Essential Reference Paper B

Essential Reference Paper ‘B’

East Herts Council’s response to Harlow Council’s Core Strategy Issues and Options Consultation, January 2010

1. East Herts Council welcomes the opportunity to comment on the Harlow Core Strategy Issues and Options consultation document. East Herts Council supports the objective of the regeneration of Harlow and hopes that Harlow Council’s Core Strategy will help to achieve that aim.

2. This document supplements and provides a basis for East Herts Council’s responses to the consultation questions as contained in the Harlow Core Strategy Issues and Options consultation document. Those answers should be read in the context of this document.

3. The Localism Act is anticipated to abolish Regional Plans before either Council’s Core Strategy is adopted. Therefore the agreement of both Councils is necessary in order to proceed with any proposals for growth of Harlow into East Herts. The “duty to co-operate in relation to planning of sustainable development” contained in the recently published Localism Bill does not appear to negate the need for such agreement.

4. East Herts Council welcomes the acknowledgment in the Harlow Core Strategy Issues and Options that “Harlow Council is considering the appropriateness of all options” (page 55), but notes with concern the statement on page 16 that “Greenfield development should be located in the north and east of Harlow”.

5. Given the changing national policy context, Harlow Council should take a fresh and open-minded approach, and set aside any preconceived notions. In order to achieve this, it will be essential for Harlow Council to carefully re-examine the evidence base prepared under the previous government’s top-down approach to planning, and identify evidence gaps and untested assumptions, before it can reach any sound conclusions as a basis for the Preferred Options.

6. East Herts Council has recently consulted on its own Core Strategy Issues and Options, and is currently processing the comments received. In response to this consultation, East Herts Council received more than 2000 individual objections to development of the land north of Harlow. This scale of local opposition should also be weighed in the balance by both Councils.

7. This response does not pre-empt the decisions of this Council in respect of its own Core Strategy Preferred Options. East Herts Council’s Issues and Options document included a consultation question on development in East Herts District north of Harlow in order to obtain community feedback and further evidence from developers, infrastructure providers East Herts Council’s response to Harlow Council’s Core Strategy Issues and Options Consultation

and others. Based on this and other evidence, East Herts Council will come to a considered view of the way forward.

8. This response serves to identify some of the fundamental concerns which this Council believes will need to be addressed by Harlow Council, before the Preferred Options of both Councils in respect of land north of Harlow can be agreed for consultation.

9. Part A looks at how the top-down agenda of the former Office of the Deputy Prime Minister (ODPM) set the context for planning around Harlow. Part B revisits the East of England Plan history to show how the then Secretary of State addressed some of the key concerns around the policy direction for Harlow. Part C provides some examples of the omissions and limitations of technical studies produced in response to this top-down policy context.

A. Agenda of the previous government.

10. East Herts Council contends that given the current shift in national policy, it is essential to re-evaluate the principles underlying the last government’s top-down approach to planning. This shift provides a timely opportunity to challenge hitherto untested assumptions and ensure that the Harlow Core Strategy Preferred Options will provide a realistic strategy to support the regeneration of Harlow without undermining the East Herts Core Strategy vision.

11. The drivers of the previous government’s Regional Spatial Strategy (RSS – East of England Plan) plan were described by the Sustainability Appraisal of the plan:

Most of the key decisions about development in the region were driven by central Government outside the RSS process. These include:  The policy of enabling and supporting housing and economic growth in London and the greater south east of England rather than seeking to spread it more evenly between regions;  The resulting requirements for high levels of housing in the East of England;  The designation of Thames Gateway, the Lea Valley (now extended to the London-Stansted-Cambridge-Peterborough Corridor) and Milton Keynes/South Midlands as growth areas with high housing targets established to a considerable extent through separate sub-regional processes;  The decision to build a second runway at Stansted as part of a ‘predict and provide’ approach to air travel growth

[East of England Plan Sustainability Report, Levett-Therivel & Land Use Consultants, November 2004]

12. The LSCP ‘growth corridor’ concept was embodied in the then Office of the Deputy Prime Minister’s 2003 ‘Sustainable Communities Plan’ and its

2 East Herts Council’s response to Harlow Council’s Core Strategy Issues and Options Consultation

underlying assumptions were not challenged by the technical work commissioned by or on behalf of the growth points, often using ODPM growth area funding. Various factors, including the decision not to build a second runway at Stansted, and the new government’s shift to a Localism policy, call into question many of these assumptions.

