BACKGROUND

Showing comments and forms 1 to 19 of 19

Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6582

Received: 14/08/2018

Respondent: Barker Parry Town Planning Ltd.

Representation:

we reiterate concerns that the evidence base, is largely significantly dated and in many instances pre-dates the National Planning Policy Framework (NPPF), such that the position established lacks any clarity or weight to enable a developer to reasonably establish the policy requirements prior to the submission of a planning application, whilst also not having regard to significant changes in the local environment as a result of subsequent planning permissions.

Full text:

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Support

Local Development Plan Pre-Submission Publication

Representation ID: 6603

Received: 14/08/2018

Respondent: East Herts District Council

Representation:

East Herts Council supports the Local Plan's intention to meet its objectively assessed housing needs, including the positive approach taken to reviewing the Green Belt to identify land for such development purposes. East Herts Council further supports Harlow Council's commitment to joint working to address the collective needs of the housing market area in terms of key infrastructure, employment and housing needs.

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6620

Received: 14/08/2018

Respondent: Forestry Commission (England)

Representation:

Thank you for consulting the Forestry Commission on the pre-submission publication. We do not have any comment on the soundness or legal compliance. We would like to draw your attention to the standing advice on Ancient Woodland https://www.gov.uk/guidance/ancient-woodlandand- veteran-trees-protection-surveys-licences should you need to assess any sites near to Ancient Woodland when delivering the plan.

Full text:

Thank you for consulting the Forestry Commission on the pre-submission publication. We do not
have any comment on the soundness or legal compliance. We would like to draw your attention
to the standing advice on Ancient Woodland https://www.gov.uk/guidance/ancient-woodlandand-
veteran-trees-protection-surveys-licences should you need to assess any sites near to
Ancient Woodland when delivering the plan.

Object

Local Development Plan Pre-Submission Publication

Representation ID: 6650

Received: 17/08/2018

Respondent: Harlow Alliance Party

Representation:

lack of consultation that has taken place with residents.
Back in the 1 990's Harlow Council produced a document called "Consultation, Guide to good practice" which set out how it would engage with residents. A copy of this is attached to this submission. lt is clear from what it has done in respect of the Local Plan has not adhered to its own commitment to consult. They way that residents have (or indeed have not) been involved in any form of consultation is very clear, simply from the fact that members of our party have spoken to hundreds of residents whilst out canvassing leading up to the recent local elections, hardly anyone has been aware of what has been proposed in respect of this plan. Harlow Council has almost exclusively consulted only with other statutory bodies, those with a vested interest in seeing Harlow expand and neighbouring Local Authorities. In doing so, it has failed to engage with the most important people of all, the residents of Harlow. We would make the following points:
The Council has primarily used its website during this entire process, but we know that many older people, those on low incomes and homeless households do not have access to a computer.
The most up-to-date information available shows that 21 % of Harlow's residents were not born in the UK and therefore a considerable number of residents may not have English as their first language. Harlow Council has failed to engage with such residents.
The Council publishes a document called Harlow Times four times a year which is delivered to every home in Harlow. This should have been used to tell residents what was going on, but Harlow Council chose not to do so.
Whilst Harlow Council engages with its tenants and leaseholders using various forums, it has none which includes residents. Harlow Council could and should have set up neighbourhood forums to specifically consult and inform on this plan.
Evidence of this lack of resident involvement can clearly be seen by the fact that supposed consultation earlier in this process only saw 136 submissions being made in response, something Harlow Council should have taken steps to be more inclusive at later stages in the process.
We enclose a petition, completed in less than 4 weeks signed by over 380 residents who object to the inclusion of 8 greenfield sites amongst the 21 sites in the Plan.

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6652

Received: 17/08/2018

Respondent: Harlow Alliance Party

Representation:

This is evidenced by the fact that residents have already been consulted about detailed plans for two of the sites (Lister House and St Andrews Meadow) when the Plan has not been agreed. In addition, running alongside this Local Plan process, is what seems a parallel process involving other sites, such as at Bushey Croft, where
Harlow Council has a Planning Application for homes on a playing field site, which is not included in the Local Plan.

