Saffron Walden Town Council

Saffron Walden Town Council's response to the Uttlesford Local Plan

SAFFRON WALDEN TOWN COUNCIL RESPONSE TO UTTLESFORD LOCAL PLAN -

Consultation on Additional Housing
Numbers and Sites
November 2013


BACKGROUND

Uttlesford District Council is currently undertaking a ‘Consultation on Additional Housing Numbers and Sites’ which will run into early January, 2014. It stems from the council’s Local Plan Working Group and the Cabinet having accepted the need to both increase the proposed rate of housing delivery (in order to meet the objectively assessed housing need within the district) and extend the period of the plan (in order to comply with the NPPF). The obvious implications are that the current draft plan must be revised because otherwise it will not be found to be ‘sound’ at examination.

4 sites have been identified for residential development in an attempt to rectify the resulting shortfall in housing allocations, these being:-
• Ashdon Road Commercial Centre, Saffron Walden 167 units
• Land south of Stortford Road, west of Great Dunmow 400 units
• Helena Romanes School, Great Dunmow 100 units
• Land north east of Elsenham 2,100 units

The stated purpose of the consultation is to seek views on the Council's assessment of the amount of housing which will be needed during the period of the new Local Plan up to 2031.

The consultation also seeks views on the sites above which UDC’s Cabinet has identified as the preferred sites to meet this additional requirement. It is important to note that the sites in this consultation are referred to as extra sites which will be added into the Draft Plan of 2012. There is no intention to review the adequacy or appropriateness of the other sites previously put forward in the Draft Plan all of which will remain in the plan.

The consultation poses a series of very specific questions. The first two relate to the period of the plan and the scale of the increase in development respectively. They clearly assume that the approach being taken in looking to revise the plan is the right one and cannot be challenged. The remaining four seek comments on each of the proposed development sites and ask what changes are sought.

This response is to the first two questions relating to the overall approach to the proposed amendments and to that relating to the site in Saffron Walden.

Question 1
Are there any reasons why the Council should not comply with government policy and prepare a plan for 15 years after it is adopted? Please clearly explain your reasons, set out what plan period you think is appropriate and explain how this can be justified against government policy.

The district council should clearly comply with government policy with regard to all aspects of local plan preparation unless it has very strong and convincing reasons to do otherwise. Any such reasons should be so robust and justifiable that they can reasonably be expected to satisfy the Inspector at the examination into the local plan. The council has never had any such reasons. It should therefore not even be consulting on whether or not to adhere to government policy in preparing a plan for 15 years but should have done so from the outset. It should not have wasted valuable time in attempting to shorten the period to some 12 years by extending it backwards (to a start date of 2011) on the pretext of continuity when the real reason was to try and minimise the amount of housing that is required to be delivered.

Whether or not the plan period should be limited to 2031 is another matter. That is because para. 157 of the Framework states:-
“Crucially, Local Plans should: ..............
• be drawn up over an appropriate time scale, preferably a 15-year time horizon, take account of longer term requirements............”.
Whilst the plan is now being prepared in accordance with the preferred time horizon of 15 years from adoption, it does not have anything like adequate regard to the longer term. Previous versions, and that which is currently being proposed, have all patently failed to do that. For the consultation document to casually mention (as it does at para. 6.1) that the site “........ between Elsenham and Henham ......... is a large strategic allocation which has the potential to expand in the future to continue to meet housing requirements beyond the current plan period” is simply inadequate.

Para. 182 of the Framework states “....the plan should be the most appropriate strategy, when considered against the reasonable alternatives...”. The identification of the possible alternative strategies must, of course, be based on the principles of what constitutes development which is sustainable. The reasonable alternative strategies which exist currently have not even been identified, let alone objectively and comprehensively assessed, such that it is simply not possible to determine which is “...the most appropriate....”.

It is highly improbable that the current overly-simplistic strategy of allocating the vast majority of development to Saffron Walden and Great Dunmow on the basis that the existing concentration of services and facilities “.....makes them suitable for a large scale of development......” will satisfy any Inspector. Hence, the whole basis of both the current draft plan and its current proposed extension to 2031 is seriously flawed and will inevitably be exposed as such by the local plan Inspector unless it is radically overhauled and effectively recommenced.

Nevertheless, the situation has now moved on from what it was when the district council produced its draft local plan for consultation in June/July 2012. Greenfield sites have been granted planning permission for major housing developments particularly in Great Dunmow, Elsenham and Stansted Mountfitchet with another key site, on the edge of Saffron Walden, also subject to pressure in the form of a planning application for 300 houses. This has been the result of opportunistic planning applications as a consequence of the district council having been unable to demonstrate a 5 year housing land supply. Uttlesford District Council’s Cabinet has also recently determined, on behalf of UDC, that “The plan should cover at least a 15 year time frame from adoption” and that “The 5 year land supply requirement is based on the objectively assessed need of 523 dwellings a year”. This means that the previous housing land supply deficit is now reinstated because the Cabinet has recently decided to do what the Council should have been doing from the outset.

The implications of the recent planning permissions, UDC Cabinet’s recent decision and the scale of the required housing developments that are not yet allocated mean that:-
• the district council now has a 5 year housing land supply deficit (of only 246 units);
• the settlement pattern of the district will change as a consequence of the implementation of the planning permissions already granted; and
• the extension of the plan period (to 2031) and the proposed increase in the annual housing requirement (from 415 to 523) is such that the amount of housing not yet committed is of the order of 7,000 units to 2031 (and that looking to the longer term would increase that dramatically).

In summary therefore the response to the question is as follows:-
• the district council should most certainly comply with government policy in preparing its local plan and is to be heavily criticised for having sought to prepare a plan which did not cover at least a 15 year plan period from the date of adoption without any justifiable reason;
• the local plan fails to “.......take account of longer term requirements.....” adequately as there is no justification for the ‘large strategic allocation’ between Elsenham and Henham being allowed “.......to expand in the future to continue to meet housing requirements beyond the current plan period”;
all of which means that
• the local plan should be recommenced and prepared in accordance with the sustainability principles set out clearly in the Framework having full regard to:-
* the current settlement pattern including all of the major development
proposals which have recently received planning permission which together
will influence the nature of that settlement pattern;
* an updated evidence base which encompasses the findings of the Strategic
Housing Land Availability Assessment, the most recent Strategic Housing
Marketing Assessment, the ‘Uttlesford Local Plan Highway Impact
Assessment : Assessment of Highway Impact of Potential Local Plan Sites’ of
October 2013 which must be updated to reflect the subsequent grant of
planning applications for major developments and the most recent forecasts
of population growth; and
* the need for the plan to both remain flexible (in order for it to be able to
respond to changing circumstances) and the need to “.....take account of
longer term requirements.....” (which should entail these two factors being
inextricably linked such that the rate of development in what is demonstrated
to be the optimum location is simply varied so as to meet the level of
identified need within a particular timescale as necessary).
Question 2
Do you agree with the Councils assessment of objectively assessed need (?) If you do not please set out your preferred alternative method of calculating housing need and supply appropriate evidence. You should also explain how your calculation meets Government policy.

