3. SPATIAL VISIONS AND LOCAL PLAN STRATEGIC OBJECTIVES

Showing comments and forms 1 to 12 of 12

Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6411

Received: 27/06/2018

Respondent: Essex Bridleways Association

Representation:

Page 22 Local Plan Strategic Objectives: Objective 1 is to 'Create and enhance high quality built environments which are well connected to revitalised green spaces'. This we do not object to, but we feel that recreational access to all green spaces for all user groups is important and should be reflected within Harlow's key objectives.

To make this Plan sound, we suggest that the wording should be amended to read 'Create and enhance high quality built environments which are well connected to revitalised fully accessible green spaces'.

Full text:

Page 22 Local Plan Strategic Objectives: Objective 1 is to 'Create and enhance high quality built environments which are well connected to revitalised green spaces'. This we do not object to, but we feel that recreational access to all green spaces for all user groups is important and should be reflected within Harlow's key objectives.

To make this Plan sound, we suggest that the wording should be amended to read 'Create and enhance high quality built environments which are well connected to revitalised fully accessible green spaces'.

Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6430

Received: 06/07/2018

Respondent: STOP Harlow North

Agent: Mr Jed Griffiths

Representation:

The spatial vision set out in this section of the Local Plan is heavily dependent on the delivery of the Harlow and Gilston Garden Town, which is opposed by STOP Harlow North (SHN). From the summary of infrastructure projects, it would appear that the only real certainty is the provision of the additional interchange on the M11 (Junction 7A). Government commitment to Cross Rail 2 has not been finalised. The four tracking of the West Anglia main line is also in doubt, because of costs and construction difficulties.

Full text:

The spatial vision set out in this section of the Local Plan is heavily dependent on the delivery of the Harlow and Gilston Garden Town, which is opposed by STOP Harlow North (SHN). From the summary of infrastructure projects, it would appear that the only real certainty is the provision of the additional interchange on the M11 (Junction 7A). Government commitment to Cross Rail 2 has not been finalised. The four tracking of the West Anglia main line is also in doubt, because of costs and construction difficulties.

Support

Local Development Plan Pre-Submission Publication

Representation ID: 6447

Received: 04/07/2018

Respondent: Deanery of Harlow (Anglican)

Representation:

I welcome the development of Gilston Garden Town; the work for the relocation or replacement of Princess Alexandra Hospital; the focus on the Town Centre (PR5) and the focus on regeneration generally. It is good to see the focus on infrastructure development generally.

Full text:

I welcome the development of Gilston Garden Town; the work for the relocation or replacement of Princess Alexandra Hospital; the focus on the Town Centre (PR5) and the focus on regeneration generally. It is good to see the focus on infrastructure development generally.

Support

Local Development Plan Pre-Submission Publication

Representation ID: 6460

Received: 05/07/2018

Respondent: The Theatres Trust

Representation:

The Trust welcomes that Harlow's vision contains reference to its residents having excellent sporting, leisure and cultural facilities.

Full text:

The Trust welcomes that Harlow's vision contains reference to its residents having excellent sporting, leisure and cultural facilities.

Support

Local Development Plan Pre-Submission Publication

Representation ID: 6461

Received: 05/07/2018

Respondent: The Theatres Trust

Representation:

We also welcome that the provision and enhancement of Harlow's sports, leisure, recreational facilities and cultural opportunities are included as a strategic objective.

Full text:

We also welcome that the provision and enhancement of Harlow's sports, leisure, recreational facilities and cultural opportunities are included as a strategic objective.

Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6568

Received: 14/08/2018

Respondent: Canal & River Trust

Representation:

Strategic Objective 1 promotes built environments well connected to green spaces. The Trust sees the River Stort as a key green space for Harlow providing connectivity for sustainable travel and open space for recreation and wellbeing. Along sections of the River Stort are areas identified in the Policies Map as employment land. Links from the proposed 3,000 new homes at Gilston Garden Town to the north of the employment land can be made via the towpath, which feeds into Strategic Objectives 13 and 14.

Strategic Objective 13 encourages sustainable modes of transport and objective 14 seeks to improve sustainable transport links to community facilities. Again, the River Stort and itstowpath is an important transport route with the potential to link up people with open space and facilities. The Trust supports these strategic objectives.

Strategic Objective 3 relates to climate change. Waterways are able to be used for heating and cooling of buildings, and the Trust have been involved in many successful projects on our network, where developments have found the system to be more efficient than air source pumps. Developers should be encouraged to explore this and other innovative technology where their site is adjacent to the River Stort.

