Core Strategy Issues and Options Consultation Document (Read-only)

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Core Strategy Issues and Options Consultation Document (Read-only)

Question 2

Representation ID: 5837

Received: 28/01/2011

Respondent: East Herts District Council

Representation:

Disagree with the statement in Section 2.3 that "Greenfield development should be located in the north and east of Harlow". This is to pre-empt the policy process. At Issues and Options stage, all options should be on the table but no decisions made.

As argued in East Herts Council's Overview paper [see attatched] recent changes to national planning policy mean that a robust case for the expansion of Harlow to the north of the River Stort has yet to be made.

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Core Strategy Issues and Options Consultation Document (Read-only)

Question 4

Representation ID: 5838

Received: 28/01/2011

Respondent: East Herts District Council

Representation:

As argued in East Herts Overview paper [see attached], Harlow Council's evidence base does not provide any robust evidence either way in respect of growth and regeneration, therefore the only credible position on this at present is one of neutrality. Urgent attention will need to be paid to deficiencies in the evidence base before a proffered strategy can be set out. The assertion that 'growth can provide the much needed stimulus to propel the regeneration and renewal of Harlow' 9paragraph 3.4.3) is not supported.



Additionally, it should be noted that for growth proposals outside Harlow District, the scale, type and location of growth are matters for consideration by the appropriate local authority. Harlow Council cannot unilaterally proceed with such plans.

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Core Strategy Issues and Options Consultation Document (Read-only)

Question 6

Representation ID: 5839

Received: 28/01/2011

Respondent: East Herts District Council

Representation:

These documents were prepared in an era of regional planning. As stated above the evidence base for growth-led regeneration needs to be re-examined. Until a robust evidence base has been established, there is no basis in these documents for growth outside of Harlow District.

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Core Strategy Issues and Options Consultation Document (Read-only)

Question 10

Representation ID: 5840

Received: 28/01/2011

Respondent: East Herts District Council

Representation:

Given the gaps in the evidence, the only credible position at the present time is one of neutrality on some of these objectives.

The correct sequence is that objectives come first, and then the best strategy to achieve the objectives should be investigated. There is a danger that objectives could be used to add legitimacy to decisions which have already been made on the basis of uncertain evidence.

Placing Shaping Objective 4:

In itself the promotion of growth is sustainable locations is appropriate, but the current evidence base will need to be reviewed and gaps filled before 'sustainable locations' can be identified. Statements in the document which identify north of Harlow are therefore premature.

Property Objective 12:

No robust evidence has yet been produced that growth into neighbouring districts is required in order to enhance or reinforce Harlow's sub-regional role.

Other Objectives:

The Scott Wilson Harlow Options Appraisal (2010) suggests that there is a danger that large-scale development north of the Stort could drain investment away from the existing town. Any attempt to achieve prosperity through growth would need to include managing this risk as a core objective.

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Core Strategy Issues and Options Consultation Document (Read-only)

Question 19

Representation ID: 5844

Received: 28/01/2011

Respondent: East Herts District Council

Representation:

The Harlow Employment Utilisation Study Stage 2 (GVA Grimley, March 2009) looked at future demand and concluded that with "Land north of Nortel" (which could provide 17HA of employment land), Harlow District has enough employment land to meet future requirements for the base case and the growth scenarios in a gross sense.



As with other technical studies, the GVA Grimley Study starts from the assumption that 16,000 homes will be provided to 2021, mainly to the North. Based on this, it draws some conclusions as to how many jobs could be created. However, as with the other technical studies, the study does not critically examine the assumptions of the RSS, nor does it examine an employment based rationale for development north of Harlow.



From the point of view of establishing future need, the argument is based on a circular logic resulting in a self-fulfilling prophecy i.e. the need is the RSS policy requirement. In a post-RSS era such a definition of need cannot be left unquestioned.

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Core Strategy Issues and Options Consultation Document (Read-only)

Question 21

Representation ID: 5847

Received: 28/01/2011

Respondent: East Herts District Council

Representation:

Option A is one of the two top-down options arising from the wording of Policy HA1. With the changes to the planning system since the study was published, there are no longer effective grounds for this option going forward.