The consultation document states (at para. 2.13) “The Council considers the objectively assessed housing need arises from the 2010-based SNPP. This takes account of migration and demographic change and is based on buoyant demographic household formation rates so it plans positively for the future needs of the District. The Council considers this housing need can be met without any adverse impacts on the policies in the NPPF as a whole or specific policies which indicate development should be restricted.” This raises two important issues which are:-
1. what constitutes ‘objectively assessed housing need’; and
2. how and why the council considers this need can be met “.....without any adverse impacts on the policies in the NPPF.......” and what this means for the strategy underlying the local plan.
Each of these is considered in turn below.

1. Objectively assessed housing need

The provision of “....the full, objectively assessed needs for market and affordable housing in the housing market area.....” is a requirement for all local planning authorities preparing local plans as specified in para. 47 of the Framework. But para. 159 goes on to tell the local planning authorities exactly how to go about determining their ‘objectively assessed needs’. It states:-
“Local planning authorities should have a clear understanding of housing
needs in their area. They should:
• prepare a Strategic Housing Market Assessment to assess their full housing needs, working with neighbouring authorities where housing market areas cross administrative boundaries. The Strategic Housing Market Assessment should identify the scale and mix of housing and the range of tenures that the local population is likely to need over the plan period which:
- meets household and population projections, taking account of migration and demographic change;
- addresses the need for all types of housing, including affordable
housing and the needs of different groups in the community (such as, but not limited to, families with children, older people, people with disabilities, service families and people wishing to build their own homes); and
- caters for housing demand and the scale of housing supply necessary to meet this demand;.............................”

So the Framework spells out that the way in which to obtain ‘a clear understanding of housing needs in their area’ in order ‘to assess their full housing needs’ is to prepare a Strategic Housing Market Assessment (SHMA).

But, instead of looking to provide the “........ full, objectively assessed needs for market and affordable housing....”, as required by the Framework, in April 2012 UDC’s Cabinet adopted the Economic Scenario as the most appropriate basis on which to develop the new Local Plan. This was despite the population and household growth in that scenario being constrained by the growth in the annual labour force.

The ‘London Commuter Belt (East)/M11 Sub-Region Strategic Housing Market Assessment 2008’ (published in 2009) was commissioned in 2008 by six local planning authorities one of which was Uttlesford. The SHMA was subsequently updated in 2012 and the ‘LCB East Sub-region Strategic Housing Market Assessment Update 2012’ published some time later in March 2013 – a year after the publication of the Framework. It identifies the housing requirement over the period 2011 to 2033, by district, according to the 4 scenarios to emerge from the detailed household projections undertaken by Edge Analytics in the ‘Greater Essex Demographic Forecasts’. For Uttlesford, the figures are as follows:-
• Trend Based Projections 11,500 (523/year)
• Approved Regional Spatial Strategy
Based Household Projections 11,100 (505/year)
• Net Nil Migration Based Household Projections 2,500 (114/year)
• Jobs-led Household Projections 8,800 (400/year)

Hence it is readily apparent that the information necessary to warrant a significant increase in the annual housing requirement has been readily available for the past 9 months on the basis that:-

1. the Framework which specifies (at para. 47) that “.......local planning authorities should use their evidence base to ensure that their Local Plan meets the full, objectively assessed needs for market and affordable housing in the housing market area......” was published in March 2012;

2. the Framework specifies (at para. 159) that local planning authorities “.....should prepare a Strategic Housing Market Assessment to assess their full housing needs............”; and

3. the updated SHMA, published in March 2013, identified that the annual housing requirement for the district during the plan period is 500 +.

In summary therefore the response to the question is that the town council agrees with the district council’s assessment of objectively assessed need. However, it should be pointed out that the information necessary to reach this conclusion has been readily available since March soon after which the district council should have determined that view. It should have also then resolved to assess how best to plan to accommodate all of the as yet uncommitted growth in the most sustainable manner. That would have inevitably involved rethinking the ‘strategy’ underlying the local plan and recommencing its preparation in accordance with the sustainability principles in the Framework.

Such a rethink should have also enabled the council to comply fully with two crucial requirements of the Framework which are to:-
1. have “......sufficient flexibility to adapt to rapid change......” (para. 14); and
2. “........take account of longer term requirements......” (para. 57)
both of which the current draft plan is failing to do.


2. How and why this housing need can be met and what this means for the strategy underlying the local plan.

The consultation states that “The Council considers this housing need can be met without any adverse impacts on the policies in the NPPF as a whole or specific policies which indicate development should be restricted.” This is an attempt to try to demonstrate compliance with para. 14 of the Framework which relates to the presumption in favour of sustainable development. Given the large size of the district, its rural nature and the fact that there are no extensive restrictive policies (e.g. green belt designation), it is to be expected that the objectively assessed needs could be readily met within its boundary.

Despite this, it is not accepted that the “....housing need can be met without any adverse impacts on the policies in the NPPF....” because, as stated above in the answers to both questions 1 and 2, the strategy on which the plan is based must be reassessed and the plan reviewed as a consequence. That is because the draft plan will demonstrably fail to deliver sustainable development which, according to the Framework, is what the purpose of planning is to help to achieve.

Question 3
Do you have any comments on this proposed site allocation or the ..... policy? If you think the policy should be changed please set out clearly in your comments what changes you would like to see.

The site which is the subject of this question is the 13 hectare Ashdon Road Commercial Centre (see map below). An outline planning application has previously been submitted for a mixed use scheme including up to 167 homes, builders merchants and yard, 2 ha of land for Classes B1, B2 and B8 (Business, General Industry and Storage and Distribution Uses), a retail store, cafe/restaurant, public house and a hotel. This council has already responded to this application recommending that it be refused for a variety of reasons.



Source : Uttlesford Local Plan - Consultation on Additional Housing Numbers and Sites Nov. 2013

 

The 2 issues which this question clearly raises are:-
1. the appropriateness of the proposed allocation; and
2. the wording of the policy itself (see Appendix) – assuming, of course, that the principle is acceptable.
Each of these is now considered in turn below.

1. Appropriateness of the proposed allocation

The proposed allocation is justified on the basis of:-
• the results of the Strategic Housing Land Availability Assessment (SHLAA) the Sustainability Appraisal (SA) and the available evidence base;
• there are not enough suitable sites available to meet the additional housing need under options of looking for more sites in the towns and key villages; so that (according to the report1)
• “.....a completely new settlement option would not be appropriate.....” but it is important to be aware that that statement is not justified; and that therefore (according to the report1)
• “It is clear that a larger scale development in one or more settlements needs to be considered”.