B. Planning History

13. An understanding of the planning history is important because it casts a searchlight on how the subsequent direction of policy in respect of growth policy was set in motion, and how critical assumptions were buried within the momentum created by this process.

14. The three appendices to this response illustrate the progress of the East of England Plan agenda. There were four broad groups of arguments made by this Council in its submission (Appendix A) to the Examination in Public (EiP), two of which the Panel (Appendix B) largely agreed with (regeneration arguments and landscape/environment arguments) but the SoS dismissed (Appendix C) without clear reasons, and two on which both the Panel and the Secretary of State were largely silent (jobs and infrastructure).

15. The following review highlights how certain key issues were never satisfactorily resolved through the EiP and subsequent technical studies. Given the new planning context, there is a fresh imperative to ensure that this evidence base is sound and key assumptions are not left unchallenged.

B(i) - Regeneration arguments

16. The Panel report was written following detailed consideration of the evidence base, together with a large numbers of representations submitted to the examination in public. East Herts Council supported the findings of the Panel, and still considers that many of the Panel’s judgements have not yet been effectively superseded in the case of development to the north of Harlow. The relevant section of the report repays detailed reading, and for this reason is reproduced in full as a basis for discussion.

17. East Herts Council expressed concerns to the Examination in Public about the lack of evidence linking regeneration and growth (Appendix A paragraphs 1 to 8).

18. Reflecting these concerns, the Panel took considerable care to differentiate what it called ‘sustainable urban extensions’ from the ‘distractions of planning for major satellite settlements’ north of Harlow and at North Weald (paragraphs 5.94 and 5.95). The Panel suggested that if regeneration is to be encouraged by growth, certain key safeguards would be needed:

For all that to happen there is in our view a need for growth to be of such a form, and carried out in such a way, as to ensure that it is part of the town and does not acquire a separate identity and momentum which could undermine the progress of the town itself. This we would take to be part of the definition of a sustainable urban extension.” (paragraph 5.86)

19. This judgement was recently echoed by Scott Wilson Consultants in their Harlow Options Appraisal (2010) which stated that

The high levels of development proposed by these growth scenarios may have negative impacts on efforts to regenerate the existing town, its centre and its relatively deprived neighbourhoods as investment may be attracted to the new extension to the north of the town….

A need to ensure that the regeneration of Harlow is not jeopardised by the substantial development to the north [which ] could mean that efforts to maximise the potential of Harlow North are weakened. The worst case scenario in this regard is that Harlow North effectively becomes a separate town competing with Harlow (Harlow Options Appraisal, 2010, p.81).

20. The then Secretary of State’s published ‘reasons’ for her decisions in relation to the Panel recommendations on regeneration and growth are far from clear, and include a series of unjustified assertions which would not bear scrutiny at examination. Some examples follows:  The Panel recommendations ‘risk not giving an appropriately strong emphasis to Harlow to achieve the degree of transformation necessary to address its substantial physical and economic regeneration needs’ (Appendix C, page 31).  ‘it would not provide adequate capacity for post 2021 needs’ (ibid);  The then SoS revised upwards the growth figures from 13,500, arguing that ‘the 16,000 figure is an appropriately stretching but achievable target’ (ibid, page 32);  and that ‘inclusion of urban extensions to the north of Harlow means the Secretary of State reaches a different conclusion from the Panel about the balance of evidence’ (ibid).  The SoS argued that ‘how far development to the north of the Stort Valley would be independent from Harlow and fail to support its regeneration is a matter of how it is developed’ (Appendix C, page 34).  ‘the potential North of Harlow for a major development of a large enough scale to be a model of sustainable development’ (Appendix C, page 35).