It is unclear why Harlow Council is consulting on Options A to E. The first page of the Executive Summary of the Scott Wilson Harlow Options Appraisal states:



'These spatial options were not developed with the intention that they should be progressed to the Issues and Options planning stage but to provide a sufficiently detailed and differentiated set of options for further testing.' [Harlow Options Appraisal, page i]



The consultants report states that:





'It should be noted that the spatial options developed through Section 3 are not the same as the spatial options which will be developed by the Partners as they prepare their issues and Options document. The spatial options that have been developed through this technical study effectively function as scenarios which constitute a framework against which an evidence base of constraints and opportunities can be identified as part of the reinforcement process.' [ Harlow Options appraisal, paragraph 2.7.3]



The options were developed as steps on the way to production of the suggested approach, and were not identified by the consultants to form stand-alone options for consultation, as they were produced prior to application of the Sustainability Test and the Reasonable Test. This is clear from Figure 3 (page 17) and the Methodology statement.

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Core Strategy Issues and Options Consultation Document (Read-only)

Question 22

Representation ID: 5848

Received: 28/01/2011

Respondent: East Herts District Council

Representation:

Option B is based on the wording of Policy HA1 of the East of England Plan, and therefore is explicitly top-down, with no basis in the bottom-up analysis which underpin Options C to E and the deleted constraints-led option.

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Core Strategy Issues and Options Consultation Document (Read-only)

Question 23

Representation ID: 5850

Received: 28/01/2011

Respondent: East Herts District Council

Representation:

Scott Wilson's analysis is that Option C is the most sustainable option, based on the combined criteria from the assessment, excluding the requirement to comply with policy HA1:



'The logic underpinning this option maintains that the areas of land which cumulatively perform the best against the criteria could lead to the most sustainable spatial option...Reflecting greater emphasis for the situation on the ground (by removing constraints provided by strategic policy objectives) , this spatial option does not correspond to key elements within the policy HA1 page 46.'



To reiterate, the consultants state that once the top-down policy has been removed, the situation 'on the ground' would suggest that development to the north is unlikely to be considered sustainable.

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Core Strategy Issues and Options Consultation Document (Read-only)

Question 24

Representation ID: 5851

Received: 28/01/2011

Respondent: East Herts District Council

Representation:

At the Examination in Public in 2006 the East of England Plan Inspector agreed with East Herts Council that the regeneration-based case for expansion to the north was unsatisfactory. Option D (the 'regeneration led' option) offers no new regeneration-based evidence for development to the north. Two of the three regeneration criteria are shown to offer little guidance as to direction (Figures 5 and 7). Indeed, the Index of Multiple Deprivation criteria (Figure 5) would suggest a distribution to the south and east rather than to the north. The northern distribution of Option D is therefore based on the relatively high levels of unemployment in area EH4 (see green area in Figure 6).

Notwithstanding the disclaimers in 3.3.9 and 3.3.13, Option D has been based essentially on data which is not of relevance to the regeneration of Harlow itself. A footnote states that "the logic behind the regeneration criteria in this sense is that development in or near to deprived areas can improve housing and environmental conditions and increase employment opportunities." (footnote 35 page 21). However Figure 8 shows that there is no evidence for expansion to the north based on areas of deprivation within Harlow.

So far no compelling evidence as to the regeneration benefits of expansion has been provided. Indeed, the Scott Wilson Harlow Options Appraisal warns that:

'The high levels of development proposed by these growth scenarios may have negative impacts on efforts to regenerate the existing town, its centre and its relatively deprived neighbourhoods as investment may be attracted to the new extension to the north of the town....

'A need to ensure that the regeneration of Harlow is not jeopardised by the substantial development to the north [which] could mean that efforts to maximise the potential of Harlow North are weakened. The worst case scenario in this regard is that Harlow North effectively becomes a separate town competing with Harlow' (Harlow Options Appraisal p.81).

The Harlow Regeneration Strategy does nothing to address these concerns. This is a striking omission from the evidence base and will need to be comprehensively addressed prior to the Preferred Options stage of the Core Strategy, if the expansion of Harlow is to be considered a realistic and sustainable option. Such evidence would need to be the cornerstone of a clear strategy to directly address this issue, without which there is a danger that expansion could jeopardise the future of Harlow, as Scott Wilson consultants point out.

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Core Strategy Issues and Options Consultation Document (Read-only)

Question 25

Representation ID: 5852

Received: 28/01/2011

Respondent: East Herts District Council

Representation:

The northern quota of 2530 under Option E was developed primarily in response to the proximity of Harlow Town and Harlow Mill railway stations, as shown in figure 10 on page 28. However, the consultants state on page 31 that:



'EH10, EH6 AND EH7 do not score highly and the barriers between these areas and Harlow (i.e. the A414, the River Stort and Navigation Way) suggest that these areas are not natural extensions of Harlow.'



East Herts Council concurs with this and would further add that these barriers also call into question whether any of the development north of the river would form a 'natural extension' to Harlow.

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