The report states (at para. 12) “These additional sites will be subject to public consultation. Evidence relating to the current sites will need to be updated to consider impacts arising from the new sites and any cumulative impacts e.g. in relation to highways, education, water. This will be done during and following the consultation process and the information made available alongside the Pre-Submission Plan when it is published for consultation in 2014.” This suggests that the sites will be incorporated into the plan irrespective of whatever the public’s response to this consultation and the findings of any ‘updated’ evidence.

The fact that the prospect of a new settlement is not even being considered is somewhat surprising given that the report actually points out (at para. 9) that para. 52 of the Framework states that “the supply of new homes can sometimes be best achieved through planning for larger scale development such as new settlements or extensions to existing villages and towns that follow the principles of Garden Cities. Working with the support of their communities local planning authorities should consider whether such opportunities provide the best way of achieving sustainable development....” (emphasis added).

Uninformed, first reactions to the proposed development of the Ridgeons site might be along the lines:-
• the site is previously developed and under-used;
• the proposed development would generate jobs;
• the proposed development would provide much needed affordable housing
and that the proposal is therefore acceptable in principle.

 

1. Local Plan Working Group Agenda Item ‘Additional Housing Sites’, 1st November 2013
However, somewhat more detailed consideration reveals the following:-
• the site is not all previously developed and the south western quadrant comprises the only area of amenity open space in the north-east part of town which is much used, and greatly valued, by local residents;
• that same south western quadrant of the site includes a football pitch (previously laid out to junior pitch specifications) which has been used by local junior teams for at least the last 17 years and has been used as a football pitch (albeit with brief gaps) for at least 40 years. Nor are there a replacement facilities to be provided “that better meet local recreational needs” (as required by local plan policy LC1);
• it has not been demonstrated that there is a reasonable prospect of the site being used for the allocated employment uses;
• the proposed development would have a serious adverse impact on areas of special roadside verge and the local wildlife site which support the rare Sulphur Clover Trifolium ochroleucon plants and other rare calcareous (chalk) grassland plants whilst also resulting in the needless loss of other wildlife habitats on the site. One such habitat is the pond at the bottom of the pit (situated at the front of Ridgeons to the left) which is proposed to be filled-in and a house built over it;
• the site is located on the ‘wrong side’ of town with regard to main destinations and routes to work because the nature and frequency of the existing public transport services, and the sheer distance of the site from the railway station and the town centre, is such that the use of sustainable modes of transport will be minimal;
• the additional development and resulting traffic would not only exacerbate existing traffic congestion but also lead to an unacceptable risk from excessive levels of air pollution;
• the proposed development would exacerbate existing problems with regard to infrastructure provision (including sewerage and roads). It would also create further education requirements in both primary and secondary schools for which there is neither existing capacity nor the scope to provide it.

It may well be that some form of development which regenerates the existing commercial buildings on the site would be perfectly acceptable. But the redevelopment of the whole site along the lines proposed would be unsustainable, and therefore unacceptable, for the reasons set out above. This applies particularly with regard to the irrevocable harm that would be done to the town and its infrastructure if the draft local plan was implemented.

The latter is amply demonstrated by the Town Council’s response to the draft local plan which proposed 800 dwellings being built on the south-eastern edge of the town. The council objected to this proposal on the basis of the following:-
• the rural setting of the town in its natural bowl in the landscape would be destroyed;
• the landscape character would be seriously degraded by the insertion of a large development on agricultural land;
• the proposed development would not be sustainable (given that the road system of the town is already overloaded, there is no direct access to the M11, no A roads nearby, no railway station in the town and no significant likelihood that employment within the town would cater for more than a very small minority of the new residents);
• the vast increase in vehicle traffic and resultant pollution which would be created by placing the development in the most inaccessible corner of the town there will be a detrimental effect on the health of residents;
• the town’s isolation from main traffic/rail systems, means it is extremely unlikely that large scale employment would locate here;
• 800 homes in the south east corner of town will result in a vast increase in vehicle journeys already crossing the town and the current problems of pollution and congestion suffered by the town will increase to even greater levels. There is no way that the existing road system can cope and not one suggestion of a plan to offer a solution is found in the plan;
• previous sustainability assessments and consultations have highlighted the problems associated with the large scale development in Saffron Walden particularly the pressures on green infrastructure, the secondary school, primary health care, the impact on the road network/air quality and the work required to the sewage network. These issues are in addition to the adverse impact on the town’s historic environment.

These reasons for rejecting the local plan because of its impact upon this historic town remain perfectly valid. Hence, given what the draft local plan in its current form proposes for Saffron Walden, the prospect of yet more development – again on the ‘wrong side’ of town where major residential development is unsustainable – is neither acceptable nor sustainable.

The remainder of this section addresses a range of key issues starting with:-

Transport
The fact that substantial additional development in the town would bring insuperable problems is readily apparent from the findings of Essex County Council in its role as Highway Authority. The Highway Authority published a document entitled ‘Comparative Transport Analysis : A Transport Analysis of potential Strategic development locations in Uttlesford’ in January 2010. The report was produced as part of the evidence base to underpin the emerging local plan and its purpose of was to set out the likely Highway/Transport requirements for each of the proposed strategic development locations in the then draft plan. It provides an overview of requirements and potential issues in each location.

Whilst the option then was for the development of 1,600 dwellings in Saffron Walden, the principles to emerge from this study remain the same for the 880 currently proposed remain exactly the same. They are as follows:-
• Impact on historic road network: Saffron Walden’s historic street network is not suited to modern day vehicles and traffic flows and prevents large flows of traffic from travelling freely, causing congestion. There is little room to improve junctions and consequently any residential development in the town will only add to the traffic flows and cause increased congestion on the historic road network;
• Bus Service and Infrastructure: a major allocation is likely to be required to provide and fund a high frequency bus service for the first five years of the development or until the service is self-funding (whichever is first). Evidence shows that a regular service with 10-15 minute frequency is the level at which people will actually consider changing their travel habits from car to bus as it offers a viable alternative. For people to use the bus, a service of high quality will need to run from initial occupation of the development;
• Air Quality: Uttlesford declared 3 Air Quality Management Areas (AQMAs) at the sites of 3 road junctions in Saffron Walden town centre because of the sub-standard air quality in those locations. The issue occurred partially due to traffic congestion at these locations. The 3 AQMAs have now been extended to cover the whole town centre. Any further development within the town is likely to put further pressure on the air quality in the AQMA and do nothing to improve its quality.
• Access to rail travel: Saffron Walden does not a station, but Audley End station is within 5km of the proposed site. Journeys from the town to the station are likely to be by car, unless a high quality and frequency bus service is provided along with a high quality, segregated cycle route.

