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

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

Question 2

Representation ID: 5814

Received: 28/01/2011

Respondent: Hallam Land Management & Commercial Estates Group

Agent: Broadway Malyan

Representation:

Response: Section 1 of the consultation document "The Context" includes a section on "Working with adjoining authorities" and recognises some of the issues arising from this including:

Harlow's tightly drawn administrative boundaries and the need to ensure that strategic planning decisions are not restricted by this

The need for the town to provide the homes, jobs, shops and services that many in adjoining districts benefit from

Delivering certain elements of the Core Strategy will require the help and support of adjoining Districts (notably the fact that much of the land with potential for expansion lies in these districts).

We consider that the importance of these matters warrants their identification as issues for the Core Strategy and not merely "context". Further, it would be beneficial for this Core Strategy to raise the issue of creating a joint Harlow policy or implementation area covering parts of Harlow, Epping Forest and East Hertfordshire Districts.

It is clear that the three districts will have to co-operate and co-ordinate their Core Strategies to plan for Harlow's future. We consider that Harlow Council's Core Strategy should take a lead in this and be instrumental in guiding the decision making process on Harlow's growth. Harlow Council could invoke the "duty to co-operate" as set out in the Localism Bill to achieve this and assist Government in defining how this duty could work to advance strategic planning decisions in areas that require major growth and regeneration.

The Government's "Plain English Guide to the Localism Bill" refers to the "Duty to cooperate". This states:

"In many cases there are very strong reasons for neighbouring local authorities, or groups of authorities, to work together on planning issues in the interests of all their local residents. This might include working together on environmental issues (like flooding), public transport networks (such as trams), or major new retail parks."

We consider this Core Strategy should define the scope and limits of this co-operation and take the lead in setting out the objectives this co-operation should address.

We would suggest an additional issue as follows:

The creation of a joint policy and implementation area for Harlow's growth including parts of the administrative areas of Epping Forest and East Hertfordshire as well as Harlow".

We note that the housing issues set out in para 2.3.1 include the statement "Greenfield Development should be located in the north and east of Harlow". It is not clear why this statement only refers to north and east Harlow and it appears to pre-judge the issue of where growth should be accommodated. Representations have been made concerning land to the south and south west of Harlow as well as the North and East and the technical work set out in the report by Scott Wilson "Generating and appraising Spatial Options for the Harlow Area" (the Scott Wilson Report) concerns potential locations all around the town. We suggest that this issue be revised to reflect options for Greenfield development to the north, east, south and south west of the town.

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: 5817

Received: 28/01/2011

Respondent: Hallam Land Management & Commercial Estates Group

Agent: Broadway Malyan

Representation:

Response: We consider that the decision on the level of growth at Harlow can only be made on the basis of a full technical assessment of housing requirements. The following needs to be considered and resolved:

How the "community" is to be defined and the geographical area for which an assessment of housing requirements will be made.
Agreement on the extent of this area with the adjoining authorities ï‚· Agreement on a joint policy approach to housing provision in this area
A clear statement of the period of time for which a housing requirement is to be calculated and a target set
A technical assessment of the current and projected housing needs for this area informed by population and household projections.

The Government's "Guidance for LPAs following the revocation of Regional Strategies" (6 July 2010) makes clear that each local authority is required to determine its own housing requirement "without the burden of regional housing targets". We consider that an assessment of the housing requirement within each of the administrative boundaries of Harlow, Epping Forest and East Hertfordshire to a common methodology should be the basis for the co-ordination of housing requirements and provision in the Harlow area.

This process can then factor in spatial planning considerations and the merits of locating new housing adjoining Harlow to meet the town's growth and regeneration objectives and ensure that housing is provided in the most sustainable locations.

We consider that Harlow should now look to a planning period that extends to at least 2026. For this reason and because housing provision has failed to keep pace with the original RSS target of 16,000 for the 2001-21 period, it is very likely that 16,000 dwellings will now be insufficient to meet the current needs of the local community and help secure the regeneration of Harlow.

It is important to recognise that a critical mass of housing growth is necessary to support and deliver the sustainable regeneration of Harlow.

