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Uttlesford Local Plan

Examination Hearing Statements

Matter 8 – The Proposed New Garden

Communities – Specific Matters (Policies

SP6, SP7 & SP8

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Matter 8: The proposed new garden communities – specific

matters (Policies SP6, SP7 & SP8)

Main issue: Whether the detailed policies for each new garden community is justified,

effective and consistent with national policy.

SP6 Easton Park

Question 1: What evidence is there to demonstrate that the proposed Easton Park

Garden Community is capable of delivering 10,000 homes (1,925 in the Plan

period)?

Capacity for delivering 10,000 homes

1.1 The Easton Park site is a greenfield site between Great Dunmow and Stansted Airport. The

Council has undertaken numerous studies in relation to Easton Park, these include:

a. Strategic Land Availability Assessment 2015 & 2018 (1104.4 HSG)

b. The Strategic Flood Risk Management Assessment May 2016 (700.1 ENV);

c. Transport Study 2016 (1500.1 TRA); Addendum 2017 (1500.3 TRA); second Addendum

2018 (1500.7 TRA); and the Rapid Transit System Preliminary Concept and Feasibility

Study (1506.1 TRA).

d. New Settlement Proposals: Landscape and Visual Impact May 2017 (708.1 ENV)

e. Ecological Sites on and Adjacent to New Settlements and Neighbourhood Proposals

May 2017 (717.1 ENV)

f. Landscape and Visual Appraisal: Easton Park June 2017 (709.1 ENV)

g. Water Cycle Study April 2018 (1202.1 INF) and the January 2019 update (1202.4 INF)

h. Heritage Impact Assessment Final January 2019 (1001.2 HEN)

i. IDP Topic Paper February 2019 (Council’s response to Initial Question 8 Appendix A)

1.2 The evidence base gives an indication of the constraints on the site for the purposes of

strategic plan-making. The position on the key constraints is summarised below:

a. Flood risk: Limited risks with regard to flooding should be considered early on1;

b. Landscape and Visual: The former parkland is not considered to be of significant

landscape value. Substantial blocks of existing woodland would provide a level of visual

containment. Additional woodland and tree belts would further mitigate the visual

impact of the development. The likely overall effect on the surrounding landscape is

considered moderate2. The site contains certain landscape features (Ancient

Woodland, a Registered Park and Garden, listed buildings, and is adjacent to a

Conservation Area and the Countryside Protection Zone3) which support its moderate

to high landscape and visual sensitivity. There is potential for part of the site to

1 Area of Search 7 Table, Appendix B Strategic Flood Risk Management Assessment (ENV 700.1)

2 See pages 9-10 New Settlement Proposals: Landscape and Visual Impact (ENV 708.1)

3 Paragraphs 2.2.1-2.2.13 Landscape and Visual Appraisal: Easton Park (ENV 709.1)

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accommodate development. It is desirable for development in the northern part of the

site to be limited on landscape and visual grounds. The southern part of the site is of

lesser sensitivity4.

c. Heritage: This is considered in more detail in question 2 below.

d. Ecology: Two Local Wildlife Sites and two woodlands identified as being of potential

ecological importance lie within the development site and a number of historic lanes

adjoin the site boundary5.

e. Highways: Easton Park has achievable access abutting onto the A120 junction west of

Great Dunmow. This junction will operate within capacity for the first five years of the

plan period as well as the whole plan period and beyond. The A120(T) currently

operates within link capacity, being largely free flowing apart from M11 J8 approaches.

A fully funded interim scheme is in place for partially improving M11 junction 8, this will

be completed by mid-2020. ECC have indicated that this provides capacity for the plan

period. Highways England is in the process of investigating strategic interventions to

Junction 8 (and also the M11 between Junctions 8 and 13) to determine investment for

the next Road Investment Strategy. A sensitivity test indicates the A120 reaches

capacity by the end of the plan period based on a worse case scenario. A major

improvement to the A120 is not considered necessary as the NPPF advises a plan

monitor approach favouring sustainable transport modes. A bus-based rapid transit

system, incorporating elements of dedicated new links could be the most suitable,

flexible and affordable solution to pursue. The scheme is planned in discrete affordable

increments. Easton Park would contribute towards two segments by the end of the

plan period, to the Airport and then to Woodside Way, Great Dunmow6.

f. Water and drainage: The required upgrades to the public sewer system and Water

Recycling Centres for Easton Park are technically feasible and will be available on time7.

g. Other: Poor air quality along the A120; and the minerals extraction in the south east

part of the site8 as identified in the SLAA.

1,925 homes in the plan period

1.3 The promoters of Easton Park have submitted evidence to the Council with an indicative

scheme for the Garden Community, see the Easton Park New Settlement Prospectus

(September 2017) (1901.14 PRD). The masterplan in this document is for a scheme of

10,000 homes on the site, and includes a phasing plan that delivers 2,500 homes in the first

4 Paragraph 6.4.1, page 18 Landscape and Visual Appraisal: Easton Park (ENV 709.1)

5 See pages 5-7 Ecological Sites on and Adjacent to New Settlements and Neighbourhood Proposals (ENV

717.1) 6 Sections 2.1.1-2.1.3 IDP Topic Paper

7 Executive Summary, page 10 Water Cycle Study 2019 update (INF 1202.4)

8 06LtEas15, Little Easton Site Assessments Strategic Land Availability Assessment (HSG 1104.4)

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ten years of the development of the site9. On 8 January 2018, Barton Willmore on behalf of

Landsec, submitted a letter to UDC analysing the delivery rates on new settlements in

relation to Easton Park with an average of around 250-350 dpa, this is appended to this

statement and indicates a willing and experienced promoter who expect to be able to

deliver homes rapidly.