The report concludes that, for Saffron Walden, the ‘Likely Infrastructure Required’ comprises the following:-
1. 10-15 minute high quality and frequency bus services within Saffron Walden and to Audley End Station (at times to coincide with rail services) and potentially beyond;
2. Significant engineering measures required to junctions within the town to increase capacity may not be feasible given limited land availability;
3. Link road required between Radwinter Road and Thaxted Road to relieve Thaxted Road/Radwinter Road/Chaters Hill/East street junction;
4. Footway/Cycleway links to connect with key services/facilities etc.;
5. Footway/cycleway links to connect with employment/services and schools in Saffron Walden, Audley End Station and amenity routes within and adjacent to Saffron Walden.

The key points to emerge from this are that, whilst there are moves afoot to deliver the cycleway to Audley End Station irrespective of the local plan:-
• none of the proposed developments include a high quality and frequent bus services within Saffron Walden and to Audley End Station;
• there is no scope to accommodate the ‘significant engineering measures required to junctions within the town to increase capacity’;
• there is no prospect of the link road between Radwinter Road and Thaxted Road being delivered which is a criterion of the draft local plan which “must be met”; and
• there is little or no prospect that cycle paths can be provided from the site through the town due to the lack of scope which exists within what is a tight-knit urban area.

The above merely serves to emphasise that the current local plan proposals cannot be accommodated within Saffron Walden and should be scrapped.

Uttlesford Council required an evaluation of the Uttlesford Local Plan proposals1 in order to identify their likely highway impact and to identify any necessary mitigation measures. It


1. Information about the proposed Local Plan development was based initially on the June 2012 Draft Local Plan. However, this was supplemented during the course of the study with the most recent updates being made in October 2012. The report specifies that any subsequent changes in policy, or development assumptions could be expected to have an impact on the analysis.
commissioned Essex Highways to undertake this study and the resulting document ‘Uttlesford Local Plan Highway Impact Assessment: Assessment of Highway Impact of Potential Local Plan Sites’ was published in October 2013. One of the specific objectives of the study was to estimate the impact of the preferred options on specific links and junctions in Saffron Walden. Where it was subsequently determined to be appropriate, mitigation measures were investigated and their effectiveness reviewed.

But it is quite obvious that the report is inadequate, and therefore flawed, in that it does not take into consideration subsequent approvals and proposals (see ‘Impact Assessment – already outdated’ on page 21) which account for a 30% increase on the amount of houses.

Background traffic growth for 2012 to these future assessment years of 2018 and 2026 were calculated using TEMPRO1 growth. Within the key study areas, which include Saffron Walden, only the adjusted TEMPRO growth has been applied (i.e. no background traffic growth using the National Transport Model2 (NTM) was applied). This was because it was considered that the degree of growth from the committed and proposed developments was sufficient to represent background growth in these specific areas, as these settlements are already constrained by their local road networks.

This fundamental assumption that new development is “sufficient to represent background growth” must be challenged on the basis that the Road Transport Forecasts 2013 document specifies, under the heading ‘Road Congestion Projections’ at para. 1.25, that “With constrained road space, road traffic growth means greater pressure on the network and therefore higher levels of congestion.” It neither states nor implies that growth can be ignored because of already constrained local road networks.


Hence the study is fundamentally flawed in that it fails to take into account:-
• the ‘background traffic growth’ which will inexorably exacerbate the traffic flows, and associated congestion, on what is readily acknowledged to be the ‘already constrained local road network’ of Saffron Walden; and
• the amount of additional development that is now both committed and proposed.

The study points out that average vehicle trip rates were extracted from TRICS3, rather than 85th%ile values, as the sites chosen for development are generally within the vicinity of locations with a good level of services (e.g. schools, shops and public transport etc.). The study states that “It has also been assumed that any future development would be expected to provide a comprehensive package of sustainable transport measures, such as new or improved public transport services and facilities, connections to the local pedestrian and cycle networks, and detailed travel plans to encourage the use of non-car modes of travel.”

1. TEMPRO is a program that provides projections of growth over time for use in local and regional transport models. It presents projections of growth in planning data, car ownership, and resultant growth in trip-making by different modes of transport under a constant-cost assumption.

2. The National Transport Model is the Department for Transport’s forecasts for traffic demand, congestion and emissions in England up to 2040.

3. TRICS (Trip Rate Information Computer System) is a database of trip rates for developments used in the United Kingdom for transport planning purposes, specifically to quantify the trip generation of new developments.
These assumptions are again fundamentally flawed on the basis that:-
1. the site proposed for 800 houses on the south-eastern edge of Saffron Walden is not within the vicinity of a ‘good level of services’ because it is well removed from the town centre, the County High School, existing primary schools, Audley End Railway Station and does not have ready access to effective public transport facilities; and
2. the ‘comprehensive package of sustainable transport measures, such as new or improved public transport which accompanied Kier’s planning application for 300 houses at Thaxted Road which comprised:-
• Provision of public transport information and promotional literature via Travel Information Packs;
• Provision of links to up-to-date timetable data and journey planning websites via Travel Plan website; and
• Bus taster tickets as part of Travel Information Pack
and that which accompanied Ridgeons’s planning application for 167 houses at
Ashdon Road which comprised:-
• public transport information and Transport Voucher;
• Travel Plan Website and Community Notice Boards; and
• investigation of the potential to introduce an extended or diverted bus service into the site and a bus turning facility.

The impact of traffic from the proposed development sites on the main highway links in Saffron Walden has been assessed in terms of the anticipated effect on the operation of each junction. It therefore fails to have regard to:-
• the convenience of the ‘no entry’ signs and one-way traffic systems and the resulting circuitous routes drivers are obliged to take which may also involve creating ‘rat runs’ through residential areas for those with the local knowledge to do so;
• the capacity of the roads (as distinct from the junctions);
• the effects on road safety;
• the effects of the increase in traffic flows upon the town’s character;
• effects on air pollution;
• the deliverability of the required traffic mitigation measures; and
• traffic implications pending the provision of the ‘required’ link road.

Each of these is briefly considered after the following assessment.

Junction Assessments
It is evident from the study that some junctions are shown to be approaching capacity in 2018 with committed development in place. In 2026 this situation is exacerbated, and the addition of the development proposals indicates that mitigation measures are needed in order to minimise their impact on the town’s road network.

