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

Search Representations

Results for Quod Planning search

New search New search

Comment

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

Question 2

Representation ID: 5915

Received: 28/01/2011

Respondent: Quod Planning

Representation:

The first bullet of section 2.2.5 (land use) identifies that previously developed land should be utilised before greenfield land. In accordance with PPS3, priority should be afforded to previously developed land, however, the Core Strategy needs to ensure sufficient land is available to meet the substantial existing and growing demand. To this end, and given the acknowledged limitation of available urban sites, the Core Strategy will need to plan for the selective release of greenfield sites.

PPS3, as a response to the recommendations of the Barker review, seeks to ensure there is an adequate and responsive supply of land for housing. Paragraph 10 of PPS3 explains that as a specific outcome the planning system should seek to deliver a flexible, responsive supply of land, managed in a way which makes efficient and effective use of land, including the re-use of previously developed land "where appropriate". PPS3 acknowledges that not all previously developed land is suitable for housing, and thus when considered against housing demand and supply, and availability of urban sites, sustainably located greenfield urban extensions may be acceptable.

The East of England Plan requires that Harlow delivers at least 16,000 new homes by 2021. This is predicated on urban extensions being delivered in association with neighbouring authorities. A key issue for the Core Strategy is therefore joint working with adjoining authorities to facilitate the regeneration and transformation of Harlow. This should be reflected as a key issue in the Core Strategy.

Full text:

Questionnaire responses incorporated as part of a written submission.

Comment

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

Question 4

Representation ID: 5917

Received: 28/01/2011

Respondent: Quod Planning

Representation:

HNJV has commissioned a series of studies to assess the needs and requirements of Harlow to enable it to more actively compete with comparable sized towns across the country. Based on the outcome of this work it is considered that the following are key to the successful development and regeneration of Harlow:

* development of a highly qualified, highly skilled workforce;
* a broadening of the economic base with expansion in services, high technology and other growth sectors;
* a more diverse housing offer;
* a vibrant, high-quality town centre able to function as a sub-regional and potentially a regional magnet for retail, leisure and cultural functions;
* creation of a much enhanced 'quality of place' in Harlow; and
* investment in infrastructure and transport to improve connectivity and encourage sustainable movement of people.

Growth is the only realistic way in which the above criteria could be achieved. If skilled and qualified people are to be attracted to, and those who develop skills retained within Harlow, it must offer a range of housing, high quality services & facilities and a high quality of life.

Substantial net growth is necessary to provide the range and quality of housing provision needed in the town to attract and retain economically active and highly skilled people. North Harlow can assist:

* ensuring the delivery of sufficient new market housing and affordable housing to meet evidenced needs and to tackle affordability pressures within the housing market;
* target the provision of affordable housing of the right size, type and quality which broadens the affordable offer, improves choice and meets the diverse range of housing needs including the delivery of intermediate accommodation; and
* facilitate and aid the delivery of housing by supporting innovation in tenure, funding and delivery mechanisms where these assist in securing the provision of market and affordable housing solutions.

Places for People, a partner in HNJV, have significant expertise in this respect which can be utilised at North Harlow.

Development of the town centre will need to involve the provision of a wider range of commercial and other services, and expansion of employment. This expansion of the economy will necessitate population growth both as a consequence of employment growth and in order to support the expanded range of town centre retail and leisure provision. Substantial growth will also be required to justify and fund the investment in services and infrastructure, and to create the improvements in Harlow's quality of place which will underpin success.

These matters were fully considered during the preparation of the RSS (in particular during independent examination) and it was concluded that around 16,000 homes were required to 2021 to support the level of transformation necessary to facilitate change at Harlow. Furthermore, the RSS states that in looking beyond this period, planned annual rates to 2021 should be rolled forward, which in the case of Harlow equates to 1,010 a year (ie 10,100 to 2031). That evidence base continues to remain valid and robust today.

To this end HNJV support the inclusion of 16,000 dwellings to 2021, and a further 10,100 to 2031, as the minimum required to meet existing and growing demand, and act as a catalyst to regeneration and investment in Harlow. Failure to provide this level of new homes will not facilitate the level of transformational change necessary.

