New sustainability appraisal – do it properly…

with No Comments

Let’s get this right.   The same officers who prepared the unsound garden communities plan are now holding behind-closed-doors meetings to appoint a consultant to do the ‘independent’ sustainability appraisal?

It seems so.  A Freedom of Information request reveals that officers appointed a company called Land Use Consultants as early as mid July to carry out the new sustainability appraisal work.  Minutes of a briefing meeting show that it was, strangely, attended by Braintree officers and NEGC Ltd representatives, not by Colchester or Tendring’s officers.

In what we now know, from three years of plan-making, is customary over-ambitious timetabling, the intention was to submit methodology to the inspector by end July and complete work by mid-October!   As far as we are aware the inspector has not been sent the methodology and we see that the appointment of LUC was deliberately kept secret by officers.  If the inspector has been approached without councillors being aware of it, this rings warning bells too.  Councillors we talk to are unaware of the brief.

The attached documents are revealing and, as ever with the NEGC proposals,  raise a number of questions which councillors need to get their heads round and start to challenge.   It is great that Colchester’s councillors have started this process of challenge and we need Braintree and Tendring to wake up to the issues.

CAUSE wishes to see a sound plan and a good, collaborative plan for north Essex which is sustainable, realistic and viable.  This will not happen if officers are allowed to continue to run the process behind closed doors, without robust challenge.    If the sustainability appraisal is not done properly – guess what?   More tax-payers’ money will be poured down the drain and we willl be back at examination, raising concerns.  If necessary we will seek a judicial review at the appropriate time.  This is us shouting ‘ICEBERG’ again.

QUESTIONS

Inspector
  • What steps are they taking to get Inspector’s buy-in to the LUC work?
  • In one breath they state work will be completed by mid-Oct, in the next they say he must be consulted by end July – but clearly he hasn’t.
Timetable
  • Timetable seems wildly optimistic if it is to be a realistic and objective piece of work.
  • Decisions will be made before A120 funding is agreed or A12 route known
Site choice and strategic backdrop
  • How are the sites being selected?
  • Five garden communities?  Which?   Why?
  • Relying on SHLAA – no new call for sites?
  • In one paragraph Sustainable Urban Extensions won’t be included because they are in section 2, in another they can be and if there is more than one at any town then they can be counted as one (?!)
  • Seemingly no strategic narrative to hang decision-making to.   Will sites be assessed in isolation?  Shouldn’t there be a north Essex strategic overview first, so that the planners can assess sites against the bigger picture?   This was a key problem of the Monks Wood SA.   The site was considered in isolation.
  • Why haven’t councillors been allowed input into the scope. If work IS underway, why hasn’t the inspector been consulted?
  • Viability should be at the heart of the process to demonstrate that any promises made can be kept
Consultation
  • Will there be consultation on the SA framework?
  • Will changes be made to the SA following consultation?  Seems not – the work will simply be sent to the inspector.  This strikes may cause problems under the SEA Directive.  Public consultation is supposed to be able to inform decision-making.
NEGC
  • Why is NEGC now responsible for viability, transport and delivery how is the work to be commissioned? NEGC Ltd’s is an unaccountable delivery vehicle whose sole purpose is to deliver the three, now-failed GC blobs.  ANy work produced will unequivocally not be independent.  They don’t have resources or expertise in-house.  Nor will the work be independent if carried out by an unaccountable delivery vehicle whose sole purpose is to deliver the three, now-failed GC blobs.
  • Viability in particulary rings warn bells.   This needs very specific expertise.
  • Spatial strategy looking at jobs, infrsatructure, connectivity, SHMA etc needed before site assessment.  Who will do this/when?
  • Why was this decision made?  NEGC Ltd has always claimed it is not interested in plan-making, just delivery of whatever is in the eventual plan.   Will councillors allow this transfer of powers?
  • Does this mean tax-payers are paying twice for planners?
  • This raises further concerns about who scrutinises NEGC.  We were told yesterday that complaints go in the first instance to the MD and then escalate to the Chairman.    Not acceptable – councillors need to get their heads around this lack of accountability.
  • Why were only BDC represented at Inception meeting?  No Colchester/Tendring

Lots in this document of interest:

LUC_FOI 2744 Action points arising from inception meeting with LUC-1 LUC_FOI 2744 North Essex SA Inception note

This confirms aiming for mid-Oct completion of work and need to submit to inspector end July:

LUC_FOI 2744 PI Stat Plan NA 050718 extract minute note

 

LUC_FOI 2744 North Essex SA Inception note