Schedule of Main Modifications - March 2020

Showing comments and forms 1 to 28 of 28

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7001

Received: 02/04/2020

Respondent: Steve Dean

Representation:

I would like to comment on chapter 11 SIR1, as follows. There appears to be no consideration for how the existing roads will be able to cope with the extra traffic from new housing developments. I think it is unreasonable for you to rely on Harlow residents to immediately changing their modes of transport so, unless you improve the existing road system, we will have a situation where the existing roads will not be able to cope with the increase in traffic from the new developments.

Full text:

I would like to comment on chapter 11 SIR1, as follows. There appears to be no consideration for how the existing roads will be able to cope with the extra traffic from new housing developments. I think it is unreasonable for you to rely on Harlow residents to immediately changing their modes of transport so, unless you improve the existing road system, we will have a situation where the existing roads will not be able to cope with the increase in traffic from the new developments.

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7002

Received: 16/04/2020

Respondent: Cllr Simon Carter

Representation:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

There is an anomaly in the proposed modifications which discriminates against people with disabilities, contrary to the Equality Act 2010. On the one hand, all
new properties should (my emphasis) meet Part M4(2) but only if the developer deems them affordable. On the other, in MM14,developments that exceed the
minimum standard for insulation by 19% will be supported (see below for relevant paragraphs).

So there is an immediate and regulatory excuse for developers to claim that accessible homes are unaffordable as they have to meet far more stringent
insulating requirements, in excess of building regulations and of other planning authorities.

According to a recent report by Habinteg Housing Association, ‘Insight Report: A forecast for accessible homes’, “In London the chances of finding a new home
of either accessible and adaptable standard or wheelchair dwelling standard is one new accessible home for every 24 people. In the East of England, there is one new accessible home for every 52 people”.
https://www.habinteg.org.uk/localplans/

There is a clear need for more accessible homes to be met through new developments – the NHS estimates there are some 1.2 million wheel chair users in the UK.

Developers often claim that accessible homes are more expensive to build than ‘normal’ homes, yet this has yet to be proved. Developers meet a higher standard in London and therefore have the experience to deliver higher numbers on a regular basis. Why should people living outside London be discriminated against?

It is difficult to reconcile an optional approach to meeting a real and practical need against having to substantially exceed a more arbitrary target of ‘insulation’. Where is the fairness in that? Both are important, but why is one
more important than the other? There are many ways to reduce CO2 emissions, but only one way to provide proper housing for disabled people.

In MM22 Policy H5 paragraph (a) must be amended to ‘all new properties must be at least Building Regulations Part M4(2) . . . We might then get some equity for wheelchair users and other people with disabilities.

Simon Carter (Cllr)
8 April 2020

MM22 Policy H5
To ensure that new homes are both accessible and adaptable to meet the changing needs of occupants:
(a) all new dwellings should be at least Building Regulations Part M4(2) standard for accessible and adaptable homes; and
(b) major residential development, a suitable proportion of M4(3) standard dwellings for wheelchair users should be provided based on the latest Strategic Housing Market Assessment (SHMA) or other appropriate evidence directly related to the housing needs of Harlow.

The provision of specialist housing developments will be supported on appropriate sites that will meet the needs of older people and other groups. Only where circumstances exist where it can be demonstrated by the applicant that it is not practically achievable or financially viable to deliver this policy will new development be exempt from these requirements.

MM14 PL3 Implementation

The Building Regulations set out the minimum requirements for the conservation of fuel and power.
Development will be supported where it exceeds the minimum standards required by Building Regulations. The amount by which the standards should be
exceeded is preferably at least 19%.

Full text:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

There is an anomaly in the proposed modifications which discriminates against people with disabilities, contrary to the Equality Act 2010. On the one hand, all
new properties should (my emphasis) meet Part M4(2) but only if the developer deems them affordable. On the other, in MM14,developments that exceed the
minimum standard for insulation by 19% will be supported (see below for relevant paragraphs).

So there is an immediate and regulatory excuse for developers to claim that accessible homes are unaffordable as they have to meet far more stringent
insulating requirements, in excess of building regulations and of other planning authorities.

According to a recent report by Habinteg Housing Association, ‘Insight Report: A forecast for accessible homes’, “In London the chances of finding a new home
of either accessible and adaptable standard or wheelchair dwelling standard is one new accessible home for every 24 people. In the East of England, there is one new accessible home for every 52 people”.
https://www.habinteg.org.uk/localplans/

There is a clear need for more accessible homes to be met through new developments – the NHS estimates there are some 1.2 million wheel chair users in the UK.

Developers often claim that accessible homes are more expensive to build than ‘normal’ homes, yet this has yet to be proved. Developers meet a higher standard in London and therefore have the experience to deliver higher numbers on a regular basis. Why should people living outside London be discriminated against?

It is difficult to reconcile an optional approach to meeting a real and practical need against having to substantially exceed a more arbitrary target of ‘insulation’. Where is the fairness in that? Both are important, but why is one
more important than the other? There are many ways to reduce CO2 emissions, but only one way to provide proper housing for disabled people.

In MM22 Policy H5 paragraph (a) must be amended to ‘all new properties must be at least Building Regulations Part M4(2) . . . We might then get some equity for wheelchair users and other people with disabilities.

Simon Carter (Cllr)
8 April 2020

MM22 Policy H5
To ensure that new homes are both accessible and adaptable to meet the changing needs of occupants:
(a) all new dwellings should be at least Building Regulations Part M4(2) standard for accessible and adaptable homes; and
(b) major residential development, a suitable proportion of M4(3) standard dwellings for wheelchair users should be provided based on the latest Strategic Housing Market Assessment (SHMA) or other appropriate evidence directly related to the housing needs of Harlow.

The provision of specialist housing developments will be supported on appropriate sites that will meet the needs of older people and other groups. Only where circumstances exist where it can be demonstrated by the applicant that it is not practically achievable or financially viable to deliver this policy will new development be exempt from these requirements.

MM14 PL3 Implementation

The Building Regulations set out the minimum requirements for the conservation of fuel and power.
Development will be supported where it exceeds the minimum standards required by Building Regulations. The amount by which the standards should be
exceeded is preferably at least 19%.

Attachments:

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7003

Received: 16/04/2020

Respondent: Cllr Joel Charles

Representation:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Introduction:

I welcome the further opportunity to contribute to the development of Harlow’s Local Plan. In June 2014, I submitted a written response to the Local Plan consultation setting out my concerns. The Local Plan has evolved significantly since my original response so I want to set out my current concerns about the plan, specifically the impact on Old Harlow.

Harlow Council has failed to properly consult local residents about the true scale of development proposed in the current version of the Local Plan. The council chose to conduct a Regulation 19 consultation which focused narrowly on the technical elements of the plan process that will govern development up to 2033. It is surprising that Harlow Council refused to pursue a full Regulation 18 process to allow open debate about, in particular, the proposed growth locations for new housing developments.

This has meant that Harlow Council has failed to achieve buy-in from the local community to the draft plan. Many residents in Old Harlow have been left confused by the approach taken by the council and the lack of communication about one of the most important governing documents that will shape the town’s future for decades to come.

There are two issues I want to focus on in my consultation response.

1. MM4 Reference 15, Playground West of 93 – 100 Jocelyns:

In the Planning Inspector’s letter dated the 17th of December (page 4, reference 15), it was proposed that Harlow Council remove the playground west of 93-100 Jocelyns as a future housing site. I welcome this change to the Local Plan as I raised formal concerns about the inclusion of the park as a potential housing site in my 2014 consultation response. However, the Planning Inspector does not go far enough to protect Jocelyns park from the threat of development. The park sits between Jocelyns and Broadway Avenue – the main access is a narrow entrance at the bottom of Broadway Avenue. Jocelyns park has been used by generations of local residents for recreation. The land flows into the tree belt (allocated Green Wedge) that borders the A414. This park should be fully reinstated as Green Wedge because there is no man-made or natural barrier separating the park and the tree belt, it is the same land and should be given the same level of protection.

2. MM5 Policy HS3, Strategic Housing Site to the East of Harlow:

I am disappointed that the Planning Inspector made no substantial modifications to the proposed strategic housing site to the East of Harlow. This corner of Harlow faces the prospect of 2,600 new homes, the construction of Junction 7A and is the preferred location, as agreed by the Princess Alexandra Hospital Trust Board, for a brand-new hospital. The complexities of building new housing and necessary infrastructure have not been properly explored by Harlow Council in this corner of Harlow.

Adding additional traffic flow onto Gilden Way, even with new traffic enhancements, will cause congestion at peak travel times. I am concerned that congestion on Gilden Way will have a knock-on impact on the rest of the local road network. The A414 will face the

brunt of the congestion as an arterial route through Mark Hall and Old Harlow. It is important that planners reconsider the impact of increased vehicle movements that would come from the proposed East of Harlow housing site.

Further consideration must be given to the loss of a significant amount of amenity land bordering Harlow and Epping. The land that stretches between Sheering and Matching along the M11 corridor enhances the overall character of the local area and the settled village community in Old Harlow. Harlow Council risks eroding the Gibberd principles of being sympathetic to and preserving, where possible, the historic character of the town.

Although I fully support the building of a new hospital on the preferred site, Harlow Council has failed to adequately set out, even in high level terms, their strategic planning ambition for phasing the development to the East of Harlow and how they will cooperate with Epping Forest District Council to achieve their goals. The scale of proposed housing development does not match the reality on the ground when planners focus on the technical undertaking needed to deliver housing growth. Churchgate Street and other established communities in Old Harlow will be badly affected. The impact on the local community has not been fully explored and steps to implement a mitigation action plan
to limit the severity of such housing growth has not been properly identified.

This should raise serious concerns and be subject to further scrutiny by the Planning Inspector. At the very least, Harlow Council should be required to produce a new indicative project plan, including milestones, for achieving their planning goals for the East of Harlow before the Local Plan is adopted.

Conclusion:

Harlow Council’s Local Plan process has been flawed from the very beginning. Residents are still largely unaware of the planning implications contained in the current version of the Local Plan. There are several unanswered questions about the strategic intention of the council to deliver its proposed housing growth locations and the administration has not been clear with the public about the scale of change that will be implemented if the current version of the Local Plan is adopted. I hope that the Planning Inspector is able to request further clarity and hold Harlow Council to account for the lack of consideration, communication and strategic vision to deliver a Local Plan that is desirable and achievable. Below are two specific recommendations that I hope the Planning Inspector is able to accept.

Recommendations:

1. Reinstate the playground west of 93-100 Jocelyns as Green Wedge land with immediate effect and update the Local Plan accordingly.

