Notes for Locals in Responding to Consultation On

Notes for Residents in responding to consultation on

Uttlesford District Council Local Plan Pre-Submission

Representation Form

Part B – Please use a separate sheet for each representation

To which part of the Local Plan does this representation relate?

Paragraph / 3.3 plan period
11.11 table / Policy / SP6 - Meeting Housing Need
SP7 - Housing Strategy
Elsenham Policy 1 - Land north east of Elsenham / Policies Map

Do you consider the Local Plan is (please tick as appropriate):

4.(1) Legally compliant / Yes /  / No
4.(2) Sound / Yes / No / 
4.(3) Complies with the Duty to co-operate / Yes / No / unknown

Please give details of why you consider the Local Plan is not legally compliant or is unsound or fails to comply with the duty to co-operate. Please be as precise as possible.

If you wish to support the legal compliance or soundness of the Local Plan or its compliance with the duty to co-operate, please also use this box to set out your comments.
The Plan is unsound (National Policy Planning Framework, NPPF, paragraph 182) in that it is not
Positively prepared being based on a strategy where

the plan period is too long contrary to the NPPF paragraph 157
it provides for excessive new housing contrary to NPPF paragraph 47

Justified - it is not the most appropriate strategy when considered against reasonable alternatives:

specifically the allocation of 2,100 homes at land north east of Elsenham is not the most appropriate strategy when considered against reasonable alternatives

Effective - it is unlikely to be deliverable over its period

specifically the allocation of 2,100 homes at land north east of Elsenham is unlikely to adequately contribute to the required delivery of new housing being too large and with inadequate infrastructure

Consistent with national policy

it does not make provision for sustainable development as described in NPPF paragraph 7, e.g. it does not

contribute to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure (economic role)
support strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations … with accessible local services that reflect the community’s needs and support its health, social and cultural well-being (social role)
contribute to protecting and enhancing our natural, built and historic environment (environmental role)
(Continue on a separate sheet/expand box if necessary)

Please set out what modification(s) you consider necessary to make the Local Plan legally compliant or sound, having regard to the test you have identified at 5 above where this relates to soundness. (NB Please note that any non-compliance with the duty to co-operate is incapable of modification at examination). You need to say why this modification will make the Local Plan legally compliant or sound. It will be helpful if you are able to put forward your suggested revised wording of any policy or text. Please be as precise as possible.

Paragraph 3.3 plan period
replace 2031 with 2030
Paragraph 11.11 table
replace ‘annual requirement of 523 homes a year for 20 years - 10,460’ with ‘annual requirement of 500 homes a year for 19 years - 9,500’
replace ‘sites of 6+ units with planning permission at April 2013 - 1,970’ with ‘sites of 6+ units with planning permission at April 2013 - 2,517’
replace ‘total supply - 4174’ with ‘total supply - 3627’
replace ‘requirement - supply - 6286’ with ‘requirement - supply - 4779’
Policy SP6 - Meeting Housing Need
replace ‘provide for 10,460 new homes between 2011 and 2031’ with ‘provide for 9,500 new homes between 2011 and 2030’
Policy SP7 - Housing Strategy
replace ‘10,460 new homes … during the period 2011 to 2031’ with ‘10,460 new homes … during the period 2011 to 2031’
delete ‘2100 new homes as a linked settlement to the north east of Elsenham’
Elsenham Policy 1 - land north east of Elsenham
delete
EXPLANATION

The latest ONS/DCLG household projections equate to a need for 500 homes p.a., the higher figure in the Plan is based on older estimates.
The plan period of 20 years to 2031 is excessive - the Plan is expected to be adopted in 2015 and the NPPF requires a plan period of 15 years. This would reduce the housing requirement by at least 500 units.
The ‘Consultation on Additional Housing Numbers and Sites, November 2013’ stated that there were “homes on sites of 6 or more which have planning permission (2,517)” (paragraph 2.16) so that the reduction in the Plan to 1,970 is an error (or at least not explained) with a loss of 547 units, a total supply of 4,721 units. The reduction to the total requirement to 9,500 means that the Plan’s allocations should be 4,779 not 6,286 - a reduction of 1,507 units.
Policy SP7 shows allocations (without NE Elsenham) of 4,081 units. This is 698 units short of the revised requirement. No figures are provided for:

Committed and identified redevelopment sites within Saffron Walden, Great Dunmow and Stansted Mountfitchet
Committed urban/settlement expansion, at Forest Hall Park, Birchanger/Stansted Mountfitchet; Priors Green Takeley/Little Canfield; Woodlands Park, Great Dunmow; and Flitch Green.

There are more sustainable siteswithin the District close to facilities and infrastructure.In particular, the site at Great Chesterfield (capacity some 3,000 units) was identified in previous Local Plan consultations as an alternative sustainable single-settlement site thatis close to Saffron Walden, with better links to the main road system, including the M11.
The objections to the NE Elsenham site include

overdevelopment on the edge of only a key village
coalescence of Elsenham and Henham, destroying the special character of Henham
this is not a sustainable location in any sense - such a description could apply to the edge of any key village, which is contrary to the overall strategy to concentrate development at the two main settlements
there is inadequate provision for education, health & community services, retailing and employment
the road system serving Elsenham is seriously sub-standard for the establishment of an extra 2,100 dwellings
the development would destroy local landscapes and the open countryside, and lose a valuable agricultural asset - all contrary to policy in the Framework.
planning permission has already been refused in November 2013 for Phase 1 of the Elsenham development. The Ecotown and ‘option 4’ proposals were firmly rejected by UDC. It is inconsistent and lacking in justification to now be proposing what has previously been rejected several times. The increase in housing numbers can be accommodated elsewhere avoiding a glaring ‘u turn’ on previous decisions.
public opinion, as expressed by thousands of objectors, is being ignored if this proposal at Elsenham is taken forward.

(Continue on a separate sheet/expand box if necessary)