Uttlesford Local Plan Examination in Public Statement by Bidwells on behalf of Taylor Wimpey UK Limited Matter 15G - Elsenham 1: Land north east of Elsenham October 2014
Uttlesford Local Plan Examination in Public Statement by Bidwells on behalf of Taylor Wimpey UK Limited October 2014 Uttlesford Local Plan Examination Matter 15G Elsenham 1: Land north east of Elsenham Issue 15G/1 Statement by Bidwells on behalf of Taylor Wimpey UK Limited 1 Background 1.1 This Statement has been prepared by Bidwells on behalf of Taylor Wimpey UK Limited. Bidwells has participated fully in the preparation of the Local Plan process to date. 1.2 This Statement is a response to the Inspector's invitation to participants to submit statements, and responds specifically to Matter 15G/1. It does not reiterate points that have already been submitted in our previous representations. 2 Matter 15G Elsenham 1: land north east of Elsenham 2.1 Issue 15G/1 Is the choice of Elsenham justified as the most appropriate location for new development, considered against the reasonable alternatives, if some form of new settlement is required to meet the District's needs? Bidwells' response: 2.2 Elsenham is not justified as the most appropriate location for new development, when considered against the reasonable alternatives. Inappropriate location 2.3 The Plan takes an approach to settlement classification that bases the hierarchy on the level of services and facilities present. Elsenham is categorised as a Key Village in the Spatial Strategy alongside Stansted Mountfitchet and some other, smaller, settlements. Within these settlements the Plan proposes "a scale of development which reinforces their role of providing services to a rural area" 1. 2.4 The Plan proposes such a scale of growth at Elsenham that is disproportionate to its role and function in the settlement hierarchy that it is entirely at odds with the spatial strategy. Elsenham has a population of 3,626 2. This places it well below Stansted Mountfitchet, population 5,883 (estimated to be increased since then with the construction of some 700 houses to the south of the Parish at Foresthall ParK), the largest settlement within the Key Villages category, third largest settlement in the District and with a wide range of services and facilities, yet Stansted Mountfitchet is proposed to take a disproportionately low amount of growth in the Plan. 2.5 The impact of growth at Elsenham upon the District's other settlements, particularly the Key Villages and Stansted Mountfitchet, is not properly considered. Such growth would deprive these settlements of growth needed to develop sustainably and to maintain their position in the settlement hierarchy. Yet the environmental impact of this approach has not been properly appraised. 2.6 The scale of growth at Elsenham would cause such unnecessary local disruption, and would require such additional infrastructure to make it acceptable in planning terms, that it cannot be reasonably considered 1 Local Plan paragraph 7.2 2 Mid 2007 population estimate for 2009 UDC EX104 Appendix 12 1
Uttlesford Local Plan Examination in Public Statement by Bidwells on behalf of Taylor Wimpey UK Limited October 2014 as the most appropriate location for new development, when considered against the reasonable alternatives. Reasonable Alternatives 2.7 The Plan's evidence base does not properly consider the reasonable alternatives. 2.8 The scope of the assessment methodology is flawed and out-of-date. The methodology 3 assesses sites which were deemed suitable, available and achievable in the SHLAA (2013). However the SHLAA takes forward sites that were assessed in previous iterations of the SHLAA, without refreshing the assessments in accordance with current planning policy. This approach is flawed because it means that some sites were deemed as unsuitable in the policy context (and the then, significantly smaller, housing requirement) of the former Regional Spatial Strategy, whilst other sites were not. This approach does not fairly reflect the full bank of sites that would have been deemed suitable had the methodology been properly conducted in accordance with national Planning Practice Guidance. 2.9 The position of Stansted Mountfitchet as the Key Village with the highest population and broad range of services renders it suitable for further housing beyond what it is credited in the Plan. As such the future planning of the settlement should be best directed to the least sensitive areas that surround it, and capable of absorbing urban extensions. The Green Belt constraints dictate that the land to the north of Stansted Mountfitchet, which is not already proposed for allocation in the Plan, should be considered suitable. 