The draft Core Strategy intends to plan development in the District to 2026 and we query whether this should be 2031 to reflect the East Herts Core Strategy and draft RSS Review, and also earlier drafts of the Harlow Core Strategy Issues and Options. Furthermore, the document states in various places that based on the targets of the adopted RSS 16,000 homes should be delivered. However, those RSS figures were over the period 2001 to 2021 with a roll forward to 2031. In March 2010 the draft revision to the RSS suggested a roll forward of the 16,000 target from 2011 to 2031. To this end the relevant text in the Core Strategy explaining the housing target should be updated.

In addition, the document states in numerous instances that the RSS has been withdrawn. This is factually incorrect. Whilst the Localism Bill confirms the Government's intent to remove the regional tier of planning policy, following the successful challenge by Cala Homes, the RSS formally remains part of the Development Plan. The necessary text should be updated accordingly.

Full text:

Questionnaire responses incorporated as part of a written submission.

Comment

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

Question 6

Representation ID: 5918

Received: 28/01/2011

Respondent: Quod Planning

Representation:

The visions identified in the 4 specified documents contain a number of positive statements and principles. However, they are rather generic in content and could apply to many towns across the country. It is HNJV's view that the Core Strategy vision for Harlow should be more specific to what the document is actually trying to achieve. It is clear from the initial chapters of the Core Strategy that the most significant issue for the town is to encourage residential and economic growth, in order to stimulate investment in the town and provide a better quality of life with more opportunities. As a result we would suggest that the vision be amended to refer to the need for the population of the town to grow to such a scale that is large enough to fulfil its potential as a major centre and to provide the level of services and facilities to sustain the town for the benefit of local residents and its surrounding hinterland.

Full text:

Questionnaire responses incorporated as part of a written submission.

Comment

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

Question 8

Representation ID: 5919

Received: 28/01/2011

Respondent: Quod Planning

Representation:

HNJV support the "Themes" identified, however, would recommend that they specifically address "Governance". The future governance of the new communities created to address Harlow's substantial and growing need for new housing are at least as important as the design of such areas. Local, robust, long term structures are required to allow places to thrive long after the development is established. Community governance, in which people have a stake in their community, should be a key theme of the Core Strategy.

Full text:

Questionnaire responses incorporated as part of a written submission.

Comment

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

Question 10

Representation ID: 5920

Received: 28/01/2011

Respondent: Quod Planning

Representation:

We have reviewed the proposed "Strategic Objectives" and on the whole we consider they are appropriate to the defined "Themes". However, HNJV would like to make the following comments:

* Placeshaping Objective 1 seeks to protect, enhance and promote access to Green Infrastructure. Whilst HNJV support the intent of this objective, given that the Core Strategy acknowledges the need for urban extensions to satisfy existing and future housing need, this objective will potentially be in conflict with any growth objectives. As a result HNJV suggest the objective be amended to read "Protecting, enhancing and promoting access to/use of the Green Infrastructure network, where appropriate having regard to growth objectives";

* The Core Strategy indicates that from responses received to date there is a desire for the town to grow and provide a greater range of housing types. Furthermore, the Core Strategy acknowledges that to satisfy this need insufficient urban sites exist and as a result urban extensions will need to be considered. In view of this and given the tight administrative boundary to Harlow, the Council will need to work with adjoining authorities. Failure to do so is likely to frustrate the local view that Harlow should grow. HNJV would therefore suggest a new Housing objective be added; "To work with adjoining authorities to deliver residential-led major mixed use urban extensions";

* HNJV would suggest the following new objectives are created under the new 'Governance' theme:
* to engage local people in decisions regarding their communities;
* to enable local communities to play an active role in managing local assets; and
* to enable local communities to share in the benefits of growth.

Full text:

Questionnaire responses incorporated as part of a written submission.

Comment

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

Question 16

Representation ID: 5921

Received: 28/01/2011

Respondent: Quod Planning

Representation:

The network of open spaces/green wedges are characteristic of Gibberd's vision for Harlow and represent vital elements of community life in Harlow. This was reinforced during HNJV's public consultation undertaken to date, with numerous respondents commenting that the existing open spaces are in part what makes Harlow unique. As a result, HNJV would support there protection and enhancement so as to provide an easily accessible recreational resource to the town's existing urban population. In areas where existing spaces areas are underused, the Council should work with the local community to enhance these spaces or utilise them for alternative forms of recreation.