2. Suspend the Local Plan process so that a review of the strategic housing site to the East of Harlow can be conducted and a new indicative strategic planning assessment can be produced. This assessment will help gain further clarity about how the feasibility of building 2,600 dwellings, Junction 7A and a new hospital can be realised.

Full text:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Introduction:

I welcome the further opportunity to contribute to the development of Harlow’s Local Plan. In June 2014, I submitted a written response to the Local Plan consultation setting out my concerns. The Local Plan has evolved significantly since my original response so I want to set out my current concerns about the plan, specifically the impact on Old Harlow.

Harlow Council has failed to properly consult local residents about the true scale of development proposed in the current version of the Local Plan. The council chose to conduct a Regulation 19 consultation which focused narrowly on the technical elements of the plan process that will govern development up to 2033. It is surprising that Harlow Council refused to pursue a full Regulation 18 process to allow open debate about, in particular, the proposed growth locations for new housing developments.

This has meant that Harlow Council has failed to achieve buy-in from the local community to the draft plan. Many residents in Old Harlow have been left confused by the approach taken by the council and the lack of communication about one of the most important governing documents that will shape the town’s future for decades to come.

There are two issues I want to focus on in my consultation response.

1. MM4 Reference 15, Playground West of 93 – 100 Jocelyns:

In the Planning Inspector’s letter dated the 17th of December (page 4, reference 15), it was proposed that Harlow Council remove the playground west of 93-100 Jocelyns as a future housing site. I welcome this change to the Local Plan as I raised formal concerns about the inclusion of the park as a potential housing site in my 2014 consultation response. However, the Planning Inspector does not go far enough to protect Jocelyns park from the threat of development. The park sits between Jocelyns and Broadway Avenue – the main access is a narrow entrance at the bottom of Broadway Avenue. Jocelyns park has been used by generations of local residents for recreation. The land flows into the tree belt (allocated Green Wedge) that borders the A414. This park should be fully reinstated as Green Wedge because there is no man-made or natural barrier separating the park and the tree belt, it is the same land and should be given the same level of protection.

2. MM5 Policy HS3, Strategic Housing Site to the East of Harlow:

I am disappointed that the Planning Inspector made no substantial modifications to the proposed strategic housing site to the East of Harlow. This corner of Harlow faces the prospect of 2,600 new homes, the construction of Junction 7A and is the preferred location, as agreed by the Princess Alexandra Hospital Trust Board, for a brand-new hospital. The complexities of building new housing and necessary infrastructure have not been properly explored by Harlow Council in this corner of Harlow.

Adding additional traffic flow onto Gilden Way, even with new traffic enhancements, will cause congestion at peak travel times. I am concerned that congestion on Gilden Way will have a knock-on impact on the rest of the local road network. The A414 will face the

brunt of the congestion as an arterial route through Mark Hall and Old Harlow. It is important that planners reconsider the impact of increased vehicle movements that would come from the proposed East of Harlow housing site.

Further consideration must be given to the loss of a significant amount of amenity land bordering Harlow and Epping. The land that stretches between Sheering and Matching along the M11 corridor enhances the overall character of the local area and the settled village community in Old Harlow. Harlow Council risks eroding the Gibberd principles of being sympathetic to and preserving, where possible, the historic character of the town.

Although I fully support the building of a new hospital on the preferred site, Harlow Council has failed to adequately set out, even in high level terms, their strategic planning ambition for phasing the development to the East of Harlow and how they will cooperate with Epping Forest District Council to achieve their goals. The scale of proposed housing development does not match the reality on the ground when planners focus on the technical undertaking needed to deliver housing growth. Churchgate Street and other established communities in Old Harlow will be badly affected. The impact on the local community has not been fully explored and steps to implement a mitigation action plan
to limit the severity of such housing growth has not been properly identified.

This should raise serious concerns and be subject to further scrutiny by the Planning Inspector. At the very least, Harlow Council should be required to produce a new indicative project plan, including milestones, for achieving their planning goals for the East of Harlow before the Local Plan is adopted.

Conclusion:

Harlow Council’s Local Plan process has been flawed from the very beginning. Residents are still largely unaware of the planning implications contained in the current version of the Local Plan. There are several unanswered questions about the strategic intention of the council to deliver its proposed housing growth locations and the administration has not been clear with the public about the scale of change that will be implemented if the current version of the Local Plan is adopted. I hope that the Planning Inspector is able to request further clarity and hold Harlow Council to account for the lack of consideration, communication and strategic vision to deliver a Local Plan that is desirable and achievable. Below are two specific recommendations that I hope the Planning Inspector is able to accept.

Recommendations:

1. Reinstate the playground west of 93-100 Jocelyns as Green Wedge land with immediate effect and update the Local Plan accordingly.

2. Suspend the Local Plan process so that a review of the strategic housing site to the East of Harlow can be conducted and a new indicative strategic planning assessment can be produced. This assessment will help gain further clarity about how the feasibility of building 2,600 dwellings, Junction 7A and a new hospital can be realised.

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7004

Received: 16/04/2020

Respondent: Capital Space

Representation:

Sir

I would like to put forward a comment on behalf of the Greenway Business Centre that has been providing space for start-up and growing businesses since 2005. During this period we have enabled a large number of people to start and to grow their businesses. This has contributed to the ongoing success of Harlow and it is something of which we are very proud.

Budding entrepreneurs can choose whether to operate from an office, a studio or a workshop. Workshops, sometimes seen as industrial units, in particular are extremely popular, perhaps because we are the only company in the town to offer this particular facility. We would like to provide more but we are constrained by a lack of space.

I enclose a scan of map 6b re-instated green belt upon which I have cross hatched a small portion adjacent to our boundary. The land cross hatched is overgrown, has no overlooking windows, no residential properties nearby and no convenient public access. Commercial buildings border the land on three sides. The fourth side is open. The value of this land as green belt is very limited. This land is referred to in or around paragraph 10.8 on P81 of the local plan.

Conversely it is the only area that could potentially available for us to expand the number of workshops. A greater number and variety of workshops than we currently offer would enable more people to start and to grow their businesses.

We surge most strongly that the inspector considers again the balance between leaving this land in its current derelict unloved state and its clearly potential social value as the site of an extension to the Greenway Business Centre.

Our understanding is that the land in owned by Harlow Council and so if it were to be released from the green belt the whole development value would accrue to the public purse.

(ALSO SEE ATTACHMENT)

Full text:

Sir

I would like to put forward a comment on behalf of the Greenway Business Centre that has been providing space for start-up and growing businesses since 2005. During this period we have enabled a large number of people to start and to grow their businesses. This has contributed to the ongoing success of Harlow and it is something of which we are very proud.

Budding entrepreneurs can choose whether to operate from an office, a studio or a workshop. Workshops, sometimes seen as industrial units, in particular are extremely popular, perhaps because we are the only company in the town to offer this particular facility. We would like to provide more but we are constrained by a lack of space.

I enclose a scan of map 6b re-instated green belt upon which I have cross hatched a small portion adjacent to our boundary. The land cross hatched is overgrown, has no overlooking windows, no residential properties nearby and no convenient public access. Commercial buildings border the land on three sides. The fourth side is open. The value of this land as green belt is very limited. This land is referred to in or around paragraph 10.8 on P81 of the local plan.

Conversely it is the only area that could potentially available for us to expand the number of workshops. A greater number and variety of workshops than we currently offer would enable more people to start and to grow their businesses.

We surge most strongly that the inspector considers again the balance between leaving this land in its current derelict unloved state and its clearly potential social value as the site of an extension to the Greenway Business Centre.

Our understanding is that the land in owned by Harlow Council and so if it were to be released from the green belt the whole development value would accrue to the public purse.

(ALSO SEE ATTACHMENT)

Attachments:

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7005

Received: 20/04/2020

Respondent: Sport England

Representation:

MM29 – New Policy L4 Health and Well-being

Support is offered for the proposed new policy L4 and its reasoned justification on health and well-being.

First the principle of including a policy which seeks development and growth to have a positive impact on health and well-being is supported as this would accord with paragraph 91 of the NPPF.

Second, criteria a, b and f of the policy are particularly supported as they would align with Sport England’s planning objectives and would help support the provision of infrastructure to support sport and physical activity and good quality design which encourages physical activity. The specific references in the implementation section to the Essex Design Guide, the Essex-wide Health Impact Assessment guidance and Sport England’s Active Design guide are especially welcome as they all include guidance and how developments can create environments through design which encourage physical activity.

Full text:

MM29 – New Policy L4 Health and Well-being

Support is offered for the proposed new policy L4 and its reasoned justification on health and well-being.

First the principle of including a policy which seeks development and growth to have a positive impact on health and well-being is supported as this would accord with paragraph 91 of the NPPF.

Second, criteria a, b and f of the policy are particularly supported as they would align with Sport England’s planning objectives and would help support the provision of infrastructure to support sport and physical activity and good quality design which encourages physical activity. The specific references in the implementation section to the Essex Design Guide, the Essex-wide Health Impact Assessment guidance and Sport England’s Active Design guide are especially welcome as they all include guidance and how developments can create environments through design which encourage physical activity.

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7006

Received: 20/04/2020

Respondent: Cllr Michael Garnett

Representation:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

I welcome an opportunity to respond to the Planning Inspector’s modifications and comment on the proposed replacement Harlow Local Plan specifically with regard to my Ward Area of Old Harlow which includes Churchgate Street and Newhall.
I submit that Harlow District Council has failed in its duty to consult properly with the local population by choosing to go to a Regulation 19 consultation which concentrated on the technical elements of the plan process whereas a section 18 process would have allowed an open debate particularly around the proposed growth locations identified and more specifically the East of Harlow Development.

