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

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

Question 10

Representation ID: 5975

Received: 28/01/2011

Respondent: Hertfordshire Biological Records Centre

Representation:

4.5.2 Placeshaping.
Objective 1. Promoting access to/use of the Green Infrastructure network completely misses the point of protecting and enhancing the natural environment; both habitats and species.

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

Question 12

Representation ID: 5976

Received: 28/01/2011

Respondent: Hertfordshire Biological Records Centre

Representation:

4.7.4 Tables; Strategic objective. Placeshaping.
This policy should concentrate on the natural environment through the protection and enhancement of the Stort Valley and the need to protect and enhance biodiversity, both habitats and species.

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

Question 31 Other Comments

Representation ID: 5978

Received: 28/01/2011

Respondent: Hertfordshire Biological Records Centre

Representation:

The report is very inconclusive. However,it does highlight several key issues:
* It is not possible to accommodate all 5,720 new dwellings with existing levels of infrastructure provision and localised improvements.

* If Outflow Sewer Phase 2 is delayed or delivery does not proceed at an acceptable pace then it will not be possible to bring forward a substantial number of new dwellings to the north of Harlow.

* A new trunk main sewer between the west of Harlow and Rye Meads STW (currently planned for 2015; subject to review) would be required.

* Development to the north of Harlow would require substantial transport investments in road, rail, cycling and pedestrian infrastructure, including a new northern spine road to connect with the A414, A1184 and M11.

* In terms of transport, there may not be the critical mass in any one area to facilitate critical infrastructure up to 2021.

* The SEA Directive suggests a range of topics for assessment; including biodiversity, fauna, flora, soil, water, air, climatic factors, land and landscape.

* Spatial Options A, D, E show negative effects on county Wildlife Sites and ancient woodlands to the north of Harlow.

* There is a substantial data gap that must be filled before development on these scales can proceed, including the impact of development on protected areas (county Wildlife Sites and ancient woodlands) amongst others.

7. Developing a delivery strategy.

Question 31: comments on Green Infrastructure and the protection of the natural environment.

Biodiversity is a key test of sustainable development, in line with national Government policy, and an essential ingredient of quality of life by contributing positively to environmental objectives.

Key wildlife habitats and species must be protected from harm and the potential impact of development and every opportunity should be taken to enhance existing habitats and species populations and to create new habitats in line with national and county Biodiversity Action Plan targets.

Wildlife sites must be retained, protected and buffered from development and wildlife corridors (green spaces) should be created between sites to allow wildlife species to migrate between sites and out into the open countryside.

Natural features and habitats, and the species they support, must be viewed as important. SSSIs are important because of their national statutory status; County Wildlife Sites are locally important because they represent what is considered to be important at a district level. All wildlife sites must be protected and connected together via a network of functional ecologically robust green corridors (networks); not isolated from each other and surrounded by housing.

Sustainable Urban Drainage Systems (SUDS) should be included in the design of proposed development, to control and contain polluted surface water run-off.

Open spaces within developed areas should consist of multifunctional greenspaces that link together and form corridors through and between each neighbourhood and ultimately link those neighbourhoods with the surrounding countryside. Green corridors and greenspaces should be used to form pedestrian walk ways and cycle routes, so that residents are able to walk/cycle to local shops, facilities and schools without using roads and cars.










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

Question 27

Representation ID: 5979

Received: 28/01/2011

Respondent: Hertfordshire Biological Records Centre

Representation:

Respondent Make the following comments on the Spatial Options for growth around Harlow.



FINAL REORT: Generating and Appraising Spatial Options for the Harlow Area. Scott Wilson. October 2009.



1. Context:

The study considered a number of locations and levels of housing growth. It did not suggest that any of the locations or levels of development are supported by local planning authorities.



The strategic nature of the project precludes a definitive outcome.