If Harlow is to be truly regenerated and transformed, major growth and investment is needed. The draft Core Strategy acknowledges that housing needs can only be met through urban extensions in the Green Belt. The Council commissioned, with East Herts and Epping Forest Councils, the Scott Wilson Options Appraisal which considered suitable options for urban extensions, and concluded the potential for 10,000 units at land north of Harlow. As a result, that document recognised the need for a separate greenbelt review. HNJV would therefore suggest a review of the greenbelt is undertaken with adjacent authorities to allow the identification of appropriate locations for urban extensions that will enable Harlow to prosper and grow.

Full text:

Questionnaire responses incorporated as part of a written submission.

Comment

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

Question 19

Representation ID: 5923

Received: 28/01/2011

Respondent: Quod Planning

Representation:

Harlow currently performs poorly economically and socially. It suffers from a declining population, outmigration and a pattern of low earnings for local residents. Harlow's economic performance is further adversely impacted by its positioning relative to higher growth industry sectors and a significant reliance on the manufacturing sector. In particular, Harlow's office and retail economies under-perform and are characterised by a lack of quality or hierarchy of offer.

Harlow has an established office market but it is not a prime office location. It is currently characterised by:

* low take up rates;
* lack of available space and low stock levels;
* low rental values;
* no significant quality out of town business location;
* poor track record of inward investment; and
* a higher than average dependence on a small number of large occupiers.

Against this background there has been limited investment in new office products in Harlow. HNJV's commercial consultants have advised that increased demand for offices at Harlow will be driven by:

* access to markets including London and Cambridge;
* access to a quality local labour pool;
* proximity to London Stansted airport for airport related business;
* existing R&D based demand, in particular where the regional policies are successful in driving the knowledge based economy in the M11 corridor; and
* significant improvements to the physical, social and amenity of Harlow Town Centre.

In order to compete more effectively for office demand Harlow will need to offer an appropriate hierarchy of quality office products, including both town centre and out of centre locations. Furthermore, in order to compete more effectively economically, Harlow has to improve the quality of its resident skill base which in the short term will be facilitated through the creation of high quality housing and employment opportunities.

North Harlow can play in important role in the long-term economic transformation of Harlow. It can deliver a substantial proportion of the existing and future housing need, providing a range of property mix and tenure including affordable housing. This will significantly enhance the resident skill base of Harlow, in a location with good access to the town centre and reinforce the existing employment hubs in the town. Furthermore, it will also assist create a more sustainable travel to work pattern for Harlow, which will in turn assist relieve congestion pressures across the town.

Full text:

Questionnaire responses incorporated as part of a written submission.

Comment

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

Question 20

Representation ID: 5924

Received: 28/01/2011

Respondent: Quod Planning

Representation:

Harlow is a sub-regional shopping destination which should be improved and enhanced. The existing Harlow retail market is characterised by:

* a poor physical environment and lack of department store;
* leakage of trade to other centres;
* decline in rental values and high vacancy rates;
* the primary catchment contains a significantly less affluent demographic than the wider catchment; and
* the retail offer is primarily value and mass offer with limited premium retailers.

HNJV recognise the need to improve the retail and leisure offer within the town centre which will assist retain the current loss of expenditure to other destinations, and improve the perception and attractiveness of Harlow as a residential and employment location.

North Harlow can assist in this objective as it has the potential to deliver a new population with a differentiated demographic offering a significant increase in retail expenditure capacity. This will act as a catalyst to enhance the positioning and level of investment in the existing retail offer of the town.

The retail offer at North Harlow would be different from the town centre, serving the day to day needs of its population. To this end North Harlow will not compete with the town centre.

Full text:

Questionnaire responses incorporated as part of a written submission.

Comment

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

Question 21

Representation ID: 5925

Received: 28/01/2011

Respondent: Quod Planning

Representation:

East Herts, Epping Forest and Harlow Councils jointly commissioned the production of "Generating and Appraising Spatial Options for the Harlow Area" (the "Options Appraisal"), originally as a requirement of the East of England RSS. Despite the pending abolition of the RSS, the evidence base that supports it is still of relevance, as recognised in Steve Quartermain's letter of 6th July 2010 to all Chief Planning Officers which confirms "evidence that informed the preparation of the revoked Regional Strategies may also be a material consideration".