There are two proposal that I want to focus my responses on:
A) MM5 Policy HS3 Proposed Housing site to the East of Harlow (Churchgate Street Area)
I am disappointed that the Inspector has made no substantial modification to the proposed strategic Housing site to the East of Harlow. This small corner of Harlow faces the prospect of 2600 new Homes in the proposed replacement Harlow Local Plan which will govern development up to 2033. There is already a development underway of 1100 homes on Gilden Park. A new motorway Junction (7a) is been built using Gilden Way as the feeder Road. There is also a preferred site for the new Princess Alexandra Hospital to be built in this area. I understand and accept the need for new Housing but I am extremely concerned of the social impact this development will have on the way of life enjoyed by the existing local population. This area is a small corner of Old Harlow and because of the lack of meaningful consultation there has been no indication or plans for what if any infrastructure that would be required for all this new build but more pertinently the impact it would have on the existing infrastructure which is already struggling to cope. Gilden Way is a relatively small country road and is already suffering from severe congestion at peak times. Gilden Way will bear the brunt of the congestion as it will become an arterial route through Mark Hall and Old Harlow. It is therefore important that planners should seriously consider the impact of increased vehicle movement that would come from the proposed East of Harlow housing site.
Harlow District Council has failed to properly set out their strategic planning ambition in cooperation with Epping Forest District Council for the phasing of this development which will have unacceptable long term repercussions for this area. The impact of a development of this size would undoubtedly have a profound effect on Churchgate Street and other local communities, for which a mitigation action plan has not been identified.
Further consideration must be given to the loss of a significant amount of amenity land which borders the districts of Epping and Harlow. The land that stretches between Sheering and Matching along the M11 corridor enhances the character of this area and the village communities of Old Harlow and Churchgate Street. This development also will erode the Gibberd principles of preserving where possible the historic character of Harlow.
Conclusion:
Harlow Council’s Proposed New Local Plan process has been flawed from the very start as residents are largely unaware of the planning implication of this proposed Replacement Local Plan. There are a number of unanswered questions about the strategic intention of the Council to deliver its housing growth locations and the administration has not been open with the public about the scale of change that will be implemented if the current version of the proposed replacement Local Plan is adopted without this amendment.
Recommendation:
Suspend the adoption of the current version of the Proposed Replacement Local Plan to enable a properly conducted consultation and review of the East of Harlow proposed housing site to include infrastructure and effect of the new M11 junction and Hospital site.
Delay any development applications coming forward for this site for 15 years to allow a new indicative strategic planning assessment to be produced following the completion of the new junction and Hospital.

B) MM4 Reference 15 Playground west of 93-100 Jocelyns.
I am pleased to see that the Planning Inspector, by his letter dated 17th December 2019 page 4 ref: 15 to Harlow District Council, has proposed the removal of this site for future housing development from the proposed Harlow Replacement Local Plan.
However, the Inspector needs to go further to protect this area from future development by allocating it into the Green Wedge. This play area lies between Jocelyns and Broadway Avenue and has been used by generations of local residents for recreation. It also has a newly constructed children’s play area.
Recommendation:
This park should be fully reinstated as Green Wedge because there is no man made or natural barrier between the park and the tree belt (allocated Green Wedge) that borders the A414. As this is part of the same area of land it should be allocated the same protection.

Full text:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

I welcome an opportunity to respond to the Planning Inspector’s modifications and comment on the proposed replacement Harlow Local Plan specifically with regard to my Ward Area of Old Harlow which includes Churchgate Street and Newhall.
I submit that Harlow District Council has failed in its duty to consult properly with the local population by choosing to go to a Regulation 19 consultation which concentrated on the technical elements of the plan process whereas a section 18 process would have allowed an open debate particularly around the proposed growth locations identified and more specifically the East of Harlow Development.

There are two proposal that I want to focus my responses on:
A) MM5 Policy HS3 Proposed Housing site to the East of Harlow (Churchgate Street Area)
I am disappointed that the Inspector has made no substantial modification to the proposed strategic Housing site to the East of Harlow. This small corner of Harlow faces the prospect of 2600 new Homes in the proposed replacement Harlow Local Plan which will govern development up to 2033. There is already a development underway of 1100 homes on Gilden Park. A new motorway Junction (7a) is been built using Gilden Way as the feeder Road. There is also a preferred site for the new Princess Alexandra Hospital to be built in this area. I understand and accept the need for new Housing but I am extremely concerned of the social impact this development will have on the way of life enjoyed by the existing local population. This area is a small corner of Old Harlow and because of the lack of meaningful consultation there has been no indication or plans for what if any infrastructure that would be required for all this new build but more pertinently the impact it would have on the existing infrastructure which is already struggling to cope. Gilden Way is a relatively small country road and is already suffering from severe congestion at peak times. Gilden Way will bear the brunt of the congestion as it will become an arterial route through Mark Hall and Old Harlow. It is therefore important that planners should seriously consider the impact of increased vehicle movement that would come from the proposed East of Harlow housing site.
Harlow District Council has failed to properly set out their strategic planning ambition in cooperation with Epping Forest District Council for the phasing of this development which will have unacceptable long term repercussions for this area. The impact of a development of this size would undoubtedly have a profound effect on Churchgate Street and other local communities, for which a mitigation action plan has not been identified.
Further consideration must be given to the loss of a significant amount of amenity land which borders the districts of Epping and Harlow. The land that stretches between Sheering and Matching along the M11 corridor enhances the character of this area and the village communities of Old Harlow and Churchgate Street. This development also will erode the Gibberd principles of preserving where possible the historic character of Harlow.
Conclusion:
Harlow Council’s Proposed New Local Plan process has been flawed from the very start as residents are largely unaware of the planning implication of this proposed Replacement Local Plan. There are a number of unanswered questions about the strategic intention of the Council to deliver its housing growth locations and the administration has not been open with the public about the scale of change that will be implemented if the current version of the proposed replacement Local Plan is adopted without this amendment.
Recommendation:
Suspend the adoption of the current version of the Proposed Replacement Local Plan to enable a properly conducted consultation and review of the East of Harlow proposed housing site to include infrastructure and effect of the new M11 junction and Hospital site.
Delay any development applications coming forward for this site for 15 years to allow a new indicative strategic planning assessment to be produced following the completion of the new junction and Hospital.

B) MM4 Reference 15 Playground west of 93-100 Jocelyns.
I am pleased to see that the Planning Inspector, by his letter dated 17th December 2019 page 4 ref: 15 to Harlow District Council, has proposed the removal of this site for future housing development from the proposed Harlow Replacement Local Plan.
However, the Inspector needs to go further to protect this area from future development by allocating it into the Green Wedge. This play area lies between Jocelyns and Broadway Avenue and has been used by generations of local residents for recreation. It also has a newly constructed children’s play area.
Recommendation:
This park should be fully reinstated as Green Wedge because there is no man made or natural barrier between the park and the tree belt (allocated Green Wedge) that borders the A414. As this is part of the same area of land it should be allocated the same protection.

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7007

Received: 24/04/2020

Respondent: Highways England

Representation:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

We have reviewed your proposed modifications, as these are minor and mostly just make the plan more in line with other parts of the plan and or national policy. Very few affect transport matters and those that do are very unlikely to result in an impact upon the strategic road network. We are satisfied the proposed modifications will not in any way affect our conclusions on your proposed plan and our previous comments remain unchanged.

Thank you for consulting us

Full text:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

We have reviewed your proposed modifications, as these are minor and mostly just make the plan more in line with other parts of the plan and or national policy. Very few affect transport matters and those that do are very unlikely to result in an impact upon the strategic road network. We are satisfied the proposed modifications will not in any way affect our conclusions on your proposed plan and our previous comments remain unchanged.

Thank you for consulting us

Attachments:

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7008

Received: 27/05/2020

Respondent: Lawson Planning Partnership

Representation:

On behalf of our client the Princess Alexandra Hospital NHS Trust, we support modifications MM3, MM4 and MM11. We would however like further clarification to MM14 concerning revised supported text at Paragraph 13.17, where it explains that development will be supported where it exceeds Building Regulations standards, which could infer development that does not exceed these standards could be refused.

Please see the attached representations letter for full details.

Full text:

On behalf of our client the Princess Alexandra Hospital NHS Trust (PAH), we write to set out our representations on the Harlow District Local Plan Schedule of Main Modifications (March 2020), for your consideration. These representations build on our previous submissions on the Local Plan Pre-submission Publication Draft (May 2018) and written and oral evidence presented to the related Examination in Public (EIP) in March/April 2019 together with the signed Statement of Common Ground (SoCG) between PAH and Harlow District Council dated 17th April 2019.

Background

1. The background to PAH’s position is set out in detail in the submissions referred to above and relates to the need to urgently re-provide and redevelop its existing acute Hospital and related services currently located on the 12.2 hectare Campus site at Hamstel Road in Central Harlow.

2. In 2019, PAH’s Trust Board approved the recommended development option for the relocation of the existing Hospital to a green field site in East Harlow adjacent to the programmed new M11 Motorway Junction J7a. This decision was recently ratified by the Department of Health (DoH), subject to clarifying a number of points, and confirmation of final Treasury funding is expected in June 2020. Also, the existing mental health services may additionally co-relocate from the main Hospital to the new site. This would enable the existing site to be comprehensively planned and redeveloped for housing, whilst optimising the number of new homes to be delivered.

3. Consequently, PAH is progressing related enabling works in support of its planning strategy for the preferred development option. This is to enable momentum on the related Business Case process to be maintained, with a view to securing planning permission for the new Hospital in 2021 and commencing development in Autumn 2022. Part of this strategy includes the redevelopment of the existing Hospital site for housing, which would be redeveloped post 2022 to provide up to approximately 550 homes.

4. If circumstances dictate that the preferred Hospital relocation could not take place, PAH would then need to embark on a redevelopment programme and re-provide services on the existing site. This fall-back option would be guided by a new masterplan prepared by the Trust and agreed with the Local Planning Authority (LPA) and may involve freeing up some potentially surplus land for approximately 100 new homes. Recognition for this scenario was also requested to be identified in the new Local Plan at the EIP and was agreed as part of the SoCG.

5. The new Hospital site falls within Epping Forest District and forms part of a strategic planning policy allocation in the 2017 Submission draft Epping Forest Local Plan, which is also at an advanced stage of preparation.

6. The preferred development option comprises the construction of a new ‘state of the art’ local acute hospital, as part of a health and well-being campus, to be fully integrated and linked with the wider Harlow and Gilston Garden Town (HGGT), which it will serve. PAH has an aspiration to design and build the most technological advanced Hospital in the Country and wishes to work with all associated partners including Harlow District Council to help deliver it. Therefore, the general reference in the proposed Local Plan Main Modifications to helping to facilitate the provision of the new Hospital and redevelopment of the existing site for approximately 550 homes, along with the fall-back development in situ scenario, is warmly welcomed.

7. Support is also given to the inclusion of healthcare facilities as part of necessary infrastructure to be included within developer contributions associated with new development.

8. Our representations set out below reflect the development strategy explained in this statement and also raise a small number of additional detailed considerations. Support is given to the references to PAH’s strategy for the preferred and fall-back development options including the housing site allocation.

9. Concern is raised and clarification sought for the intended inclusion of a policy requiring construction standards to be in excess of current Building Regulations provisions for sustainable design and energy efficiency. This could have both procedural and viability implications concerning how the LPA may determine planning applications and how development may be affected. In short, planning policy should not seek to determine or duplicate matters that are addressed through separate legislation, i.e the Building Act 1984 in this instance.