1.4 Attached at appendix 2 is a timetable for the production of the Development Plan Document

(DPD) for Easton Park. This indicates adoption of the DPD in September 2021 following a

process of just over two years. This is considered to be a challenging but realistic timetable,

the Council has recently appointed three members of staff to work on the DPDs for Easton

Park and North Uttlesford and anticipates swift progress on their production.

1.5 It is helpful to compare this timetable to the production of other DPDs. North West

Cambridge AAP took around three years to produce, this included five rounds of

consultation10, and the Uttlesford DPDs are expected to be swifter due to only three rounds

of consultation (two pre-submission and one post-submission).

1.6 This timetable has a regulation 19 consultation on the DPD in summer 2020. This is also

around the time the Council considers that the Local Plan is expected to be adopted, subject

to the progress of this examination. The Council considers that work that has been used

progress the DPD up to this point will be capable of being used to inform the planning

application for Easton Park. The Council’s decision to adopt the Local Plan at the same time

the Council decides to publish a Regulation 19 DPD will provide a trigger for work to begin in

earnest on the planning application for Easton Park11. The Council anticipates adoption of

the DPD in Autumn 2021, with the formal decision on outline and reserved matters planning

applications to follow shortly afterwards in Winter 2021 and Spring 2022 respectively.

1.7 With the promotor’s evidence that 2,500 homes can be delivered in the first ten years

(which is at the bottom end of their average range of 250-350), even if there is some

slippage in the timetable of the DPD or planning application, 1,925 homes is considered

realistic.

1.8 The Lichfields Report Start to Finish indicates that the average planning approval period is

6.1 years, although this is quicker for larger sites, averaging 5 years. Figure 3 in the report12

is clear there is variation between schemes, with approval processes for some sites taking

less. UDC considers that securing the principle of development and identifying the key

issues in the Local Plan and then working through the detailed planning issues in the DPD will

allow for swifter than average delivery on Easton Park and North Uttlesford. Furthermore,

dual tracking the Local Plan and DPD; and then the DPD and planning application will allow

for more rapid consideration of the issues. Figure 513 highlights that the key findings in the

report are averages and some large schemes of 2000+ units are capable of coming forward

in under two years.

9 See pages 58 & 60

10 Three pre-submission and two post-submission

11 i.e. in Spring 2020

12 See page 7

13 See page 9

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1.9 The Council considers that taken together the evidence indicates that Easton Park is capable

of delivering 10,000 homes and 1,925 in the plan period.

QUESTION 2: The Heritage Impact Assessment says this site is situated within an

area of moderate to high sensitivity. Has this been factored into the calculation of

the likely developable area of the site and the provision of infrastructure and

services?

2.1 The Heritage Impact Assessment Final January 2019 1001.2 includes a development concept

criteria plan for Easton Park GC to assist the delivery of the proposed Garden Community.

The criteria plan EPGC-06 is based on an assessment of sensitivities of relevant heritage

assets and settings including the listed Easton Lodge Registered Park & Garden and Little

Easton Conservation Area. The criteria plan is based on a redline assessment without a

masterplan as a worse-case scenario of sensitivities. The HIA considers initial mitigation to

assist each site in meeting its identified development potential subject to these being

pursued at a more detailed level. The central section of the site is the former WWII airfield

marked as low sensitivity, and an intermediate area is marked as medium sensitivity14. The

Easton Park Development Concept Criteria Map identifies a potential extent of least harm

(220 ha); a potential extent of medium sensitivity (305 ha, including the area of least harm).

2.2 The land budget included in the Easton Park New Settlement Prospectus (September 2017)

(PRD 1901.14) indicates 287 ha of built development15. This is less than the extent of

medium sensitivity and area of least harm combined of 350ha. It is likely that a proportion of

open space will also be located within the area of built development, so the ‘land take’

within the area of built development will be more than 287 ha, however open space is

unlikely to have significant impacts on heritage assets and can be used to build in

appropriate mitigation. It is also worth noting that the Heritage Impact Assessment is based

on a ‘red line’ assessment of the site which assumes development across the whole site and

does not take into account mitigation measures or a masterplan. With appropriate

mitigation there is likely to be potential for well-designed built development within the

areas identified as medium sensitivity and for some appropriately sensitive development in

the high sensitivity area. For example the area north of park road shown as high sensitivity

has potential for elements of appropriately located development that protects the setting of

historic assets by incorporating suitable buffers and open viewing corridors. This would

respect the views between RPG and Little Easton conservation area and where possible keep

the most relevant agricultural setting.

2.3 Work on the DPD will examine this in further detail.

Question 3: Has any work been undertaken to assess the likely impact of the

proposal on the surrounding landscape?