The Options Appraisal represents an independent assessment of the potential locations for growth around Harlow which not only meet the substantial and growing housing need in Essex and Hertfordshire, but also assist the regeneration of Harlow. As set out in PPS12, this is an important deliverability requirement for all Core Strategies, which are required to ensure "that what is in the plan is consistent with other relevant plans and strategies relating to adjoining areas". Indeed plans would not be sound if they did not do so. Furthermore, paragraph 4.45 of PPS12 requires Core Strategies to be "coherent with the core strategies prepared by neighbouring authorities, where cross boundary issues are relevant". This is also consistent with the Localism Bill which places a duty of cooperation on local planning authorities during the production of development plan documents.

To this end the conclusions of this independent assessment cannot be dismissed. Option A positively identifies the potential for development North of Harlow, however, it also defines a number of perceived constraints. HNJV has interrogated these conclusions with it's professional team, and the exercise has identified some significant discrepancies, which are highlighted in Table 2 [see attahced].

Table 2 demonstrates that the perceived negative constraints to development North of Harlow identified by Scott Wilson do not actually represent barriers to development. As such, the Options Appraisal in conjunction with the responses in Table 2, provides an independent and robust assessment which supports development at North Harlow.

The draft Core Strategy recognises that the RSS evidence base remains valid and relevant to Harlow, in particular the role that housing and job growth, even on sites beyond the District, can have in delivering the regeneration of the town. To this end North Harlow, despite being beyond the District boundary, has a significant role to play in supporting the regeneration of Harlow as supported by the Scott Wilson assessment. In particular, the North Harlow development will be supported by a full range of social infrastructure including schools, health facilities, community facilities, and open space and leisure facilities. These facilities will not only benefit the new population of the site but also the existing communities adjacent including Harlow residents.

To this end HNJV support the principle of Option A, but do not support the conclusion that the option presents an unacceptable risk due to the constraints identified.

Full text:

Questionnaire responses incorporated as part of a written submission.

Comment

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

Question 22

Representation ID: 5926

Received: 28/01/2011

Respondent: Quod Planning

Representation:

HNJV do not support the conclusions of this option. In the first instance the option is inconsistent with the adopted East of England Plan which requires that North Harlow accommodate "an eventual development of at least 10,000 dwellings and possibly significantly more". The RSS policy was formulated on the basis that it was recognised that a significant scale of development was required to act as a transformational catalyst to stimulate further investment in Harlow and address its current deficiencies. The specific identification of large scale growth at North Harlow was recognition that smaller scale incremental development would not provide the level of change required at Harlow, and that North Harlow is the only realistic location to provide such a scale of growth.

HNJV consider the provision of only 3,600 dwellings north of Harlow as a missed opportunity. Focusing development in other locations, particularly east and west would not provide the level of transformational change that is required to reverse Harlow's current decline. The small scale nature of these sites means that they would not be able to deliver the same level of benefit to the wider regeneration of Harlow.

Development at North Harlow would be able to accommodate all necessary physical and social infrastructure for the new residents, meaning that there would be no detrimental impact to existing services and facilities in the area. Smaller scale developments to the south, west and east, as proposed in Option B would be unlikely to provide infrastructure in a similarly comprehensive way.

Furthermore, in view of the scale of the North Harlow site, it has the potential to employ various technological innovations that will minimise the impact of the new residential development, in a manner that could not be accommodated by spreading development across a number of smaller sites throughout Harlow. For example, HNJV intend to give greater emphasis to on-site collection and treatment of water thus minimising its impact on the environment; as well as providing a decentralised energy centre to serve the entire site with zero carbon heat and power. To this end HNJV strongly disagree that sewerage will act as a significant constraint at North Harlow (conversely it should be viewed as a positive), although it is likely to be a restraint for the other 3 potential growth destinations.

In addition, North Harlow is better related in transport terms to the town centre, railway station and employment areas than the other growth locations as summarised in Table 3 below. This demonstrates that North Harlow is well-located to each of these facilities and is the closest of all the potential development areas identified, except the Pinnacles where development to the west is a little closer.

[see attatched for table 3]

The scale of development at North Harlow therefore offers a unique opportunity to leverage investment in a range of areas that can benefit Harlow and the wider area as a whole. Focusing growth in a sustainable urban extension is more appropriate than isolated, incremental parcels of development across Harlow.

Full text:

Questionnaire responses incorporated as part of a written submission.

If you are having trouble using the system, please try our help guide.