21. In relation to this last point, it is entirely unclear what is meant by this, or why scale per se should be a defining characteristic of sustainability. The Eco-towns programme was not conceived as a regeneration programme and the PPS on Eco-towns is entirely silent on this issue. Indeed, as

alluded to above, the massive investment in transport infrastructure required for any satellite development north of the Stort raises serious questions about the sustainability of this option.

22. East Herts Council maintains that there is a lack of reasoning or evidence behind any of these assertions, as expressed by the then Secretary of State. This is in sharp contrast with the carefully considered arguments put forward by the Panel. The justifications for the SoS’ statements are entirely opaque, and do not sit comfortably with the new culture of transparency and openness. It is possible to speculate that there were other non-planning considerations behind these judgements which have not been subjected to proper democratic scrutiny.

B(ii) Landscape and Urban Form arguments

23. East Herts Council’s concerns about Landscape and Urban Form were set out in its submission to the Examination in Public (Appendix A, paragraphs 9 to 18).

24. The submission warned of the environmental and landscape damage that could be caused. Appendix D includes an extract from the Harlow Area Landscape and Environment Study 2005, which details many of the assets north of Harlow (although again, this study was written in the context of the top-down growth agenda).

25. The submission also cautioned about the incoherence of the proposals in respect of urban form (Appendix A paragraphs 11-13, and 31). It is doubtful whether the 500 metre distance across the Stort floodplain could justifiably fit into Gibberd’s definition of a ‘green wedge’ within an expanded town. More likely the limited number of river crossing points would create a separate town to the north, which the redevelopment of the town station and a ‘living bridge’ could do little to mitigate against.

26. Recently a further barrier to coherent urban form has come to light. The HNJV submission to the Harlow Options Appraisal identifies that the 400kV high-voltage overhead power cables running through their landholdings would require an 800 metre wide ‘wayleave’ (400m on each side). This is confirmed by the National Grid submission to East Herts Council’s Core Strategy Issues and Options consultation, which states that the company has a policy to leave such power lines in situ at new development. Such a feature would form an incongruous element of any proposed urban form, leading to an even more disjointed and incoherent urban pattern, possibly with significant negative impacts on sustainability and regeneration objectives. The incorporation of such a wide void as a ‘green infrastructure’ feature along the lines of a Gibberd Green Wedge does not appear very convincing, particularly given its tangential relationship to Harlow.

27. The Panel agreed with East Herts Council that there are ‘serious landscape constraints’ (Appendix B paragraph 5.83) to expanding the

town, and examined the effects in each direction, and also the context of Gibberd’s Town Plan. The Panel also considered the proposals by Ropemaker to turn the Stort into a ‘living bridge’. Taking all these considerations together, and especially pointing out the degree of separation from the town posed by breaching the Stort (Appendix B, paragraphs 5.90 to 5.91), the Panel recommended that there should be no development north of the Stort.

28. Again, the then SoS’s ‘reasons for decision’ in overturning the Panel recommendations are dismissive and do not provide any reasoned justification:  ‘How the evidence on landscape and other environmental issues identified by the Panel is considered largely a matter of interpretation. There are significant environmental features but they are largely of local importance.’ (Appendix C, page 34).

B(iii) – Jobs arguments

29. In its submission to the East of England Plan EiP, East Herts Council pointed out several concerns about the deliverability of the proposed jobs numbers (Appendix A page 15-16). However, neither the Panel report nor the SoS report (Appendices B and C) addressed arguments related to the deliverability of the level of new jobs anticipated.

30. Perhaps for this reason little robust evidence for jobs deliverability has been added to the evidence base as listed in Appendix 2 of the Harlow Core Strategy Issues and Options document. The Harlow Employment Land Utilisation Study (2008) and the Harlow Area Investment and Renewal Framework (2007) are the only relevant documents cited. It might reasonably be expected that one or other of these studies would demonstrate how the urban extensions could drive jobs growth, or in what type or quantum; or that they would address a strategy to prevent the urban extensions possibly sucking jobs out of the town (see paragraphs 17-18 above); or the sub-regional jobs implications. Neither study addresses these issues.