10. Also, if higher construction standards are sought to be imposed, this may have viability consequences for development schemes, particularly in the current economic climate and therefore, any such policy would require a degree of flexibility to be built in to avoid potentially and unnecessarily stifling development. Therefore, further clarification and refinement is considered to be needed regarding Policy PL3.

11. Our Specific representations are set out below.

Specific Representations on Schedule of Main Modifications (MMs) – March 2020

12. MM3 – (Pages 57) Policy HS2: Housing Allocations, Ref. 1 Princess Alexandra Hospital. Support change of dwelling capacity target to 550 dwellings, which is also reflected in SoCG.

13. MM4 – (Pages 58-59) Policy HS3: Strategic Housing Site East of Harlow, Criterion 9f) provision of community infrastructure. Support inclusion of ‘healthcare facilities’ as part of infrastructure to be provided.

14. MM11 – (Page 93/94) Para 11.18 & following para – reference to re-provision of Princess Alexandra Hospital to East Harlow and fall-back redevelopment in situ option. Support inclusion of revised wording which is also reflected in SoCG.

15. We also note that the associated Schedule of Additional (Minor) Modifications (March 2020) document, includes references to the updated PAH position in paragraphs 5.38 and 5.39 of the Local Plan for consistency, as agreed in the SoCG.

16. MM14 – (Page 105) – Policy PL3 Sustainable Design, Construction and Energy Use, policy emphasis change and addition of further detailed supporting justification. No objection to the policy wording which seeks high standards of sustainable design, construction and energy efficiency. However, further clarification is required concerning the proposed revised supporting text at para 13.17. This text explains that development will be supported where it exceeds Building Regulations standards. The inference to this could be that development that does not exceed Building Regulations standards may not supported even if there was a good reason not to do so and therefore, could be refused planning permission if interpreted literally.

17. The legislation guiding Building Regulations is the Building Act 1984, whereas, planning matters are dealt with by separate Town & Country Planning legislation. Planning policy should not seek to determine or duplicate matters that are addressed through separate legislation and therefore, the interpretation and application of the text in para 13.17 needs to be clarified in this respect to avoid confusion and potential challenge.

18. Also, if higher constructions standards are sought to be imposed, this may have viability consequences for development schemes, particularly in the current economic climate, including healthcare and residential led schemes brought forward by PAH. Therefore, the application of Policy PL3 requires a degree of flexibility through the inclusion of a viability clause in a similar way that affordable housing and other developer contribution based policies are constructed. If such a suitable clause was applied in this instance, PAH would not object to the aspirational policy approach in PL3, which seeks high standards of design and sustainability.

We trust you will find our representations to be useful helpful as part of the Local Plan review process and please contact us if you require further clarification.

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7009

Received: 28/05/2020

Respondent: Historic England

Representation:

Thank you for consulting Historic England about the Proposed Modifications to the
Harlow Local Plan. We have the following comments to make on the suggested changes
to the Plan:
We welcome many of the proposed Main Modifications and Additional Modifications set
out in the Tables. Our detailed comments on the proposed Main Modifications and
Additional Modifications to the Plan are set out in Appendix A.
We have several outstanding areas of concern.
1. The first relates to Policy HGT1. The Inspector (17.12.19) had indicated that you
should use Historic England’s wording.
2. Secondly, for policy HS2, we continue to have concerns at the lack of detail in
relation to site allocations and policy wording.
3. Thirdly, in relation to policy HS3, the Inspector (17.12.19) had again indicated that
you should use Historic England’s wording.
4. Fourth, in relation to policy PL11, we continue to suggest that the reference to
enabling development should be removed and the Plan should include a policy to
address Heritage at Risk.
All of these issues are addressed in more detail in the accompanying Appendix A.

Finally, we should like to stress that this opinion is based on the information provided by
the Council in its consultation. To avoid any doubt, this does not affect our obligation to
provide further advice and, potentially, object to specific proposals, which may
subsequently arise where we consider that these would have an adverse effect upon the
historic environment.
If you have any queries about any of the matters raised or consider that a meeting would
be helpful, please do not hesitate to contact me.

(ALSO SEE ATTACHMENTS)

Full text:

Thank you for consulting Historic England about the Proposed Modifications to the
Harlow Local Plan. We have the following comments to make on the suggested changes
to the Plan:
We welcome many of the proposed Main Modifications and Additional Modifications set
out in the Tables. Our detailed comments on the proposed Main Modifications and
Additional Modifications to the Plan are set out in Appendix A.
We have several outstanding areas of concern.
1. The first relates to Policy HGT1. The Inspector (17.12.19) had indicated that you
should use Historic England’s wording.
2. Secondly, for policy HS2, we continue to have concerns at the lack of detail in
relation to site allocations and policy wording.
3. Thirdly, in relation to policy HS3, the Inspector (17.12.19) had again indicated that
you should use Historic England’s wording.
4. Fourth, in relation to policy PL11, we continue to suggest that the reference to
enabling development should be removed and the Plan should include a policy to
address Heritage at Risk.
All of these issues are addressed in more detail in the accompanying Appendix A.

Finally, we should like to stress that this opinion is based on the information provided by
the Council in its consultation. To avoid any doubt, this does not affect our obligation to
provide further advice and, potentially, object to specific proposals, which may
subsequently arise where we consider that these would have an adverse effect upon the
historic environment.
If you have any queries about any of the matters raised or consider that a meeting would
be helpful, please do not hesitate to contact me.

(ALSO SEE ATTACHMENTS)

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7010

Received: 28/05/2020

Respondent: Mr Alan Leverett

Representation:

In these unprecedented times it is clear that it cost of mitigating the pandemic will be over £123bn. If we are to survive without stupendous borrowing it will take in excess of 5 years to reach some kind of financial recovery. This together with the fact unemployment is going to rise to new record levels will make the aspirations in our Local Plan to be unachievable within the expected time frame. One has to ask is the current plan realistic to meet the needs of our community in light of the length of time we are to be under the influence of the pandemic.

The Local Plans for all local authorities involved with the Harlow and Gilston Garden Town have large amounts of residential properties proposed (admittedly some so called affordable). Who is going to be able to afford these when businesses are likely to fail and many people in Harlow and surrounding areas will be unemployed?

Another issue that must be addressed is how will the government fund the necessary infrastructure to facilitate the transport and community projects without any money left in the pot?

It is clear from the outcome of the Examination of Harlow Council’s Local Plan that it was deeply flawed in the way that it was prepared, information was not available on time and consultation with residents was woefully lacking. Evidence of this can be seen for example from the huge number of changes that have had to be made to the Plan, the amount of new information that became available during and after the Examination took place and the deletion of seven sites on which homes were to be built.

The arrogance shown by both local Political Parties, with a 'we know best attitude', indeed one Councillor saying in public that they did not consult residents further because it would not have made any difference just shows how out of touch those running Harlow Council are with residents.

HAP is pleased to see many of the changes made to the Plan. There seems to be no doubt that the objections raised by HAP, supported by hundreds of residents, to the proposals to build on many green field sites around the town were accepted by the Inspector. Keeping the golf course within the Green Belt is also to be applauded.

Many sentiments expressed within the Plan are at best aspirational. Few if any of those involved in producing the Plan and that of The Harlow and Gilston Garden Town can provide services themselves, whilst the capital costs for new schools, health centres and leisure and cultural services may be built, it is another matter when it comes to providing short, let alone long term revenue funding for these services and getting staff to work in them. Residents have for years complained about the lack of services within the town, waiting times at doctors surgeries, poor bus services, reduced council services, reduced school funding and the reduction in library services to name just a few. The existing residents of Harlow can only make judgements about this Plan from past experience, many will look on this Plan with deep concern for the towns future.

HAP have held numerous public meetings in 2019, from which it is clear that most people are not aware of the plans to expand Harlow, which in reality means building thousands of homes on the other side of Harlow’s boundary, destroying Green Belt land which is effectively Harlow’s but lies in neighbouring authorities. The one thing that has been mentioned time and time again is the pressure on Harlow's road system that the huge increase in the number of homes and thus population the area will see in the next 13 years and beyond. Car manufacturers are not spending billions of pounds to develop electric and driverless cars with an expectation that in the future most journeys will be taken using public transport or by walking or cycling.


Specific comments about the Plan

The document shows changes to the transport corridors but gives no explanation for why these changes have been made.

It would appear ludicrous to not include some of the existing estates along the Water Lane route for the Sustainable Transport as it would relieve pressure on the overall traffic congestion along Southern Way which will suffer from those entering the town from development to the South and Eastern boundaries.

There is no detail about what work will be done along these corridors to enhance what is already there.

Where will the Elizabeth Way traveller site be re-located?

Whilst one of the Plans main objectives must be to meet the housing need of a growing population, there is no undertaking to ensure that homes are built specifically for older residents, in the form of bungalows or complexes. In a survey carried out by The Harlow Alliance Party, over 80% of those responding want see such homes built in the town. This would free up homes that are larger than the needs of existing residents and make best use of the existing housing stock in the town.

The present cycleway in Harlow is the envy of most towns in the country but much of it is in a very poor state of repair and there are parts which need to be connected together. Without an undertaking to remedy these issues, it seems very unlikely that there will be any increase in their current use, which is a crucial element in trying to mitigate increased congestion on the town’s roads.

Whilst the council have expressed a wish to see 30% of all new homes being ‘affordable’, the ‘get out clauses’ in the Plan make it all too easy for developers to avoid building homes in such numbers, evidenced by recent Planning Applications. The plan should clearly state that unless a developer comes forward with a scheme which meets the 30% affordable criteria then the application will be refused.

It has been recently been suggested by the government that affordable housing requirements should be relaxed so as not to stop developments because the developer is unable to meet the cost. HAP is not supporting this view.

Full text:

In these unprecedented times it is clear that it cost of mitigating the pandemic will be over £123bn. If we are to survive without stupendous borrowing it will take in excess of 5 years to reach some kind of financial recovery. This together with the fact unemployment is going to rise to new record levels will make the aspirations in our Local Plan to be unachievable within the expected time frame. One has to ask is the current plan realistic to meet the needs of our community in light of the length of time we are to be under the influence of the pandemic.

The Local Plans for all local authorities involved with the Harlow and Gilston Garden Town have large amounts of residential properties proposed (admittedly some so called affordable). Who is going to be able to afford these when businesses are likely to fail and many people in Harlow and surrounding areas will be unemployed?