3.1 Yes, work has been undertaken from a formative stage of local plan preparation to assess

landscape impacts on the surrounding area of the plan of a Garden Community (GC) at 14

Paragraphs 8.6.8-8.6.10 and Easton Park maps, pages 92-99 Heritage Impact Assessment Final (HEN 1001.2) 15

See page 39

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Easton Park. Following Issues and option consultation initial work on landscape impacts of

GC locations was produced to inform option testing locations for New Settlement Proposals

including “Easton Park Landscape and visual impact April 2017” (708.1 ENV).

3.2 This found “It is evident that parts of the proposed development would be visible in views

taken from outside the site, and there is a likelihood that the development would be visible

in some distant views. In conclusion, the former parkland is not considered to be of

significant landscape value. Whilst much of the proposal site is on the elevated plateau land,

the substantial blocks of woodland on and adjacent to the site would provide a level of

visual containment of the proposed development. The provision of additional woodland and

tree belts would provide further mitigation of the potential visual impact of the

development. The likely overall effect of the proposed development on the surrounding

landscape is considered moderate.”.

3.3 Uttlesford Council commissioned a further Landscape and Visual Appraisal: “Land at Easton

Park Landscape & Visual Appraisal June 2017” (709.1 ENV). The study finds no policy

landscape designations i.e. strategic gap or green-belt within or adjacent to the site. There

are 4 small areas of ancient woodland on the site and the larger area of High Wood adjoins

the site to the south east.

3.4 Visibility across the Site is in part restricted due to a combination of the gentle topography

and vegetation structure. The northern part of the Site is more sloping than the rest of the

Site, and therefore the potential for views into this part of the Site is greater than elsewhere

within the Site, and is more constrained due to the presence of Easton Lodge RPG and

woodland structure. The landscape sensitivity to development therefore varies from

moderate to high. The southern part of the site is the least constrained due to the aggregate

quarrying site and the presence of major road infrastructure. The Appraisal finds that the

northern part of the Site (Figure EP3), is the most sensitive part of the Site where desirable

for development in this location to be limited. However, the above provides a worst case

scenario and a more detailed LVA would be expected to establish more detail on capacity.

The finalised evidence would be based on a detailed masterplan. Such an LVA would

examine the potential for some development away from the heritage designations in the

north of the site.

3.5 The site promoters produced an intervisibility study, a summary of the findings of which can

be found at appendix 3.

Question 4: Should the policy recognise that the site lies within the ZoI for

recreational impacts for Hatfield Forest SSSI?

4.1 The Hatfield SSSI 14.6km proposed recreational ZoI covers a large part of Uttlesford District

Council and consequently the potential appropriate mitigation measures will be applied to

the sites falling within the zone. There is further work to be undertaken to identify

appropriate mitigation measures for sites within the ZoI. The measures may be different

depending on the level of green infrastructure being provided on news sites.

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4.2 Following a Strategic letter (ED9) from Natural England and evidence from the National Trust

looking at impacts on the forest (ED9A), the Council is working with Natural England on the

production of a Statement of Common Ground to agree appropriate modifications to policy

to recognise that Easton Park lies within the ZoI for Hatfield Forest.

Question 5: Will the working quarry on the site affect the rate of delivery of

development? Are there any other likely impacts?

5.1 Landsec, the promoter of the Garden Community, has prepared illustrative phasing plans

(see the Easton Park New Settlement Prospectus (September 2017) (1901.14 PRD)) to take

account of the extent of the consented mineral extraction and potential western extension

of the operational quarry. These plans are set out section 5 and 6. Master Plan and phasing

proposals will form part of the Strategic Growth Development Plan Document.

5.2 Landsec propose to sign a Statement of Common Ground with the Minerals and Waste

Planning Authority at Essex County Council who do not object to Easton Park Garden

Community, subject to no sterilisation of viable mineral resource and no adverse impact

upon the effective working of the permitted mineral site and waste operations at Highwood

Quarry, and no adverse impact upon the effective working of the potential western

extension to Highwood Quarry.

5.3 The current mineral and waste permission anticipates completion by March 2026. A further

western extension to the quarry would prevent sterilisation of a viable mineral resource, but

would require planning permission. The mineral and waste development would continue

during the first and second phases of development of the garden community, which would

be likely to be in the north-west quadrant of the site with a 2.5 kilometre access road being

provided from the A120 junction. The District Council expects that the delivery rates

proposed will be achieved with these arrangements in line with the answers given to

Question 1 of Matter 8. Through phasing of the Garden Community and with provision of

mitigation measures by Landsec, which will be incorporated into the development, the

Garden Community could be developed such that there is no adverse impact upon the

effective working of the mineral and waste site and no sterilisation of viable mineral

resource and no adverse environmental impact upon residents of the Garden Community.

Question 6: Should the Plan identify specific allocation / areas within the policy

area for employment use?

6.1 The Council considers that the question in matter 8 relating to employment16 can effectively

be addressed with a single response.