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: 5819

Received: 28/01/2011

Respondent: Hallam Land Management & Commercial Estates Group

Agent: Broadway Malyan

Representation:

Response: The Community Strategy, the Council's Regeneration Strategy and the Council's Corporate Plan set out important principles for the future of the town that we support. However, the Vision should more explicitly point to the growth of the town as the pre-requisite for achieving the ideal conditions that are set out here. Growth in housing and employment are essential if the town is to become a "place of aspiration", a "prime business location" and 4 a "sub regional centre and retail destination" as set out in the Council's "Regeneration and Social Inclusion Strategy". In paragraph 1.7.1 the consultation document states "the Council believes that growth and investment is an important catalyst for regeneration". We consider that this principle and specific endorsement of significant housing and employment growth at Harlow should be included in the vision and priorities set by 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: 5820

Received: 28/01/2011

Respondent: Hallam Land Management & Commercial Estates Group

Agent: Broadway Malyan

Representation:

Response: Subject to the comments we have made above in response to question 6, and the other issues we have raised in response to this Core Strategy consultation, we largely agree that the Core Strategy objectives provide the necessary framework to deliver the regeneration of Harlow.

Full text:

Questionnaire responses incorporated as part of a written submission.

Comment

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

Question 12

Representation ID: 5822

Received: 28/01/2011

Respondent: Hallam Land Management & Commercial Estates Group

Agent: Broadway Malyan

Representation:

Response: We consider that the policy areas identified do not cover all the issues that are relevant to the regeneration of Harlow. In particular, we consider that the assessment of options for development around Harlow should give greater emphasis to how they serve regeneration objectives. We have set out important policy principles to this effect in our response to Question 13 below.

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: 5823

Received: 28/01/2011

Respondent: Hallam Land Management & Commercial Estates Group

Agent: Broadway Malyan

Representation:

Further Comments: We consider that the Green Wedges are a fundamental part of Harlow's structure. They provide valuable open space, amenity and recreational opportunities for the local community. Sir Fredrick Gibberd envisaged the urban form being "broken down into compact units by areas of landscape" which provided "open spaces required for uses such as parkways and playing fields". Furthermore, he was a pioneer in ensuring that the existing landscape features and landform shaped the new town, rather than simply imposing a pre - conceived masterplan upon it. He felt that links to the surrounding countryside would be essential "projecting into the area as wedges which bring rural life into immediate contact with the urban area". The Green Wedges are highly valued by Harlow's residents and should be retained.

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: 5825

Received: 28/01/2011

Respondent: Hallam Land Management & Commercial Estates Group

Agent: Broadway Malyan

Representation:

Harlow's existing key employment sites are located away from the strategic highway network. This is a major disadvantage in meeting current and future employment needs for the following reasons:

The poor access puts these sites at a disadvantage in competing with more accessible locations in other parts of Essex and the East of England

It makes it more difficult to attract new and retain existing businesses which may need to operate from more accessible sites

It gives rise to congestion as commercial traffic has to move through the town in order to access the strategic highway network.