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6712

Received: 20/08/2018

Respondent: Mr James Humphreys

Representation:

Firstly, can I say that the secretive approach to this has been incredibly alarming. When PHE plans were announced there was a full public consultation, and looking at other neighbouring councils, it seems they take a more open and consultative approach. This plan has seemingly been hidden from residents in the hope that nobody notices so that you can continue with the plans. While there is the opportunity to view the plans online and in libraries, it is hard to find and there has been no publication of these to people who actually work 9-5 and the publication period is Thursday 24 May 2018 to Friday 6 July 2018. I hope this is only a publication period and not a consultation period as this less than two weeks nowhere near long enough to invite consultation on something that hasn't even been made public and is hundreds of pages long including evidence base. It looks like it has been rushed and public comment is not actually welcome. At the very least this should be 30 days.

Full text:

Hi,
I would like to add comments to the Harlow Local Development Plan via the Forward
Planning Team please.
Firstly, can I say that the secretive approach to this has been incredibly alarming. When
PHE plans were announced there was a full public consultation, and looking at other
neighbouring councils, it seems they take a more open and consultative approach. This
plan has seemingly been hidden from residents in the hope that nobody notices so that
you can continue with the plans. While there is the opportunity to view the plans online
and in libraries, it is hard to find and there has been no publication of these to people
who actually work 9-5 and the publication period is Thursday 24 May 2018 to Friday 6
July 2018. I hope this is only a publication period and not a consultation period as this
less than two weeks nowhere near long enough to invite consultation on something that
hasn't even been made public and is hundreds of pages long including evidence base. It
looks like it has been rushed and public comment is not actually welcome. At the very
least this should be 30 days.
I believe these plans have serious flaws and should be paused immediately and public
consultation should be invited, rather than hoped nobody finds it. In addition, a lot of
the evidence based used is over 10 years old, which renders it either out of date or at
worst inaccurate, including infrastructure and health. Other more recent reports aren't
localised enough or provide the right information needed, such as wildlife and other
environmental factor reports seem to have been simply ignored. More worryingly, your
link to sign up to be kept informed about developments doesn't work despite numerous
attempts to create a log on, I have still not received a registration email so there doesn't
seem to be a way to be kept informed even if I am trying to be so.
I currently live in Greygoose Park (backing on to the playing fields and Katherines Way)
and I am very concerned about the council plans to build 69 homes on this land. While
the minor inconvenience of the losing a view and house value decline are
understandable, I do have additional concerns that I don't think have been taken into
account when the council looked at this area. It is also disappointing that a council that
prides Harlow on having green space and puts covenant control on residents and their
homes, is actually flying in the face of its own rules and planning to build on every last
bit of green land space. We bought our home three years ago so do have a fairly recent
environmental report which leads me to ask the following questions.
Flooding
With the brook running parallel to Katherines Way, there is a flood risk. While theflooding at the moment is low risk and is mainly confined to the allotments (as you may
be aware some are unusable due to the ground conditions and constant saturation),
additional housing on this land which may act as an area for water to be drained into will
put extreme pressure on this brook and leave the surrounding land liable to flooding as
there will be no run off areas for water to go except for into the brook. This will place
enormous pressure on a small stream that will flood repeatedly should this part of the
plan go ahead. This flood risk was mentioned in our environmental impact report when
buying our home. Your own flood impact report dated 2016 shows an existing flood risk
on this area (page 4), so what would happen should houses be built there? This
assessment has not been carried out in full.
Wildlife impact
There is a vast array of wildlife in the field next to Katherines Way including mice,
shrews, hedgehogs, owls, amphibians, foxes and most importantly bats. As you may be
aware bats are an incredibly protected species and any developments or changes to their
natural habitat require a licence from Natural England. With the removal of trees and
food sources for the bats, I feel that the plans to build housing in this area will severely
impact this native and protected species. Your evidence base is from 2010/11. That is
eight years old and it is not localised to specific parts of Harlow, meaning you have no
idea what is living in the areas that have been earmarked for development. This is quite
the assumption to make.
Road access
Currently, road access to Greygoose, Fir and Deer park is very limited and is off
Kingsmoor Road at three points. Should additional housing be added to this area, more
access points will need to be considered as the current roads are currently very narrow
and or congested at peak times. While not a legal requirement it is often advised that
large emergency vehicles should be able to pass through roads easily. At the current