Another issue that must be addressed is how will the government fund the necessary infrastructure to facilitate the transport and community projects without any money left in the pot?

It is clear from the outcome of the Examination of Harlow Council’s Local Plan that it was deeply flawed in the way that it was prepared, information was not available on time and consultation with residents was woefully lacking. Evidence of this can be seen for example from the huge number of changes that have had to be made to the Plan, the amount of new information that became available during and after the Examination took place and the deletion of seven sites on which homes were to be built.

The arrogance shown by both local Political Parties, with a 'we know best attitude', indeed one Councillor saying in public that they did not consult residents further because it would not have made any difference just shows how out of touch those running Harlow Council are with residents.

HAP is pleased to see many of the changes made to the Plan. There seems to be no doubt that the objections raised by HAP, supported by hundreds of residents, to the proposals to build on many green field sites around the town were accepted by the Inspector. Keeping the golf course within the Green Belt is also to be applauded.

Many sentiments expressed within the Plan are at best aspirational. Few if any of those involved in producing the Plan and that of The Harlow and Gilston Garden Town can provide services themselves, whilst the capital costs for new schools, health centres and leisure and cultural services may be built, it is another matter when it comes to providing short, let alone long term revenue funding for these services and getting staff to work in them. Residents have for years complained about the lack of services within the town, waiting times at doctors surgeries, poor bus services, reduced council services, reduced school funding and the reduction in library services to name just a few. The existing residents of Harlow can only make judgements about this Plan from past experience, many will look on this Plan with deep concern for the towns future.

HAP have held numerous public meetings in 2019, from which it is clear that most people are not aware of the plans to expand Harlow, which in reality means building thousands of homes on the other side of Harlow’s boundary, destroying Green Belt land which is effectively Harlow’s but lies in neighbouring authorities. The one thing that has been mentioned time and time again is the pressure on Harlow's road system that the huge increase in the number of homes and thus population the area will see in the next 13 years and beyond. Car manufacturers are not spending billions of pounds to develop electric and driverless cars with an expectation that in the future most journeys will be taken using public transport or by walking or cycling.


Specific comments about the Plan

The document shows changes to the transport corridors but gives no explanation for why these changes have been made.

It would appear ludicrous to not include some of the existing estates along the Water Lane route for the Sustainable Transport as it would relieve pressure on the overall traffic congestion along Southern Way which will suffer from those entering the town from development to the South and Eastern boundaries.

There is no detail about what work will be done along these corridors to enhance what is already there.

Where will the Elizabeth Way traveller site be re-located?

Whilst one of the Plans main objectives must be to meet the housing need of a growing population, there is no undertaking to ensure that homes are built specifically for older residents, in the form of bungalows or complexes. In a survey carried out by The Harlow Alliance Party, over 80% of those responding want see such homes built in the town. This would free up homes that are larger than the needs of existing residents and make best use of the existing housing stock in the town.

The present cycleway in Harlow is the envy of most towns in the country but much of it is in a very poor state of repair and there are parts which need to be connected together. Without an undertaking to remedy these issues, it seems very unlikely that there will be any increase in their current use, which is a crucial element in trying to mitigate increased congestion on the town’s roads.

Whilst the council have expressed a wish to see 30% of all new homes being ‘affordable’, the ‘get out clauses’ in the Plan make it all too easy for developers to avoid building homes in such numbers, evidenced by recent Planning Applications. The plan should clearly state that unless a developer comes forward with a scheme which meets the 30% affordable criteria then the application will be refused.

It has been recently been suggested by the government that affordable housing requirements should be relaxed so as not to stop developments because the developer is unable to meet the cost. HAP is not supporting this view.

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7011

Received: 28/05/2020

Respondent: Barratt Strategic, Persimmon & Taylor Wimpey

Representation:

(SEE ATTACHMENT)

Full text:

(SEE ATTACHMENT)

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7012

Received: 28/05/2020

Respondent: Epping Upland Parish Council

Representation:

Further to your letter dated 27 March 2020 regarding the extension to the plan modification extensions closing date. Please note that the parish council planning committee have considered the plans and have the following comments to make:

Our concerns are that included in the plan is substantial erosion of the green belt and loss of farmland.

We are also unable to see how the transport infrastructure will cope with the increased extension.

Full text:

Further to your letter dated 27 March 2020 regarding the extension to the plan modification extensions closing date. Please note that the parish council planning committee have considered the plans and have the following comments to make:

Our concerns are that included in the plan is substantial erosion of the green belt and loss of farmland.

We are also unable to see how the transport infrastructure will cope with the increased extension.

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7013

Received: 29/05/2020

Respondent: National Grid

Representation:

National Grid has appointed Avison Young to review and respond to
local planning authority Development Plan Document consultations on its
behalf. We are instructed by our client to submit the following
representation with regard to the current consultation on the above
document.
About National Grid
National Grid Electricity Transmission plc (NGET) owns and maintains the
electricity transmission system in England and Wales. The energy is then
distributed to the electricity distribution network operators, so it can reach
homes and businesses.

National Grid Gas plc (NGG) owns and operates the high-pressure gas
transmission system across the UK. In the UK, gas leaves the transmission
system and enters the UK’s four gas distribution networks where pressure is
reduced for public use.
National Grid Ventures (NGV) is separate from National Grid’s core
regulated businesses. NGV develop, operate and invest in energy
projects, technologies, and partnerships to help accelerate the
development of a clean energy future for consumers across the UK,
Europe and the United States.
Proposed development sites crossed or in close proximity to National Grid
assets:
Following a review of the above Development Plan Document, we have
identified that one or more proposed development sites are crossed or in
close proximity to National Grid assets.
Details of the sites affecting National Grid assets are provided below.

Gas Transmission
Development Plan Document
Site Reference

Asset Description

SIR1-5 Pardndon Wood
Cemetry Extension

Gas Transmission Pipeline, route: MATCHING GREEN TO RYE HOUSE
A plan showing details of the site locations and details of National Grid’s assets is attached to
this letter. Please note that this plan is illustrative only.
Please also see attached information outlining further guidance on development close to National
Grid assets.
Further Advice
National Grid is happy to provide advice and guidance to the Council concerning their networks. If
we can be of any assistance to you in providing informal comments in confidence during your policy
development, please do not hesitate to contact us.

To help ensure the continued safe operation of existing sites and equipment and to facilitate future
infrastructure investment, National Grid wishes to be involved in the preparation, alteration and
review of plans and strategies which may affect their assets. Please remember to consult National
Grid on any Development Plan Document (DPD) or site-specific proposals that could affect National
Grid’s assets. We would be grateful if you could check that our details as shown below are included
on your consultation database:

(ALSO SEE ATTACHMENT)

Full text:

National Grid has appointed Avison Young to review and respond to
local planning authority Development Plan Document consultations on its
behalf. We are instructed by our client to submit the following
representation with regard to the current consultation on the above
document.
About National Grid
National Grid Electricity Transmission plc (NGET) owns and maintains the
electricity transmission system in England and Wales. The energy is then
distributed to the electricity distribution network operators, so it can reach
homes and businesses.

National Grid Gas plc (NGG) owns and operates the high-pressure gas
transmission system across the UK. In the UK, gas leaves the transmission
system and enters the UK’s four gas distribution networks where pressure is
reduced for public use.
National Grid Ventures (NGV) is separate from National Grid’s core
regulated businesses. NGV develop, operate and invest in energy
projects, technologies, and partnerships to help accelerate the
development of a clean energy future for consumers across the UK,
Europe and the United States.
Proposed development sites crossed or in close proximity to National Grid
assets:
Following a review of the above Development Plan Document, we have
identified that one or more proposed development sites are crossed or in
close proximity to National Grid assets.
Details of the sites affecting National Grid assets are provided below.

Gas Transmission
Development Plan Document
Site Reference

Asset Description

SIR1-5 Pardndon Wood
Cemetry Extension

Gas Transmission Pipeline, route: MATCHING GREEN TO RYE HOUSE
A plan showing details of the site locations and details of National Grid’s assets is attached to
this letter. Please note that this plan is illustrative only.
Please also see attached information outlining further guidance on development close to National
Grid assets.
Further Advice
National Grid is happy to provide advice and guidance to the Council concerning their networks. If
we can be of any assistance to you in providing informal comments in confidence during your policy
development, please do not hesitate to contact us.

To help ensure the continued safe operation of existing sites and equipment and to facilitate future
infrastructure investment, National Grid wishes to be involved in the preparation, alteration and
review of plans and strategies which may affect their assets. Please remember to consult National
Grid on any Development Plan Document (DPD) or site-specific proposals that could affect National
Grid’s assets. We would be grateful if you could check that our details as shown below are included
on your consultation database:

(ALSO SEE ATTACHMENT)

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7014

Received: 29/05/2020

Respondent: The Roydon Society

Representation:

Thanks for making the Society aware of changes to the above. We were pleased to see amendments have been made in regards to parking provision which was one of the comments the Society had.



One comment on the amended plan was the reduction of housing provision in the hatches, garage sites etc, reduced from over 1000 to just over 800. Where will the 200 odd houses now be allocated to make up the total number for Harlow?



That was the Society's only comment.

Full text:

Thanks for making the Society aware of changes to the above. We were pleased to see amendments have been made in regards to parking provision which was one of the comments the Society had.



One comment on the amended plan was the reduction of housing provision in the hatches, garage sites etc, reduced from over 1000 to just over 800. Where will the 200 odd houses now be allocated to make up the total number for Harlow?



That was the Society's only comment.

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7015

Received: 29/05/2020

Respondent: Home Builders Federation

Representation:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Full text:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7016

Received: 29/05/2020

Respondent: Thames Water

Representation:

Thank you for consulting Thames Water on the above document. Thames Water is the statutory sewerage undertaker for the area and is hence a “specific consultation body” in accordance with the Town & Country Planning (Local Development) Regulations 2012. We have been liaising with the Council and adjoining boroughs in relation to sewerage infrastructure requirements to support growth in and around Harlow and will continue to do so in order to ensure that the growth proposed is supported by any necessary wastewater infrastructure.
In relation to the proposed main modifications we have the following comments.
General Comments
It is noted that the changes to Policy HS1 include an increase in potential housing development over the plan period from 9,200 to 10,620 homes.

It is acknowledged that the surplus allows for flexibility, possible slippage of large sites and for some permissions to lapse. However, if all the 10,620 homes were to come forward over the Local Plan period this could impact on the capacity of sewage infrastructure including treatment capacity at Rye Meads Sewage Treatment Works. As such, Thames Water would seek to continue close engagement with the local authority and developers, together with other adjoining local authorities, following the implementation of the new Local Plan. Such engagement will be essential in order to monitor development coming forward and the rates of delivery and ensure that the impacts on sewage treatment and network infrastructure are fully understood with necessary upgrades programmed accordingly.
I trust the above and enclosed comments are satisfactory, but please do not hesitate to contact me if you have any queries.

