Duty to Co-operate

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Object

Local Development Plan Pre-Submission Publication

Representation ID: 6427

Received: 06/07/2018

Respondent: STOP Harlow North

Agent: Mr Jed Griffiths

Representation:

As noted in response to paragraphs 1.9 - 1.19 above, SHN notes the efforts made by Harlow District Council to fulfill the Duty to Co-operate. The overall strategy for Harlow and the surrounding area, however, has not been subjected to any meaningful engagement with local communities. There is a democratic deficit which should be addressed.

Full text:

As noted in response to paragraphs 1.9 - 1.19 above, SHN notes the efforts made by Harlow District Council to fulfill the Duty to Co-operate. The overall strategy for Harlow and the surrounding area, however, has not been subjected to any meaningful engagement with local communities. There is a democratic deficit which should be addressed.

Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6699

Received: 20/08/2018

Respondent: Home Builders Federation

Representation:

There has clearly been a significant level of co-operation between Epping Forest and those other authorities in the East Herts and West Essex Housing Market Area (HMA). The four authorities forming this HMA have worked together to identify the housing needs for the area and then agreed a distribution between each authority. This distribution places significant emphasis on growth in and around the Harlow area, a similar approach to that identified in the East of England Regional Spatial Strategy.
Whilst we welcome the level of co-operation that has been achieved between the four authorities in the HMA, we remain concerned regarding the approach taken in assessing the level of housing needs for the HMA and the subsequent approach taken to distributing needs across each LPA. In summary we consider that there the Council's within the HMA have underestimated their housing needs by unjustifiably reducing the demographic starting point and taking insufficient account of market signals. We consider that there is a need to allocate further sites across the HMA in order to meet needs. However, in relation to Harlow we recognise the limited ability to increase delivery given the tightly bounded nature of the Council's boundary. A brief appraisal of the Council's assessment of housing needs is set out below.

Full text:

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Support

Local Development Plan Pre-Submission Publication

Representation ID: 6810

Received: 24/08/2018

Respondent: Chelmsford City Council

Representation:

Duty to Co-operate has been met through the ongoing engagement via the West Essex authorities forming Harlow's Housing Market Area. The Plan's allocations are unlikely to have any adverse cross-boundary impacts on Chelmsford.

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6826

Received: 30/08/2018

Respondent: Epping Forest District Council

Representation:

EFDC are pleased to note the Plan's reference to the Duty to Cooperate and to the agreed MoUs to which EFDC is a signatory. Further detail could be given on the Duty to Cooperate working that has taken place such as through the Cooperation for Sustainable Development Board. This would further emphasise the productive and collaborative working between the Essex, Hertfordshire and Greater London authorities that has taken place since the creation of the Board in 2014.

Full text:

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Comment

Local Development Plan Pre-Submission Publication

Representation ID: 6831

Received: 30/08/2018

Respondent: Epping Forest District Council

Representation:

Paragraph 1.31 makes reference to the MoU with respect to the management of growth from development on the Epping Forest SAC. It would be helpful, for the sake of completeness, to provide further commentary which explains that this is in relation to the potential effects of recreational pressure and air pollution on the integrity of the SAC.

EFDC recognises that there are no European designated nature conservation sites within the Harlow District Council administrative area. However, it is suggested that
again, for completeness, and in order to reflect the MoU, that reference is made to the Epping Forest SAC site (and it is suggested the Lee Valley SPA/Ramsar site) as being
located to the south and south east of Harlow within the supporting text to Policy WE3 Biodiversity and Geodiversity, particularly bearing in mind the statutory 'in combination' test applicable under Habitats Regulations. It would also be helpful to include the
Plan's Habitats Regulations Assessment (HRA) findings with regard to these two European sites and in particular to those findings in relation to the Epping Forest SAC.

Full text:

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