Update
Following our Open Letter to Uttlesford District Councillors there has been a rethink of the Local Plan process. The meeting set for tomorrow to finalise the selection of New Town sites has been cancelled.
You can read Uttlesford’s news release here.
There remains much work to be done.
Original news item
Over recent weeks we have been working closely with fellow Parish Councils from Stebbing, Great Saling, Rayne and Shalford to produce a letter displaying our united opposition to the Local Plan proposal to build a New Town of 13,000 houses on land around Andrewsfield and Boxted Wood.
Uttlesford District Council’s Planning Policy Working Group will be making a decision on their recommendation for the location for the New Town/s at a public meeting to be held on 25th November. It will then go to full council for agreement.
We have therefore sent all Councillors an open letter, which follows:
Open letter to all members of UDC
Dear Councillors
We are writing to you representing the Parish Councils of Felsted, Stebbing, Great Saling, Rayne and Shalford, regarding the UDC Local Plan new settlement selection process.
We believe that the area identified as ‘Andrewsfield and Boxted Wood, West of Braintree’ offers a high risk option for selection as the location of a new settlement.
Our concerns can be summarised:
Working with Braintree District Council (BDC)
The Andrewsfield and Boxted Wood sites’ ability to contribute towards UDC’s 5 year housing supply requirement is completely reliant upon the selection and timely infrastructure delivery of BDC’s ‘West of Braintree’ site, as identified in their draft Local Plan.
BDC are reporting that, predominantly due to infrastructure requirements, their development could only support 2500 houses, from an eventual total of 9000, to 2033. It must therefore be a high risk strategy to assume that UDC will obtain approval to add further homes in the same period onto the side of this BDC development.
We understand that Marks Tey is a priority for BDC and that they are also considering a third option at Monks Wood.
Andrewsfield/Boxted Wood should only therefore be considered by UDC once BDC has received approval for its Local Plan and then only if their site ‘West of Braintree’ is successfully taken forward to development. For UDC to take Andrewsfield/Boxted Wood forward in advance of any development by BDC is a high risk strategy.
Both Great Chesterford and Easton Park are within UDC boundaries and so have a zero risk in respect to dependence on decisions being made by neighbouring Districts.
Development potential into future Local Plans
With a total capacity of c4000 houses in UDC, the Andrewsfield and Boxted Wood sites offer a low potential for housing supply into future plan periods and a total which is marginal for a sustainable new settlement.
Proposed housing densities should also be challenged, since the land area is small compared to that being considered by BDC, but is being offered at half the number of houses as on the BDC land, suggesting a much higher housing density. These densities appear much higher than TCPA policy recommendations and overall this would deem it unsustainable.
Great Chesterford has a stated total capacity of 5,000 houses and Easton Park 10,000. Were one, or a combination of both these sites, taken forward, then they offer greater housing volumes into future plan periods.
Community engagement and social cohesion
A key requirement of TCPA Garden City principles is the establishment of community engagement. It is clear from the representations made to Parish Councils, and the existence of the SERCLE community protest group, that the development of Andrewsfield/Boxted Wood is seen by the community as wrong and will be resisted at every step.
There are many examples of poor social cohesion within new developments, exacerbated where the development does not offer younger residents easy access to established, local, social facilities and networks.
Both Andrewsfield and Boxted Wood sites are remote from existing towns and the established social facilities they offer. Easton Park however offers easy access to Dunmow and its existing facilities.
Mineral extraction
In the BDC consultation plans, the main A120 access for the new settlement is across an area designated for mineral extraction. Given the mineral extraction period of c15 years, this suggests that either the development will go ahead without this A120 access, or it must be delayed beyond the mineral extraction period. In either scenario, the development is not viable for this plan period.
In addition, and in accordance with NPPF sec13, 143, land potentially suitable for mineral extraction must be protected from development. We understand that investigations have detected further reserves across the area identified for housing. This leaves significant areas across the remainder of the site at high risk as being rejected for housing in favour of mineral extraction.
Noise pollution
The site is located in an area overflown by Stansted airport runway 4 Clacton route. The reference documents used to show numbers of flights are old and do not show the new levels, which have more than doubled following the change in flightpath usage introduced in Feb 2016. Noise complaints to Stansted have increased 10 fold when compared to the same period last year. This does not bode well for the prospect of quiet living for potential residents and is against a key principle of ‘TCPA garden city’ development, being to deliver ‘healthy communities’.
Road and public transport access
The junction requiring investment to deliver improved road access to the A120 for the Andrewsfield/Boxted Wood sites is on land within Braintree District, and is being considered within the draft BDC Local Plan new settlement area ‘West of Braintree’.
If BDC does not go ahead with their ‘West of Braintree’ settlement then it would be unsafe to simply assume that ECC Highways would consider this road improvement cost effective and deliverable for UDC alone.
This leaves delivery of this critical element of UDC’s Andrewsfield/Boxted Wood proposal at high risk and outside of UDC’s control.
Given that transport plans for proposed new developments were a key reason for the 2014 plan withdrawal, it must therefore be considered a severe risk that this uncertainty would cause the new plan to fail again.
