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

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Comment

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

Question 2

Representation ID: 5014

Received: 24/01/2011

Respondent: Pegasus Planning Group

Representation:

The issues identified under the Housing Category need to be more general at this initial stage and
not so detailed and specific to avoid any prejudging prior to a thorough and robust analysis of the
issues. Paragraph 2.3.1 (last bullet point) states that Greenfield development should be located in
the north and east of Harlow. It is unclear at this stage if this is the view of the Council or views
received during consultation workshops. Additional clarity is required here.
Paragraph 2.9.1 lists the findings of the evidence base in relation to housing. A bullet point should
be added here which refers to the need to provide additional housing land outside of the Harlow
Urban Area in order to meet the housing requirements of the reinstated EEP (refer to our response
on the EEP under Question 31). This was a finding of the Scott Wilson Technical report
summarised in Section 6 of the Core Strategy.

Full text:

Questionnaire + Submitted Letter and Supporting Document

Comment

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

Question 4

Representation ID: 5015

Received: 24/01/2011

Respondent: Pegasus Planning Group

Representation:

Policy HA1 of the reinstated EEP states that there will be the provision of 16,000 additional
dwellings between 2001 and 2021 at the Harlow Key Centre for Development and Change and this
will incorporate urban extensions in Epping Forest and East Hertfordshire districts. This refers to
housing provision required up to 2021, the Harlow Core Strategy plan period extends to 2026 and
therefore an additional 5 years of housing growth should be included. 16,000 houses between
2001 and 2021 equates to 800 per annum and therefore an additional 4,000 houses should be
provided for up to 2026 (800 p.a x 5 years) providing a total of 20,000 houses. This requirement
should also be referred to as a lower limit and not a ceiling which should not be exceeded as was
the intention of the EEP.

Full text:

Questionnaire + Submitted Letter and Supporting Document

Comment

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

Question 21

Representation ID: 5062

Received: 24/01/2011

Respondent: Pegasus Planning Group

Representation:

It is not considered helpful to include such a large portion of an evidence base document within the Core Strategy. The Scott Wilson Report was intended as an independent evidence base document which should inform the Core Strategy process for the three neighbouring authorities of Harlow, Epping Forest and East Hertfordshire. To include such large sections of the report with no clear emphasis on a particular approach which Harlow Council themselves recommend or favour is not helpful to this process of providing potential options. You will recall that we submitted on behalf of the Harlow West Consortium on 15th June 2010, a detailed response to the Scott Wilson report which we considered failed to deal with potential urban extensions arising at the edge of Harlow in a consistent/equitable manner (For completeness a copy of our full report is attached to this questionnaire). The Consortium contends that the report prepared for the local planning authorities in connection with the Harlow area incorporates meaningless and misleading conclusions which cannot reliably be used as part of the Council's evidence base.

The Consortium considers that the methodology applied in the study represents an inconsistent, biased and flawed approach to determining potential sustainable locations for future growth to the west of Harlow. The Appraisal split the land around Harlow into a series of Spatial Land Areas (SLAs) for evaluation against a set of criteria derived from the overall policy objectives for Harlow set out in Policy HA1 of the EEP. Upon reaching the final stage of the criteria-based assessment, the study selectively split one of the SLAs on the western side of Harlow to form a smaller land parcel (known as EF4a) which it then put forward as the optimal location for new growth for west Harlow, primarily based on its alleged ability to contribute towards regeneration initiatives, specifically in existing neighbourhood renewal areas. This was considered to represent the strictest application of the Policy objectives in evaluating the SLAs. Prior to the splitting of the SLA in question this land area had been assessed, as part of the original SLA, as a less favourable location for development than other SLAs to the west of Harlow. No other SLAs were subdivided to ascertain if other smaller parcels of land could more accurately be assessed for confirmation with the regeneration objective or any of the other Policy objectives. At no point was the smaller land parcel resulting from the split individually subjected to assessment against the other criteria used in the assessment.

The Consortium has serious concerns about the methodological irregularities, the inconsistent approach to the issue of Green Belt coalescence and the unsound justification for the preferred western growth option presented in the Appraisal.

The Consortium considers that the selective splitting of just one SLA to form a smaller land parcel which was then tested against only one of the criteria in the Appraisal introduced inappropriate methodological inconsistencies to the study which resulted in biased and invalid conclusions being drawn about the options for growth to the west of Harlow. Not only does the study fail to explain why other SLAs are not also considered for sub-division for the most accurate assessment against Policy objectives, the Appraisal places undue emphasis on the final regeneration criterion assessment in the evaluation, the findings of which are at odds with the earlier assessment of regeneration in the study using Indices of Multiple Deprivation. The Consortium would strongly argue that the preservation of Green Belt purposes and the integration with sustainable transport links are equally important aims of the Policy and should be afforded similar credence in the evaluation of spatial options. Weighting the appraisal in the manner described above renders the findings highly questionable and unreliable for use as an evidence base to inform spatial growth options for the district. The inexplicable emphasis placed on the SLA's relative ability to contribute towards only 'existing neighbourhood renewal areas' in the final assessment stage therefore seems to be a blatant and contrived effort to manipulate the regeneration category and the results of the appraisal in favour of EF4a.

Methodological concerns are also raised by the reliance on a special sub-area analysis undertaken for one parcel of land only, which does not represent a balanced assessment of the relative merits of the potentially suitable options. The Appraisal can not be said to directly and meaningfully compare any of the other SLAs against EF4a, as this parcel had not also been subject to analysis against the other criteria. This invalidates any conclusion that the Appraisal has robustly and systematically identified this land parcel as the most appropriate location for growth west of Harlow.

It is also considered that the examination of Green Belt purposes and more specifically the issue of coalescence on the west side of Harlow is inconsistently dealt with throughout the report, with coalescence with Roydon initially dismissed and then emphasised as a limitation to growth on this side of the town. The EEP clearly set out the growth requirements for Harlow Growth Options and it was accepted that this would include a requirement to place some growth in areas currently designated as Green Belt (Policy HA1): to exclude options for growth on the grounds of Green Belt conflicts alone is therefore not in accordance with these early policy decisions.