6.2 The Council agrees that the plan should identify specific allocation / areas within the policy

for employment uses as a result of the NEA007 (2000.9 OED) Letter from Planning Inspector

Roger Clews which suggested to the North Essex Authorities (NEA) that states in IED011

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Easton Park question 6, North Uttlesford question 3 and West of Braintree question 5

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Point 99 that “The lack of any quantitative employment land or floorspace requirements for

the GCs undermines the strong positive score given to its economic benefits.”.

6.3 Following the NEA Inspector’s letter of 8 June (2000.1 OED) UDC commissioned Hardisty

Jones Associates to produce a report entitled. “Ensuring Robust Employment Evidence for

the Uttlesford Local Plan” (600.1 EMP). The report provides a critical review of the

Regulation 19 Local Plan and other relevant documentation to identify any additional work

required to ensure a sound evidence base with regard to employment and to provide an

indicative forecast of the amount of employment land to be included within the three

Garden Communities in the plan period to 2033 and beyond.

6.4 At the time of publication of this report the Council did not consider it necessary to include

indicative figures for employment floorspace for the Garden Communities in the plan as

there was further work to undertake to refine these figures. However on reflection, the

Council does consider its inclusion appropriate, so long as they are clearly labelled as

indicative and work on the DPD is able to further refine them.

6.5 The appendix sets out the indicative employment land provision for each of the three garden

communities, and proposed modifications are included in Appendix 4. The modification for

Easton Park is Main Mod reference: MM/03/15.

Question 7: Does the Policy refer to the most up to date Sports Strategy?

7.1 Policy SP6 criterion 4 states that the new Garden Community at Easton Park will “provide

….sports facilities ……in line with standards established in the Local Plan …..”

7.2 Policy INF2 refers to the “most up to date sports strategy”.

7.3 Policy SP6 is therefore not clear that it refers to the most up to date sports strategy.

7.4 It is therefore recommended that a major modification is made to Policy SP6 as set out in

IC18 25.2.19 modification MM/03/07.

Question 8: How have any impacts from flight paths to and from Stansted Airport

on the Easton Park proposed Garden Community been considered?

The Council considers that this issue can effectively be addressed for SP6, SP7 and SP8 with a

single response

8.1 The impacts have been considered using current and emerging government policy and data

prepared by the Environmental Research and Consultancy Department (ERCD) of the CAA.

In addition, Manchester Airports Group (MAG) published a suite of noise contours in its

environmental statement for its planning application to expand Stansted Airport to 43mppa.

These contours are based on ERCD modelling and data, but use MAG’s licenced OS map

base.

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8.2 In the Aviation Policy Framework the Government explains in paragraph 3.21 that local

planning policies and decisions should ensure that new development is appropriate for its

location and the effects of pollution – including noise – on health, the natural environment

or general amenity are taken into account. However, this does not rule out noise-sensitive

development in locations that experience aircraft noise. In the Aviation 2050 Green Paper

paragraph 3.116 states that, given the Government’s priority to provide new homes, it is

unrealistic to expect that new homes will not be built in areas affected by aircraft noise to

some extent

8.3 Every year, ERCD generates noise exposure contours for Stansted Airport, the latest being

ERCD Report 1803 for 2017 The 2018 report is expected shortly. Paragraphs 1.4 and 1.5 set

out the context for the day-time LAeq 16-hour and night-time 8-hour contours which are

published from Figure 12 onwards. The contours display the linear nature of aircraft noise

when based on the actual pattern of arrivals and departures, and none of the garden

communities lie within the contours. The suite of contours published by MAG in its

Environmental Statement are included in the link below: Stansted Airport Application –

environmental statement volume 3 appendix 7.3 noise contours These contours include

assessments for 2028 with the airport operating at 43mppa. These contours do not show

any appreciable widening south-eastwards towards Easton Park Garden Community which

would be located closest to the airport.

8.4 In the APF, again in paragraph 3.21, the Government acknowledges that people have

differing tolerances to aircraft noise and that those living further from airports may consider

that they are disturbed by, for instance, new flightpaths or by increased use of existing

flightpaths where there may be low background noise. On its website, MAG has published

four plans showing flight track data in 2018 for an average summer 24-hour day:

Departing on Easterly Noise Preferential Routes

Departing on Westerly Noise Preferential Routes

Arriving towards the North East

Arriving towards the North West

In summary, the plans show the following;

Easton Park Garden Community – Aircraft will skirt the eastern side on Runway 04 Detling

departures, but these are few in number as following an earlier airspace change, most 04

southbound departures now head out east using Clacton.

North Uttlesford Garden Community – Will experience some higher level overflying from

aircraft on both Runway 04 and 22 arrivals, but this is quite general across the north and

west of Uttlesford.

West of Braintree Garden Community – Aircraft will pass over about the southern third on

Runway 04 Clacton departures, but the more frequently used 22 Clacton departure route

will clear the settlement completely to the south. There is some overflying from 04 arrivals,

but this is at higher level and is quite general across the area between Great Dunmow and

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Braintree

8.5 UK airspace is currently undergoing comprehensive modernisation, moving away from

ground-based navigation and extensive air traffic control intervention to a system based on

satellite navigation with less intervention. The main purposes are to ensure that, in the

future, airspace is not a constraint on airport development, to reduce the likelihood of

delays and to reduce or eliminate low-level stacking. Opportunities will exist to manage

overflying of communities principally by the use of more precise tracking, and the use where

appropriate of multiple paths and respite periods from aircraft noise. The timescale for

implementing airspace modernisation in the south of the UK is 2024.

