Pity the consultants who have picked up the Sustainability Appraisal half way through the Local Plan process. (The first lot had to be replaced because the Inspector was not happy with the work they had done).
The new lot, Land Use Consultants, hosted a workshop on Friday 29 March.
Why were we there?
Land Use Consultants themselves were extremely clear about the challenging job they have taken on. There was much mention of the complications involved. They have received over 60 responses to the consultation on their proposed methodology, some very lengthy and many very challenging. (We would agree with that.) At the beginning, they admitted that they have taken something on half-way through:
Normally the strategy is done first. The way we are having to do this presents a methodological challenge.
We were reminded that:
- The outcome may or may not include garden communities (Hallelujah! Someone has understood the Inspector’s letter at last!)
- The Inspector requires objectivity
- Reasons must be given for the selection of alternatives and combinations
Then we were told that viability & deliverability is separate. CAUSE has pretty strong views on this – how can you assess any site without a strategy, an idea of how you are going to fund infrastructure and what can actually be delivered? The Inspector was clear that:
“…before embarking on any other work the Councils will need to rexamine the evidence base for any GC’s they wish to assess, particularly with regard to viability, the provision of transport infrastructure and employment opportunities, in order to ensure they have a sound basis on which to score them against the SA objectives.”
So why exactly were we at a workshop about the Sustainability Appraisal when the consultants have not been given any of this stuff by the authorities?
Then followed an update. All the 22 or so sites have now been plugged into a database (except the site at Witham, by the looks of it).
The first phase involved mapping every site against distance from bus stops, stations, doctor’s surgeries, Local Wildlife Sites, Heritage sites, mineral deposits etc. Then assumptions are overlaid so that if a site is big enough to include a primary school, for example, that is added, thus sometimes making a site which is otherwise unsustainable sustainable.
Reservations were raised by the audience, some answered, some noted:
- Capacity is not assessed. What if site is near a station with an overflowing car park, full trains, a full school which can’t be expanded and a surgery which is refusing new patients? Apparently that is not the job of the appraisal.
- How do Section 1 and Section 2 interact? A: Complicated. We need to grapple with this. They should mutually support each other.
- Plan period and beyond – creates additional complications.
- What science or analysis is there behind decisions? Vague answer.
- You have accepted that the process is back-to-front – did you challenge this? The Plan could drop off a cliff. A: started as “It may well drop…” and then was rephrased as needing to step back and take a bottom up/top down approach.
- How can the sites be assessed without viability evidence? It isn’t LUC’s job to do that. That’s up to the authorities.
- The minimum size (2,000 for settlement extensions, 5,000 for garden communities) is causing problems because it is deemed to be arbitrary.
- The scale may also cause problems with the existing settlement hierarchy because settlements will compete.
- Where is the kill switch? No Infrastructure, no Plan.
- Are walking distances measured along walking routes or as the crow flies? A: as the crow flies
- Don’t you have to go back to Regulation 18 (an earlier stage of the Local Plan), otherwise you risk legal challenge?
- There is a risk to objectivity of this process due to government involvement in the project , given funding, HIF bids and desire to become a Locally Led New Town Development Corporation
- Favourite question:
“Isn’t your job impossible?”
We were told there have been no ‘showstoppers’ and all 22 sites have survived the first phase.
We will know more about changes to the methodology in due course. It must ensure a consistent appraisal of all sites.
Pin the tail on the donkey
In the afternoon, we had a workshop about ‘spatial strategy’ to discuss the best way of allocating the 7,500 homes allocated to the three garden communities in the Plan period. At our tables we had to discuss things like whether we wanted proportionate growth, hierarchical growth, garden communities, urban extensions, CAUSE’s Metro Plan.
We were shown a load of maps with dots, which at the speed we had to absorb what was going on was rather confusing and felt a bit like being asked to,
“Spread 7,500 pins across the map”
We should not reduce our future to trying to spread the houses around on a map. A strategy is needed first: What infrastructure do we have, where are the crunch points, do we have transit corridors, where is the brownfield, where are the jobs, should we have a Community Infrastructure Levy, how will we fund everything, etc?
The groups fed back as follows:
- One size does not fit all
- Locational attributes
- Demography & affordability / deliver need e.g as assessed in SHMA
- Minimise travel from home to work / Co-locate work and homes
- Infrastructure & services capacity assessment / What infrastructure is there? /What new infrastructure do we need / How can we pay for it?
- Stations /Rail focused growth
- Hierarchical growth rather than proportionate / Gittins Plan is a good start
- Sustainable urban extensions can bring public transport benefits (may need buffers)
- Garden villages (NOT TOWNS) may have their place
- Balanced economic growth strategy
- Think about existing communities: what benefits to them?
- Transport led growth / transport focus / e.g CAUSE Metro Plan / Linked communities
- Empowering local communities (Neighbourhood Plans)
- New rail if possible
- Bus & MRT must be viable and useful
- Amenities close to housing
- Minimise environmental impact
- Could scale facilitate major new infrastructure?
- Impact of neighbouring Plan e.g WOB / Andrewsfield (Uttlesford)
- Commuter patterns
- Flexible phasing
Credit to Land Use Consultants for doing their best and listening but they have an impossible job. One of the land promoters summed it up as he left at the end,
“This is back to front. I am not sure what we have achieved.”
 We think CAUSE wins – 55 pages: http://www.cause4livingessex.com/wp-content/uploads/2017/07/CAUSEResponseLUCMethodologyJan31.pdf