A review of the justification given in the Appraisal for the preferred western expansion area identified clearly demonstrates the inconsistencies which resulted from the biased methodological approach at the assessment stage, and further reveals the unsound basis by which the EF4a subarea was arrived at as the suggested spatial growth option. Avoiding coalescence; sustainability arguments; infrastructure limitations; and spurious generalisations about regeneration and proximity to existing green infrastructure are cited as reasons for the identification of the preferred western growth option location, each of which can either equally or to a greater extent be applied to at least one other land parcel to the western side of Harlow, (the Consortium's own site), or are entirely misleading and inaccurate justifications for the EF4a parcel. Much of the reasoning given appears somewhat confused and smacks of an attempt to validate a preferred option which has been arrived at via a contrived and artificial process.

Based on the analysis presented in this report, the Consortium contends that not only is the method by which the preferred western spatial option is identified conspicuously biased and invalid, the justification subsequently put forward by the Appraisal for the option is unacceptable and does not accurately represent the context in which the SLAs are said to have been considered. Given these serious inconsistencies in the manner in which the preferred growth option has been identified, the Appraisal fails, in a fundamental way, to test all reasonable alternatives as required by PPS12. The Consortium would strongly argue that the Councils can not reasonably use the Appraisal as an evidence base on which to develop a future growth strategy for their districts.

In view of the above comments and following no further comment from any Councils nor Scott Wilson since the submission of these comments in June 2010, the Consortium respectfully request that the Appraisal is either revisited to present a balanced assessment of the spatial options available to the west of Harlow or is removed from the evidence base and it most definitely should not be copied so fully within the Harlow Core Strategy.

The Sustainability Appraisal Report (October 2010) related to the Core Strategy is not considered sound or robust. The options tested in the SA undertaken by Scott Wilson relate only to those suggested by Scott Wilson in their Spatial Options Report. This appears to have prejudged the Core Strategy Issues and Options stage as the only options tested are those put forward in a biased evidence base document undertaken to inform the Core Strategy rather than to establish the strategy. The SA will need to be redone once appropriate Spatial Strategy Options have been set out by Harlow Council.

Full text:

Questionnaire + Submitted Letter and Supporting Document

Comment

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

Question 22

Representation ID: 5156

Received: 24/01/2011

Respondent: Pegasus Planning Group

Representation:

It is not considered helpful to include such a large portion of an evidence base document within the Core Strategy. The Scott Wilson Report was intended as an independent evidence base document which should inform the Core Strategy process for the three neighbouring authorities of Harlow, Epping Forest and East Hertfordshire. To include such large sections of the report with no clear emphasis on a particular approach which Harlow Council themselves recommend or favour is not helpful to this process of providing potential options. You will recall that we submitted on behalf of the Harlow West Consortium on 15th June 2010, a detailed response to the Scott Wilson report which we considered failed to deal with potential urban extensions arising at the edge of Harlow in a consistent/equitable manner (For completeness a copy of our full report is attached to this questionnaire). The Consortium contends that the report prepared for the local planning authorities in connection with the Harlow area incorporates meaningless and misleading conclusions which cannot reliably be used as part of the Council's evidence base.

The Consortium considers that the methodology applied in the study represents an inconsistent, biased and flawed approach to determining potential sustainable locations for future growth to the west of Harlow. The Appraisal split the land around Harlow into a series of Spatial Land Areas (SLAs) for evaluation against a set of criteria derived from the overall policy objectives for Harlow set out in Policy HA1 of the EEP. Upon reaching the final stage of the criteria-based assessment, the study selectively split one of the SLAs on the western side of Harlow to form a smaller land parcel (known as EF4a) which it then put forward as the optimal location for new growth for west Harlow, primarily based on its alleged ability to contribute towards regeneration initiatives, specifically in existing neighbourhood renewal areas. This was considered to represent the strictest application of the Policy objectives in evaluating the SLAs. Prior to the splitting of the SLA in question this land area had been assessed, as part of the original SLA, as a less favourable location for development than other SLAs to the west of Harlow. No other SLAs were subdivided to ascertain if other smaller parcels of land could more accurately be assessed for confirmation with the regeneration objective or any of the other Policy objectives. At no point was the smaller land parcel resulting from the split individually subjected to assessment against the other criteria used in the assessment.

The Consortium has serious concerns about the methodological irregularities, the inconsistent approach to the issue of Green Belt coalescence and the unsound justification for the preferred western growth option presented in the Appraisal.

The Consortium considers that the selective splitting of just one SLA to form a smaller land parcel which was then tested against only one of the criteria in the Appraisal introduced inappropriate methodological inconsistencies to the study which resulted in biased and invalid conclusions being drawn about the options for growth to the west of Harlow. Not only does the study fail to explain why other SLAs are not also considered for sub-division for the most accurate assessment against Policy objectives, the Appraisal places undue emphasis on the final regeneration criterion assessment in the evaluation, the findings of which are at odds with the earlier assessment of regeneration in the study using Indices of Multiple Deprivation. The Consortium would strongly argue that the preservation of Green Belt purposes and the integration with sustainable transport links are equally important aims of the Policy and should be afforded similar credence in the evaluation of spatial options. Weighting the appraisal in the manner described above renders the findings highly questionable and unreliable for use as an evidence base to inform spatial growth options for the district. The inexplicable emphasis placed on the SLA's relative ability to contribute towards only 'existing neighbourhood renewal areas' in the final assessment stage therefore seems to be a blatant and contrived effort to manipulate the regeneration category and the results of the appraisal in favour of EF4a.

Methodological concerns are also raised by the reliance on a special sub-area analysis undertaken for one parcel of land only, which does not represent a balanced assessment of the relative merits of the potentially suitable options. The Appraisal can not be said to directly and meaningfully compare any of the other SLAs against EF4a, as this parcel had not also been subject to analysis against the other criteria. This invalidates any conclusion that the Appraisal has robustly and systematically identified this land parcel as the most appropriate location for growth west of Harlow.

It is also considered that the examination of Green Belt purposes and more specifically the issue of coalescence on the west side of Harlow is inconsistently dealt with throughout the report, with coalescence with Roydon initially dismissed and then emphasised as a limitation to growth on this side of the town. The EEP clearly set out the growth requirements for Harlow Growth Options and it was accepted that this would include a requirement to place some growth in areas currently designated as Green Belt (Policy HA1): to exclude options for growth on the grounds of Green Belt conflicts alone is therefore not in accordance with these early policy decisions.