Once on the A120, existing exit routes to the south, via the A131 towards Chelmsford, for rail links to London, are already overloaded and cannot take additional road traffic. This is without any of the 2000 additional houses proposed for Great Leighs within the Chelmsford Local Plan. Access to the Braintree rail station is also severely hampered by traffic and offers a very poor commuter service to London (only 1 train per hour).
There are no plans to improve any other roads in the development area. This will overload small village roads and protected lanes. Nearby villages will become rat runs and will be in need of clear proposals to protect their environment, before the Andrewsfield/Boxted Wood option can be taken forward.
This fails against a key aspect of the TCPA Garden City principles that, ‘New Garden Cities should be located only where there are existing rapid public transport links to major cities, or where real plans are already in place for its provision.’
The Chesterford Science Park is a major area of growth and employment in the science and technology field, with quotes of ’14 jobs for each applicant’. Andrewsfield/Boxted Wood has no access to this area, nor does it offer effective access to the A120 for Stansted airport, the other major employment growth hub in the region.
The Great Chesterford and Great Easton sites meanwhile offer existing access options to main transport routes for these employment hot spots. They are both much better located to address the employment opportunities.
We also understand that there are plans for a public transport link from the Easton Park area to Stansted, which would satisfy the requirements of TCPA principles.
Great Chesterford also satisfies UDC’s adopted principle of dispersal of housing across the District, rather than focusing it all on the A120 corridor. Given that dispersal is the adopted principle and is being applied for smaller developments, it must also be seen to be applied to the large settlements.
The north of Uttlesford must not gain the appearance of being unreasonably and unjustifiably protected from development, when it so clearly satisfies housing demand for the London/Stansted/Cambridge corridor.
Utilities
At a recent presentation to Felsted Parish, Affinity Water, who cover the Andrewsfield area, reported that they had no future plans to increase water supply, and in fact expected the water available to them to reduce by 2040. They forecast a shortfall of 170 million litres of water a day by 2040.
Stebbing is considered an arid zone. Felsted is already suffering from low water pressure, which resulted in the loss of an important school building to fire in 2012. Ray Skinner, Essex County Fire and Rescue said: “We have been hampered throughout this incident by a poor water supply.”
Building a new settlement to the north of Felsted, alongside Stebbing and using the same water source, must be considered a high risk to fire safety and must be the subject of a full safety review before any decisions are made that assume this critically low pressure supply can be spread to even more houses in the area.
Conservation
As per NPPF sec 12, point 126, Local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment.
Boxted Wood must be protected as an ancient woodland. Protection of its delicate ecology also requires protection of the land beyond its direct boundaries and against light pollution. With the area identified as one of the few in Essex where skies are dark enough to view the stars, light pollution will harm wildlife such as bats and owls. Without a full study of the potential impact on these species, this must be considered a high risk to its likely approval for development.
UDC would also be required to address the Amber/Red rated risks highlighted by AECOM in their report to BDC for the development of Andrewsfield with respect to heritage.
The area to the south of the proposed development also has a high flood risk. A full study must be carried out regarding the additional flood risk to this area from ‘paving over’ Andrewsfield, before it can be taken forward.
The site would also be required to ensure that contaminated run-off and flood water did not affect the River Ter SSSI site.
The proposed development area also includes a high proportion of Grade 2 and 3 agricultural land. Section 11 of the National Planning Policy Framework must be adhered to. Specifically section 112, ‘Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.’
This was demonstrated through planning application UTT/16/0287/OP Land to the South of Braintree Road, Felsted, outline application for up to 55 dwellings. Permission was refused on 28 July 2016. Reasons stated included: “…a disproportional loss of this best and most versatile agricultural land contrary to policy ENV5 of the Uttlesford District Local Plan as Adopted (2005) and the National Planning Policy Framework.”
There are however, brownfield sites available for consideration, including the MOD Wethersfield site, which is promoted as being available for 4850 houses in 2020, but for some reason is not included in the BDC Plan process and not recognised for its potential impact on UDC development proposals for Andrewsfield, or surrounding transport routes.
In summary, we again repeat that we believe there are as yet unquantified and unconsidered, significant risks associated with the selection of Andrewsfield and/or Boxted Wood as the location for a new settlement, this is not sustainable.
There appears to be an unrealistic over-reliance on the delivery of the infrastructure specified in BDC’s draft Plan for ‘West of Braintree’ to support UDC in delivering a development on Andrewsfield/Boxted Wood.
This becomes an even higher risk when considering that BDC has now added a third option for their new settlement location and will not make a decision until after UDC have made theirs.
We have also identified a number of areas where the Andrewsfield/Boxted Wood proposal fails completely against TCPA Garden City Principles.
The north of Uttlesford must not gain the appearance of being unreasonably and unjustifiably protected from development when it has clear demand.
We therefore believe it unsafe and a high risk to Plan rejection to take Andrewsfield and/or Boxted Wood forward into the preferred option process for the UDC Local Plan.
Yours faithfully
Diane Smith
Clerk to Felsted Parish Council
On behalf of:
Felsted Parish Council
Great Saling Parish Council
Rayne Parish Council
Shalford Parish Council
Stebbing Parish Council