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Full text:

Thank you for consulting Thames Water on the above document. Thames Water is the statutory sewerage undertaker for the area and is hence a “specific consultation body” in accordance with the Town & Country Planning (Local Development) Regulations 2012. We have been liaising with the Council and adjoining boroughs in relation to sewerage infrastructure requirements to support growth in and around Harlow and will continue to do so in order to ensure that the growth proposed is supported by any necessary wastewater infrastructure.
In relation to the proposed main modifications we have the following comments.
General Comments
It is noted that the changes to Policy HS1 include an increase in potential housing development over the plan period from 9,200 to 10,620 homes.

It is acknowledged that the surplus allows for flexibility, possible slippage of large sites and for some permissions to lapse. However, if all the 10,620 homes were to come forward over the Local Plan period this could impact on the capacity of sewage infrastructure including treatment capacity at Rye Meads Sewage Treatment Works. As such, Thames Water would seek to continue close engagement with the local authority and developers, together with other adjoining local authorities, following the implementation of the new Local Plan. Such engagement will be essential in order to monitor development coming forward and the rates of delivery and ensure that the impacts on sewage treatment and network infrastructure are fully understood with necessary upgrades programmed accordingly.
I trust the above and enclosed comments are satisfactory, but please do not hesitate to contact me if you have any queries.

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7017

Received: 29/05/2020

Respondent: Essex County Council

Representation:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Full text:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Attachments:

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7018

Received: 29/05/2020

Respondent: Barton Willmore

Representation:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Full text:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Attachments:

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7019

Received: 29/05/2020

Respondent: Powerrapid

Representation:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Full text:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7020

Received: 29/05/2020

Respondent: Canal & River Trust

Representation:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Full text:

(SEE ATTACHMENT FOR ORIGINAL LETTER)

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7021

Received: 31/05/2020

Respondent: Mrs Amanda Henderson

Representation:

I am a member of Harlow Steel Band and we are based at the Lutheran Church in Tawneys Road. If this building is knocked down, we will be homeless. We have a lot of equipment and need storage and practice space. Also, where are the members of the Church supposed to worship??

Full text:

I am a member of Harlow Steel Band and we are based at the Lutheran Church in Tawneys Road. If this building is knocked down, we will be homeless. We have a lot of equipment and need storage and practice space. Also, where are the members of the Church supposed to worship??

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7022

Received: 31/05/2020

Respondent: Mr Stephen Ashworth

Representation:

Policy IN6 should be expanded to provide a better and clearer platform for the recovery of appropriate planning contributions, in particular towards strategic infrastructure benefiting the area as a whole both within the present plan period and beyond.

Full text:

I write on behalf of Places for People Developments Ltd, the promoters of Gilston Park Estate. Representations were submitted at all stages of the Local Plan process on their behalf suggesting that the framework for securing infrastructure contributions should be clearer, and should provide a better foundation for future SPDs. In particular it was suggested that it should be clear that contributions would be required, where appropriate towards strategic infrastructure (such as the new river crossings) from all types and sized of development, within the present and future plan periods. MM1 recognises the need for contributions in relation to development covered by HGT1, although there is concern about the linkage to the IDP (on which Places for People made separate representations) . Places for People believe that IN6 should be expanded to outline the nature and type of contributions that will be sought, from what types of development and over what period, set out the anticipated relationship with CIL, and should recognise that in calculating contributions the local planning authority should take account of existing infrastructure deficiencies. Given that Housing Infrastructure Fund recycling will depend, in part, on the strength of the policy framework it is disappointing that a stronger planning policy platform has not been promoted.

Although this representation is made in relation to the Main Modifications our view is that the necessary changes could be made by way of Additional (Minor) Modifications.

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7023

Received: 01/06/2020

Respondent: Natural England

Representation:

Thank you for your consultation on the above dated the 12th of March 2020.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
Natural England welcomes the progression of Harlow Local Plan and is in general satisfied that the
modifications proposed are appropriate. We do, however, have some concerns regarding the
wording used for policy WE3.

Under the heading of ‘Nationally Designated Wildlife Sites’ the policy sets out 4 criteria (marked a to
d) which would allow development to be supported. These ‘tests’, particularly a) that development
would be supported if it is required in connection with the management or conservation of the site,
c) imperative reasons of overriding public interest and d) no suitable alternatives are those set out in
the Conservation of Habitats and Species Regulations 2017 and as such are more appropriate for
‘Internationally Designated Wildlife Sites’. We advise that plans should distinguish between the
hierarchy of sites and offer policies commensurate with the level of protection.
Natural England notes that in policy WE3 the main modification advises that the Epping Forest
Mitigation Strategy must be in place by the time of the local plan adoption. In general Natural
England supports this approach and this is in accordance with our previous advice. We note,
however, that in this case very limited development within the Harlow district is proposed within the
current recreational Zone of Influence for Epping Forest Special Area of Conservation (SAC) and
preliminary reading of further survey work suggests that there is unlikely to be a significant
expansion of the Zone of Influence for the foreseeable future. See also our previous advice relating
to air quality.

The inspector for nearby Broxbourne Local Plan in his ‘Report on the Examination of the
Broxbourne Local Plan’ dated the 14th of April 2020 took the view that it would not be reasonable to
require the mitigation strategy to be in place before the plan is adopted as it was being prepared by
a 3rd party and that he was nevertheless satisfied that the necessary mitigation measures would be
delivered. Whilst in that case Natural England contested that Broxbourne, as a competent authority
under the Habitat Regulations, should jointly take responsibility for the mitigation strategy we do
recognise the difficulties this poses. With regards to Harlow specifically, given that its district
boundary is further away from the SAC than Broxbourne’s and that the local plan allocates
negligible levels of development in the south of the district we consider it a matter for the inspectors
discretion as to whether the requirement for the mitigation strategy is proportionate provided that he
is satisfied that any required mitigation remains deliverable.

Paragraph 3 of MM10: Policy WE3a Implementation states that “In terms of air quality, it is
estimated that 99% of all additional vehicle movements through Epping Forest SAC during the plan
period will arise from growth in Epping Forest district rather than the neighbouring authorities
including Harlow.” Natural England does not hold data on the above but instinctively this feels
unlikely to be true and advises that it is checked. We say this without prejudice to the rest of the
paragraph and if that is indeed what the modelling shows – we are not raising any concerns.
We welcome the references to the requirements of net gains for biodiversity.
We would be happy to comment further should the need arise but if in the meantime you have any
queries please do not hesitate to contact us.
For any queries relating to the specific advice in this letter only please contact Jamie Melvin on 020
802 61025. For any new consultations, or to provide further information on this consultation please
send your correspondences to consultations@naturalengland.org.uk.

(ALSO SEE ATTACHMENT FOR ORIGINAL LETTER)

Full text:

Thank you for your consultation on the above dated the 12th of March 2020.
Natural England is a non-departmental public body. Our statutory purpose is to ensure that the
natural environment is conserved, enhanced, and managed for the benefit of present and future
generations, thereby contributing to sustainable development.
Natural England welcomes the progression of Harlow Local Plan and is in general satisfied that the
modifications proposed are appropriate. We do, however, have some concerns regarding the
wording used for policy WE3.

Under the heading of ‘Nationally Designated Wildlife Sites’ the policy sets out 4 criteria (marked a to
d) which would allow development to be supported. These ‘tests’, particularly a) that development
would be supported if it is required in connection with the management or conservation of the site,
c) imperative reasons of overriding public interest and d) no suitable alternatives are those set out in
the Conservation of Habitats and Species Regulations 2017 and as such are more appropriate for
‘Internationally Designated Wildlife Sites’. We advise that plans should distinguish between the
hierarchy of sites and offer policies commensurate with the level of protection.
Natural England notes that in policy WE3 the main modification advises that the Epping Forest
Mitigation Strategy must be in place by the time of the local plan adoption. In general Natural
England supports this approach and this is in accordance with our previous advice. We note,
however, that in this case very limited development within the Harlow district is proposed within the
current recreational Zone of Influence for Epping Forest Special Area of Conservation (SAC) and
preliminary reading of further survey work suggests that there is unlikely to be a significant
expansion of the Zone of Influence for the foreseeable future. See also our previous advice relating
to air quality.

The inspector for nearby Broxbourne Local Plan in his ‘Report on the Examination of the
Broxbourne Local Plan’ dated the 14th of April 2020 took the view that it would not be reasonable to
require the mitigation strategy to be in place before the plan is adopted as it was being prepared by
a 3rd party and that he was nevertheless satisfied that the necessary mitigation measures would be
delivered. Whilst in that case Natural England contested that Broxbourne, as a competent authority
under the Habitat Regulations, should jointly take responsibility for the mitigation strategy we do
recognise the difficulties this poses. With regards to Harlow specifically, given that its district
boundary is further away from the SAC than Broxbourne’s and that the local plan allocates
negligible levels of development in the south of the district we consider it a matter for the inspectors
discretion as to whether the requirement for the mitigation strategy is proportionate provided that he
is satisfied that any required mitigation remains deliverable.

Paragraph 3 of MM10: Policy WE3a Implementation states that “In terms of air quality, it is
estimated that 99% of all additional vehicle movements through Epping Forest SAC during the plan
period will arise from growth in Epping Forest district rather than the neighbouring authorities
including Harlow.” Natural England does not hold data on the above but instinctively this feels
unlikely to be true and advises that it is checked. We say this without prejudice to the rest of the
paragraph and if that is indeed what the modelling shows – we are not raising any concerns.
We welcome the references to the requirements of net gains for biodiversity.
We would be happy to comment further should the need arise but if in the meantime you have any
queries please do not hesitate to contact us.
For any queries relating to the specific advice in this letter only please contact Jamie Melvin on 020
802 61025. For any new consultations, or to provide further information on this consultation please
send your correspondences to consultations@naturalengland.org.uk.