8.6 It is not yet known what the effect of this modernisation process will be on departure and

arrival paths from Stansted Airport. The airport operator will be responsible for sponsoring

applications for airspace change from 0-7,000ft, and NATS will have the same responsibility

for changes between 7,000-31,500ft. All applications will be submitted to the CAA for

determination under its 7-stage airspace change process, which includes public consultation.

Current information from NATS is that consultation should be in the latter part of 2020.

8.7 In determining airspace change applications, the Government sets out altitude-based

priorities which should be taken into account when considering the potential environmental

impact of airspace changes. These priorities are set out in paragraphs 3.2 and 3.3 of the

DfT’s Air Navigation Guidance 2017, here. Below 7,000ft, the environmental priority is to

minimise the impact of aviation noise, whereas above 7,000ft the priority is reducing CO2

emissions.

SP7 North Uttlesford Garden Community

Question 1: What evidence is there to demonstrate that the proposed North

Uttlesford Garden Community is capable of delivering 5,000 homes (1,925 in the

Plan Period)?

9.1 The latest Land Budget information provided by the promoter is included in Appendix 5. The

Land Budget is based on the illustrative masterplan for NUGC and demonstrates that there is

sufficient land to provide flexibility in the masterplan, with developable land taking up circa

42% (approx.192 hectares including employment and community facilities etc) of the whole

site area. A further 245 hectares (54% of the whole site) is available to accommodate the

appropriate levels of green infrastructure, retained agricultural land & outdoor recreation.

9.2 This plan is for the purpose of showing the flexibility of proposed developable land vs. the

remaining open green space. This plan doesn’t represent the proposed gross to net split

(circa 50:50), which would be part of the final planning application.

9.3 The Infrastructure Delivery Plan sets out the expected breakdown of green infrastructure for

NUGC including natural/semi-natural greenspace, amenity green space, play areas and

sports pitches etc. The remaining undeveloped green land not used for the required green

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infrastructure would be retained as agricultural land, which would not be included within

the planning application boundary.

9.4 The apportionment of 1,925 new homes at North Uttlesford within the plan period reflects

the Council’s analysis of likely build out rates for a garden community given the proposed

Development Plan Document timetable and expert advice such as the Lichfields Report Start

to Finish. These considerations are more fully rehearsed in the answers to Easton Park

Matter 8 Question 1 and are equally applicable to North Uttlesford.

9.5 Paragraph 3.101 in the Regulation 19 Local Plan describes the requirement for developer

funded highway improvements in the A505 corridor to provide additional capacity to

accommodate new development at North Uttlesford. These improvements, estimated at an

indicative cost of between £6.5m to £11m, are described in the Transport Study; South

Cambridgeshire Junction Assessments reference 1500.4 TRA (especially para 9.2.13) to

support about 3,300 new homes at North Uttlesford.

9.6 Additional transport improvements will be required in the A505 corridor to accommodate

the further housing provision at North Uttlesford after 2033 as well as the long term needs

of this successful economic growth corridor. Cambridgeshire and Peterborough Combined

Authority has authorised a comprehensive Multi-Modal Transport Study of the A505 to

identify longer term improvements that are required. This Study is due to be commenced

shortly.

Question 2: The Heritage Impact Assessment says that this site is situated within a

sensitive landscape with significant highly sensitive areas and contains extensive

heritage assets. Has this been factored into the calculation of the likely

developable area of the site and the provision of infrastructure and services?

10.1 It should be noted that the extent of the proposal i.e. 5,000 homes on a site of 469 ha has

from its inception allowed for extensive open areas to take account of heritage impacts. The

Heritage Impact Assessment Final January 2019 (1001.2 HEN) includes a development

concept criteria plan NUGC-08 for NUGC to assist the delivery of the proposed Garden

Community. The criteria plan is based on an assessment of sensitivities of relevant heritage

assets and settings including the on-site Scheduled Monument, listed Park Farm Farmhouse

and undesignated potentially surviving deer park boundaries. The criteria plan is based on a

redline assessment without a masterplan as a worse-case scenario of sensitivities. The HIA

considers initial mitigation to assist each site to meet its identified development potential

subject to these being pursued at a more detailed level of DPD and planning application.

10.2 The land budget in the NUGC prospectus (1902.24 PRD) shows 190ha for developable land

compared to 250ha for the area of least harm from the HIA NUGC concept plan indicating

that sensitive areas will not be encroached upon. It is likely that a proportion of open space

will also be located within the area of built development, so the ‘land take’ within the area

of built development will be more than 190 ha, however open space is unlikely to have

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significant impacts on heritage assets and can be used to build in appropriate mitigation.

NUGC has sufficient land available to take account of both sensitive and less sensitive assets

with open areas and mitigation as appropriate.

Question 3: Should the Plan identify specific allocation / areas within the policy

area for employment use?

11.1 The Council considers that questions 3, 4 and 6 can effectively be addressed with a single

response. Please refer to the response for SP6, Question 3. The modification to the plan is

referenced MM/03/16

Question 4: Does the Policy refer to the most up to date Sports Strategy?