A review of the justification given in the Appraisal for the preferred western expansion area identified clearly demonstrates the inconsistencies which resulted from the biased methodological approach at the assessment stage, and further reveals the unsound basis by which the EF4a subarea was arrived at as the suggested spatial growth option. Avoiding coalescence; sustainability arguments; infrastructure limitations; and spurious generalisations about regeneration and proximity to existing green infrastructure are cited as reasons for the identification of the preferred western growth option location, each of which can either equally or to a greater extent be applied to at least one other land parcel to the western side of Harlow, (the Consortium's own site), or are entirely misleading and inaccurate justifications for the EF4a parcel. Much of the reasoning given appears somewhat confused and smacks of an attempt to validate a preferred option which has been arrived at via a contrived and artificial process.

Based on the analysis presented in this report, the Consortium contends that not only is the method by which the preferred western spatial option is identified conspicuously biased and invalid, the justification subsequently put forward by the Appraisal for the option is unacceptable and does not accurately represent the context in which the SLAs are said to have been considered. Given these serious inconsistencies in the manner in which the preferred growth option has been identified, the Appraisal fails, in a fundamental way, to test all reasonable alternatives as required by PPS12. The Consortium would strongly argue that the Councils can not reasonably use the Appraisal as an evidence base on which to develop a future growth strategy for their districts.

In view of the above comments and following no further comment from any Councils nor Scott Wilson since the submission of these comments in June 2010, the Consortium respectfully request that the Appraisal is either revisited to present a balanced assessment of the spatial options available to the west of Harlow or is removed from the evidence base and it most definitely should not be copied so fully within the Harlow Core Strategy.

The Sustainability Appraisal Report (October 2010) related to the Core Strategy is not considered sound or robust. The options tested in the SA undertaken by Scott Wilson relate only to those suggested by Scott Wilson in their Spatial Options Report. This appears to have prejudged the Core Strategy Issues and Options stage as the only options tested are those put forward in a biased evidence base document undertaken to inform the Core Strategy rather than to establish the strategy. The SA will need to be redone once appropriate Spatial Strategy Options have been set out by Harlow Council.

Full text:

Questionnaire + Submitted Letter and Supporting Document

Comment

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

Question 23

Representation ID: 5157

Received: 24/01/2011

Respondent: Pegasus Planning Group

Representation:

It is not considered helpful to include such a large portion of an evidence base document within the Core Strategy. The Scott Wilson Report was intended as an independent evidence base document which should inform the Core Strategy process for the three neighbouring authorities of Harlow, Epping Forest and East Hertfordshire. To include such large sections of the report with no clear emphasis on a particular approach which Harlow Council themselves recommend or favour is not helpful to this process of providing potential options. You will recall that we submitted on behalf of the Harlow West Consortium on 15th June 2010, a detailed response to the Scott Wilson report which we considered failed to deal with potential urban extensions arising at the edge of Harlow in a consistent/equitable manner (For completeness a copy of our full report is attached to this questionnaire). The Consortium contends that the report prepared for the local planning authorities in connection with the Harlow area incorporates meaningless and misleading conclusions which cannot reliably be used as part of the Council's evidence base.

The Consortium considers that the methodology applied in the study represents an inconsistent, biased and flawed approach to determining potential sustainable locations for future growth to the west of Harlow. The Appraisal split the land around Harlow into a series of Spatial Land Areas (SLAs) for evaluation against a set of criteria derived from the overall policy objectives for Harlow set out in Policy HA1 of the EEP. Upon reaching the final stage of the criteria-based assessment, the study selectively split one of the SLAs on the western side of Harlow to form a smaller land parcel (known as EF4a) which it then put forward as the optimal location for new growth for west Harlow, primarily based on its alleged ability to contribute towards regeneration initiatives, specifically in existing neighbourhood renewal areas. This was considered to represent the strictest application of the Policy objectives in evaluating the SLAs. Prior to the splitting of the SLA in question this land area had been assessed, as part of the original SLA, as a less favourable location for development than other SLAs to the west of Harlow. No other SLAs were subdivided to ascertain if other smaller parcels of land could more accurately be assessed for confirmation with the regeneration objective or any of the other Policy objectives. At no point was the smaller land parcel resulting from the split individually subjected to assessment against the other criteria used in the assessment.

The Consortium has serious concerns about the methodological irregularities, the inconsistent approach to the issue of Green Belt coalescence and the unsound justification for the preferred western growth option presented in the Appraisal.

The Consortium considers that the selective splitting of just one SLA to form a smaller land parcel which was then tested against only one of the criteria in the Appraisal introduced inappropriate methodological inconsistencies to the study which resulted in biased and invalid conclusions being drawn about the options for growth to the west of Harlow. Not only does the study fail to explain why other SLAs are not also considered for sub-division for the most accurate assessment against Policy objectives, the Appraisal places undue emphasis on the final regeneration criterion assessment in the evaluation, the findings of which are at odds with the earlier assessment of regeneration in the study using Indices of Multiple Deprivation. The Consortium would strongly argue that the preservation of Green Belt purposes and the integration with sustainable transport links are equally important aims of the Policy and should be afforded similar credence in the evaluation of spatial options. Weighting the appraisal in the manner described above renders the findings highly questionable and unreliable for use as an evidence base to inform spatial growth options for the district. The inexplicable emphasis placed on the SLA's relative ability to contribute towards only 'existing neighbourhood renewal areas' in the final assessment stage therefore seems to be a blatant and contrived effort to manipulate the regeneration category and the results of the appraisal in favour of EF4a.

Methodological concerns are also raised by the reliance on a special sub-area analysis undertaken for one parcel of land only, which does not represent a balanced assessment of the relative merits of the potentially suitable options. The Appraisal can not be said to directly and meaningfully compare any of the other SLAs against EF4a, as this parcel had not also been subject to analysis against the other criteria. This invalidates any conclusion that the Appraisal has robustly and systematically identified this land parcel as the most appropriate location for growth west of Harlow.

It is also considered that the examination of Green Belt purposes and more specifically the issue of coalescence on the west side of Harlow is inconsistently dealt with throughout the report, with coalescence with Roydon initially dismissed and then emphasised as a limitation to growth on this side of the town. The EEP clearly set out the growth requirements for Harlow Growth Options and it was accepted that this would include a requirement to place some growth in areas currently designated as Green Belt (Policy HA1): to exclude options for growth on the grounds of Green Belt conflicts alone is therefore not in accordance with these early policy decisions.