(ALSO SEE ATTACHMENT FOR ORIGINAL LETTER)

Attachments:

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7024

Received: 01/06/2020

Respondent: Harlow Conservatives

Representation:

May 2020
Consultation response by The Conservative Group on Harlow Council
Main modifications to the pre-submission version of the Harlow Local Plan
Dear Sirs
We are responding to the consultation on the main modifications to the Harlow Local Plan published by Harlow District Council earlier this year. Several Conservative councillors have also responded individually.
It is, of course, important that Harlow Council has an up-to-date local plan to provide structure for the future development and growth of the town, preventing speculative and uncontrolled development, but it should not be at any cost and residents should have been involved at every stage of its development.
Overarching the whole of the local plan process, the Conservative Group feels that Harlow Council has completely failed in its duty to properly consult local residents about the true scale of development proposed in the current version of the Local Plan. By choosing to prematurely conduct a Regulation 19 consultation they focused narrowly on only the technical elements of the plan process that will govern development up to 2033.
It was both surprising and sad that Harlow Council refused to pursue a second Regulation 18 process to allow open debate about, in particular, the proposed growth locations for new housing developments.
We, as an opposition group, have opposed the Harlow Local Plan and the Epping Forest Local Plan over the last decade. We still strongly feel that development should not be on green belt or green wedges within Harlow, and not to the south or south west of the town in Epping Forest. We have consistently made these points at council meetings and working groups during that period but as the opposition we have been powerless to change the council’s path.
The Labour administration, however, has changed path and on several occasions. Initially, it agreed with the Conservative view of opposing development to the south and south west of Harlow and submitted an objection to Epping Forest’s Local Plan consultation to that effect. It then had to bring that back to full council to reverse the decision and remove the objection, again without consultation with the public.
This is a common theme with the council’s approach to the draft plan and a key criticism we would like to raise in this consultation. There has been a distinct failure on the part of Harlow District Council to properly involve and consult with residents of the town. There was no real effort to engage with residents, largely leaving them to find out about the consultations instead of being proactive and encouraging people to participate in the planning of the future of their town. The level of response to the Reg 18 and Reg 19 consultations were the result: 126 and 74 respectively. We believe that it is not the case that residents of Harlow do not care about their and the town’s future, it is that they did not know about the consultations.
Across many wards there is a very low level of awareness of the Local Plan. By not consulting properly, Harlow Council has failed to achieve any buy-in from the local community. Many residents have been left confused by the approach taken by the council and the lack of communication about one of the most important governing documents that will shape the town’s future for decades to come.
Apart from the lack of leadership from the council and the lack of meaningful consultation, the Local Plan, as it stands, aims to exacerbate divisions within Harlow.
This lack of consultation also extends to neighbouring authorities. There has been poor communication with neighbouring authorities under the duty to cooperate. This has meant that other potential growth sites have not been properly considered to meet Harlow’s overall dwelling supply target over the next 30 years.
Furthermore, discussions with neighbouring authorities over the Local Plan and the progression of the Harlow & Gilston Garden Community have been very much one-sided: the administration has failed to secure any sharing of the benefits of development, such as affordable housing, council tax and New Homes Bonus. This in the full knowledge that Harlow will have to endure the pressure on its infrastructure, including: education, health, traffic and pressure on our town centre, issues over which we will have no control or influence.
There is an anomaly in the proposed modifications which discriminates against people with disabilities, contrary to the Equality Act 2010. On the one hand, all new properties should meet Part M4(2) but only if the developer deems them affordable. On the other, in MM14, developments that exceed the minimum standard for insulation by 19% will be supported, which appears to provide a regulatory excuse for developers to claim that accessible homes are unaffordable as they have to meet far more stringent insulating requirements, in excess of building regulations and of other planning authorities. Meeting the real and practical needs of disabled people should not be in effect “optional”.
MM4 Policy HS2 Housing Allocations
Ref 3. Land East of Katherines Way, west of Deer Park – The Conservative Group welcomes the Planning Inspector’s decision to reinstate this site as Green Wedge.
Ref 9. Land east of 144-154 Fennells – It is a positive step that the Planning Inspector has requested this site be deleted as a housing site. Harlow Council should protect the site from the prospect of future attempts to build housing and designate it as Green Belt.
Ref 15. Playground west of 93-100 Jocelyns – The Planning Inspector was right to recommend the removal of Jocelyns Park as a potential housing site. This park should be fully reinstated as Green Wedge because there is no man-made or natural barrier separating the park and the tree belt bordering the site, it is the same land and should be given the same level of protection.


Conclusion
The Conservative Group continues to have serious reservations about the Local Plan. Harlow Council has been able to balance urban development with the need for green spaces in the past but the administration’s plan is a threat to the vision that has held true for decades.
There are some potential positive infrastructure developments. The Conservative Group supports the preferred site for a new Harlow Hospital because it is a once in a generation opportunity to improve healthcare provision in the town.
The Conservative Government’s decision to invest in the Enterprise Zone and the new headquarters for Public Health England in Harlow are significant milestones for the town, but the Labour council administration is failing to provide the leadership required to integrate these huge investments into the town, and ensure the support they need.
There is a clear need for more accessible homes to be met through new developments and the Local Plan should reflect this.
Suggested recommendations
1. The Planning Inspector should pause the Local Plan process and request that Harlow Council undertake a new comprehensive analysis of the infrastructure requirements needed for all the identified housing growth locations. A new indicative strategic planning assessment for the whole town should be produced at the very least.
2. All housing allocation sites that have been recommended for removal by the Planning Inspector should be given the appropriate protection to avoid consideration as potential housing sites in the future.
3. The Planning Inspector should request that Harlow Council conduct further consultation with residents about the potential implications of the identified strategic housing sites before any implementation commences.
4. Harlow Council should publish all its written communications with neighbouring authorities under the duty to cooperate in the interests of transparency.
5. In MM22 Policy H5 paragraph (a) should be amended to ‘all new properties must be at least Building Regulations Part M4(2) . . .”

Yours faithfully
On behalf of Harlow Conservative Group on Harlow District Council.
Cllr Andrew Johnson – Leader
Cllr Michael Hardware – Shadow Portfolio Holder for Environment

(ALSO SEE ATTACHMENT FOR ORIGINAL LETTER)

Full text:

May 2020
Consultation response by The Conservative Group on Harlow Council
Main modifications to the pre-submission version of the Harlow Local Plan
Dear Sirs
We are responding to the consultation on the main modifications to the Harlow Local Plan published by Harlow District Council earlier this year. Several Conservative councillors have also responded individually.
It is, of course, important that Harlow Council has an up-to-date local plan to provide structure for the future development and growth of the town, preventing speculative and uncontrolled development, but it should not be at any cost and residents should have been involved at every stage of its development.
Overarching the whole of the local plan process, the Conservative Group feels that Harlow Council has completely failed in its duty to properly consult local residents about the true scale of development proposed in the current version of the Local Plan. By choosing to prematurely conduct a Regulation 19 consultation they focused narrowly on only the technical elements of the plan process that will govern development up to 2033.
It was both surprising and sad that Harlow Council refused to pursue a second Regulation 18 process to allow open debate about, in particular, the proposed growth locations for new housing developments.
We, as an opposition group, have opposed the Harlow Local Plan and the Epping Forest Local Plan over the last decade. We still strongly feel that development should not be on green belt or green wedges within Harlow, and not to the south or south west of the town in Epping Forest. We have consistently made these points at council meetings and working groups during that period but as the opposition we have been powerless to change the council’s path.
The Labour administration, however, has changed path and on several occasions. Initially, it agreed with the Conservative view of opposing development to the south and south west of Harlow and submitted an objection to Epping Forest’s Local Plan consultation to that effect. It then had to bring that back to full council to reverse the decision and remove the objection, again without consultation with the public.
This is a common theme with the council’s approach to the draft plan and a key criticism we would like to raise in this consultation. There has been a distinct failure on the part of Harlow District Council to properly involve and consult with residents of the town. There was no real effort to engage with residents, largely leaving them to find out about the consultations instead of being proactive and encouraging people to participate in the planning of the future of their town. The level of response to the Reg 18 and Reg 19 consultations were the result: 126 and 74 respectively. We believe that it is not the case that residents of Harlow do not care about their and the town’s future, it is that they did not know about the consultations.
Across many wards there is a very low level of awareness of the Local Plan. By not consulting properly, Harlow Council has failed to achieve any buy-in from the local community. Many residents have been left confused by the approach taken by the council and the lack of communication about one of the most important governing documents that will shape the town’s future for decades to come.
Apart from the lack of leadership from the council and the lack of meaningful consultation, the Local Plan, as it stands, aims to exacerbate divisions within Harlow.
This lack of consultation also extends to neighbouring authorities. There has been poor communication with neighbouring authorities under the duty to cooperate. This has meant that other potential growth sites have not been properly considered to meet Harlow’s overall dwelling supply target over the next 30 years.
Furthermore, discussions with neighbouring authorities over the Local Plan and the progression of the Harlow & Gilston Garden Community have been very much one-sided: the administration has failed to secure any sharing of the benefits of development, such as affordable housing, council tax and New Homes Bonus. This in the full knowledge that Harlow will have to endure the pressure on its infrastructure, including: education, health, traffic and pressure on our town centre, issues over which we will have no control or influence.
There is an anomaly in the proposed modifications which discriminates against people with disabilities, contrary to the Equality Act 2010. On the one hand, all new properties should meet Part M4(2) but only if the developer deems them affordable. On the other, in MM14, developments that exceed the minimum standard for insulation by 19% will be supported, which appears to provide a regulatory excuse for developers to claim that accessible homes are unaffordable as they have to meet far more stringent insulating requirements, in excess of building regulations and of other planning authorities. Meeting the real and practical needs of disabled people should not be in effect “optional”.
MM4 Policy HS2 Housing Allocations
Ref 3. Land East of Katherines Way, west of Deer Park – The Conservative Group welcomes the Planning Inspector’s decision to reinstate this site as Green Wedge.
Ref 9. Land east of 144-154 Fennells – It is a positive step that the Planning Inspector has requested this site be deleted as a housing site. Harlow Council should protect the site from the prospect of future attempts to build housing and designate it as Green Belt.
Ref 15. Playground west of 93-100 Jocelyns – The Planning Inspector was right to recommend the removal of Jocelyns Park as a potential housing site. This park should be fully reinstated as Green Wedge because there is no man-made or natural barrier separating the park and the tree belt bordering the site, it is the same land and should be given the same level of protection.