2. Criteria:

The aim of the study was to identify areas that were either suitable or unsuitable for development. Spatial land Areas were identified for evidence gathering and analysis. The study claims to have gathered a broad range of information, including Nature Conservation.



Sieve One - Exclusionary Criteria:

National and Local nature designations, including Ramsar sites, SAC, SPA, SSSI, Wildlife Sites, Local Nature Reserve.



3.Spatial Options:

One of the options was for development north of Harlow, in East Hertfordshire.



Areas with the greatest amount of flood risk are predictably along the Stort Valley, including Stort tributaries.



The report states: para. 3.4.2. "....it is not possible to allocate fixed levels of new dwellings that will be provided within each extension. These will be determined at a later date as part of the LDF process for each district."



Landscape-led Option:

The report states: para. 3.4.18. "....no distinct pattern emerges which would reasonably indicate appropriate directions and distributions for development."



3.5 Conclusion:

The report states: para. 3.5.2. "....at this stage the exact boundaries and new dwelling allocations have not been defined, indeed, this exercise is beyond the scope of this study."



4. Testing Spatial Options:

The report states: para. 4.4.1. "While the impact on the landscape to the north will inevitably be significant there are opportunities to maintain key features as part of green infrastructure in new development."



A new Outfall Sewer Phase 1 (2010-2012) will provide some capacity for Harlow North (2,000 dwellings). Sewer Phase 2 (2015; subject to review) will provide capacity for longer term growth.



Development to the north of Harlow would require substantial transport investments in road, rail, cycling and pedestrian infrastructure, including a new northern spine road to connect with the A414, A1184 and M11. In terms of transport, there may not be the critical mass in any one area to facilitate critical infrastructure up to 2021.



Development North of Harlow (5720 dwellings):

The report states (page 63): "If it is not possible to accommodate all 5,720 new dwellings with existing levels of infrastructure provision and localised improvements, then the plan will not be delivered during this time. Secondly, if Outflow Sewer Phase 2 is delayed or delivery does not proceed at an acceptable pace then it will not be possible to bring forward a substantial number of new dwellings to the north of Harlow during the plan period."



Page 66: The report states: "In light of the transport and wastewater infrastructure constraints associated with high levels of development in the northern part of the area, there is an unacceptable risk that the option might not be fully implemented."



4.9 Reasonableness Test Conclusion:



4.9.2. The report states: "However, several factors suggest that 4,000 new dwellings to the north of Harlow may form an approximate maximum level of development (up to 2021)."



4.10.4. The Sustainability test will be extended and include further information on the key effects.



4.10.6 The SEA Directive suggests a range of topics for assessment; including biodiversity, fauna, flora, soil, water, air, climatic factors, land and landscape.



Spatial Options A, D, E:

These options show negative effects on county Wildlife Sites and ancient woodlands to the north of Harlow.



Discussion:

4.11.7 The report states: "In terms of strategic transport improvements to the A414, a northern spine road and new motorway junction northeast of Harlow would most likely be required at the minimum and would effect the phasing of delivery.."



4.11.9 A new trunk main sewer between the west of Harlow and Rye Meads STW (currently planned for 2015; subject to review) would be required. Operational concerns at Rye Meads STW will hinder their capacity to utilise current consents to discharge. In addition, the provision of drainage infrastructure will be expensive and require a long lead time.



4.11.10 The report admits that it is not possible to meaningfully differentiate between the three scenarios of development at this stage. There is also a substantial data gap that must be filled before development on these scales can proceed, including the impact of development on protected areas (county Wildlife Sites and ancient woodlands) amongst others.



4.13.3 There are opportunities to maximise and enhance the areas green infrastructure network - what ever that might mean!



Special consideration for the Harlow Area qualities:

7.3.8 Objectives of the strategy include:

* Creating and maintaining a network of multi-functional greenspaces around the town.

* Protecting and maintaining designated Wildlife Sites and providing for biodiversity.

* Retaining and enhancing existing environmental and historic features;

amongst others.


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