Planning Team, Uttlesford District Council,
Council Offices, London Road,
Saffron Walden, CB11 4ER

19 August 2013

Dear Sir or Madam,

Ref: Planning Application UTT/13/2060/OP – application for 300 dwellings and associated development on land south and north of Thaxted Road, Saffron Walden(the “Kier development”).

I am writing to OPPOSEthe Kier development on Thaxted Rd, which is in breach of local and national planning policies for the reasons set out below.

Kier Development

  • The application is unsustainable:The National Planning Policy Framework (NPPF) requires that development be sustainable and the proposed development is unsustainable. The evidence base assembled by UDC as part of its Local Plan and summarised in its February 2010 housing strategy is clear that the most sustainable housing strategy for Uttlesford is to build a new settlement for the bulk of the forecasted housing need, and to permit only limited development in the existing settlements. The absolute sustainable level of housing development for Saffron Walden was identified by UDC at 250 new homes in the 15 years from 2011. Taking into account permissions already granted, the proposed development greatly exceeds this proposed sustainable level. Additionally, the location of the Applicant’s site is inherently unsustainable;it is in the most inaccessible part of Saffron Walden, on completely the wrong side for access to jobs, schools, the railway station, other facilities and major transport links;
  • This application is against the existing Local Plan:In 2011 UDC members stood and were elected on the Local Plan basis that new housing would be focused in a single new settlement; that approach is still UDC’s official preferred option. Whilst soon after the election the UDC Cabinet started developing an emerging plan that would disperse housing into existing settlements, that plan has not been adopted; the evidence base for it has been completely contradicted by the 2012 demographic forecasts, it has been rejected by 99% of respondents in the 2012 Public Consultation, and is still has to be reviewed by the Planning Inspectorate. Until that time applications must be judged against the current, single-settlement plan. This is a very large housing application for Saffron Walden and it falls outside of the current adopted Local Plan, and therefore on that basis it cannot be recommended and should be refused;
  • Incomplete Highways analysis:The Transport Assessment accompanying the Application deals only with the additional traffic from the proposed Kier Development and certain other developments; it does not assess the cumulative impact of the traffic from all of the other schemes which have been approved but are not yet built and which will bring additional traffic on to Thaxted Rdand neighbouring roads and junctions, including: the residential developments in the course of construction on the Thaxted and Radwinter Roads, the 130 house development on the Ashdon Road and completion of the Bell Language School housing developments. UDC commissioned a full Highways Assessment for Uttlesford in 2012. At the June 2013 UDC Area Forums the UDC Leader stated that even though the report was in draft status, it was complete for Saffron Walden. However UDC has refused to publish the draft, even under Freedom-of-Information requests. Given the huge traffic congestion issues in Saffron Walden, and the associated air pollution, this is material information which must be published and scrutinised before a proper assessment of the development can be made. Neither UDC nor the public can properly assess the Application without this fundamental background report;
  • Directly attributable impacts to key Thaxted/Radwinter Rd junction are alarming: The Applicant’sTransport Assessment forecasts extraordinary levels of queuing at the Radwinter Road / Thaxted Rd junction. Table 3.3 of the Transport Assessment states that the existing peak queues are on average 19.1 vehicles long; according to Table 6.4, after the developers’ junction improvements, traffic queues will be 59.9 and 71.0 vehicles long, which is completely unsustainable. Planning regulation requires that the developer mitigate the impacts of their development; by allowing a quadrupling of congestion (and the associated air quality issues) at this key junction, the developer is failing in their basic requirement and if UDC recommends or approves the development, they will be failing in their legal planning obligations, opening up council tax payers to environmental fines, and increasing the likelihood of a legal challenge by residents and/or the Town Council;