Full text:

Dear Forward Planning Team,
Re: Harlow Local Development Plan Pre-Submission Publication May 2018
Thank you for your consultation.
The Canal & River Trust (the Trust) is the guardian of 2,000 miles of historic waterways
across England and Wales. We are among the largest charities in the UK. Our vision is that
"living waterways transform places and enrich lives".
The Trust is the owner and navigation authority of the River Stort and adjacent towpath
which runs along the northern side of the local development plan area. The river does, or
has the potential to provide important areas for recreation, biodiversity, sustainable active
transport (with related health and air quality benefit), business, tourism, a focal point for
cultural activities, and is a heritage asset.
Waterways can also provide a resource that can be used to heat and cool buildings, a
corridor in which new utilities infrastructure can be installed and a way of sustainably
draining surface water away from new developments. In some cases it is also possible to
transport freight via our waterways.
The Trust has reviewed the consultation document, and has the following comments to
make.
We note and welcome the many positive references to the River Stort within the plan and its
inclusion in Fig 4.1
Page 22, Fig. 3.3 Local Plan Strategic Objectives
Strategic Objective 1 promotes built environments well connected to green spaces. The
Trust sees the River Stort as a key green space for Harlow providing connectivity for
sustainable travel and open space for recreation and wellbeing. Along sections of the River
Stort are areas identified in the Policies Map as employment land. Links from the proposed
3,000 new homes at Gilston Garden Town to the north of the employment land can be made
via the towpath, which feeds into Strategic Objectives 13 and 14.
Strategic Objective 13 encourages sustainable modes of transport and objective 14 seeks to
improve sustainable transport links to community facilities. Again, the River Stort and itstowpath is an important transport route with the potential to link up people with open space
and facilities. The Trust supports these strategic objectives.
Strategic Objective 3 relates to climate change. Waterways are able to be used for heating
and cooling of buildings, and the Trust have been involved in many successful projects on
our network, where developments have found the system to be more efficient than air source
pumps. Developers should be encouraged to explore this and other innovative technology
where their site is adjacent to the River Stort.
Page 38, HGT1 Development and Delivery of Garden Town Communities in the Harlow
and Gilston Garden Town
The Trust supports stakeholder involvement in the design and delivery of the Garden Towns
and would consider itself to be a key consultee for the Garden Towns, particularly Gilston
due to its proximity to the River Stort. The Trust considers towpath improvements (as a
Sustainable Transport Corridor) necessary to meet the needs of residents (existing and
future) to support sustainable travel.
The development of a significant number of new homes at Gilston Garden Town to the north
of the River Stort Navigation and improved access to the River Stort means it is highly likely
there will be an increase in the usage of the towpath for recreational and possibly commuting
purposes the impact of which we would wish to see mitigated through the appropriate use of
planning obligation or other suitable mechanisms. We therefore note and welcome reference
in Policy HG1 to a funding mechanism for future stewardship, management, maintenance
and renewal of community infrastructure and assets and the need for developers to set out a
sustainable long term arrangement for governance and stewardship arrangement for
community assets including green infrastructure
Point 5.36 of the policy justification identifies a widened Central Stort Crossing and a Second
Stort Crossing. The Trust has provided pre-application advice on these proposed crossings
and in that advice, referred to the HS2 Design Principles for Bridge Crossings and the Code
of Practice for Works Affecting the Canal & River Trust. Whilst the Trust has no objection in
principle to the proposed crossings it has raised a number of concerns in relation to the
alignment of the Eastern Crossing and detailed design and would wish to be consulted
further in respect of the detailed design of any proposed works
The Trust welcomes policy point HGT1(m) on mitigation from and adaption to climate
change through design and construction. Our waterways can play a part in such mitigation
through, for example, use for heating and cooling of development and surface water
drainage where appropriate.
Page 69, ED4 Developing a Visitor Economy
The Trust welcomes the recognition given to the importance of the River Stort to the visitor
economy of Harlow and to the need for improvements to Green Infrastructure links to
connect the river with other attractions. People come from near and far to visit our
waterways. They can have a beneficial impact on the local economy by providing
sustainable active travel routes and attractive settings for waterside and on-waterbusinesses. By encouraging these uses in appropriate locations, development plans can
help the waterway attract more people and support the local economy.
Page 81, WE1 Strategic Green Infrastructure
The Trust generally supports the protection and enhancement of green infrastructure in
Harlow. Towpaths make excellent places for people to walk and cycle considerately. Not