31. None of the evidence base listed in Appendix 2 of the Harlow Core Strategy Issues and Options document addresses the issue of where jobs growth is going to come from. Current jobs forecasts for Harlow are very low. There appears to be no coherent strategy contained in the Harlow Regeneration Strategy for creating the required number of jobs and to reverse existing trends. Insisting on the need for ‘transformational change’ as per the 2005 Regeneration Strategy study cited below (paragraphs 39-45) does not constitute a strategy in itself.

B(iv) - Infrastructure arguments

32. Concerns about infrastructure provision were made by East Herts Council in its submission to the EiP (Appendix A pages 20-21). These included arguments about infrastructure deficit and transport capacity.

33. The only infrastructure consideration to receive explicit direction through the East of England Plan was the issue of capacity at Rye Meads Sewage Treatment works. East Herts Council is aware that although the Water Cycle Strategy (Hyder Ltd, 2009) failed to resolve the issues into a strategy, some progress has been made on technical issues with the Environment Agency, although the issue of funding remains uncertain.

34. The Harlow Infrastructure Study (Roger Tym, 2010) presented the following findings:  For Harlow as a whole, infrastructure requirements total £753 million  Transport and education are the two biggest elements of this cost making up 47% and 29% of costs respectively  Existing infrastructure deficits will need to be addressed  Addressing funding gaps early on is critical  The rate of house building implied by the East of England Plan is unrealistic, based on historic data  Growth to the east of Harlow should be prioritised  For Harlow North specifically, key costs will include a northern spine road/M11 link (£150 million); a new M11 junction (£50 million); and new primary and secondary schools (total £87 million)

35. Prior to advancing their Core Strategy Preferred Options, Harlow Council should pay particular attention to how such infrastructure is to be funded, in order to ensure that development and infrastructure are appropriately phased. Without a firm commitment from the developers as to how much they are willing to pay, it will be very difficult to identify any funding gaps from mainstream public funds.

C. Examples of Evidence Base Limitations

36. Having considered the planning history and context for the arguments, the three examples below show how the direction of travel set by the then Secretary of State’s reasons influenced and limited the scope of subsequent technical studies, such that the assumptions underpinning the SoS’s judgements were no longer questioned.

37. This represented a shift in the direction of technical studies in respect of the growth of Harlow. As the Report of the East of England Plan Panel observed, ‘prior to the [Robin Thomson RPG14 Strategy Review] the growth studies, and the ‘banked draft’ RPG14 had considered urban extensions (albeit of a lesser scale) to the east, south, and west of Harlow’ (Appendix B paragraph 5.90).

38. Three examples show how the top-down agenda of the previous government affected the findings and scope of many of the technical studies of this period from approximately 2004 onwards.

39. Firstly, the Regeneration Strategy study for Harlow of 2005 (PACEC and Halcrow) argues the need for ‘dynamic transformation’ of Harlow, entailing 20,000 new homes and 16,000 to 20,000 new jobs.

40. However, the justification which supports this (in section 5.3) consists of a series of assertions rather than demonstrable evidence. For example, it is claimed that ‘Scenario 3 [dynamic transformation] presents the greatest potential for generating the necessary critical mass for public and private sector investment as a result of increased demand & access to a larger workforce. This scenario has the greatest potential for increasing the local employment land offer and for improved choice for residents.’ (table 5.1 page 24).

41. Critical mass is mentioned approvingly in the Harlow Core Strategy consultation document (e.g. paragraph 1.7.2). However, the arguments for critical mass as a basis for regeneration are unclear. The 2005 study “City/town size, growth and benefits to residents and firms in Harlow” was vague on the benefits:

The overall message from the above analysis is that there are potentially both economic and social benefits to be exploited from increased city/town size and more rapid growth [PACEC, 2005, Paragraph 1.4.1]

42. East Herts Council commissioned a critique of this study (by Strategic Planning Advice Ltd) which was submitted to the Examination in Public. As that study pointed out, growth is often a sign of success rather than a cause of success. Also, there are many thriving small towns, and conversely many large cities with urgent regeneration needs, so it is hard to correlate size with success.