  • Air Qualityobligations not met and application will cause illegal levels of pollution: Air pollution at the Radwinter/Thaxted Road junction already significantly exceeds legal limits. Paragraph 124 of the NPPF requires that development should contribute to compliance with legal limits – instead the proposed development would massively increase traffic at that junction (see above) and will therefore worsen air pollution. Paragraph 124 of the NPPF also requires a cumulative impact study of air pollution of all of the above developments, which the Applicant has not provided. Additionally the Applicant’s Air Quality Assessment has been prepared usingout-of-dateDEFRA standards, which weresuperseded in 2012 (Interim Advice Note 170/12). Irrespective of this, the Application’s own assessment is unbelievable and is directly contradicted by ECC’s draft Air Quality assessment for Saffron Walden. For example, the ECC assessment, using the required Interim Advice Note 170/12, predicts that NO2 pollution at the Thaxted Rd junction wouldbe 50.9microg/ by 2018, assuming that none of the Kier development homes are then built; the Applicant’s air quality assessment claims that NO2 levels would be only 29.09microg, assuming that all 300 of the new homes have been built; set against existing NO2 levels of 46microg, the Applicant’s air quality claims are ridiculous.ThisApplication should be refused until a credible and proper cumulative air quality assessment for all the major junctions in Saffron Walden is prepared and submitted in accordance with the DEFRA interim advice note 170/12;
  • Unsustainable for Education and actual provision not planned: Irrespective of any Section-106 obligations levied on the Applicant, there are no school places and no plans for additional space. Both the catchment area schools (Saffron Walden County High and RAB) are already over or forecast to be at capacity. As ECC Education suggest, the application should be refused unless and until there is a clear and deliverable programme for providing the additional school places. An education contribution without a deliverable plan for providing the additional school places before the development is completed should not be acceptable. Based on standard ECC Education calculations, the 300 new homes proposed would be expected to result in an additional 98Primary,65Secondary and 13 6th Formstudents with a matching £2,500,000 Section-106 obligation education, and yet irrespective of the financial obligation, there is absolutely no provision for them, and nothing planned for the foreseeable future;
  • Unsustainable for Employment: The Employment Land Review prepared for UDC states clearly that Saffron Walden is relatively unattractive for employers because of its relative expense and its poor transport links, and that the principal areas of job creation in Uttlesford will be north of Great Chesterford, as part of the Cambridge Corridor, or south, near to Stansted Airport. Paragraphs 17, 34 and 37 of the NPPF provide that sustainable development should reduce the need to travel and integrate employment and housing, not build them in totally separate locations. Inevitably, in the absence of significant employment in Saffron Walden, the proposed development would result in large numbers of people driving to work, in contradiction of the NPPF sustainability requirements;
  • Unsustainable for Waste Water Treatment capacity: The 2012 Hyder Consulting Water Cycle Study commissioned by UDC found that sewerage capacity was exhausted in Saffron Walden and that UDC should not grant further planning permission until new capacity was planned. The study also indicated that any planned developments would need to be phased to allow for the time it takes for sewage upgrades (5-10 years). In recent direct communication, Anglia Water has indicated of the Kier application “additional sewerage capacity will be required for this development” and that they didn’t plan to submit expansion proposals for Saffron Walden to Ofwat until PR19 (for 2020). UDC cannot recommend this development and it cannot be determined by the UDC Planning Committee until sewerage capacity and provisioning issues have been addressed;
  • Uncommitted road to nowhere: Even though UDC is refusing to publish the ECC Highways Assessment, the Kier application includes the provision of the first quarter of a new estate road that UDC is proposingto link Thaxted and Radwinter Roads. However, the Kier portion of the estate road is not directly necessary for the Kier application and it will have no benefit to the town without the delivery of the rest of the road; and even if delivered in its entirety, the estate road will have no benefit to the east-west movement of traffic through the town as it begins and ends in the east. UDC proposes that the additional 3/4 of the link road be funded by further development on adjacent land (SAF04). The adjacent landowner has not filed a development application or stated their intent to fully develop the land between Radwinter Rd and the Kier development. Without a firm, written commitment for the remainder of the estate road from the SAF04 landowner, the Kier “link-road” will be a white-elephant UDC needs to gain this delivery commitment from the SAF04 owner before determination by the UDC Planning Committee;
  • Not supported by Saffron Walden Town Council:In September 2009 the Saffron Walden Town Council objected to housing on this site because of the: lack of road capacity; lack of secondary schooling facilities; difficulty of access road; and very prominent nature of site in landscape. None of these issues have been addressed since then or in this application. The Saffron Walden Town Council has recently reconfirmed its opposition for development of the site in the local newspapers.

Yours faithfully,

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