12.1 Policy SP7 criterion 4 states that the new Garden Community at Easton Park will “provide

….sports facilities ……in line with standards established in the Local Plan …..”

12.2 Policy INF2 refers to the “most up to date sports strategy”.

12.3 Policy SP7 is therefore not clear that it refers to the most up to date sports strategy.

12.4 It is therefore recommended that a major modification is made to Policy SP7 as set out in

IC18 25.2.19 modification MM/03/08.

Question 5: Do local railway stations have the capacity to cope with the increased

passenger demand likely to be created by this development?

13.1 Whittlesford Parkway Station is an important local station 6 kilometres from North

Uttlesford. The number of annual passengers using the station based on the Office of Rail

Regulation (ORR) indicates that passenger numbers are over capacity. The station is

currently subject to a Masterplanning exercise to address the needs of growth in the wider

area which will include demand arising from NUGC.

13.2 The details of the proposed improvement are set out in a report commissioned by Greater

Cambridge Partnership (December 2018)

https://www.greatercambridge.org.uk/download/7153/Whittlesford%20Parkway%20Stage

%20Two%20Report%20-%20Final.pdf . Short and medium term improvements (to be

implemented before 2024 subject to funding) that will be of benefit to NUGC include

improvements to the sustainable mode interchange at Whittlesford Parkway, improving

drop off and pick up by bus, increased cycle parking capacity and public realm

enhancements, linking in with NUGCs own sustainable mode strategies and reducing the

need to travel by car to the station. The improvements will significantly improve bus

accessibility to the station which will allow more effective feeder services to operate. It also

provides improvements to the station capacity through new lifts, helping accommodate

growth in use of the station over time.

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13.3 Based on ORR figures, Great Chesterford Station is operating significantly under capacity

relative to annual patronage numbers so there is existing reserve capacity. However, whilst

2 kilometres from NUGC, Great Chesterford is not the focus of the NUGC rail strategy and is

likely to play a more minor role as it offers a slower stopping service that is less desirable for

commuting when constraints are greatest.

13.4 The transport strategy for NUGC includes a commitment to provide appropriate financial

support towards the delivery of measures identified within the Whittlesford Parkway

Station Masterplan and to Greater Anglia to improve access at Great Chesterford Station.

13.5 The question of station capacity relates to peak hour travel related to journeys to work. The

location of the Garden Community relative to nearby employment sites [principally the

three Life Science sites at Chesterford Research Park (located within 3 kilometres), the

Genome Campus (located within 2 kilometres) and Granta Park (located within 5

kilometres) which between them currently support over 4,000 jobs] provides the

opportunity to reduce the need for commuters to travel to work further afield by rail as

there is significant job growth planned within relatively close proximity for access by other

sustainable modes of transport.

Question 6: Has the proposed Genome expansion within South Cambridgeshire

considered the cumulative implications of the new community North of

Uttlesford?

14.1 No. The proposals in the current planning application that is being promoted by the

Wellcome Trust do not form part of the adopted South Cambridgeshire Local Plan 2018 and

have yet to be considered by the Planning Committee of the District Council.

Question 7: Has an assessment been made of the flood risk and if so what were the

findings? Is flooding likely to affect the development of the site and if so how?

15.1 UDC Level 1 Strategic Flood Risk Assessment (SFRA) of Garden Communities 2016 for the 14

Search Areas (700.1 ENV) including the 3 preferred GCs. Concludes in this relatively rural

district, it should be possible to keep the majority of major developments within Flood Zone

1 and away from other sources of flood risk. The Areas of Search are very large, and so none

of them can be ruled out on flood risk grounds; however, all of them have some local flood

risk identified. A detailed Water Cycle Study was advised above flood work acceptable

subject to a sensitivity test of modelled flows from theoretical new on-site WRCs. These

identified no flooding issues.

15.2 NUGC flood risk surface water strategy (1902.10 PRD) found that there is limited fluvial

flooding within the site and any localised flooding is likely to be restricted to the

watercourse corridors. Surface water flooding may also be an issue along the watercourse

corridors. No flooding from any other sources is likely to affect the site. Appropriate surface

14

water management measures within a SuDS based strategy will be required to support

development of the site and, given the sloping nature of the site. Potentially feasible for the

development of NUGC to provide betterment downstream, by providing flood storage on

site benefiting the recreation ground and properties on Walden Road which are currently at

risk of flooding, even with the existing flood embankments alongside the drain.

Question 8: How have any impacts from flight paths to and from Stansted Airport

on the North Uttlesford proposed Garden Community been considered?

16.1 The Council considers that this issue can effectively be addressed for SP6, SP7 and SP8 with a

single response, see Easton Park Question 8.

SP8 West of Braintree Garden Community

Question 1 What evidence is there to demonstrate that the proposed West of

Braintree Garden Community is capable of delivering 10,500 -13,500 homes overall

and up to [3,500] in Uttlesford (970 in the Plan period)

17.1 In terms of the whole new community, a range of capacities on the Braintree part of the

settlement were explored in a Concept Framework (AECOM, May 2017) which includes a

Land Budget in Section 3.3. North Essex Garden Communities Company, the promoter of

the Garden Community, has prepared an updated illustrative Land Budget of the whole

settlement and this document is due to be published in July 2019.