only is this great for recreation, it can be an attractive way for people to commute, reducing
congestion, carbon emissions and poor air quality in the wider area and supporting people to
lead healthier lives.
The Trust is supportive of connecting key locations with other infrastructure and recognises
individual waterways and water spaces need to be viewed as an integral part of a wider
network, and not in isolation. New development often brings new people onto the waterways,
particularly the towpaths. Improvements to signage and wayfinding is therefore also seen as
a positive enhancement to help with connectivity of networks.
The policy describes a new linear 'Stort Riverpark'. As the owner and navigation authority of
the river, the Trust would expect to be engaged in this proposal from an early stage and
should be identified as a partner at point 10.15. The Trust is already working with other local
authorities and partners to improve the River Stort environment elsewhere and is able to
provide a strategic link between the Harlow area and surrounding areas.
Page 91, SIR1 Infrastructure Requirements
Policy SIR1 identifies the Central River Stort Crossing and the Second River Stort Crossing
at River Way (SIR1-3), as infrastructure projects with land use implications. Whilst the Trust
has no objection in principle to such proposals, any works would need to be carefully
designed in terms of their impact on our waterway and we would wish to be consulted further
in respect of their detailed design.
The Trust has previously provided comments in respect of proposals for the Central
Crossing Bridge at which time concern was expressed about its proposed alignment and
design which we would wish to see addressed in any future proposal.
Page 96, SIR2 Enhancing Key Gateway Locations
Policy SIR2 identifies two crossings of the River Stort as key gateway locations to be
integrated with the wider transport and green infrastructure network and enhanced and
improved through measures including landscaping, open space, wayfinding, improvements
to pedestrian and cycle routes and security and safety.
Whilst the Trust has no objection in principle to such a proposal works would need to be
carefully designed in terms of their impact on our waterway and we would wish to be
consulted in respect of their detailed design.
The Trust has previously provided comments in respect of works relating to the Eastern Stort
Crossing which enters Templefields Employment Area at River Way (number 4). at which
time concerns were expressed about the proposed alignment and design of the bridge. We
would wish to be consulted further in respect of the detailed design of any proposed works.
We would also request that paragraph 11.36 should be amended to refer to discussion with
landowners and statutory consultees for completeness.
Page 103, PL1 Design Principles for Development
Part (b) should include protection, enhancement and improvement of the River Stort as a
distinctive environmental feature, natural asset and leisure and recreation attraction of
Harlow. The Trust would expect development alongside the River Stort to be of a high
standard of urban and architectural design.
Page 105, PL3 Sustainable Design, Construction and Energy Use
We note the reference to onsite low carbon/ renewable energy technology in the justification
to policy PL3 and would advise that our waterways provide readily available opportunities for
developments to incorporate innovative technologies to make use of its water such as
hydropower and the abstraction of water for the heating and cooling of buildings, and we
have been involved in many successful projects on our network, where developments have
found the system to be more efficient than air source pumps.
Page 106, PL4 Green Wedges and Green Fingers
Small-scale development referred to in point 13.23 should include facilities and services
associated with an existing use including moorings and other waterway uses as required.
Page 114, PL10 Water Quality, Water Management, Flooding and Sustainable Drainage
Systems
The quality of water in canals and rivers can affect how attractive they are as spaces for
people to be on, in or alongside and impact on the plants and wildlife that rely on it. It is
therefore important that new developments are appropriately located, designed to minimise
risk and do not adversely affect our assets. We therefore welcome reference in Policy PL10
to development not adversely affecting the water quality of waterways.
We note reference to surface water discharge to surface water bodies in para 13.68. and
advise that our waterways present a number of opportunities to support and enhance urban
development, with particular reference to water management. With careful design and
assessment, our waterways may be able to receive runoff from future development sites,
providing sustainable options for site drainage (although mitigation works to the canal
infrastructure may be necessary to cope with this.) The Trust is not however a land drainage
authority and any such discharge would be subject to an agreement with the Trust's Utilities
Team and appropriate controls to protect water quality.
Page 159, IN1 Development and Sustainable Modes of Travel
Waterway corridors provide an ideal environment for sustainable active travel and we
welcome reference in Policy IN1 to new development being required to link with and where
appropriate improve the existing network of cycleways and paths. The list of routes identified
in Policy IN1 could however usefully be expanded to include reference to towpaths to
provide clarity on this matter.