It is clear from the RSS and LDF evidence base that major new infrastructure will be required to improve access to the existing employment areas to the north and west of the town. These proposals include a northern or southern bypass (the northern option requiring a new junction on the M11). These are long term proposals which are subject to considerable uncertainty, primarily due to the high costs involved at a time of severe constraints on public expenditure. However, the immediate constraint on all traffic movements into and out of Harlow (including commercial traffic) is the limited capacity of M11 Junction 7. The first priority should be early implementation of proposals to upgrade and remove capacity constraints at this junction. This can be achieved at relatively low cost and will allow strategic employment land to be identified and programmed for early delivery as an integral part of urban extensions to East and South Harlow, as defined in the Scott Wilson report. A park and ride facility could be provided at Junction 7 in parallel with junction improvements. In the longer term, a partial or complete southern bypass is the best solution to Harlow's highway capacity problems and to the problem of access to existing and proposed employment areas south and west of the town. There is potential in the medium term to make provision for Bus Rapid Transit (BRT) that would connect the new employment / housing areas south of Harlow to the town centre and to the Central Line at Epping. This would ensure that the provision of employment land South of Harlow as well as being the best option to provide new employment land with good access to the M11, would be a sustainable option in terms of access by public transport. The first of seven "Priority Outcomes" set out in Harlow Council's "Regeneration and Social Inclusion Strategy" is: "A prosperous community with sound infrastructure - Harlow at the heart of a dynamic sub-regional economy with excellent connections to regional, national and global economic opportunities" Our analysis of Harlow's employment land requirements, is consistent with the list of proposed actions to achieve this outcome, particularly action (iii) which refers to: "(iii) Developing a strategy for Harlow's employment land offer to enable it to cater for both the existing business sector needs and also the needs of the above sector growth, including consideration of the appropriateness of existing employment areas and the possibility of creating new employment areas. Reviewing, defining needs for, and planning delivery of transportation and other infrastructure requirements for employment areas which can feed into the Local Development framework process." Action (iv) then refers to: "Tackling congestion within the town and unblocking congestion connecting Harlow to strategic transportation routes are of paramount importance for the success of current and future businesses. However, it refers to this action as a "long term project" with a new motorway junction on the M11 being "a key priority". We consider that shorter term actions including improvements to M11 junction 7 and the allocation of employment land close to this junction have a major role in achieving the objectives of the "Regeneration and Social Inclusion Strategy" without dependence upon uncertain longer term investment. We consider these short-terms actions are vital to underpin Harlow's employment base and ensure the town does not lose businesses and jobs to competing centres. If this trend becomes established, it will be more difficult to turn the situation around in the longer term.

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: 5826

Received: 28/01/2011

Respondent: Hallam Land Management & Commercial Estates Group

Agent: Broadway Malyan

Representation:

We support the Council's objective to improve the quality and range of shopping provision in the town centre and transform the townscape quality of the area. There is an important link between the growth of Harlow (in terms of additional housing and employment) and the growth in retail expenditure needed to underpin improvements to 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: 5829

Received: 28/01/2011

Respondent: Hallam Land Management & Commercial Estates Group

Agent: Broadway Malyan

Representation:

Further Comments: The Core Strategy consultation paper cites the consultants' view that this is not a reasonable option because there is an unacceptable risk that it would not be delivered during the plan period, largely due to constraints on this level of development at North Harlow and there being insufficient time to deliver the key infrastructure required. However, it is worth noting the consultants' conclusion from this analysis that "consideration should be given to lower amounts of growth to 2021 with distribution accommodated by larger extensions to the east and south". There are additional factors that count against such a high concentration of growth in one location, including:

The long lead times associated with major development areas
The need for realism in assessing maximum feasible annual house building rates within the period up to 2021
The lack of market choice presented by a single location for growth

All of these factors suggest a much lower level of development is possible at North Harlow, regardless of other constraints.

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: 5830

Received: 28/01/2011

Respondent: Hallam Land Management & Commercial Estates Group

Agent: Broadway Malyan

Representation:

Response; - We agree with the consultants' conclusions on this option (i.e. that this could be a reasonable option if lower levels of housing growth were prescribed for the area west of Harlow with greater growth explored to the east and south). Further Comments: - We have already highlighted, in our response to question 13, the regeneration benefits of development at South Harlow (identified by Scott Wilson in assessing this option). We also note that the Scott Wilson report states that the scale of development proposed to the south in this option (1,300 dwellings) is "not so large that it would breach the ridgeline to the south of Harlow". The report also states that "significant development to the south and west could provide a cost effective solution to the delivery of utilities in these areas compared to smaller, more distributed provision" (table on page 58). Option B is the only one of the five options (A to E) where the consultants conclude that it could be a reasonable option (the condition for this being lower levels of housing growth West of Harlow and greater growth explored to the East and South). All of the other options carry the conclusion "this is not considered a reasonable option". Option B, with the recommended adjustments is therefore worthy of further consideration.

Full text:

Questionnaire responses incorporated as part of a written submission.

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