2.10 Land at Bentfield Green is attributed reference number STA13 in the SHLAA. The SHLAA offers an opinion that development of STA13, 7.5 hectares in size, would cause an adverse impact upon the landscape. However there is no substantive evidence that leads to such a conclusion. The independent Landscape Character Assessment undertaken by Chris Blandford Associates on behalf of the Council in 2006 made no such assessment. It did make the general comment that Stansted Mountfitchet was "visible across the farm land to the north", but then confirmed that "Proposed Landscape Strategy Objectives" should include the protection, improvement and reinforcement of landscape features and gave encouragement that, subject to careful regard to issues of scale and form, there remained scope to incorporate a sensitively planned urban extension on the edges of historic villages. 2.11 Appendix A to this Statement contains representations by Bidwells on behalf of Taylor Wimpey submitted in response to the 2014 Pre-Submission Local Plan. The representations contain an indicative masterplan to show how development could be suitably accommodated on a 2.3 hectare portion of the site (plus 4.8 hectares of public open space including potential provision of a new primary school). 2.12 It is considered that the land at Bentfield Green presents a sensitive, sustainable, proportionate and suitable urban extension to Stansted Mountfitchet which responds directly to the nature and scale of the District's housing challenge. This offers a reasonable alternative to the development at Elsenham. New settlement option 2.13 Having regard to the above, if a strategy of dispersal were adopted in accordance with the Spatial Strategy, including a higher and more proportionate apportionment to Stansted Mountfitchet in line with its status in the settlement hierarchy, its population and its local service and facility provision, it therefore follows that a new settlement would not be required to meet the District's needs. 3 Methodology for Selecting Additional Sites, October 2013 2
Uttlesford Local Plan Examination in Public Statement by Bidwells on behalf of Taylor Wimpey UK Limited October 2014 Summary 2.14 The growth proposed at Elsenham is at odds with the spatial strategy. It unduly deprives other settlements of a share of sustainable growth, and would cause such significant change that it cannot reasonably be considered as the most appropriate location for development. 2.15 The reasonable alternatives to Elsenham are not properly considered. The evidence which favours Elsenham over other locations is therefore flawed. 2.16 The, is subject to an unjustified and out-of-date SHLAA assessment. The attached representations from June 2014 demonstrate that a suitable development could be delivered on the land at Bentfield Green, Stansted Mountfitchet, as a reasonable alternative to Elsenham. 2.17 If the pattern of land allocations were to attribute a higher apportionment to the other settlements, in particular Stansted Mountfitchet, in accordance with the Spatial Strategy a new settlement would not be required to meet the District's needs. 2.18 The choice of a new settlement at Elsenham is therefore not justified as the most appropriate location for new development, considered against the reasonable alternatives. 3
Uttlesford Local Plan Examination in Public Statement by Bidwells on behalf of Taylor Wimpey UK Limited October 2014 Appendices Appendix A Bidwells Representations to Pre-Submission Local Plan Consultation, May 2014 4
Uttlesford Local Plan Examination in Public Statement by Bidwells on behalf of Taylor Wimpey UK Limited October 2014 Appendix A Bidwells Representations to Pre-Submission Local Plan Consultation, May 2014 5
Uttlesford Local Plan Pre-Submission Consultation, May 2014 Representations on behalf of Taylor Wimpey UK Limited In respect of May 2014
Representations on behalf of Taylor Wimpey UK Limited In respect of May 2014 Quality Assurance Site name: Client name: Taylor Wimpey UK Limited Type of report: Written Representations Prepared by: Steven Butler BSc (Hons) MSc MRTPI Signed Date 21 May 2014 Reviewed by: Andrew Blackwell BA (Hons) MRTPI Signed Date 21 May 2014 i
Representations on behalf of Taylor Wimpey UK Limited In respect of May 2014 Table of Contents 1 Introduction... 3 2 Elsenham Policy 1 Land north east of Elsenham... 3 3... 5 4 Summary... 6 Appendix 1 Site Location Plan and Illustrative Development Layout for Land at Bentfield Green, Stansted Mountfitchet ii