A review of the justification given in the Appraisal for the preferred western expansion area identified clearly demonstrates the inconsistencies which resulted from the biased methodological approach at the assessment stage, and further reveals the unsound basis by which the EF4a subarea was arrived at as the suggested spatial growth option. Avoiding coalescence; sustainability arguments; infrastructure limitations; and spurious generalisations about regeneration and proximity to existing green infrastructure are cited as reasons for the identification of the preferred western growth option location, each of which can either equally or to a greater extent be applied to at least one other land parcel to the western side of Harlow, (the Consortium's own site), or are entirely misleading and inaccurate justifications for the EF4a parcel. Much of the reasoning given appears somewhat confused and smacks of an attempt to validate a preferred option which has been arrived at via a contrived and artificial process.

Based on the analysis presented in this report, the Consortium contends that not only is the method by which the preferred western spatial option is identified conspicuously biased and invalid, the justification subsequently put forward by the Appraisal for the option is unacceptable and does not accurately represent the context in which the SLAs are said to have been considered. Given these serious inconsistencies in the manner in which the preferred growth option has been identified, the Appraisal fails, in a fundamental way, to test all reasonable alternatives as required by PPS12. The Consortium would strongly argue that the Councils can not reasonably use the Appraisal as an evidence base on which to develop a future growth strategy for their districts.

In view of the above comments and following no further comment from any Councils nor Scott Wilson since the submission of these comments in June 2010, the Consortium respectfully request that the Appraisal is either revisited to present a balanced assessment of the spatial options available to the west of Harlow or is removed from the evidence base and it most definitely should not be copied so fully within the Harlow Core Strategy.

The Sustainability Appraisal Report (October 2010) related to the Core Strategy is not considered sound or robust. The options tested in the SA undertaken by Scott Wilson relate only to those suggested by Scott Wilson in their Spatial Options Report. This appears to have prejudged the Core Strategy Issues and Options stage as the only options tested are those put forward in a biased evidence base document undertaken to inform the Core Strategy rather than to establish the strategy. The SA will need to be redone once appropriate Spatial Strategy Options have been set out by Harlow Council.

Full text:

Questionnaire + Submitted Letter and Supporting Document

Comment

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

Question 24

Representation ID: 5159

Received: 24/01/2011

Respondent: Pegasus Planning Group

Representation:

It is not considered helpful to include such a large portion of an evidence base document within the Core Strategy. The Scott Wilson Report was intended as an independent evidence base document which should inform the Core Strategy process for the three neighbouring authorities of Harlow, Epping Forest and East Hertfordshire. To include such large sections of the report with no clear emphasis on a particular approach which Harlow Council themselves recommend or favour is not helpful to this process of providing potential options. You will recall that we submitted on behalf of the Harlow West Consortium on 15th June 2010, a detailed response to the Scott Wilson report which we considered failed to deal with potential urban extensions arising at the edge of Harlow in a consistent/equitable manner (For completeness a copy of our full report is attached to this questionnaire). The Consortium contends that the report prepared for the local planning authorities in connection with the Harlow area incorporates meaningless and misleading conclusions which cannot reliably be used as part of the Council's evidence base.

The Consortium considers that the methodology applied in the study represents an inconsistent, biased and flawed approach to determining potential sustainable locations for future growth to the west of Harlow. The Appraisal split the land around Harlow into a series of Spatial Land Areas (SLAs) for evaluation against a set of criteria derived from the overall policy objectives for Harlow set out in Policy HA1 of the EEP. Upon reaching the final stage of the criteria-based assessment, the study selectively split one of the SLAs on the western side of Harlow to form a smaller land parcel (known as EF4a) which it then put forward as the optimal location for new growth for west Harlow, primarily based on its alleged ability to contribute towards regeneration initiatives, specifically in existing neighbourhood renewal areas. This was considered to represent the strictest application of the Policy objectives in evaluating the SLAs. Prior to the splitting of the SLA in question this land area had been assessed, as part of the original SLA, as a less favourable location for development than other SLAs to the west of Harlow. No other SLAs were subdivided to ascertain if other smaller parcels of land could more accurately be assessed for confirmation with the regeneration objective or any of the other Policy objectives. At no point was the smaller land parcel resulting from the split individually subjected to assessment against the other criteria used in the assessment.

The Consortium has serious concerns about the methodological irregularities, the inconsistent approach to the issue of Green Belt coalescence and the unsound justification for the preferred western growth option presented in the Appraisal.

The Consortium considers that the selective splitting of just one SLA to form a smaller land parcel which was then tested against only one of the criteria in the Appraisal introduced inappropriate methodological inconsistencies to the study which resulted in biased and invalid conclusions being drawn about the options for growth to the west of Harlow. Not only does the study fail to explain why other SLAs are not also considered for sub-division for the most accurate assessment against Policy objectives, the Appraisal places undue emphasis on the final regeneration criterion assessment in the evaluation, the findings of which are at odds with the earlier assessment of regeneration in the study using Indices of Multiple Deprivation. The Consortium would strongly argue that the preservation of Green Belt purposes and the integration with sustainable transport links are equally important aims of the Policy and should be afforded similar credence in the evaluation of spatial options. Weighting the appraisal in the manner described above renders the findings highly questionable and unreliable for use as an evidence base to inform spatial growth options for the district. The inexplicable emphasis placed on the SLA's relative ability to contribute towards only 'existing neighbourhood renewal areas' in the final assessment stage therefore seems to be a blatant and contrived effort to manipulate the regeneration category and the results of the appraisal in favour of EF4a.

Methodological concerns are also raised by the reliance on a special sub-area analysis undertaken for one parcel of land only, which does not represent a balanced assessment of the relative merits of the potentially suitable options. The Appraisal can not be said to directly and meaningfully compare any of the other SLAs against EF4a, as this parcel had not also been subject to analysis against the other criteria. This invalidates any conclusion that the Appraisal has robustly and systematically identified this land parcel as the most appropriate location for growth west of Harlow.

It is also considered that the examination of Green Belt purposes and more specifically the issue of coalescence on the west side of Harlow is inconsistently dealt with throughout the report, with coalescence with Roydon initially dismissed and then emphasised as a limitation to growth on this side of the town. The EEP clearly set out the growth requirements for Harlow Growth Options and it was accepted that this would include a requirement to place some growth in areas currently designated as Green Belt (Policy HA1): to exclude options for growth on the grounds of Green Belt conflicts alone is therefore not in accordance with these early policy decisions.

