North Essex Authorities (Neas) Section One Shared Strategic Plan
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North Essex Authorities (NEAs) Section One Shared Strategic Plan Matter 8: Sustainability Appraisal Response to Further Hearing Statement December 2019 1 North Essex Authorities’ response to Further Hearings Statements related to Matter 8 (Sustainability Appraisal) The North Essex Authorities (NEAs) and independent consultants LUC have reviewed the Further Hearings Statements submitted in respect of Matter 8. Most of the representations made have already been addressed in the NEA’s original hearing statement. However, where statements have raised particular issues and arguments that require a further response, these are set out below. Question 1 (a) Is there adequate justification for the threshold of approximately 2,000 dwellings (ASA Main Report para 2.52) which was applied when selecting the strategic sites to be appraised at Stage 1 of the ASA? (b) If not, what threshold should have been applied, and why? An objection1 have been received suggesting that the 2,000 dwelling threshold overlooks the cumulative strategic significance of smaller urban sites that are physically close and/or actually linked. This is incorrect since the NEAs considered the potential for physically close sites to be combined into a coherent whole when identifying 'call for sites' submissions to be appraised as strategic sites. Question 2 Is the Stage 1 appraisal of alternative strategic sites based on sound and adequate evidence? Objections have been received that the level of detailed evidence is much greater for the NEA’s preferred Garden Community proposals than for alternative options and the assessment has not therefore been carried out on an equal basis. This is incorrect. While more detailed evidence exists for the preferred Garden Communities than for the reasonable alternatives, the SA only drew on evidence that was available at the same level of detail for all alternative strategic sites. Stage 1 defined distances beyond which walking distances to key services and facilities would be judged unacceptable and lead to a negative appraisal score. Objectors contend that some of these distances are flawed (e.g. 2km for railway stations and 1,200m for primary schools) when dealing with large strategic because these sites might be larger than 2km in radius. The SA required at least 50% of a site to be within a defined walking catchment. This basis of assessment was designed to be representative of walking distances for the majority of new residents and is a reasonable approach. 1 Matter 8 hearing statement by CPRE 2 An objector 2 states that the ASA describes Kelvedon as providing an hourly rail service to central London but it actually provides nine trains during the morning peak hour thereby providing future residents with a highly sustainable travel option. Although the ASA states (para. 3.1811) that Kelvedon "offers an hourly service to London throughout the day" it is also stated that "journeys to the centres of Witham and Colchester, and further to London, are well served by rail" and VE1 – Land at Kelvedon was not scored negatively on the basis of the frequency of the train service to London. Instead, effects in relation to SA objective 7 for longer commuting journeys were scored more negatively than would otherwise have be the case because the majority of the site is located beyond an 'acceptable' walking distance (defined as 1km by Table 2.2 of the ASA methodology) from Kelvedon railway station. In relation to the benefits of access to rail services, the conclusions of the ASA (Chapter 6) highlight that alternative spatial strategies "associated with the Great Eastern mainline offer use of existing infrastructure and sustainable access to key commuting destinations" and "those alternatives that offer a combination of both access to existing rail and investment in RTS perform strongly in sustainable transport terms". As detailed in Appendix 7 to the ASA when appraising the effects in relation to long distance commuting for spatial strategy West 7 (East of Braintree, SUE2 + Kelvedon, VE1), the positive effects of the anticipated connection of site SUE2 to a RTS are recognised but the potential positive effects of site VE1 being served by Kelvedon station on the Great Eastern mainline are reduced by the fact that the station is not within ‘acceptable’ walking distance of the majority of the site. An objector 3 states that the ASA does not consider evidence on the recreational disturbance to European protected sites. As well as considering the potential for strategic sites to lead to direct loss of or damage to European sites, potential offsite impacts are considered by reference to SSSI impact risk zones. More detailed consideration of potential effects on European sites is a matter for the HRA. Question 3 Has the Stage 1 appraisal of alternative strategic sites been carried out with appropriate objectivity and impartiality? An objector 4 states that the advantages of a smaller development at Marks Tey (e.g. ALTGC6) including better access to rail and less reliance on the re-alignment of the A12 have not been properly assessed. As detailed in Appendix 5 to the ASA, the appraisal recognises that the northern edge of ALTGC6 is close to Marks Tey station but the potential benefits this brings in terms of new residents making longer journeys by rail are reduced by the fact that only about 17% of the site is within 'desirable' or 'acceptable' walking distance of the station and capacity issues during peak hours. 