Representations on behalf of Taylor Wimpey UK Limited In respect of May 2014 1 Introduction 1.1 These representations have been prepared on behalf of Taylor Wimpey UK Limited in respect of the Pre- Submission Uttlesford Local Plan. Taylor Wimpey has a stakeholder interest in the Land at Bentfield Green, Stansted Mountfitchet ("the Site"). 1.2 Taylor Wimpey objects to Elsenham Policy 1 Land north east of Elsenham, for which an allocation of 2100 homes is proposed. Elsenham Policy 1 is unsound because it is unjustified when considered against reasonable alternatives. In the context of this objection, we provide an Illustrative Development Layout of the to show that UDC should include this as an alternative option because it would accord with the Pre-Submission Local Plan's spatial strategy. Background to these Representations 1.3 Taylor Wimpey has promoted the Land at Bentfield Green for residential purposes through the Local Plan process for a number of years. Throughout this time an extensive range of evidence has been commissioned by Taylor Wimpey to seek to assist Uttlesford District Council (UDC) in identifying the suitability of the Site for allocation in the emerging Local Plan. 1.4 In Autumn 2012, and in light of a 5 year housing land supply shortfall, Taylor Wimpey entered into preapplication discussions with UDC culminating in the submission of an outline planning application for residential development of up to 140 homes in May 2013 under reference number UTT/13/1203/OP. The application was recommended for approval by the Assistant Director of Planning and Building Control to the Planning Committee. But it was refused for two reasons; firstly, relating to the impact of additional noise and traffic arising from the proposals upon the countryside and adjacent Conservation Area; and secondly, relating to the loss of the best and most versatile agricultural land. 1.5 Taylor Wimpey appealed UDC's decision (appeal reference APP/C1570/A/13/2201844) and a Public Inquiry was held in November 2013. At the Inquiry UDC sought not to defend its second reason for refusal, relating to the loss of agricultural land. A comprehensive package of additional supporting evidence was commissioned by Taylor Wimpey to provide rebuttal to UDC's reasons for refusal and third party objections, and to assist the Inspector in his deliberations. 1.6 The Planning Inspector's decision was issued on 7 January 2014. The appeal was dismissed. Notwithstanding the decision, Taylor Wimpey seeks to highlight to UDC that the unsuccessful appeal should not act as a prohibiting factor to a smaller scale development of the Site, and that the Illustrative Development Layout accompanying these representations shows how development could be delivered on the Site in a way that responds to the comments of the Appeal Inspector. 2 Elsenham Policy 1 Land north east of Elsenham 2.1 We object to Elsenham Policy 1 due to the following reasons: The scale of the allocation is inconsistent with the Pre-Submission Local Plan's spatial strategy; If such a strategic scale allocation at Elsenham Policy 1 is to be found sound at Examination, the Local Plan, and the spatial strategy within it, would require a whole scale revision in order to properly accommodate the shift in numerical context that has occurred since the publication of the Draft Local Plan;
Representations on behalf of Taylor Wimpey UK Limited In respect of May 2014 Elsenham Policy 1 cannot be considered as a credible allocation in the context of a refused application for 800 new homes on part of the allocated land. The Scale of the Proposed Allocation 2.2 It should firstly be noted that the residential allocation of Elsenham Policy 1 came forward as part of UDC's response to the National Planning Policy Framework paragraph 47 requirement that Local Plans meet their objectively assessed housing needs. The draft version of the Local Plan, published in 2012, made no such provision for an allocation of this magnitude at Elsenham because the policy context was different. 2.3 The Consultation on Additional Housing Numbers and Sites in December 2013 sought to add sites to the draft Local Plan, including the Elsenham Policy 1 site. It therefore follows that if the Local Plan is to be found sound at Examination in Public, the sites proposed as part of the December 2013 consultation should sit alongside and be in accordance with the draft Local Plan and its spatial strategy. Notwithstanding the Framework's presumption in favour of sustainable development, any additional consultation material that represents a significant departure from the draft Local Plan could not reasonably be considered sound at Examination, and should be removed. 