A review of the justification given in the Appraisal for the preferred western expansion area identified clearly demonstrates the inconsistencies which resulted from the biased methodological approach at the assessment stage, and further reveals the unsound basis by which the EF4a subarea was arrived at as the suggested spatial growth option. Avoiding coalescence; sustainability arguments; infrastructure limitations; and spurious generalisations about regeneration and proximity to existing green infrastructure are cited as reasons for the identification of the preferred western growth option location, each of which can either equally or to a greater extent be applied to at least one other land parcel to the western side of Harlow, (the Consortium's own site), or are entirely misleading and inaccurate justifications for the EF4a parcel. Much of the reasoning given appears somewhat confused and smacks of an attempt to validate a preferred option which has been arrived at via a contrived and artificial process.

Based on the analysis presented in this report, the Consortium contends that not only is the method by which the preferred western spatial option is identified conspicuously biased and invalid, the justification subsequently put forward by the Appraisal for the option is unacceptable and does not accurately represent the context in which the SLAs are said to have been considered. Given these serious inconsistencies in the manner in which the preferred growth option has been identified, the Appraisal fails, in a fundamental way, to test all reasonable alternatives as required by PPS12. The Consortium would strongly argue that the Councils can not reasonably use the Appraisal as an evidence base on which to develop a future growth strategy for their districts.

In view of the above comments and following no further comment from any Councils nor Scott Wilson since the submission of these comments in June 2010, the Consortium respectfully request that the Appraisal is either revisited to present a balanced assessment of the spatial options available to the west of Harlow or is removed from the evidence base and it most definitely should not be copied so fully within the Harlow Core Strategy.

The Sustainability Appraisal Report (October 2010) related to the Core Strategy is not considered sound or robust. The options tested in the SA undertaken by Scott Wilson relate only to those suggested by Scott Wilson in their Spatial Options Report. This appears to have prejudged the Core Strategy Issues and Options stage as the only options tested are those put forward in a biased evidence base document undertaken to inform the Core Strategy rather than to establish the strategy. The SA will need to be redone once appropriate Spatial Strategy Options have been set out by Harlow Council.

Full text:

Questionnaire + Submitted Letter and Supporting Document

Comment

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

Question 25

Representation ID: 5161

Received: 24/01/2011

Respondent: Pegasus Planning Group

Representation:

It is not considered helpful to include such a large portion of an evidence base document within the Core Strategy. The Scott Wilson Report was intended as an independent evidence base document which should inform the Core Strategy process for the three neighbouring authorities of Harlow, Epping Forest and East Hertfordshire. To include such large sections of the report with no clear emphasis on a particular approach which Harlow Council themselves recommend or favour is not helpful to this process of providing potential options. You will recall that we submitted on behalf of the Harlow West Consortium on 15th June 2010, a detailed response to the Scott Wilson report which we considered failed to deal with potential urban extensions arising at the edge of Harlow in a consistent/equitable manner (For completeness a copy of our full report is attached to this questionnaire). The Consortium contends that the report prepared for the local planning authorities in connection with the Harlow area incorporates meaningless and misleading conclusions which cannot reliably be used as part of the Council's evidence base.

The Consortium considers that the methodology applied in the study represents an inconsistent, biased and flawed approach to determining potential sustainable locations for future growth to the west of Harlow. The Appraisal split the land around Harlow into a series of Spatial Land Areas (SLAs) for evaluation against a set of criteria derived from the overall policy objectives for Harlow set out in Policy HA1 of the EEP. Upon reaching the final stage of the criteria-based assessment, the study selectively split one of the SLAs on the western side of Harlow to form a smaller land parcel (known as EF4a) which it then put forward as the optimal location for new growth for west Harlow, primarily based on its alleged ability to contribute towards regeneration initiatives, specifically in existing neighbourhood renewal areas. This was considered to represent the strictest application of the Policy objectives in evaluating the SLAs. Prior to the splitting of the SLA in question this land area had been assessed, as part of the original SLA, as a less favourable location for development than other SLAs to the west of Harlow. No other SLAs were subdivided to ascertain if other smaller parcels of land could more accurately be assessed for confirmation with the regeneration objective or any of the other Policy objectives. At no point was the smaller land parcel resulting from the split individually subjected to assessment against the other criteria used in the assessment.

The Consortium has serious concerns about the methodological irregularities, the inconsistent approach to the issue of Green Belt coalescence and the unsound justification for the preferred western growth option presented in the Appraisal.

The Consortium considers that the selective splitting of just one SLA to form a smaller land parcel which was then tested against only one of the criteria in the Appraisal introduced inappropriate methodological inconsistencies to the study which resulted in biased and invalid conclusions being drawn about the options for growth to the west of Harlow. Not only does the study fail to explain why other SLAs are not also considered for sub-division for the most accurate assessment against Policy objectives, the Appraisal places undue emphasis on the final regeneration criterion assessment in the evaluation, the findings of which are at odds with the earlier assessment of regeneration in the study using Indices of Multiple Deprivation. The Consortium would strongly argue that the preservation of Green Belt purposes and the integration with sustainable transport links are equally important aims of the Policy and should be afforded similar credence in the evaluation of spatial options. Weighting the appraisal in the manner described above renders the findings highly questionable and unreliable for use as an evidence base to inform spatial growth options for the district. The inexplicable emphasis placed on the SLA's relative ability to contribute towards only 'existing neighbourhood renewal areas' in the final assessment stage therefore seems to be a blatant and contrived effort to manipulate the regeneration category and the results of the appraisal in favour of EF4a.

Methodological concerns are also raised by the reliance on a special sub-area analysis undertaken for one parcel of land only, which does not represent a balanced assessment of the relative merits of the potentially suitable options. The Appraisal can not be said to directly and meaningfully compare any of the other SLAs against EF4a, as this parcel had not also been subject to analysis against the other criteria. This invalidates any conclusion that the Appraisal has robustly and systematically identified this land parcel as the most appropriate location for growth west of Harlow.

It is also considered that the examination of Green Belt purposes and more specifically the issue of coalescence on the west side of Harlow is inconsistently dealt with throughout the report, with coalescence with Roydon initially dismissed and then emphasised as a limitation to growth on this side of the town. The EEP clearly set out the growth requirements for Harlow Growth Options and it was accepted that this would include a requirement to place some growth in areas currently designated as Green Belt (Policy HA1): to exclude options for growth on the grounds of Green Belt conflicts alone is therefore not in accordance with these early policy decisions.