17.2 The Infrastructure Delivery Plan sets out the expected breakdown of green infrastructure for

WoBGC including natural and semi-natural greenspace, amenity green space, play areas and

sports pitches etc.

17.3 The apportionment of 970 homes17 at West of Braintree Garden Community within the plan

period reflects the Council’s analysis of likely build out rates for a garden community given

the proposed Development Plan Document timetable and expert advice such as the

Lichfields Report Start to Finish. The anticipated start date (2025/6) reflects the Council’s

view that the joint arrangements with Braintree District Council would take longer to

commence implementation than the other two Garden Communities in the Local Plan. The

need to address further issues through the North Essex Authorities Local Plan process

support this more cautious approach to the delivery timetable. The proposed apportionment

represents half the annual build out rates for North Uttlesford and Easton Park and this

reflects the fact that the Garden Community straddles the district boundary and will be

developed as a single settlement.

17

UDC are working on a Statement of Common Ground with BDC, which may amend the number of homes within the plan period, this will be available in time for the hearings

15

Question 2: What arrangements have been made for joint working between

Braintree and Uttlesford District Councils to deliver the proposed garden

community?

18.1 Braintree and Uttlesford Districts have been co-operating closely in preparing the proposals

for the Garden Community and the section entitled ‘Duty to Co-operate with Braintree

District Council’ in the Examination Library evidences these arrangements. One key element

of this work has been the preparation of the Issues and Options Development Plan

Document.

18.2 In addition Uttlesford District Council takes an active role in the joint arrangements that

have been established by the North Essex Authorities (which includes Braintree) and the

North Essex Garden Communities Company (NEGC) to oversee the planning and delivery of

the Garden Community. These arrangements are shown in Appendix 6 (NEGC structure). In

particular Uttlesford officers routinely receive papers and take part in meetings of the NEGC

Economic & Engagement Meeting; and the NEGC Joint Statutory Planning and Transport

meetings.

18.3 A decision has yet to be made about the delivery model for the West of Braintree Garden

Community with a locally led development corporation being one of the options that is

actively being considered. Uttlesford District Council will be party to this decision to ensure

that the principles and policies set out in the Local Plan are secured.

Question 3: The Heritage Impact Assessment says this site is situated within an

area of moderate to high sensitivity. Has this been factored into the calculation of

the likely developable area of the site and the provision of infrastructure and

services?

19.1 The Heritage Impact Assessment Final January 2019 1001.2 includes development concept

criteria plan AFGCWB-06 for West of Braintree GC to assist the delivery of the proposed

Garden Community. The criteria plan is based on an assessment of sensitivities of relevant

heritage assets and settings including the Great Saling Registered Park & Garden and

Conservation Area (all in BDC). The criteria plan is based on a redline assessment without a

masterplan as a worse-case scenario of sensitivities. The HIA considers initial mitigation to

assist each site in meeting its identified development potential subject to these being

pursued at a more detailed level. Both parts of the site within Uttlesford have areas of low

sensitivity, as does a large proportion of the site in Braintree. The West of Braintree

Development Concept Criteria Map identifies a potential extent of least harm (73.55 ha in

UDC and 298.65 ha in BDC); a potential extent of medium sensitivity (126.5 ha in UDC and

474.34 ha in BDC, including the area of least harm).

16

19.2 The land budget included in the ANC Masterplan 2018 (1903.19 PRD) and Boxted Wood Land

Use Plan (1903.7 PRD) and indicates 376ha of built development18. This is only slightly above

the area of least harm of 372ha and much less than the 474.74ha area of medium/least

sensitivity. It is likely that a proportion of open space will also be located within the area of

built development, so the ‘land take’ within the area of built development will be more than

376ha, however open space is unlikely to have significant impacts on heritage assets and can

be used to build in appropriate mitigation. It is also worth noting that the Heritage Impact

Assessment is based on a ‘red line’ assessment of the site which assumes development

across the whole site and does not take into account mitigation measures or a masterplan.

With appropriate mitigation there is likely to be potential for an appropriate amount of well-

designed built development within the areas identified as medium sensitivity. This would not

encroach on any of the area of high sensitivity.

Question 4: Should the plan identify specific allocation / areas within the policy for

employment use?

20.1 The Council considers that questions 3, 4 and 6 can effectively be addressed with a single

response. Please refer to the response for SP6, Question 3. The modification to SP8 is

referenced MM/03/17

Question 5: Does the policy refer to the most up to date sports strategy?

21.1 Policy SP8 criterion 4 states that the new Garden Community at Easton Park will “provide

….sports facilities……in line with standards established in the Local Plan…..”

21.2 Policy INF2 refers to the “most up to date sports strategy”.

21.3 Policy SP6 is therefore not clear that it refers to the most up to date sports strategy.

21.4 It is therefore recommended that a major modification is made to Policy SP8 as set out in

IC18 25.2.19 modification MM/03/09.

Question 6: Will this development result in the loss of a pilot training school and if

so will a replacement site need to be found in order for this part of the site to be

redeveloped.