2 Matter 8 hearing statement by Parker Strategic 3 Matter 8 hearing statement by the Wivenhoe Society 4 Matter 8 hearing statement by Crest Nic holson 3 Question 4 Does the ASA give clear and justified reasons (including in Appendix 6) for selecting the strategic sites that are taken forward from the Stage 1 to the Stage 2 appraisal, and for rejecting the alternative strategic sites? [No substantive new points that have not already been addressed by the NEA or LUC responses in the submitted hearing statement.] Question 5 In seeking to meet the residual housing need within the Plan period to 2033 (ASA Appendix 6, Principle 1), should the spatial strategy alternatives for the Stage 2 appraisal seek to provide land for: a) 7,500 dwellings; or b) 1,720 or 2,000 dwellings (the residual requirement identified in Appendix 6, Table 1); or c) another figure? [No substantive new points that have not already been addressed by the NEA or LUC responses in the submitted hearing statement.] Question 6 (a) Is the allocation of residual housing need between West of Colchester and East of Colchester on a 2:1 ratio (ASA Appendix 6, Principle 3) justified by relative housing need and commuting patterns? (b) If not, what alternative spatial allocation of residual housing need would be justified, and why? [No substantive new points that have not already been addressed by the NEA or LUC responses in the submitted hearing statement.] Question 7 (a) Is there adequate justification (including in Appendix 6) for the selection of spatial strategy options to be appraised at Stage 2 of the ASA? (b) If not, what other spatial strategy option(s) should be assessed, and why? [No substantive new points that have not already been addressed by the NEA or LUC responses in the submitted hearing statement.] 4 Question 8 Is there justification for basing the proportionate (hierarchy-based) growth spatial strategy options (West 2 and East 2) on different settlement hierarchies from those identified in the NEAs’ Section 2 Plans? [No substantive new points that have not already been addressed by the NEA or LUC responses in the submitted hearing statement.] Question 9 Is the Stage 2 appraisal of spatial strategy options based on sound and adequate evidence? [No substantive new points that have not already been addressed by the NEA or LUC responses in the submitted hearing statement.] Question 10 Has the Stage 2 appraisal of spatial strategy options been carried out with appropriate objectivity and impartiality? A number of objectors question the reliance placed on the delivery of the RTS to inform the judgements in the ASA and claim that this has resulted in an unjustified uplift to the ASA scores of relevant spatial strategy options in relation to SA objective 7 (Sustainable travel). The adequacy of the evidence base to support the RTS proposals is being examined under other Matters. For the purposes of the ASA, it is reasonable to rely on the strategy-specific infrastructure assumptions provided by the NEAs in their 'Identification of spatial strategy alternatives' paper (Appendix 6 to the ASA). The associated uncertainty of positive effects on sustainable travel is clearly acknowledged in the ASA Report, particularly where the NEAs have identified a reliance on external infrastructure funding. Question 11 Does the Stage 2 appraisal adequately and appropriately evaluate the spatial strategy options at both the end of the Section 1 Plan period and as fully built-out? Objectors state that the differences between the results for within the plan period and for when fully built out are very slight and insufficient account is taken of the uncertainty relating to the deliverability of key infrastructure such as the RTS. In terms of the SA scores awarded, it is true that many of these are the same for both time periods. This is not a flaw in the methodology but simply reflects that many types of social infrastructure (a notable exception being new primary healthcare facilities) would be provided in phases as development progresses rather than once development is fully built out. This results in small 5 differences in appraisal scores between the two time periods. As noted in relation to Question 10, uncertainty of positive effects on sustainable travel is clearly acknowledged in the ASA Report. Objections are also made to the failure of the ASA to differentiate between the effects of different delivery rates within the plan period.