council access point to this land (for maintenance and mowing) that is not something
that is achievable, with residents parking off the pavement and on the road. While
residents are perfectly within their rights to do so, it shows that the long term view of
putting extra housing in was not considered for this area and would not be able to cope
with additional traffic for residents, let alone the large lorries and equipment needed to
build additional houses. The road surfaces are not suitable nor are the streets wide for
large equipment needed to build new homes. Also, with Public Health England bringing
10,000 jobs to the GSK site, the pressure that will be put on the roads in that area will be
extreme already, let alone with the strain of building additional homes. Worryingly, there
is no link up to Epping council who will also see some of these problems given their
proximity to the area and roads that feed into Harlow, this may put Harlow council on a
collision course with another authority. What plans do the council have to either build
more roads, improve existing roads or improve public transport do deal with an extra
10,000 people in this small area?
Healthcare infrastructure
As you may be aware, healthcare in Harlow is under an enormous amount of strain.
While I support the expansion/redevelopment of PAH, the local GP services are in
complete disarray. For example, our GP surgery is Lister House Medical Centre. This
centre is vastly over-subscribed. I myself cannot get to see my own GP, they have six
week wait lists that are completely full. My only hope of seeing a GP is to be seen in a
private clinic, referred to by Lister House at Keats House which I, working in the industry
I do (Pharmaceutical Policy Director for Dementia and Vaccines), know exactly how much
that costs to do. It is grossly inefficient use of healthcare funds and a result of poor
healthcare resourcing and management. More worryingly, my young son was unable to
get any appointments (normal or emergency) and actually had appointments cancelled
without explanation by this surgery at a few weeks old. Despite moving to a new facility,
this GP surgery is dangerously over-subscribed (and will continue to be so if Osler House
closes down) as well as poorly run. Additional house building, not only on Katherines
Way, but at other sites, will force the local healthcare system into complete meltdown.
Additional to this problem, the boundary cut off for Barbara Castle Health Centre is
Katherines Way. Nothing beyond that boundary will get in there as they too are full,
leaving that further pressure solely to Lister House. I firmly believe that GP and
community health services are starting to fail badly in Harlow, and while there is
improvement in the hospital, local GP surgeries still have to deal with a challenging
patient population and deprivation in some parts of Harlow and the wards surrounding
mine (Staple tye etc...). My fear is that it could become a lot worse and turn areas into
healthcare slums as many will not be able to access a basic quality of healthcare.
Existing unoccupied housing
There is already unoccupied housing in Harlow, which is not being utilised. Will the
council prioritise filling these homes before building new ones? In addition, existing
unused offices and brownfield sites are being converted into homes, yet this is not
accounted for in the plan. Is this additional housing considered in an earlier plan or has
this been overlooked as part of the target for new homes?
Lastly green space
As you will be aware, green spaces have a strong link to happiness and healthcare
outcomes. This has been known since Victorian times and has been referenced many
times by government - http://researchbriefings.files.parliament.uk/documents/POST-PN-
0538/POST-PN-0538.pdf. Getting rid of Green space and actual green belt land is a
backwards step for Harlow and will add to the problems that currently exist with health
deprivation. Your own council planning eludes to protecting environmental assets, not
build on them. As a side point, the space in question beside Katerines Way is currently
poorly maintained and there has been a noticeable decline in the management in this
land. I'm currently having to fend off brambles, bind-weed and small trees starting to
grow into my garden from your land.
Green space and health -researchbriefings.files.parliament.uk
researchbriefings.files.parliament.uk
POSTnote 538 October 2016 Green Space and Health A range of bodies, including
Government agencies, have promoted the possible physical and mental health benefits
of access to green
So as you can see, I am not a resident who is just merely annoyed that these housing
plans will just impact the value of my home. I believe that these plans are ill thought out,
and will have a number of negative consequences for Harlow and in particular our area. I
therefore ask that you will consider opening these plans to a full public consultation
across Harlow, given the size of the proposed developments. i have no issues with
creating more homes in Harlow, but it has to be done in a logical and sustainable way
with infrastructure considered hand in hand. This development plan has none of these
things.
I look forward to your response on these issues raised.
With Regards
James Humphreys

Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6718

Received: 21/08/2018

Respondent: Jean Wright

Representation:

This document is an idealistic wish list but trying to achieve quality of life with meeting government required housing numbers is not easy. Nor is the type of housing required necessarily that which will be built. Harlow desperately needs more social housing. There
will always be people who cannot afford to buy, cannot afford deposits and rents required by private landlords.