The study assumes that the proposed link road between Thaxted Road and Radwinter Road will not be in place until 2026 (because the majority of the housing on this site is not likely to be built until after 2020/21) but this is a false assumption because the housing may well be substantially completed by 2020/21. The link road is shown to help to reduce pressure at the Thaxted Road/Radwinter Road junction but that it is still over capacity. The study also shows that many other junctions would be likely to continue to experience capacity issues in 2026 with committed and proposed development. Additional mitigation measures would therefore be required to enable delivery of the proposed development.
In order to mitigate congestion at the Thaxted Road/Radwinter Road junction and to reduce impact on the Peaslands Road corridor, two further measures were identified as follows:-
• a northbound No Entry restriction (except for buses) on Thaxted Road at its junction with Peaslands Road; and
• a northbound No Entry restriction on Debden Road at its junction with Mount Pleasant Road.
Northbound No Entry on Thaxted Road at its junction with Peaslands Road
The findings suggest that this would have a significant adverse impact on several of the junctions in the town as follows:-
• Thaxted Road / Radwinter Road junction - Radwinter Road would experience further congestion as local traffic is reassigned on to the link road and the route from Thaxted Road south of Peaslands Road in order to reach Thaxted Road north of Peaslands Road;
• Thaxted Road / Peaslands Road - significant worsening in conditions on Thaxted Road north in the PM peak would occur due to the increase in traffic moving from west to south;
• Mount Pleasant Road / Borough Lane / Debden Road - Mount Pleasant Road approach would function at a level well over capacity in both the AM and PM peak hours;
• Debden Road / London Road - Debden Road south would reach capacity in the AM peak;
• High Street / George Street - both north and south approaches would operate above capacity with associated excessive queuing;
• London Road / Borough Lane - western approach would reach capacity.

Northbound No Entry on Debden Rd at its junction with Mount Pleasant Rd
This would require some further mitigation measures at both the Mount Pleasant Road and Debden Road/London Road junctions because:-
• Debden Road / London Road –London Road approach would be near capacity in the AM peak. Debden Road would reach capacity in PM peak;
• London Road / Borough Lane – Borough Lane would operate significantly above capacity with associated extensive queuing, particularly in AM peak. London Road south approach would be heavily impacted on by vastly increased flow turning right and hence operate above capacity.

Further junction improvements are needed in order to mitigate the impact of the proposed development. Improvements have been identified as follows:-
• B184 Thaxted Road / B1053 Radwinter Road;
• B184 Thaxted Road / Peaslands Road mini-roundabout;
• Mount Pleasant Road / Debden Road;
• B1052 London Road / Debden Road mini-roundabout;
• B184 High Street / B184 George Street;
• B1052 London Road / Borough Lane & B1052 Newport Road / Audley End Road.
Conclusion
The study concludes by stating that the analysis suggests that, if all the above measures were implemented, some of the key junctions in the Saffron Walden road network would be likely to be able to accommodate the additional traffic resulting from the proposed development sites in the local plan. However, three junctions in the town would continue to operate over capacity, and it has not been possible to identify further enhancements due to highway land constraints. These are:-
• High Street/George Street
• High Street/Church Street
• Mount Pleasant Road/Debden Road.
But this ignores the fact that, as pointed out below, the Newport Road/ Audley End Road junction would not operate within capacity and also be regularly affected by traffic queuing back from the London Road/Borough Lane junction.

In addition to the identified mitigation measures, the study recommends that demand management methods are investigated in order to reduce overall traffic flows in the town. Activities such as travel planning for employment sites and school developments, together with personal travel planning at existing and proposed residential developments are suggested in an attempt to help to improve awareness of alternative travel modes and encourage a shift towards non-car modes of travel and reduce traffic congestion in the town.

Whilst the results suggest that the London Road/Borough Lane junction would operate within capacity, queuing levels would still be relatively high in the AM peak hour, with tail backs through the Newport Road/Audley End Road priority junction. The results of the analysis show that the revised Newport Road / Audley End Road priority junction would not operate within capacity with the London Road and Audley End Road approaches operating over capacity in the AM and PM peak hours respectively. Its operation would also be regularly affected by traffic queuing back from the neighbouring London Road/Borough Lane junction.

It should also be borne in mind that the study is basically flawed and fails to give a true picture because it fails to take into account:-
• the ‘background traffic growth’ which exacerbate the existing traffic flows, and associated congestion; and
• the amount of additional development that is now both committed and proposed.

Proposed one-way traffic systems and resulting circuitous routes
The proposed one-way systems will result in substantial detours for many drivers (depending upon their approach to, and destination within, the town). This will cause longer journeys and hence increased pollution. It will also lead to ‘rat-runs’ which involve some drivers seeking shorter routes using roads either not designed, or with the capacity, for an increased amount of ‘through traffic’ which has no business in the area.

This would be likely to impact adversely upon both the environment of the area (with many of the potential routes being along residential roads) and road safety (as a consequence of relatively fast moving traffic along what may be confined roadspace because of parked cars).

Capacity of the roads (as distinct from the junctions)
Whilst the capacity of the junctions has been established, the same does not apply to the roads themselves. Many, if not all, of the roads that will be subject to increases in traffic and the introduction of one-way systems are already subject to on-street parking. Whilst it will be possible to remove this in order to smooth the flow of traffic, it may cause insurmountable problems to the people who use these spaces if they are local residents who do not have any feasible alternative parking options.

Effects on road safety
The increased amounts of traffic, and possibly increased speed along ‘rat-runs’, must inevitably result in the increased risk of accidents. This will particularly be the case in the vicinity of the County High School where Borough Lane is proposed to be made one-way north-bound.

It should be noted that the proposed ‘no entry’s and one-way systems succeed in focussing significant increases in traffic onto the main access to the County High School and straight past the Friends School.

The study’s assessment of the revised London Road / Borough Lane junction layout showed that, whilst the results suggest that the junction would operate within capacity, queuing levels would still be relatively high in the AM peak hour, with some tail backs through the Newport Road / Audley End Road priority junction. The results of the analysis show that the revised Newport Road / Audley End Road junction (which would become a priority junction) would not operate within capacity. The London Road and Audley End Road approaches would operate over capacity in the AM and PM peak hours respectively. Its operation would also be regularly affected by traffic queuing back from the neighbouring London Road / Borough Lane junction.

This serves to illustrate that there will be a significant increase in queuing traffic at these two junctions in the peak hours. The AM peak will coincide with the peak period for children walking to the County High School when the London Road /Audley End Road junction will be operating over capacity with traffic queuing back from the London Road / Borough Lane junction across the proposed pedestrian crossing. This will inevitably lead to conflicts between vehicles and pedestrians on that crossing with a resulting high risk of accident.

The Mount Pleasant Road / Debden Road junction is now a priority crossroads. The introduction of the proposed link road, together with the associated closure of Thaxted Road north-bound, would change the key movements though the junction. The modelling of a signalised layout found that it would reduce queuing on Mount Pleasant Road albeit at the cost of increased queues on the other approaches. The results suggest that the junction would operate with some spare overall capacity, although the introduction of a pedestrian stage would cause some approaches to reach saturation.

The redesigned junction as proposed makes no provision for a pedestrian crossing. This must surely be essential in road safety terms given the location of the Friends School immediately adjacent to the junction given the anticipated increase in traffic on what will effectively become the southern ring road around the town centre. Such a situation cannot reasonably be considered to be acceptable.