A review of the justification given in the Appraisal for the preferred western expansion area identified clearly demonstrates the inconsistencies which resulted from the biased methodological approach at the assessment stage, and further reveals the unsound basis by which the EF4a subarea was arrived at as the suggested spatial growth option. Avoiding coalescence; sustainability arguments; infrastructure limitations; and spurious generalisations about regeneration and proximity to existing green infrastructure are cited as reasons for the identification of the preferred western growth option location, each of which can either equally or to a greater extent be applied to at least one other land parcel to the western side of Harlow, (the Consortium's own site), or are entirely misleading and inaccurate justifications for the EF4a parcel. Much of the reasoning given appears somewhat confused and smacks of an attempt to validate a preferred option which has been arrived at via a contrived and artificial process.

Based on the analysis presented in this report, the Consortium contends that not only is the method by which the preferred western spatial option is identified conspicuously biased and invalid, the justification subsequently put forward by the Appraisal for the option is unacceptable and does not accurately represent the context in which the SLAs are said to have been considered. Given these serious inconsistencies in the manner in which the preferred growth option has been identified, the Appraisal fails, in a fundamental way, to test all reasonable alternatives as required by PPS12. The Consortium would strongly argue that the Councils can not reasonably use the Appraisal as an evidence base on which to develop a future growth strategy for their districts.

In view of the above comments and following no further comment from any Councils nor Scott Wilson since the submission of these comments in June 2010, the Consortium respectfully request that the Appraisal is either revisited to present a balanced assessment of the spatial options available to the west of Harlow or is removed from the evidence base and it most definitely should not be copied so fully within the Harlow Core Strategy.

The Sustainability Appraisal Report (October 2010) related to the Core Strategy is not considered sound or robust. The options tested in the SA undertaken by Scott Wilson relate only to those suggested by Scott Wilson in their Spatial Options Report. This appears to have prejudged the Core Strategy Issues and Options stage as the only options tested are those put forward in a biased evidence base document undertaken to inform the Core Strategy rather than to establish the strategy. The SA will need to be redone once appropriate Spatial Strategy Options have been set out by Harlow Council.

Full text:

Questionnaire + Submitted Letter and Supporting Document

Comment

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

Question 26

Representation ID: 5162

Received: 24/01/2011

Respondent: Pegasus Planning Group

Representation:

It is not considered helpful to include such a large portion of an evidence base document within the Core Strategy. The Scott Wilson Report was intended as an independent evidence base document which should inform the Core Strategy process for the three neighbouring authorities of Harlow, Epping Forest and East Hertfordshire. To include such large sections of the report with no clear emphasis on a particular approach which Harlow Council themselves recommend or favour is not helpful to this process of providing potential options. You will recall that we submitted on behalf of the Harlow West Consortium on 15th June 2010, a detailed response to the Scott Wilson report which we considered failed to deal with potential urban extensions arising at the edge of Harlow in a consistent/equitable manner (For completeness a copy of our full report is attached to this questionnaire). The Consortium contends that the report prepared for the local planning authorities in connection with the Harlow area incorporates meaningless and misleading conclusions which cannot reliably be used as part of the Council's evidence base.

The Consortium considers that the methodology applied in the study represents an inconsistent, biased and flawed approach to determining potential sustainable locations for future growth to the west of Harlow. The Appraisal split the land around Harlow into a series of Spatial Land Areas (SLAs) for evaluation against a set of criteria derived from the overall policy objectives for Harlow set out in Policy HA1 of the EEP. Upon reaching the final stage of the criteria-based assessment, the study selectively split one of the SLAs on the western side of Harlow to form a smaller land parcel (known as EF4a) which it then put forward as the optimal location for new growth for west Harlow, primarily based on its alleged ability to contribute towards regeneration initiatives, specifically in existing neighbourhood renewal areas. This was considered to represent the strictest application of the Policy objectives in evaluating the SLAs. Prior to the splitting of the SLA in question this land area had been assessed, as part of the original SLA, as a less favourable location for development than other SLAs to the west of Harlow. No other SLAs were subdivided to ascertain if other smaller parcels of land could more accurately be assessed for confirmation with the regeneration objective or any of the other Policy objectives. At no point was the smaller land parcel resulting from the split individually subjected to assessment against the other criteria used in the assessment.

The Consortium has serious concerns about the methodological irregularities, the inconsistent approach to the issue of Green Belt coalescence and the unsound justification for the preferred western growth option presented in the Appraisal.

The Consortium considers that the selective splitting of just one SLA to form a smaller land parcel which was then tested against only one of the criteria in the Appraisal introduced inappropriate methodological inconsistencies to the study which resulted in biased and invalid conclusions being drawn about the options for growth to the west of Harlow. Not only does the study fail to explain why other SLAs are not also considered for sub-division for the most accurate assessment against Policy objectives, the Appraisal places undue emphasis on the final regeneration criterion assessment in the evaluation, the findings of which are at odds with the earlier assessment of regeneration in the study using Indices of Multiple Deprivation. The Consortium would strongly argue that the preservation of Green Belt purposes and the integration with sustainable transport links are equally important aims of the Policy and should be afforded similar credence in the evaluation of spatial options. Weighting the appraisal in the manner described above renders the findings highly questionable and unreliable for use as an evidence base to inform spatial growth options for the district. The inexplicable emphasis placed on the SLA's relative ability to contribute towards only 'existing neighbourhood renewal areas' in the final assessment stage therefore seems to be a blatant and contrived effort to manipulate the regeneration category and the results of the appraisal in favour of EF4a.

Methodological concerns are also raised by the reliance on a special sub-area analysis undertaken for one parcel of land only, which does not represent a balanced assessment of the relative merits of the potentially suitable options. The Appraisal can not be said to directly and meaningfully compare any of the other SLAs against EF4a, as this parcel had not also been subject to analysis against the other criteria. This invalidates any conclusion that the Appraisal has robustly and systematically identified this land parcel as the most appropriate location for growth west of Harlow.

It is also considered that the examination of Green Belt purposes and more specifically the issue of coalescence on the west side of Harlow is inconsistently dealt with throughout the report, with coalescence with Roydon initially dismissed and then emphasised as a limitation to growth on this side of the town. The EEP clearly set out the growth requirements for Harlow Growth Options and it was accepted that this would include a requirement to place some growth in areas currently designated as Green Belt (Policy HA1): to exclude options for growth on the grounds of Green Belt conflicts alone is therefore not in accordance with these early policy decisions.