22.1 The West of Braintree site includes Andrewsfield Airfield which operates a pilot training

school from the airfield. The West of Braintree Concept Framework explores three spatial

options19 on the Braintree side of the site, two of which have development adjacent to the

Airfield in Uttlesford and one of which does not. Option 3, which is identified as the

18

245.03 + 101.82 + 4.45 + 7.68 + 17.78 = 376ha 19

See page 67

17

preferred option20 is the option which does not have development within or adjacent to the

Airfield.

22.2 The final development boundary for the site will be determined through the DPD process.

The West of Braintree Issues and Options Report started to explore these issues21 and

further iterations of this report will develop this thinking further.

22.3 The Aviation Strategy 2050: The future of UK aviation recognises the incentives there are for

aerodrome owners to sell land for housing22, and notes that the NPPF 2018 requires

planners to “…recognise the importance of maintaining a national network of General

Aviation airfields…”23. The NPPF 2012 includes no such requirement. The draft strategy also

discusses recommendations to government, for example setting up a General Aviation

Strategic Network (GASN) to identify strategically important aerodromes24. The report does

no conclude on the need for a GASN.

22.4 If the final development boundary includes Andrewsfield Airfield then the pilot training

school will be lost. Policy SP8 does not include a requirement for the pilot training school to

be replaced if it is lost. The Council considers that while the government is acknowledging

the loss of aerodromes could be a potential issue, in advance of the government identifying

a solution to this issue and given this local plan is being examined under the transitional

arrangements in the NPPF, there is no need for a policy requirement to replace the pilot

training school if lost.

Question 7: How have any impacts from flight paths to and from Stansted Airport

on the West of Braintree proposed Garden Community been considered?

23.1 The Council considers that this issue can effectively be addressed for SP 6, SP 7 and SP 8 with

a single response, see Easton Park Question 8.

20

See page 26 21

See page 42 22

Paragraph 7.16, page 152 23

Paragraph 7.17, page 153 24

Paragraphs 7.23-7.25, pages 154-155

18

Appendix 1: Letter from Barton Willmore in relation to delivery rates on

Easton Park

19

20

Appendix 2: Timetable for DPD production

Milestone Proposed

Achievem

ent Date

Comments

Commence DPD Preparation June 2019 By then QCP

SOCG and

PPA signed

Review Vision/Prospectus Documentation and

Commission Strategic Masterplanning

work

June 2019

Consult Community Forum July 2019

Report Strategic Masterplanning work to GC

Delivery Board

November 2019

Formal consideration by UDC PPWG, Cabinet

and Council

December 2020

Commence Regulation 18 Plan Consultation January 2020

Complete Regulation 18 Consultation February 2020

Consult Community Forum March 2020

Report Consultation Feedback and any

proposed changes to GC Delivery Board

April 2020

Formal consideration by UDC PPWG, Cabinet

and Council

April 2020 Expected Adoption

Date of Local

Plan

Commence Work on Outline Planning

Applications

April 2020

Commence Regulation 19 Plan Consultation June 2020

Complete Regulation 19 Consultation July 2020

Consult Community Forum September 2020

Report Consultation Feedback and any

proposed changes to GC Delivery Board

September 2020

Submission of DPD to PINS October 2020

21

Examination January 2021

Inspectors’ Report May 2021

Consult Community Forum July 2021

Report Inspector’s Report and any proposed

mods to GC Delivery Board

July 2021

Consultation on modifications July-September

2021

Formal consideration by UDC PPWG, Cabinet

and Council and other formal processes

September 2021

Adoption of DPD September 2021

Formal Decision on Outline Application December 2021 S106 Heads of

Terms Agreed

First Phase Reserved Matters March 2022

22

Appendix 3: Easton Park Promotor’s intervisibility study

“Strategic landscape and Visual appraisal 2017” (1901.9 PRD) including defining a Zone of

Theoretical Visibility for the proposal. This was modelled on the existing landform and

screening effect of existing vegetation assuming 3 story development. The work finds most

of the Zone is sparsely populated and devoid of settlement, so receptors to experience views

very limited because of containment provided by topography and woodland. In particular;

• Few properties close to the site

• Great Dunmow 1250m from site, well screened and buffer within site

• Little Easton orientated away from site limiting views

• Little Canfield 1300m from site well screened

In summary the ZTV is relatively contained given the scale of development proposed with

the majority of surrounding major settlements such as Gt Dunmow and Takeley unaffected.

The actual number of receptors to experience views in the ZTV is also limited.

23

Appendix 4: Proposed modifications to reflect employment land

requirements

Question 6

Indicative Employment Land in the Garden Community Deliverable in the Plan Period

Garden Community Employment

Land (Ha)

Office / Industrial

Easton Park Garden

Community

1-2ha Office

3-5ha Industrial

North Uttlesford Garden

Community

1-2ha Office

3-5ha Industrial

West of Braintree Garden

Community (Uttlesford

Element Only)

1ha Office

2-3ha Industrial

Total Office 3-5ha Office

Total Industrial 8-13ha Industrial

Total Office and Industrial

Garden Community

Employment Land

11-18ha Combined