Effects of the increase in traffic flows upon the character of the town
The eventual introduction of ‘no entry’ signs on major routes into the town, together with the creation of one-way systems and associated sets of traffic lights along it in order to try to manage the effects of the dramatic increase in traffic that will result from the scale of the proposed developments, is not in keeping with the character of a country market town. It is more typical of what would be expected in large towns and cities where heavy traffic is the norm that has to be accommodated by using the road system to its maximum capacity.

That kind of approach is not appropriate in a relatively small market town – especially one which has such a historic character and charm as Saffron Walden. The effect would be marked and adverse. This serves to emphasise that the town should not be subject to the scale of development currently proposed because it cannot accommodate it satisfactorily.

Effects on air pollution
Local authorities are required1 to periodically review and assess air quality standards (AQSs) in their areas. The process identifies areas where it is unlikely that the AQSs will be achieved. These locations must be designated as Air Quality Management Areas (AQMA) and a subsequent Air Quality Action Plan (AQAP) developed to reduce pollutant emissions and achieve the AQSs2.

Essex County Council commissioned consultants to undertake an air quality assessment of the effects of proposed developments in the draft Uttlesford Local Plan on nitrogen dioxide (NO2) concentrations. The study entitled ‘Assessment of Uttlesford District’s Local Plan on Air Quality in Saffron Walden: Nitrogen Dioxide Dispersion Modelling Report’ was published in October 2013.

The assessment aimed at identifying whether mitigation is required and/or possible. It involved updating an existing air quality model for Saffron Walden to incorporate revised traffic data and the latest emission factors and air quality tools released by Defra in 2012/13. Modelling of air quality at four key junctions was undertaken for the proposed development scenario opening years of 2018 and 2026. This was in order to determine whether air quality was expected to comply with the air quality standards for NO2 in the relevant opening years, and to assess the significance of changes in air quality by comparing a “do-minimum” with “full” schemes in each year. The trend in measured NO2 concentrations in Saffron Walden indicates that there has been no significant reduction in concentration between 2007 and 2011. This is consistent with the findings of the Defra report3 on long term trends in NO2.

Traffic queue length data were modelled at the following 4 junctions, for the base year (2011) and future year scenarios:-
1. B184 Thaxted Road / East Street / B1053 Radwinter Road / Chaters Hill:
2. B1052 London Road mini-roundabout junction with Debden Road:
3. B1052 High Street / B184 George Street / Abbey Lane / Hill Street:
4. B184 Bridge Street / Castle Street / Myddylton Place.

1. Part IV of the Environment Act 1995.

2. UDC has not produced an Air Quality Action Plan. (The AQMA was declared in 2012).

3. See footnote 1 on page 18.
The modelling assessment considered the following scenarios:
• A base year scenario of 2011 which was also used to define model adjustment factors for the future year scenarios.
• An opening year of 2018 “do minimum” scenario containing committed developments, excluding proposed AQAP improvements.
• An opening year of 2018 “full scheme” scenario containing 80 proposed houses and proposed AQAP improvements.
• An opening year of 2026 “do minimum” scenario containing 80 proposed houses, excluding any junction improvements.
• An opening year of 2026 “full scheme” scenario containing 880 proposed houses, including proposed junction improvements.

Defra1 and the Highways Agency2 (HA) have different predictions as to the rate at which NO2 concentrations will change in future. The HA’s Long Term Trend Gap Analysis (LTT) predicts future higher NO2 concentrations then Defra’s LAQM TG(09) because the likely impacts of future lower emission vehicles are not yet fully understood. The HA’s advice is that a long term trend based on the emissions of existing vehicles is assumed to be linear and continue at this projected rate of decrease into the future.

Given the relatively low penetration of these lower emission Euro VI vehicles3 prior to 2018 and their contribution to total emission rates, the LTT methodology could be considered reliable up to then. Beyond 2018, the LTT projections are expected to be conservative as the penetration of Euro VI increases, and as more information becomes available the LTT projections will be reviewed and the HA’s Interim Advice Note updated accordingly.

When forming a judgement on the significance of the impacts, both the projections based on LAQM TG(09) and those based on the LTT method should be provided. A justification statement, setting out the reasons for selecting the results, should be used to inform the judgement on significance. In this study, the 2018 scenario is only shortly after the start of Euro VI uptake and it was considered unlikely that the roadside NO2 concentrations would be influenced more by Euro VI vehicles than the existing trends in emissions from the pre-Euro VI vehicles which will still form the majority.

1. In July 2011 Defra published a report which showed that there has been a clear decrease in NO2 concentrations between 1996 and 2002 which subsequently stabilised with little to no reduction between 2004 and 2010. The consequence of the conclusions of Defra’s advice on long term trends is that there is now a gap between current projected vehicle emission reductions and projections on the annual rate of improvements in ambient air quality.

2. The HA developed the LTT Gap Analysis methodology to adjust model predictions based on the method in LAQM TG(09) (using the relationship between the base year and the future year vehicle emission rates and the measured trends in roadside NO2 concentrations to better align future year predicted concentrations with the long term trends of NO2).

3. The current trends in air quality are based on measurements of emissions from the existing vehicle fleet. New vehicles will need to comply with the more stringent Euro VI emissions standards from September 2014 onwards. Vehicles complying with the Euro VI emissions standard are not yet on the road network, and therefore the performance of these vehicles is not present in the long term air quality monitoring trends. If the Euro VI fleet emissions perform as predicted, then this should lead to substantial reductions in predicted future roadside air quality concentrations.
A precautionary approach was therefore applied here, where the LTT method representing long term trends provides the predicted NO2 concentrations in 2018, and thus the basis for judgements. Predictions for 2026 using the LTT projection method maybe overly conservative, and likewise the predictions for NO2 using the LAQM TG(09) method may be overly optimistic. Both were used in the final assessment to provide context for the uncertainty in predictions.

The assessment of air quality for the Saffron Walden Local Plan developments was undertaken using the ADMS-Roads Air Dispersion Modelling Software1. The modelled results show that exceedence of the NO2 annual mean AQS of 40 μg/cu. m.2 is predicted where the squares are shown in red in the figure below.

Maximum modelled NO2 concentrations at each of 4 junctions (μg/m3)

2011 2018 Scenario 2026 Scenario
model Do minimum Full scheme Do minimum Full scheme
Junction Max. NO2 conc. LAQM TG(09) LTT LAQM TG(09) LTT LAQM TG(09) LTT LAQM TG(09) LTT
B184 Thaxted Rd / East St / Radwinter Rd / Chaters Hill 55.2 41.4 56.3 37.4 50.9 27.1 53.4 16.2 31.9
B1052 London Road / Debden Road 41.3 31.7 44.2 31.5 43.9 21.6 44.2 21.9 44.8
B1052 High St / B184 George St/ Abbey Lane / Hill St 54.8 46.8 66.3 47.1 66.7 28.2 63.6 32.7 69.1
B184 Bridge Street/ Castle Street / Myddylton Place 36.4 25.6 37.3 25.4 37 16.3 35 17.8 38.2

Source : Assessment of Uttlesford District’s Local Plan on Air Quality in Saffron Walden, Oct. 2013

The prediction of NO2 concentrations beyond 2018 is subject to considerable uncertainty due to the difference between the model outputs using the Defra emissions data and tools which underpin the LAQM TG(09) methodology, and the long term trends in NO2 which are utilised in the LTT methodology. The rate of growth in traffic flows predicted in the traffic data used for this assessment is greater than the rate of reduction shown in monitoring trends in NO2. Due to this, modelled NO2 concentrations using the LTT methodology increase into the future and therefore the number of properties predicted to be in exceedence of NO2 AQSs also increases.