A review of the justification given in the Appraisal for the preferred western expansion area identified clearly demonstrates the inconsistencies which resulted from the biased methodological approach at the assessment stage, and further reveals the unsound basis by which the EF4a subarea was arrived at as the suggested spatial growth option. Avoiding coalescence; sustainability arguments; infrastructure limitations; and spurious generalisations about regeneration and proximity to existing green infrastructure are cited as reasons for the identification of the preferred western growth option location, each of which can either equally or to a greater extent be applied to at least one other land parcel to the western side of Harlow, (the Consortium's own site), or are entirely misleading and inaccurate justifications for the EF4a parcel. Much of the reasoning given appears somewhat confused and smacks of an attempt to validate a preferred option which has been arrived at via a contrived and artificial process.

Based on the analysis presented in this report, the Consortium contends that not only is the method by which the preferred western spatial option is identified conspicuously biased and invalid, the justification subsequently put forward by the Appraisal for the option is unacceptable and does not accurately represent the context in which the SLAs are said to have been considered. Given these serious inconsistencies in the manner in which the preferred growth option has been identified, the Appraisal fails, in a fundamental way, to test all reasonable alternatives as required by PPS12. The Consortium would strongly argue that the Councils can not reasonably use the Appraisal as an evidence base on which to develop a future growth strategy for their districts.

In view of the above comments and following no further comment from any Councils nor Scott Wilson since the submission of these comments in June 2010, the Consortium respectfully request that the Appraisal is either revisited to present a balanced assessment of the spatial options available to the west of Harlow or is removed from the evidence base and it most definitely should not be copied so fully within the Harlow Core Strategy.

The Sustainability Appraisal Report (October 2010) related to the Core Strategy is not considered sound or robust. The options tested in the SA undertaken by Scott Wilson relate only to those suggested by Scott Wilson in their Spatial Options Report. This appears to have prejudged the Core Strategy Issues and Options stage as the only options tested are those put forward in a biased evidence base document undertaken to inform the Core Strategy rather than to establish the strategy. The SA will need to be redone once appropriate Spatial Strategy Options have been set out by Harlow Council.

Full text:

Questionnaire + Submitted Letter and Supporting Document

Comment

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

Question 27

Representation ID: 5164

Received: 24/01/2011

Respondent: Pegasus Planning Group

Representation:

It is not considered helpful to include such a large portion of an evidence base document within the Core Strategy. The Scott Wilson Report was intended as an independent evidence base document which should inform the Core Strategy process for the three neighbouring authorities of Harlow, Epping Forest and East Hertfordshire. To include such large sections of the report with no clear emphasis on a particular approach which Harlow Council themselves recommend or favour is not helpful to this process of providing potential options. You will recall that we submitted on behalf of the Harlow West Consortium on 15th June 2010, a detailed response to the Scott Wilson report which we considered failed to deal with potential urban extensions arising at the edge of Harlow in a consistent/equitable manner (For completeness a copy of our full report is attached to this questionnaire). The Consortium contends that the report prepared for the local planning authorities in connection with the Harlow area incorporates meaningless and misleading conclusions which cannot reliably be used as part of the Council's evidence base.

The Consortium considers that the methodology applied in the study represents an inconsistent, biased and flawed approach to determining potential sustainable locations for future growth to the west of Harlow. The Appraisal split the land around Harlow into a series of Spatial Land Areas (SLAs) for evaluation against a set of criteria derived from the overall policy objectives for Harlow set out in Policy HA1 of the EEP. Upon reaching the final stage of the criteria-based assessment, the study selectively split one of the SLAs on the western side of Harlow to form a smaller land parcel (known as EF4a) which it then put forward as the optimal location for new growth for west Harlow, primarily based on its alleged ability to contribute towards regeneration initiatives, specifically in existing neighbourhood renewal areas. This was considered to represent the strictest application of the Policy objectives in evaluating the SLAs. Prior to the splitting of the SLA in question this land area had been assessed, as part of the original SLA, as a less favourable location for development than other SLAs to the west of Harlow. No other SLAs were subdivided to ascertain if other smaller parcels of land could more accurately be assessed for confirmation with the regeneration objective or any of the other Policy objectives. At no point was the smaller land parcel resulting from the split individually subjected to assessment against the other criteria used in the assessment.

The Consortium has serious concerns about the methodological irregularities, the inconsistent approach to the issue of Green Belt coalescence and the unsound justification for the preferred western growth option presented in the Appraisal.

The Consortium considers that the selective splitting of just one SLA to form a smaller land parcel which was then tested against only one of the criteria in the Appraisal introduced inappropriate methodological inconsistencies to the study which resulted in biased and invalid conclusions being drawn about the options for growth to the west of Harlow. Not only does the study fail to explain why other SLAs are not also considered for sub-division for the most accurate assessment against Policy objectives, the Appraisal places undue emphasis on the final regeneration criterion assessment in the evaluation, the findings of which are at odds with the earlier assessment of regeneration in the study using Indices of Multiple Deprivation. The Consortium would strongly argue that the preservation of Green Belt purposes and the integration with sustainable transport links are equally important aims of the Policy and should be afforded similar credence in the evaluation of spatial options. Weighting the appraisal in the manner described above renders the findings highly questionable and unreliable for use as an evidence base to inform spatial growth options for the district. The inexplicable emphasis placed on the SLA's relative ability to contribute towards only 'existing neighbourhood renewal areas' in the final assessment stage therefore seems to be a blatant and contrived effort to manipulate the regeneration category and the results of the appraisal in favour of EF4a.

Methodological concerns are also raised by the reliance on a special sub-area analysis undertaken for one parcel of land only, which does not represent a balanced assessment of the relative merits of the potentially suitable options. The Appraisal can not be said to directly and meaningfully compare any of the other SLAs against EF4a, as this parcel had not also been subject to analysis against the other criteria. This invalidates any conclusion that the Appraisal has robustly and systematically identified this land parcel as the most appropriate location for growth west of Harlow.

It is also considered that the examination of Green Belt purposes and more specifically the issue of coalescence on the west side of Harlow is inconsistently dealt with throughout the report, with coalescence with Roydon initially dismissed and then emphasised as a limitation to growth on this side of the town. The EEP clearly set out the growth requirements for Harlow Growth Options and it was accepted that this would include a requirement to place some growth in areas currently designated as Green Belt (Policy HA1): to exclude options for growth on the grounds of Green Belt conflicts alone is therefore not in accordance with these early policy decisions.