2.4 The spatial strategy that emerged from the draft Local Plan identified the market towns of Great Dunmow and Saffron Walden as the major focus for development in the District. The Key Villages, which included Elsenham and Stansted Mountfitchet, were identified within the next echelon of settlements in the hierarchy. 400 of the units were envisaged to be delivered in Elsenham. 2.5 The scale of the allocation in Elsenham Policy 1 plainly does not align with the spatial strategy as originally set out in the draft Local Plan, which has not changed. The allocation for 2100 units, on top of the 400 envisaged in the draft Local Plan, is of such strategic scale that it is entirely at odds with the spatial strategy. Furthermore, when added to all of the other draft Local Plan allocations for Elsenham (which now have planning permission), this would lead to the total allocation of approximately 2500 new homes in the village over the plan period. This scale of development cannot reasonably be considered to be consistent with the spatial strategy and therefore should not be proposed as an additional housing site in this consultation. It should be removed and the numbers redistributed elsewhere in the District in accordance with the spatial strategy. Shift in Numerical Context 2.6 The draft Local Plan sought to provide a total of 6255 new dwellings for the period 2011 2026, based on 2 years at the RSS annual requirement of 430 dwellings per annum and 13 years at the economic scenario rate of 415 dwellings per annum. For the purpose of these representations the delivery rates contained in the RSS and economic population scenario are considered broadly the same. The RSS was in effect for a number of years prior to the introduction of the Framework in 2012, and the evidence base informing the draft Local Plan, in particular the SHLAA, was prepared in the context of the RSS/economic housing figures. As explained in our representations to the Consultation on Additional Housing Numbers and Sites in December 2013, Bidwells supports the higher, most up-to-date housing numbers proposed by the Pre-Submission Plan because this approach is Framework compliant. 2.7 The context applicable at the time of the RSS/economic figures has since changed, but the "Methodology for Selecting Additional Housing Sites" (a document that evidenced the additional housing sites), the process by which Elsenham Policy 1 was identified, still sought to use the SHLAA evidence that was prepared in the context of the RSS/economic scenario. Paragraph 25 of the Methodology for Selecting Additional Housing Sites seeks to justify the allocation of Elsenham Policy 1 by confirming that a dispersed strategy would fail to meet the objectively assessed need for the District as required by paragraph 47 of the Framework: " Whilst there are some suitable sites available to meet the additional
Representations on behalf of Taylor Wimpey UK Limited In respect of May 2014 housing need [in accordance with the draft Local Plan spatial strategy] there are not enough sites to meet the increased scale of need under option A [dispersal amongst the settlements in the hierarchy]". This approach is symptomatic of the flaw in the methodology, caused by the more restrictive housing numbers applicable at the time of the SHLAA's preparation in 2012. 2.8 UDC should refresh its evidence, in particular the SHLAA, to make up-to-date and relevant conclusions on sites considered for allocation in the context of the Framework. It is submitted that UDC may find more sites across the District that accord with the Local Plan's spatial strategy, and in doing so, would remove the necessity to make an allocation of such a strategic scale at Elsenham. Deliverability of Elsenham Policy 1 2.9 Outline application UTT/13/0808/OP for up to 800 dwellings was refused by the Council in 2013. The evidence accompanying the refused application sought to confirm the deliverability of the land. However, an allocation for 1300 more units than was proposed in the refused application must be considered vulnerable to non-delivery. 2.10 In the context of the above: Elsenham Policy 1 should be removed from the Pre-Submission Local Plan because its delivery cannot be ensured, and because a development of strategic scale is inconsistent with the spatial strategy; The numbers arising from the removal Elsenham Policy 1 should be re-distributed to: allow for non-implementation, and in order to accord with the Pre-Submission Local Plan's spatial strategy 3 3.1 These representations are submitted in the context of the planning appeal for 140 new homes on Land at Bentfield Green. The decision was issued by the Planning Inspectorate on 7 January 2014, and the appeal was dismissed. 