1. ADMS Roads is a recognised tool for carrying out air quality impact assessments and has been comprehensively validated by both the manufacturers and independently.

2. 40 μg/m3 - concentration below which health effects are unlikely even in sensitive population groups, or below which risks to public health would be exceedingly small.
The figure above serves to illustrate the marked contrast that the different predictions have upon the findings of the study. But it clearly shows that:-
• the Thaxted Road/Radwinter Road and the High Street/George Street junctions will be subject to the highest concentrations of NO2;
• the proposed link road would have a beneficial effect upon the Thaxted Road/Radwinter Road junction – as would be expected;
• the impact of the proposed link road and associated traffic management measures on the Borough Lane/Debden Road, Borough Lane/London Road and Newport Road/Audley End Road junctions are unknown; and
• the effect of the redevelopment of the previously developed sites without the 800 houses proposed in the local plan is totally unknown.

Deliverability of the required traffic mitigation measures
The preliminary estimates of the costs of implementing the proposed improvements identified to the various junctions are as follows:-
• B184 Thaxted Road / B1053 Radwinter Road: £18,500
• B184 Thaxted Road / Peaslands Road: £207,000
• Mount Pleasant Road / Debden Road: It is understood (by Essex County Council) that signalisation of this junction is a planning obligation of a recent planning approval and therefore no costing is required.
• B1052 London Road / Debden Road: £19,000
• B184 High Street / B184 George Street: £260,300
• B1052 London Road / Borough Lane + B1052 Newport Road / Audley End Road: two junction works combined - £473,300.

All of these preliminary costed schemes give a total of £978,100 (i.e. in reality an absolute minimum of £ 1 million). But these schemes would only be necessary in the long term if and when the ‘link road’ is operational. Essex County Council would be seeking unspecified ‘contributions’ to these schemes from developers of sites which might be expected to impact upon these junctions. But it cannot do so as yet because the local plan is only in draft form and there is no commitment to the individual schemes. Given the location and scale of the current development proposals for which planning permission is already being, or will shortly be, sought, it is apparent that there will be little or no scope to secure funding from developers such that the whole cost of the necessary junction improvements would fall to the County Council to provide.

Hence it is very probable that, in the event of the ‘link road’ being provided and the junction improvements made necessary, the County Council, as highway authority, will have to fund them. That will entail a cost of £1 m. + at 2013 prices. Without such a commitment the required traffic mitigation measures will not be deliverable.

Traffic implications pending the provision of the ‘required’ link road
The study assumes that the link road (from Radwinter Road to Thaxted Road) will not be delivered before 2026. But, in the meantime, the council has already granted permission for 52 units at The Kilns, 14 houses at Goddards Yard, Thaxted Road, received planning applications for 300 houses east of Thaxted Road, 167 on the Ridgeons site, and will shortly receive a revised scheme for 50+ dwellings on the Willis and Gambier site and one for a further 300 units south of Radwinter Road which has recently been the subject of public consultation by the prospective developers. If it is assumed that all of these gain approval (and experience suggests that those outstanding will all be recommended for approval), that is some 880+ units. If the large schemes are developed at a rate of, say, 50 per year, then it is quite reasonable to expect that all 880+ will be developed by the end of 2020 – a full 6 years in advance of when the link road is anticipated.

Given that, according to the draft local plan, the link road is an essential prerequisite to the provision of the 800 houses (in that it must be provided), let alone the 167 proposed at Ridgeons, plus the other sites, it is readily apparent that, if these schemes are allowed to go ahead, traffic in the town will be in complete and utter chaos from 2020 (i.e. 6 years hence) at the very latest.

Impact Assessment – already outdated
It is important to note that the Uttlesford Local Plan Highway Impact Assessment has regard to the development proposals in the June 2012 Draft Local Plan updated to include further development proposals as at October 2012. Consequently, the study does not include:-
• 52 dwellings grated planning permission at the rear of The Kilns;
• 52 dwellings proposed on the former Willis and Gambier site; and
• 167 units proposed on the Ridgeons site which is subject to this consultation.

The report specifies that any subsequent changes in policy, or development assumptions could be expected to have an impact on the analysis. The 271 dwellings proposed on the 3 sites above, represents a 31% increase on the 800 earmarked for the area on the south-eastern edge of the town, which would clearly have a dramatic impact on the analysis. Consequently, given that the 52units at the Kilns have already been approved, of the order of 50 units at Willis and Gambier are likely to be, and the 167 at Ridgeons are intended to be incorporated into the local plan, the study needs to be redone, taking the current situation into account, if it is to have any meaningful output.

Education
The County’s secondary school number of roll forecasts1 indicate a shortfall (i.e. a deficit) of 147 spaces for the County High School in 2016/17 rising to 186 when the then anticipated new housing is taken into account. But given that planning permission has already been
granted for all of those developments, and that construction will therefore take place within the next one or two years, then the forecast deficit of places at the County High School (including an adjustment for new houses) has effectively risen from 186 to 206. There is, in addition, the prospect of residential development on the following sites:-
• former Willis and Gambier factory, Radwinter Road; and
• Ashdon Road Commercial Centre (i.e. Ridgeons site).
In the event that these were progressed and approved, they have the potential to jointly add a further 230+ dwellings, thus generating a further potential 46 pupils. This would take the shortfall to 252 places.

It is understood that the County High School – which is now an academy2 – does not wish to

1. Commissioning School Places in Essex 2012-2017, Essex County Council, 2012.

2. Academy schools are state funded independent schools which are directly funded by central government and independent of direct control by local government in England (in this case Essex County Council – the local education authority).
expand beyond its current size or take on extra responsibilities by way of another facility (such as a sixth form college). This must therefore mean that there is no scope whatsoever for the implementation of the proposal in the draft local plan of 800 houses to the south-east of the town as this would be expected to generate the need for an additional 160 places1,2 (making a potential total shortfall of 400 +).