Unless Harlow's assets of green space are seriously protected people moving here for jobs may well not live in Harlow but commute in from villages offering serenity if nothing else. This has been the choice of many professionals working in Harlow.

Full text:

Dear Sir

I felt I had to make some comments on the documents comprising
Harlow Local Development Plan Pre-Submission Publication.

Gibberd described Harlow as:
'An organism which would go on changing and being rebuilt as the needs of the people altered'.

I have failed to find the source of this quote except to find a document online which details it as being made in 1950. The source does not seem to have been listed in the document.
If this was made in 1950 it seems to have little reference to now.
The quote appears in several recent documents.


One would expect a town to change but if this source is dated from 1950 then the planned Harlow was a very different place. Yes, it is a reference to change but the envisaged Harlow was a much smaller place. lt does not imply wholesale expansion into
open countryside.

As the basic master plan principles have been broken in regard to Gilden Park, it seems inappropriate to use a quote by Gibberd at all.

The map used in the pack does not show Gilden Park or the land being developed as a designated building site. This is misleading as anyone looking at it, unfamiliar with the now building site on Gilden Way, would think it was still an open space. lt now resembles an industrial site more than a building site with what looks like houses which could be found anywhere in Britain and large heaps of what looks like subsoil which appear to be constantly on the move or being increased in size.

To add insult to injury the main footpath across the site has been closed which was a great recreational source for people in Old Harlow. We have some open spaces here but in the main use of these is restricted to sport use. We will be very lacking now in green space. When the footpath reopens we will not be able to enjoy our once green area.

This document is an idealistic wish list but trying to achieve quality of life with meeting government required housing numbers is not easy. Nor is the type of housing required necessarily that which will be built. Harlow desperately needs more social housing. There
will always be people who cannot afford to buy, cannot afford deposits and rents required by private landlords.

Unless Harlow's assets of green space are seriously protected people moving here for jobs may well not live in Harlow but commute in from villages offering serenity if nothing else. This has been the choice of many professionals working in Harlow.

Yours faithfully,
Jean M. Wright

Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6721

Received: 21/08/2018

Respondent: Mrs Karen Garrod

Representation:

Uncertainty
Throughout the report, there seems to be "significant levels of uncertainty" in key areas which undermines the subject matter.

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6726

Received: 21/08/2018

Respondent: Little Hadham Parish Council

Representation:

The plan appears deliverable and sufficiently meets development needs. The Harlow A&E hospital is the local A&E for Little Hadham residents, please consider this when deciding on a suitable location for the new hospital as part of this plan so that it continues to be accessible. Please provide more details on how/where water is likely to be drawn from to provide water supplies to all the new homes.

Full text:

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Support

Local Development Plan Pre-Submission Publication

Representation ID: 6761

Received: 22/08/2018

Respondent: Quod Planning

Representation:

PfP are strongly supportive of Harlow's ambition, and pro-activity strategy for growth over the Local Plan period. PfP welcome the opportunity to continue to engage with HDC on the evolution of Harlow's Local Development Plan, whether regarding the above points, or more generally, particularly as the detail on the proposals for the GPE, and Central and Eastern Stort Crossings, continues to progress.

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6762

Received: 22/08/2018

Respondent: Lawson Planning Partnership

Representation:

The current Adopted Replacement Harlow Local Plan (2006) makes reference to the need to facilitate the improvement of PAH's local health services, guided by a Master Plan as follows:
"Saved Policy CP4: The future development of Princess Alexandra Hospital will be granted planning permission subject to it according with their approved Master Plan."

The previous Master Plan was developed having regard for the constraints of the site; these include a group Tree Preservation Order covering the whole site (TPO/10/92), two Scheduled Monument designations (bowl barrows in the north and east of the site), a Grade II listed building (Parndon Hall) and land designated as a Green Wedge. A strip of land in the south east of the site also contains two central water mains serving the wider Harlow area.

Whilst the draft Local Plan acknowledges the redevelopment of the existing Hospital site is a credible possibility, the Trust would like to see a similar masterplanning policy in this document which supports the redevelopment of the site for hospital uses, should this be identified as the preferred option in the future.
Without this supportive policy basis, the longer-term strategic aims of the Trust in redeveloping and expanding the site would not be acknowledged, and thus in the process, applications for short-term development necessary to achieve this could encounter a lack of planning policy certainty and support.