Conclusion
The Conservative Group continues to have serious reservations about the Local Plan. Harlow Council has been able to balance urban development with the need for green spaces in the past but the administration’s plan is a threat to the vision that has held true for decades.
There are some potential positive infrastructure developments. The Conservative Group supports the preferred site for a new Harlow Hospital because it is a once in a generation opportunity to improve healthcare provision in the town.
The Conservative Government’s decision to invest in the Enterprise Zone and the new headquarters for Public Health England in Harlow are significant milestones for the town, but the Labour council administration is failing to provide the leadership required to integrate these huge investments into the town, and ensure the support they need.
There is a clear need for more accessible homes to be met through new developments and the Local Plan should reflect this.
Suggested recommendations
1. The Planning Inspector should pause the Local Plan process and request that Harlow Council undertake a new comprehensive analysis of the infrastructure requirements needed for all the identified housing growth locations. A new indicative strategic planning assessment for the whole town should be produced at the very least.
2. All housing allocation sites that have been recommended for removal by the Planning Inspector should be given the appropriate protection to avoid consideration as potential housing sites in the future.
3. The Planning Inspector should request that Harlow Council conduct further consultation with residents about the potential implications of the identified strategic housing sites before any implementation commences.
4. Harlow Council should publish all its written communications with neighbouring authorities under the duty to cooperate in the interests of transparency.
5. In MM22 Policy H5 paragraph (a) should be amended to ‘all new properties must be at least Building Regulations Part M4(2) . . .”

Yours faithfully
On behalf of Harlow Conservative Group on Harlow District Council.
Cllr Andrew Johnson – Leader
Cllr Michael Hardware – Shadow Portfolio Holder for Environment

(ALSO SEE ATTACHMENT FOR ORIGINAL LETTER)

Attachments:

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7025

Received: 01/06/2020

Respondent: Harlow Conservatives

Representation:

May 2020
Consultation response by Cllr Michael Hardware, Staple Tye Ward
Main modifications to the pre-submission version of the Harlow Local Plan
Dear Sirs
I am responding to the consultation on the main modifications published by Harlow District Council earlier this year.
Although it is important that a council has an up-to-date local plan to provide the structure for the future development and growth of the town, it should not be at any cost.
There has been a distinct failure on the part of Harlow District Council to properly involve and consult with residents of the town. There was no real effort to engage with residents, largely leaving them to find out about the consultations instead of being proactive and encouraging people to participate in the planning of the future of their town. The level of response to the Reg 18 and Reg 19 consultations were the result: 126 and 74 respectively. It is not that the residents of Harlow do not care about their future, it is that they did not know about the consultation.
In my ward, Staple Tye, there is a very low level of awareness of the local plan. By not consulting properly, Harlow Council has failed to achieve any buy-in from the local community. Many residents have been left confused by the approach taken by the council and the lack of communication about one of the most important governing documents that will shape the town’s future for decades to come.
Apart from the lack of consultation, there are just a few issues I want to focus on in my consultation response.
1. MM1 Chapter intro
The reference to the four Garden Town Communities (Water Lane, Gilston Villages, Latton Priory and East Harlow) “must integrate with and regenerate neighbouring areas of Harlow” is crucial and needs to be made more explicit. Without such integration and regeneration, a divided town will be created – the new town, built to Garden Town standards, and the old town, which will be viewed as a lower standard. The new needs to be fully integrated with the old to avoid alienation between them.
Using the term “Garden Town Communities” is wrong: there is only one Garden Town, and that is Harlow and Gilston Garden Town, by separating the new elements into communities, you are exacerbating the division mentioned above – they should perhaps be called “the four new garden communities within the Garden Town”.
The capitalisation is also wrong: Garden Town Communities is not a common noun, but the Garden Town is (as in Harlow and Gilston Garden Town).
2. MM1 Policy HGT1 Page 38 (i)
Why are seeking to only reduce single-occupant car journeys? The aim is to reduce car journeys per se. Remove “single-occupant”.
Under (p) there is a missing ‘)’ after M11 J7a.
Under (q) does this mean developers need to make contributions to all the highway requirements in the IDP, or just those adjoining their development? It is not clear and needs to be.
Yours faithfully
Cllr Michael Hardware
Conservative Councillor for Staple Tye

(ALSO SEE ATTACHMENT FOR ORIGINAL LETTER)

Full text:

May 2020
Consultation response by Cllr Michael Hardware, Staple Tye Ward
Main modifications to the pre-submission version of the Harlow Local Plan
Dear Sirs
I am responding to the consultation on the main modifications published by Harlow District Council earlier this year.
Although it is important that a council has an up-to-date local plan to provide the structure for the future development and growth of the town, it should not be at any cost.
There has been a distinct failure on the part of Harlow District Council to properly involve and consult with residents of the town. There was no real effort to engage with residents, largely leaving them to find out about the consultations instead of being proactive and encouraging people to participate in the planning of the future of their town. The level of response to the Reg 18 and Reg 19 consultations were the result: 126 and 74 respectively. It is not that the residents of Harlow do not care about their future, it is that they did not know about the consultation.
In my ward, Staple Tye, there is a very low level of awareness of the local plan. By not consulting properly, Harlow Council has failed to achieve any buy-in from the local community. Many residents have been left confused by the approach taken by the council and the lack of communication about one of the most important governing documents that will shape the town’s future for decades to come.
Apart from the lack of consultation, there are just a few issues I want to focus on in my consultation response.
1. MM1 Chapter intro
The reference to the four Garden Town Communities (Water Lane, Gilston Villages, Latton Priory and East Harlow) “must integrate with and regenerate neighbouring areas of Harlow” is crucial and needs to be made more explicit. Without such integration and regeneration, a divided town will be created – the new town, built to Garden Town standards, and the old town, which will be viewed as a lower standard. The new needs to be fully integrated with the old to avoid alienation between them.
Using the term “Garden Town Communities” is wrong: there is only one Garden Town, and that is Harlow and Gilston Garden Town, by separating the new elements into communities, you are exacerbating the division mentioned above – they should perhaps be called “the four new garden communities within the Garden Town”.
The capitalisation is also wrong: Garden Town Communities is not a common noun, but the Garden Town is (as in Harlow and Gilston Garden Town).
2. MM1 Policy HGT1 Page 38 (i)
Why are seeking to only reduce single-occupant car journeys? The aim is to reduce car journeys per se. Remove “single-occupant”.
Under (p) there is a missing ‘)’ after M11 J7a.
Under (q) does this mean developers need to make contributions to all the highway requirements in the IDP, or just those adjoining their development? It is not clear and needs to be.
Yours faithfully
Cllr Michael Hardware
Conservative Councillor for Staple Tye

(ALSO SEE ATTACHMENT FOR ORIGINAL LETTER)

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7026

Received: 01/06/2020

Respondent: East Herts District Council

Representation:

(SEE ATTACHMENT FOR REPORT)

Full text:

(SEE ATTACHMENT FOR REPORT)

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7027

Received: 01/06/2020

Respondent: Epping Forest District Council

Representation:

SEE ATTACHMENTS FOR ORIGINAL SUBMISSIONS.

Full text:

SEE ATTACHMENTS FOR ORIGINAL SUBMISSIONS.

Attachments:

Comment

Local Development Plan Main Modifications Consultation

Representation ID: 7028

Received: 01/06/2020

Respondent: Environment Agency

Representation:

We would like to make the following comments and observations:



WE1 Strategic Green Infrastructure - We are pleased to see our comments have been taken on board.



PL10 Water Quality, Water Management, Flooding and SuDS - We are pleased to see that the majority of our comments have been taken on board.



PL10 Water Quality, Water Management, Flooding and SuDS (Implementation) - We are pleased to see our comments have been taken on board.



PL10 Water Quality, Water Management, Flooding and SuDS (Justification) - No further comments to make.



PL4 Green Wedges & Green Fingers - We note and support the amendments made in regard to our remit.



PL5 Other Open Spaces - No further comments to make.



PL7 Green Infrastructure & Landscaping - We note and support the amendments made in regard to our remit.



SIR1 Infrastructure Requirements - No further comments to make.



HS3 Strategic Housing Site East of Harlow - No further comments to make.



PL8 Biodiversity & Geodiversity assets - Whilst we support the policy and are pleased to note that biodiversity net gain has been included, we recommend that this wording is added to to further strengthen the policy and add clarity. This should help with implementation, as applicants should be quantifying the net gain required for their development via the appropriate metric. We would therefore recommend adding to the text reference to ensuring a net gain in biodiversity through using the most up to date biodiversity metric.



PL9 Pollution & Contaminations - Although we support the amendments made, we think that the new paragraph in section PL9 Implementation (after para 13.55 - page 114) should strike out ‘high risk development proposal within a vulnerable groundwater area’ as the sentence implies that this can always be mitigated against. It might not always be possible to mitigate high-risk developments proposed in a vulnerable groundwater area, for example, Source Protection Zone 1 (which has a 50 day travel time for groundwater/pollutants to reach an abstraction point). Although we will take into consideration all possible options to minimise the risk to groundwater, there are some types of development which even with mitigation measures, are considered too risky to be located there because we simply can’t control all potential future mishaps occurring.



H10 Travellers Pitches & Plots - No further comments to make.

Full text:

We would like to make the following comments and observations:



WE1 Strategic Green Infrastructure - We are pleased to see our comments have been taken on board.



PL10 Water Quality, Water Management, Flooding and SuDS - We are pleased to see that the majority of our comments have been taken on board.



PL10 Water Quality, Water Management, Flooding and SuDS (Implementation) - We are pleased to see our comments have been taken on board.



PL10 Water Quality, Water Management, Flooding and SuDS (Justification) - No further comments to make.



PL4 Green Wedges & Green Fingers - We note and support the amendments made in regard to our remit.



PL5 Other Open Spaces - No further comments to make.



PL7 Green Infrastructure & Landscaping - We note and support the amendments made in regard to our remit.



SIR1 Infrastructure Requirements - No further comments to make.



HS3 Strategic Housing Site East of Harlow - No further comments to make.



PL8 Biodiversity & Geodiversity assets - Whilst we support the policy and are pleased to note that biodiversity net gain has been included, we recommend that this wording is added to to further strengthen the policy and add clarity. This should help with implementation, as applicants should be quantifying the net gain required for their development via the appropriate metric. We would therefore recommend adding to the text reference to ensuring a net gain in biodiversity through using the most up to date biodiversity metric.



PL9 Pollution & Contaminations - Although we support the amendments made, we think that the new paragraph in section PL9 Implementation (after para 13.55 - page 114) should strike out ‘high risk development proposal within a vulnerable groundwater area’ as the sentence implies that this can always be mitigated against. It might not always be possible to mitigate high-risk developments proposed in a vulnerable groundwater area, for example, Source Protection Zone 1 (which has a 50 day travel time for groundwater/pollutants to reach an abstraction point). Although we will take into consideration all possible options to minimise the risk to groundwater, there are some types of development which even with mitigation measures, are considered too risky to be located there because we simply can’t control all potential future mishaps occurring.



H10 Travellers Pitches & Plots - No further comments to make.