city boundary. Specifically, development of these sites
would result in an unacceptable increase in traffic to an already congested area and
would place severe pressure on existing drainage and educational services. Overall,
there is insufficient infrastructure and local facilities within Basildon’s own borough
to support these sites such that the burden of development would be wholly felt by
Chelmsford.
The issues highlighted above already form the basis of the continued challenge by
residents of Runwell to the recently approved application at Land South of Downham
Road for the erection of 68 dwellings. The approval of this application has set an
undesirable precedent to allow for the further development of the land to the west of
Wickford to the significant detriment of the living conditions of the residents of
Runwell. The Runwell community is alarmed to see further development sites
identified so close to the Chelmsford boundary as they will undoubtedly and
irrevocably impact upon the quality of life of these residents through increased noise,
traffic, drainage and school placements. Indeed the Runwell residents are surprised
that firstly, this application has been approved and secondly, that further sites within
the same vicinity have been identified given that Basildon Borough Council originally
refused permission for the proposal at Land North of Station Avenue. The
development of this land was only allowed by virtue of a decision taken by the
Secretary of State. This would give rise to the assumption that the further expansion
of Wickford to the west is in fact entirely inappropriate and unsustainable.
On other matters, Chelmsford Council would object to the manner in which Basildon
Borough Council has failed to engage with Chelmsford Council who, as an adjoining
authority, will be affected by decisions taken by Basildon Borough Council on issues
of growth and housing allocation. As Basildon Borough Council will be aware, under
the new Localism Act all local authorities have a ‘duty to co-operate’ which, amongst other things, requires them to engage constructively, actively and on an
ongoing basis with neighbouring authorities on issues of common concern. Failure to
do so can lead to unsound plan-making. There have been no meetings between
officers and Members of the two authorities prior to the publication of Basildon
Borough Council’s Preferred Options document.
There has been an apparent disregard by Basildon Borough Council to actively
engage with Chelmsford Council and this is only highlighted by the fact that one site
identified in Basildon’s SHLAA, namely SS0053, partly falls within Chelmsford’s
own boundary. As a matter of good practice, Basildon Borough Council should have
consulted with Chelmsford in a clear and transparent way in the earlier stages of their plan-making process so a strategic approach to key cross-boundary issues could have been taken. Instead, it is felt that Basildon Borough Council has made decisions on ‘larger than local’ issues to which Chelmsford Council should have played an active role.
Highlights from Chelmsford City Council’s Proposed Consultation Response 6 March 2014
Basildon Borough Council is currently undertaking a consultation on their Revised
Preferred Option of the Local Plan Core Strategy, part of a major review of the
Borough’s Development Plan.
The business community was particularly concerned that limited investment into the area from the scale of growth posed a threat to the long-term viability of major regeneration schemes, including Basildon Town Centre, and the preferred option would be unlikely to generate sufficient funding from the development to contribute to necessary infrastructure upgrades.
Gypsy and Traveller, Travelling showpeople Local Needs
Basildon Borough Council has undertaken a recent Gypsy and Traveller, Travelling
showpeople Accommodation Assessment (GTAA) which was published in January
2014. This study concludes that the estimated new pitch provision that is
required for Gypsy and Travellers in the Borough to 2028 is 257 pitches. There
was no current need for Travelling showpeople identified by the study. These
figures are based on the provision which is necessary to meet the projected needs
of Basildon Borough.
Broken down into five year timeframes, with the existing needs being met first and
then future household formation being spread over the entire period, this amounts to 133 pitches within the period 2012 – 2017, 37 pitches between 2018 – 2022 and 41 pitches between 2028 – 2032.
However, Core Policy 5 in the Revised Preferred Options document only seeks to
address the provision of 121 pitches over the Plan period, and divides this equally
over each five year period rather than dealing with the existing shortfall within the
first five years. As a result the plan does not seek to meet Basildon Borough Council’s identifiedGypsy and Traveller need in full.
The difference between the number of pitches identified in the GTAA and the
number put forward in the proposed plan is as a result of Basildon Borough
Council’s view that they should not have to provide for the need arising from the
Dale Farm encampment, contrary to the advice and findings of their GTAA.
As a result Core Policy 5 seeks to deliver only 121 new pitches over the Plan
period. Furthermore, this policy states that only 30 pitches will be provided (15
pitches have already been delivered through a permission granted in 2012) by
2016.The remaining 91 pitches proposed by Basildon Borough Council are proposed to be identified through a Gypsy, Traveller and Travelling showpeople Local Plan.There is however no timetable for when such a document may be produced or where such site may be located.
In respect of the remaining 155 pitches required to meet the needs arising from
the Dale Farm encampment the Council states, in Core Policy 5 that they ‘‘will
seek the provision of the additional 155 pitches arising from the projected growth of
unauthorised households from Dale Farm, Crays Hill to be provided outside of the
Borough through the continued cross boundary working with the local planning authorities within Essex over the plan period.’’ In short, the Council will not provide these 155pitches within Basildon Borough and expect other Essex authorities to deliver thispitch requirement.
Basildon Borough Council are proposing that they intend to provide 121 pitches
over the Plan period and will look to other authorities to meet the additional 155
pitches identified through the GTAA. It goes no further to identify which
authorities these may be, but as a neighbouring authority there is great concern
that Chelmsford will be expected to assist on this matter. To date Basildon
Borough Council has not approached Chelmsford on the matter.
Green Belt Review
Basildon Borough Council undertook a Green Belt Review in 2013. This identified
73 areas for consideration to assist in determining the boundaries of the broad
locations. This resulted in 26 areas being identified as possible locations to
accommodate development needs.
Therefore, the 26 areas were examined and used to consider alternative ways of
distributing the required dwellings to be found from the Green Belt across the
Borough. This included further detailed analysis under a series of subject areas,
namely environment, infrastructure, deliverability and sustainability. The plan at
Appendix B sets out further the suitability of those Green Belt areas, based
solely on the level of mitigation required for each.
The Green Belt Review which was carried out identified 9 broad locations as
being primary areas of search for development. The study does not recommend
development sites, but simply identifies areas of the Green Belt where
development may be an option and which areas of the Green Belt should continue
to be protected from development. It does not provide site specific areas, but
identifies broad locations.
Conclusion
Chelmsford City Council raises objections on the following grounds:
- The failure to comply with the Duty to Co-operate
- The potential impact that the broad locations identified in the Core Strategy
would have on the highway network and other services within the Chelmsford
City Council area
- The insufficient levels of Gypsy and Traveller pitch provision proposed
Therefore, Officers recommend that Chelmsford City Council formally submits
the proposed consultation responses to the Plan.