3.2 Bidwells acknowledges the dismissal but only insofar as the scale of development caused by 140 new homes in this location would have upon the landscape and adjacent Conservation Area. However these factors should not necessarily rule out the possibility of a smaller scale development of the site, or part thereof. 3.3 The SHLAA anticipated a potential yield of between 169 and 281 units and its assessment of the landscape impact was based on these numbers. Taylor Wimpey sought to address this issue through previous consultations and the appeal through the preparation and submission of an extensive portfolio of evidence. It is now apparent that the appeal scheme for 140 units, even though it was a reduction on the indicative SHLAA yield, was not significant enough reduction in numbers to mitigate its impact upon the landscape. This should not however prohibit a sensitively planned development commensurate with its spatial surroundings from coming forward on the site in the Local Plan, and in the context of our concerns expressed in respect of Elsenham above, should be reviewed. 3.4 Attached to this report at Appendix 1 is an illustrative scheme showing development occupying a 2.3 hectare portion of the site (plus 4.8 hectares of public open space including potential provision of a new
Representations on behalf of Taylor Wimpey UK Limited In respect of May 2014 primary school). The potential number of homes would equate to between 60 and 70 and this scale of development would positively respond to the Appeal Inspector's comments. In particular the following should be noted: Smaller development footprint provides greater landscape containment Potential for a primary school site if the need arises Proposed vehicle access via Rainsford Road would remove vehicle traffic away from Bentfield Green Conservation Area 3.5 It is considered that the attached illustrative development layout represents a sensitive and suitable response to the comments raised by the Inspector in a way that would accord with the Pre-Submission Local Plan spatial strategy. 4 Summary 4.1 In light of: Our concerns over the scale of the proposed allocation of Elsenham Policy 1 being at odds with the Pre-Submission Local Plan spatial strategy; Our concerns over the applicability of the SHLAA which was produced within a different policy, spatial and strategic context; Our concerns over the deliverability of Elsenham Policy 1 as a proposed allocation site, UDC should remove Elsenham Policy 1 as a residential land allocation and redistribute the numbers in accordance with the Pre-Submission Local Plan spatial strategy. In doing so UDC should review its Methodology for Selecting Additional Sites, and the applicable evidence base, so that the attached illustrative development layout for the Land at Bentfield Green may be fairly assessed in the context of upto-date national planning policy and circumstances.
Representations on behalf of Taylor Wimpey UK Limited In respect of May 2014 Appendices
Representations on behalf of Taylor Wimpey UK Limited In respect of May 2014 Appendix 1 Site Location Plan and Illustrative Development Layout for Land at Bentfield Green, Stansted Mountfitchet
The copyright of this drawing and designs remains with CSa Environmental Planning. Do not scale from this drawing. Refer to figured dimensions only. LEGEND Existing Landscape Buffer Development area: 3.6ha Proposed housing area: 2.3ha Pond General Amenity Space and SuDS: 1.3ha Existing Allotments Public Open Space: 4.8ha Housing Existing Landscape Buffer Location of Potential School Site Housing Existing trees and hedges Proposed trees 70 74 88 Drainage pond 55 Proposed Access E AN Proposed vehicular access L 41 N O GT IN Potential pedestrian links 81 N 27 79 N PE 30 Tank 29 29a Location of Potential School Site Public Open Space 15 T OF NG CR LO 24 16 Existing Landscape Buffer Bentfield Primary School 1 14 Potential Footpath 1 & Cycle Link 8 19 A 5 UR ST 9 E 2 18 44 34 6 High Waters House Tower 20 CSa Project Bentfield Green Stansted Mountfitchet Title Illustrative Development Layout Client Taylor Wimpey UK Ltd Scale @ Size Date 1:2000 @ A3 January 2014 46 mp El Sub Sta 6 31 Bentfield Green Hargrave House Pu 33 43 49 (PH) Bentfield Green 15 62 Rose and Crown DP Layout amended By Description Dixies Barns High Street, Ashwell Hertfordshire, SG7 5NT t 01462 743647 f 01462 743648 environmental planning e ashwell@csaenvironmental.co.uk Works 4 32 26 50 56 13.01.13 Revision Date PA 16 21 ES AT LO b Sta El Su Pond 68 RF HE ET W 53 70 IEL Playground D Pond 52 The Yews ston Mile a 50 35a 45 7 Pond Bentfield Green Drawn DP Checked RR 66 es 1 37 39 Sub El Sta Drawing Number CSa/1936/142 Revision A