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6767

Received: 22/08/2018

Respondent: Tetlow King Planning

Representation:

The Government consulted on proposed changes to the NPPF, and aims to publish the "NPPF2" this month. The proposed changes include a new definition of affordable housing with a number of new categories aimed at widening the scope of the definition to include a wider array of tenures to assist people into homes that meet their needs, including rent to buy under 'other affordable routes to home ownership'. While Rentplus has sought a minor amendment to that definition, we do not anticipate significant changes to be made to the document prior to publication.

The significant level of need for affordable housing in Harlow points clearly to a need for a step change in delivery to meet those needs. The Local Plan Spatial Vision clearly captures this need and sets the right tone for an ambitious approach to maximising delivery of affordable housing over the Plan period. Access to a deposit remains one of the most challenging blockers on accessing home ownership, which even intermediate affordable housing does not resolve; the Council should take a proactive approach to welcoming the delivery of the wider range of affordable tenures set out in the draft NPPF to encourage a more diverse housing stock and to improve the ability of all developers, particularly those bringing forward the new Garden Communities, to deliver an appropriate and higher quantum of affordable housing.

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6781

Received: 22/08/2018

Respondent: The Roydon Society

Representation:

The Roydon Society supports the comments made by Roydon Parish Council and
sent under separate cover recently.

Full text:

The Roydon Society supports the comments made by Roydon Parish Council and
sent under separate cover recently.
With many thanks
S.N.Wilkinson
Hon Sec and Councillor Roydon Village Ward

Support

Local Development Plan Pre-Submission Publication

Representation ID: 6807

Received: 24/08/2018

Respondent: Chelmsford City Council

Representation:

Officers have reviewed the Local Development Plan Pre-Submission Publication, and consider that the identified housing, employment and infrastructure needs for development in Harlow to 2033 will be met through delivery of the Plan. Officers are satisfied that the duty to co-operate has been met, and consider the plan to be sound.

Full text:

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Object

Local Development Plan Pre-Submission Publication

Representation ID: 6846

Received: 30/08/2018

Respondent: Miss Mary Wiltshire

Representation:

Object to the whole document. As it is a wish-list rather than set of plan for discussion. It is not much of consultation.

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6849

Received: 30/08/2018

Respondent: Miss Mary Wiltshire

Representation:

typographical error has been found.

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6870

Received: 31/08/2018

Respondent: Essex County Council

Representation:

ECC has worked to ensure as far as possible through its ongoing engagement and representations with HC throughout plan preparation that this Draft Plan addresses ECC's areas of responsibility consistent with national policy to enable sustainable development. The ECC response to the Draft Plan recommends several areas for clarification to enable effective delivery and amendments to improve policy and explanatory text. ECC will work cooperatively with HC to ensure issues can be positively addressed prior to HC submitting the Draft Plan for examination. It is likely that Statement(s) of Common Ground will be needed to be prepared at that time to address any outstanding issues or ahead of the examination hearings. The approach will be confirmed with HC closer to the time.

ECC has identified a limited number of issues arising through the Draft Plan relating to consistency with national (planning) policy. These are set out in Appendix 1 and most are considered capable of being readily addressed relatively easily, through policy revisions, rewording etc. The main area where ECC recommends a change to ensure consistency with NPPF is in relation to health and well-being matters. It is accordingly recommended that ECC urges the inclusion of an embracing health and well-being policy and sets out requirements for HIAs, to reflect NPPF requirements and the profile of health and well-being within the NPPF. Some basic elements of well-being considerations are evident but these are not deemed sufficiently clear explicit and their scope is too limited. This point was made by ECC at the previous Plan-making stage.

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6871

Received: 31/08/2018

Respondent: Essex County Council

Representation:

The Local Plan includes only basic reference to well-being matters. Accordingly, ECC Public Health recommends that an over-arching health and well-being policy and/or a specific Health Impact Assessment (HIA) policy is included in the Local Plan. It is accordingly unclear as to how this specifically supports the NPPF 'Promoting Healthy Communities' sections. This matter was raised by ECC in its representations at the Development Management Policies (Local Plan) consultation stage in 2017.
This also means absence of an appropriate policy basis for assessing development proposals (the Plan being largely silent on these matters)

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6994

Received: 31/07/2018

Respondent: Natural England

Representation:

See attachment.

Full text:

See attachment.