The River Stort provides a flat, direct and easy to access route for walking and cycling and
close links with the rail network in the Harlow area mean that the towpath can easily be used
for the first/last mile of journeys and have a positive impact on congestion as well as the
health and wellbeing of local people.
Improved access and relatively simple improvements to the towpath can have a big impact
on people's propensity to use it as part of their daily routine.
Whilst Policy IN1 refers to new development contributing to the improvement and
development of routes, such reference is missing within the justification of the policy. The
Trusts therefore consider that more emphasis could be placed on the benefits of upgrading
existing infrastructure and access to it to support active travel within the policy justification
Page 165, Policy IN6 Planning Obligations
The Trust notes and welcomes policy IN6 which recognises the impact new development
can have on local infrastructure and the need to mitigate any adverse impacts. Development
in the vicinity of our waterways can increase the number of users which, whilst generally
welcomed, may require existing towpaths to be upgraded or significantly increase ongoing
liabilities for the Trust. We note that the council is intending to produce a Planning
Obligations SPD and would welcome the opportunity to comment further on this.
Other Comments
We would request that page 7 'Applying the policies in the assessment of planning
applications' point 1.36-1.42 include a section encouraging developers to seek preapplication
advice. Where their proposal is adjacent to our waterway, they should consult the
Trust, we provide free pre-application advice. We would also advise developers to consult
our Code of Practice for practical advice:
https://canalrivertrust.org.uk/business-and-trade/undertaking-works-on-our-property-and-ourcode-
of-practice

Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6622

Received: 14/08/2018

Respondent: GLADMAN

Representation:

Gladman support the Council's Spatial Vision and particularly the provision of sufficient new homes to meet local need and significantly increase the provision of affordable housing.
This clearly reflects the Council's Corporate Priorities with more and better housing sitting at the top of the Council's stated aims.
This priority is reflected in the Council's Strategic Objectives 4, 5 and 6 which are also supported.
Harlow also is located within the London Stansted Cambridge Corridor (LSCC) and is clearly key to the delivery of substantial growth over the Local Plan period that will support the economic objectives of the LSCC.

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6667

Received: 17/08/2018

Respondent: Hertfordshire County Council

Representation:

Figure 3.1: Spatial vision for Harlow to 2033, based on the Harlow Corporate Plan 2017. Improvements to sustainable modes would not conflict with HCC's Local Transport Plan (LTP). However, the proposed route of a northern bypass or whether it would in fact be in East Herts District is unknown. If this is the case it may need to be considered further.
Figure 3.3: Local Plan Strategic Objectives. Reducing the need to travel by car and improving options for sustainable travel that are outlined in paragraphs 13 and 14, are approaches that are reflected in HCC's LTP.

Full text:

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Support

Local Development Plan Pre-Submission Publication

Representation ID: 6687

Received: 20/08/2018

Respondent: Historic England

Representation:

Welcome reference to delivering high quality design through new development whilst protecting and enhancing the districts historic environment.

Full text:

Harlow Local Development Plan - Pre-Submission Publication May 2018
Thank you for consulting Historic England on the Harlow Local Plan Pre-Submission Publication. As a statutory consultee, our role is to ensure that the conservation of the historic environment is fully integrated into planning policy and that any policy documents make provision for a positive strategy for the preservation and enjoyment of the historic environment.
Our comments below should be read with reference to our previous response dated 6th September 2017. Please also see our detailed comments in the attached table.
SUMMARY
We very much welcome the changes that you have made in response to our previous comments.
Whilst we consider the majority of the plan to be sound we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan.
Under paragraph 182 of the National Planning Policy Framework ('The Framework') some aspects of this Plan are unsound as they have not been positively prepared, are not justified, effective, or consistent with national policy. We have identified in detail below where we find the Plan unsound and what measures are needed to make the Plan sound. In summary we highlight the following issues:
a) Reference is made to the Harlow and Gilston Design Charter throughout the Plan. This underpins many of the policies. However, we understand that this document is not yet available to view. Without sight of this document it is not possible to say whether sufficient protection has been given to the historic environment in policy
b) There is a lack of a detailed and proportionate historic environment evidence base underpinning the Plan and the Sustainability Appraisal. This is a particular issue for the strategic site at East Harlow and also site HS2-7 (Kingsmoor). Therefore we have provided more detail on these policies. We suggest that HIAs are prepared for both of these sites in advance of the EiP to test the suitability of these sites in terms of the potential impact on the historic environment. It is important to establish the suitability of the site per se prior to allocation. Paragraph 158 of the NPPF requires a proportionate evidence base for Plans. WE also have suggested the inclusion of a concept diagram for Policy HS3.
c) The site allocations in Policy HS2 require more detail. At the moment, the site address is simply listed. Paragraph 154 of the NPPF makes it clear that policies should provide a clear indication of how a decision maker should react to a development. The policies (particularly for the larger sites should be re-worded to include criteria for clarity and to provide greater protection for the historic environment and robust policies that provide the decision maker and developers with a clear indication of expectations for the sites.
d) Reference to enabling development in Policy PL11 should be deleted.
e) A policy to address Heritage at Risk should be included.
We have suggested a series of other changes to the Plan. Many of these changes suggested do not go to the heart of the Plan's soundness, but instead are intended to improve upon it. We believe that these comments can be addressed by changes to wording in the plan.
Conclusions
In preparation of the forthcoming local plan, we encourage you to draw on the knowledge of local conservation officers, the county archaeologist and local heritage groups.
Please note that absence of a comment on a policy, allocation or document in this letter does not mean that Historic England is content that the policy, allocation or document is devoid of historic environment issues.
Finally, we should like to stress that this response 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 as a result of this plan, where we consider that these would have an adverse effect upon the historic environment.
If you have any questions with regards to the comments made then please do get back to me. I would be very happy to meet to discuss these comments further. In the meantime we look forward to continuing to work with you and your colleagues.

Support

Local Development Plan Pre-Submission Publication

Representation ID: 6729

Received: 21/08/2018

Respondent: Natural England

Representation:

Natural England supports the spatial vision's recognition of the value of Green Infrastructure and the ambition to retain and supplement existing green wedges. We note that Local Plan Strategic Objective mentions 'revitalised green spaces', however we would advise that these should be strengthened to include objectives specifically relating to the safeguarding, creation and enhancement of green infrastructure and environmental designations under the 'Placeshaping (Enhancing the quality of the built environment) theme.
We are pleased to see the positive approach to the environment supported in the Local Plan Vision for the LSCC Core Area and commend the recognition of the economic value of green assets.

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6751

Received: 22/08/2018

Respondent: Quod Planning

Representation:

HDC identifies the pressing need for the urgent economic and social regeneration of Harlow which can only be delivered through a combination of housing and economic development. This is clearly articulated in HDC's evidence base which explains that insufficient land exists within Harlow (given its tight administrative boundaries) to satisfy growth and regeneration requirements. As a result, it is incumbent on surrounding Council's to work collaboratively with HDC to assist in meeting the development requirements that cannot wholly be met within Harlow's administrative boundary.
PfP strongly support the need for regeneration within Harlow which has been a strategic objective of regional and local planning policy and guidance for over a decade. The New local Plan and the initiatives being brought forward under the wider 'Garden Town' banner can help support the long-awaited delivery of these objectives.
The London-Stansted-Cambridge Consortium lists Harlow as an integral economic location and labour market needed to support the prosperity of the corridor (LSCC, An Agenda for Jobs, Growth and Improved Liveability, 2014).
Development at GPE will deliver substantial new housing comprising a broad mix of unit types and tenures that can help support the economic stimulus of this part of the M11 corridor, building on relationships with Stansted airport and the Enterprise Zone at Harlow, as well as supporting existing travel to work patterns.
PfP therefore strongly support Harlow's overall ambition set out within the Pre-Submission District Plan, in particular Harlow's role as an employment location and the need for a Skills Strategy (Policies ED1, ED2, and ED3). Harlow's role as a retail centre is also encouraged. A residential led mixed-use development at GPE will help support the economic and social regeneration of Harlow and enable the strategic objectives to be achieved.

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6877

Received: 31/08/2018

Respondent: Essex County Council

Representation:

In response to the evidence base on Harlow health and well-being issues, the Local Plan vision, Local Plan themes and Local Plan objectives need revising and substantial content added to frame the overall Local Plan approach to Health and Well-being, including the current (brief) references to
* Harlow's residents will be more active, taking advantage of Harlow's excellent
* Sporting, leisure and cultural facilities
* Major progress will have been made to address Harlow's health and wealth inequalities as well as addressing localised deprivation across the district's deprived neighbourhoods
* The current 'Lifestyles' Objective also needs review and revision:
* '11. To provide and enhance sporting, leisure, recreational facilities and cultural opportunities in the district'

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