A review of the justification given in the Appraisal for the preferred western expansion area identified clearly demonstrates the inconsistencies which resulted from the biased methodological approach at the assessment stage, and further reveals the unsound basis by which the EF4a subarea was arrived at as the suggested spatial growth option. Avoiding coalescence; sustainability arguments; infrastructure limitations; and spurious generalisations about regeneration and proximity to existing green infrastructure are cited as reasons for the identification of the preferred western growth option location, each of which can either equally or to a greater extent be applied to at least one other land parcel to the western side of Harlow, (the Consortium's own site), or are entirely misleading and inaccurate justifications for the EF4a parcel. Much of the reasoning given appears somewhat confused and smacks of an attempt to validate a preferred option which has been arrived at via a contrived and artificial process.

Based on the analysis presented in this report, the Consortium contends that not only is the method by which the preferred western spatial option is identified conspicuously biased and invalid, the justification subsequently put forward by the Appraisal for the option is unacceptable and does not accurately represent the context in which the SLAs are said to have been considered. Given these serious inconsistencies in the manner in which the preferred growth option has been identified, the Appraisal fails, in a fundamental way, to test all reasonable alternatives as required by PPS12. The Consortium would strongly argue that the Councils can not reasonably use the Appraisal as an evidence base on which to develop a future growth strategy for their districts.

In view of the above comments and following no further comment from any Councils nor Scott Wilson since the submission of these comments in June 2010, the Consortium respectfully request that the Appraisal is either revisited to present a balanced assessment of the spatial options available to the west of Harlow or is removed from the evidence base and it most definitely should not be copied so fully within the Harlow Core Strategy.

The Sustainability Appraisal Report (October 2010) related to the Core Strategy is not considered sound or robust. The options tested in the SA undertaken by Scott Wilson relate only to those suggested by Scott Wilson in their Spatial Options Report. This appears to have prejudged the Core Strategy Issues and Options stage as the only options tested are those put forward in a biased evidence base document undertaken to inform the Core Strategy rather than to establish the strategy. The SA will need to be redone once appropriate Spatial Strategy Options have been set out by Harlow Council.

Full text:

Questionnaire + Submitted Letter and Supporting Document

Comment

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

Question 31 Other Comments

Representation ID: 5166

Received: 24/01/2011

Respondent: Pegasus Planning Group

Representation:

Status of East of England Plan

The Core Strategy Issues and Options makes continued reference to the withdrawn East of England Plan (EEP). Following the High Court judgement on 10th November 2010 in the case brought by Cala Homes regarding the unlawful revocation of regional strategies, the East of England Plan has been reinstated as a fundamental component of the statutory development plan. As such, it is a material consideration in the formulation of the Core Strategy. Therefore, it is both pertinent and necessary specifically to refer to the relationship between the EEP and the Core Strategy, including the provision of new housing. It is essential that the Core Strategy is updated to reflect the status of the EEP and to demonstrate how the emerging policies are in accordance with and reflect the objectives of the EEP.

The Core Planning Strategy must be prepared in accordance with Section 19(2)(b) of the Planning and Compulsory Purchase Act 2004 which requires that local planning authorities "must" have regard to the regional strategy when preparing LDDs. Section 38(3) of the 2004 Act and Section 82 of the Local Democracy, Economic Development and Construction Act 2009 clearly state that the regional strategy is part of the development plan. Section 70(1) of the Local Democracy, Economic Development and Construction Act 2009 states that "there is to be" a regional strategy for each region other than London and Section 70(2) of the 2009 Act requires the regional strategy to establish policies in relation to the development and use of land in the region. The Core Strategy must have regard to the EEP if it is to be judged legally compliant within the terms of paragraph 4.50 of PPS12. We would also observe that regulation 13(6) of the Town and Country Planning (Local Development) (England) Regulations 2004 as amended states that policies contained in a DPD must be in conformity with the policies in the development plan as referred to in the 2004 Act. Paragraph 4.50 of PPS12 clearly requires a core strategy to conform generally to the relevant regional strategy.

Therefore due to the legislation currently in place, the Harlow Core Strategy must comply with the EEP and appropriately reference its relevant and pivotal policies. It is encouraging that throughout the Core Strategy, Harlow Council state that they intend to continue to work jointly with the neighbouring authorities to deliver the Strategy. This is essential in the case of Harlow due to its tightly drawn administrative boundaries. In order to successfully deliver a sustainable strategy it is considered that this co-operation must continue throughout the plan period.

Response to Question 13

Whilst it is considered important to direct development to areas that will maximise regeneration of the town, this should not override other policy objectives. A balance is required to locate new development in the most sustainable locations taking into account all aspects which affect development. As stated in our response to question 27 relating to the Spatial Options Report undertaken by Scott Wilson, there is undue emphasis on the final regeneration criterion assessment in the evaluation, the findings of which are at odds with the earlier assessment of regeneration in the study using Indices of Multiple Deprivation. The Consortium would strongly argue that the preservation of Green Belt purposes and the integration with sustainable transport links are equally important aims and should be afforded similar credence in the evaluation of spatial options.

Question 17 requests individuals to rank development issues. It is considered that the Council is best placed to provide this judgement taking into account all aspects involved with development.

Response to Question 15

Policy SS7 of the East of England Plan states that strategic reviews of existing green belt boundaries are required in certain key areas to accommodate development requirements "at the most sustainable locations." One of the specified localities is "Harlow, involving land in Harlow, East Hertfordshire and Epping Forest Districts."

Paragraph 3.28 of the EEP establishes the exceptional circumstances which justify the strategic green belt reviews described at Policy SS7. Existing green belt boundaries should be reassessed as Policy SS2 of the EEP directs significant development to major urban areas for sustainability reasons. The EEP observes that "tightly drawn green belt boundaries, while assisting urban concentration, have made it increasingly difficult to meet development needs, particularly for housing, resulting in greater dispersal of development and thereby contributed to unsustainable travel patterns."

The EEP acknowledges that housing requirements are likely to intensify further because of the proximity to London and the scale of future employment growth. Given these circumstances, Harlow is expected to play a key role in the delivery of a sustainable spatial policy framework for the London Arc.

In view of this policy justification, it is considered that the Core Strategy should make it clear that development will need to occur within the Green Belt in order to meet the housing requirements as set out in the EEP and that this should form an integral part of the strategy rather than as a bolt-on towards the end of the plan period.

Full text:

Questionnaire + Submitted Letter and Supporting Document

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