Sewerage
Uttlesford District Council appointed Hyder Consulting (UK), in March 2012, to complete a Water Cycle Study3 to inform it of the possible constraints and opportunities to the suggested strategic sites. The ‘Uttlesford District Water Cycle Study—Stage 24: Detailed Strategy’ was published in November 2012. It found the following (with the key point emphasised in bold):-
“Saffron Walden is predominantly served by a separate surface water and foul water sewerage system. The foul water sewerage system operates primarily by gravity, conveying wastewater to the WwTW5 to the northwest of the town.

The development trajectory for Saffron Walden proposes that 880 new dwellings are to be constructed. The majority of the new development is planned to occur in AMP7 and AMP8 (i.e. from 2020 to 2028). The Local Plan allocation sites are located at the opposite side of the town to the WwTW. The existing sewerage network is at capacity and extensive upgrades will be required. The linear distance from the development to the WwTW is approximately 2 km but the actual sewer lengths will depend on the route of any new sewers or specific sections that need upgrading.”

1. The likely number of pupils that will move into a development and require an additional place at the local school is calculated using factors for houses and flats. These are multiplied by the forecast number of new dwellings to estimate the number of pupils that will be produced by a particular development overall. Units that are unlikely to house children are discounted from the calculation. The factors used for secondary pupils are 0.2 additional pupils per new house and 0.1 additional pupils per new flat.

2. The draft local plan features another criterion which “......must be met......” in association with the development of 800 houses to the south-east of the town. It is that the proposed development “provides off site provision of land adjacent to Saffron Walden County High School or on site provision of ** ha2 of land for secondary school facility as part of (the) education contribution.”

3. A Water Cycle Study (WCS) forms a key part of the evidence base of the emerging local plan. It is needed in order to ensure that water supply, water quality, sewerage and flood risk management issues can be addressed to enable growth during the and beyond, whilst preserving and enhancing the water environment.

4. The purposes of the Stage 2 Detailed WCS include:
• confirming with the statutory sewerage undertakers, Anglian Water Services (AWS) and Thames Water Utilities Limited (TWU), that the network of sewers in the District can accommodate the increase in flows from the proposed strategic sites and confirm the upgrades required to overcome any sewerage capacity constraints; and
• liaising with AWS and TWU to identify the wastewater treatment works which will be affected by the proposed development, and confirm the upgrades required to accommodate this increase in flows.

5. Waste water treatment works.
Assessment
The proposed allocation of the Ridgeons site for predominantly residential purposes should be rejected because of the serious adverse impact that the huge amount of development that is proposed in the current draft local plan would have upon both the character and the infrastructure of the town to its very significant detriment.

Saffron Walden should be able to develop in a way that will meet the current and future needs of its residents, businesses and visitors to the town. But that development should both respect and reflect the nature of the town and what makes it so very special in terms of both its history and its character. The town is now perceived, by both residents and the Town Council, as being under the threat of excessive and ill-considered development which will damage it irrevocably. That is not what the planning system is intended to deliver – quite the opposite, in fact.

But the Town Council is not totally opposed to development taking place within the town and neither are its residents. It is right and proper that un- and under-used sites should be brought back into beneficial use. And that includes the previously-developed part of the Ridgeons site. But the massive amount of development that is currently proposed will have such a dramatic adverse impact upon the town that even that is now undesirable because of the cumulative effect of developments upon the town.

But that view could well be expected to change if Saffron Walden wasn’t under the threat of such massive undesirable development. If the proposal to develop 800 houses on greenfield land (in the area between Radwinter Road and Thaxted Road) were to be deleted from the draft local plan then it would enable the Town and District Councils to properly plan for the future of this town in a manner which ensures that it delivers development which is sustainable.

This would necessitate the district council recommencing the local plan and preparing it in accordance with the sustainability principles set out clearly in the Framework such that it might be expected to satisfy the Inspector at the local plan inquiry. Para. 182 of the Framework states “....the plan should be the most appropriate strategy, when considered against the reasonable alternatives...”. Given the proposed changes to the local plan regarding the period that it will cover and the scale of uncommitted development that it must accommodate, the district council now has not only the opportunity but also the duty to demonstrate that it has chosen ‘the most appropriate strategy’ if the local plan is to be adopted.


Proposed changes to draft policy
If the draft policy (see Appendix) is to be accepted in principle, then this will be subject to the deletion of the 800 houses currently included in the draft local plan on the south-eastern edge of Saffron Walden. Under those circumstances then it will be possible to accept the principle of the redevelopment of the site for some form of employment-based development.

Nevertheless, any such acceptance would be subject to the following:-
• a comprehensive and independent study which clearly demonstrates that there is no reasonable prospect of a site being used for the allocated employment use (to satisfy para. 22 of the Framework);
• the current areas of special roadside verge and local wildlife site should be retained with the road access to the site amended accordingly if necessary;
• the retention of the area of amenity open space (including the area used as a football pitch) in the south west section of the site; and
• the retention of the wildlife habitats (including the dense continuous scrub, the semi improved grassland and the hedgerow/scrub areas) which would otherwise be needlessly lost.

Clearly it is nonsense for the draft policy to refer, as it does, to employment land and greenspace in terms of site area (i.e. hectares) but to dwellings in terms of absolute numbers. Thus, in order to encapsulate the requisite changes, the wording should be amended as follows and the map as shown below:-

Existing wording Recommended wording
167 residential dwellings 3 hectares of land for housing
4 hectares of natural and semi-natural green space to the northern and eastern edges of the allocation 5 hectares of natural and semi-natural green space to the northern, western and eastern edges of the allocation


Recommended proposal map to accompany recommended policy


APPENDIX : UDC’S PROPOSED LOCAL PLAN POLICY FOR THE RIDGEONS SITE


Ashdon Road Commercial Centre

The land to the north east of Saffron Walden is allocated for a mixed use development consisting of 167 residential dwellings and 4 hectares of employment land.

The following criteria must be met:
• The development provides for a mixed and balanced community to include at least 5% older persons and 1 and 2 bed bungalows across tenure.
• The housing allocation is subject to a linked employment allocation which should come forward as part of the Master Plan. The employment element will consist of 4 hectares of employment uses comprising offices, and/or industry and/or warehousing and/or similar "sui generis" uses.
• It provides for informal recreation open space within the development. The provision of children's play space 2 LAPs and a LEAP. The provision of a strategic landscape buffer to include 4 hectares of natural and semi-natural green space to the northern and eastern edges of the allocation.
• The development is designed to mitigate adverse effects upon existing residential and community interests and may be required, by legal obligation, to provide or contribute towards wider and longer term planning benefits reasonably associated with the alleviation of any such impact.

The application should be accompanied by a Transport Assessment, Drainage
Strategy and Air Quality Assessment and other required documents and any
recommended improvements/remedial works will be controlled through the
legal obligation.

Development will need to be implemented in accordance with the Master Plan
and design guidance approved by the Council and other Development
Management Policies. Implementation of the Master Plan proposals will be
regulated by legal obligation in association with the grant of planning
permissions.