The North Essex authorities recently held a consultation into the proposed methodology for their Sustainability Appraisal for ‘Section 1’ (the long term, strategic plan which, before the Inspector’s letter, included the three garden communities).
Responses to the consultation have now been published and it is hard to see how the authorities will be able to see the wood for the trees. It is clear that the previous lack of framework for decision-making combined with the lack of justification for decisions made has stored up trouble. This particularly manifests itself in the number of alternative options being promoted by developers, now bringing the total to 26 alternatives to be considered. Added to this are concerns about the size threshold set for strategic sites and descriptions of alternatives such as urban extensions and proportionate growth.
Unsurprisingly, the ‘check and challenge’ workshop for ‘stakeholders’ (the developers, campaign groups and others who participated in the Examination last time) which was scheduled for end February has been postponed.
It is likely that the authorities will have to cling desperately to the claim that professional judgement trumps everything else. However, this will not help them when, a) viability appraisals are finally published and b) the Plan is examined against the National Planning Policy Framework and the Strategic Environmental Assessment Directive.
In the meantime, CAUSE continues to argue that there is a better approach. It is not too late to revert to the Inspector’s ‘Option 1’, which would allow the District Local Plans to proceed to adoption, affording north Essex protection against speculative developer applications, and allowing time for proper consultation about the long-term.
General themes in the consultation responses
Size. Concerns expressed by most about size of developments to be evaluated – in particular the minimum 2,000-homes figure which is generally thought to be unjustified. Promoters are leaping through hoops to clear the minimum size threshold.
A number of respondents pointed out that if CAUSE’s, ‘Small is Beautiful’ analysis is correct then it makes no sense to set the minimum threshold at the point at which viability begins to decline.
Bias. A large number of respondents expressed concern about bias towards the preferred three garden communities and stated that any Plan arising from the proposed methodology will not be sound.
Ignoring the inspector. A majority of respondents expressed concern that the inspector is being ignored and his letter misinterpreted.
Call for sites. Some promoters with new sites raised the point that the new methodology looks only at sites previously in the 2014 call for sites process. There are three new GC alternatives put forward through the consultation, details below. The promoter of the new site at Halstead states that the authorities a) have not attempted to understand what they can offer, getting the size wrong (8,500 homes in the SA, only 6,000 proposed) and misunderstanding the level of growth which triggers a new Halstead bypass (c2,000 homes) and b) have shown bias against it.
Proportionate growth. A number of respondents, including DLA Piper (for Pigeon), stated that proportionate growth is not being properly assessed as an alternative and that this is unlawful. There are concerns about the Section 1 and Section 2 split and about the interpretation of ‘proportionate’.
Prematurity – respondents mentioned the lack of viability; lack of transport evidence; lack of meetings to understand proposals; the fact that the process is so far advanced already, and had started long before the consultation therefore raising the question whether responses can be taken into account.
Lightwood Strategic (the promoter behind ‘Monks Wood’, at Pattiswick) has written to the Head of RIS2 at the Department for Transport saying that Route D for the A120 is the wrong route and that it should be route A. It states that it can provide free land, and that route A provides the best BCR ratio. (CAUSE has alerted MP’s and Essex County Council to this). Lightwood proposes an alternative development strategy which includes Temple Border, 5,000 homes at ‘Monks Wood’ and a small ‘garden community’ at Marks Tey. It says that this negates the need to waste £100m HIF money on moving the A12. However, the Lightwood map shows uninterrupted development between Colchester and Braintree. Lightwood continues to use a map stating that Bosch is an anchor tenant, and CAUSE has raised this as a concern with the authorities.
Gateway 120 (the promoter behind 17,000 of the 24,000 homes at ‘West Tey’) says: that it will build 9,000 homes before the A120 is dualled and A120 widened; that NEGC/a development corporation is not needed; that the authorities have chosen the wrong sizes/alternatives of West Tey to evaluate; that CAUSE’s Metro Plan is not properly promoted, given lack of detail & lack of land; Small is Beautiful is flawed.
CAUSE’s Metro Plan – Some promoters, including Gateway120, suggested that the Metro Plan should be dismissed because there is not enough evidence to support it, i.e. CAUSE has no land to promote. Lightwood, on the other hand, said it should be properly investigated.
Healthcare – interesting North Essex Healthcare CCG response, expressing disappointment that the methodology does not adequately address the impact on health services or health infrastructure:
The situation is becoming ever more complicated. Below are the three big new GC alternatives now submitted through this consultation, and it is more clear than ever that the promise of protecting villages from sprawl was hollow. Developers are jumping through hoops to prove that they have enough homes to meet the arbitrary 2,000 home threshold. The sites below are in addition to those included in the 22 sites already being assessed in the proposed Sustainability Appraisal, shown here:
(Wethersfield Airfield may be a late entrant to the party, with the MOD announcing that it will be available from 2025 for development)
South Haverhill ‘alternative’, c 4600 homes:
North Kelvedon ‘alternative’, 600 hectares
North Witham ‘alternative’ c 2500 homes
The Gittins Plan
Ted Gittins is an independent planning consultant who launched an alternative for north Essex at CAUSE’s seminar in January 2019. His full report can be found here: Gittins Plan