43. The Harlow-Council commissioned PACEC study itself pointed out the flaws with arguments based on critical mass:

… reflections which claim that urban size is the fundamental determinant of urban location costs and benefits have met with heavy criticism and many issues remain unresolved and provide limited guidance on whether specific cities and towns should be contained or expanded. [PACEC 2005, Paragraph 1.1.2]

44. It is our understanding that the ‘current research’ linking critical mass and housing growth referred to in Paragraph 3.3.2 of the consultation document refers to studies submitted to the Regional Plan Examination in Public in 2005, including those mentioned here, and that no further study has been undertaken since this time.

45. In respect of the above key technical studies therefore, it is not hard to draw the conclusion that with the expected outcomes already clear from the top-down policy, the Harlow Regeneration Strategy seized on the

prevailing direction of government policy without adequately testing its assumptions in respect of the regeneration agenda.

46. Secondly, the 2005 Harlow Area Study by Matrix Consultants examines the likely effect of large-scale growth north of Harlow in terms of its impact on the urban pattern of Harlow, assessing it in relation to the original masterplan by Sir Frederick Gibberd.

[Gloss on Gibberd’s plan]: The railway line, river and new road as the ‘baseline for the town” – with the Hertfordshire Hills free of building to the north

[Consultants’ commentary]: Gibberd’s baseline suggests a restriction on development north of the Stort. Current best practice, however, seeks to maximise highly accessible locations and Regional Growth pressures will call into question Harlow’s existing settlement boundary. (Harlow Area Study – Final Report - Matrix Consultants, April 2005, paragraph 3.2.3 page 13)

47. The Matrix report admits that development north of the Stort would be contrary to the Gibberd design, but brushes this aside because of ‘Regional Growth pressures’. Indeed, the subsequent Harlow Infrastructure Study (Roger Tym, 2010) suggested that land north of Harlow would require a £150 million link road and a £50 million junction on the M11, which brings into question the Matrix claim that north of Harlow is ‘accessible’.

48. Thirdly, the recent Harlow Options Appraisal (Scott Wilson consultants, 2010) generated and assessed five options for growth around Harlow. Having considered the options, the suggested approach included substantial growth north of the Stort. However, the consultants were clear that without the top-down policy steer of the East of England Plan, the best approach, based on the bottom-up ‘combined criteria-led’ option (Option C) would be preferred. This option limits growth to the east, south, and west. However, this option was discounted as ‘not realistic’ because it was contrary to RSS policy HA1.

49. Additionally, the Harlow Options Appraisal dismissed a constraints-led option (including landscape, greenbelt, and flooding considerations) on the basis that it ‘offers no directional guidance’. The requirement for directional guidance arises from Policy HA1 of the RSS. Without the RSS requirement, the constraints-led approach takes on fresh importance.

50. These are but three examples of how a centrally imposed agenda led to a failure of technical studies hitherto to critically examine the core assumption that growth would assist the regeneration of Harlow. Secondly, because of top-down policy requirements, adequate weight is not given to environmental constraints. Therefore, East Herts Council believes that, although there is much that is valuable in these technical

studies, they do not constitute sufficient basis for proceeding with large- scale growth north of the River Stort.

51. From Appendix 2 of the Harlow Core Strategy Issues and Options document it is clear that the LDF Evidence Base is lacking in any fresh studies conceived outside the former government’s framework. This is a major omission and some basis for an independent assessment agreed by both Councils is urgently required, given the major long-term effects of this decision for Harlow and people from the surrounding areas in East Herts and elsewhere.

Conclusions

52. Change in government policy has exposed untested assumptions and hence large gaps in the evidence base for growth-based regeneration of Harlow. There is an urgent need to plug such gaps in the evidence base prior to developing any Preferred Options.

53. Both East Herts and Harlow Council should revisit the judgements of the independent Panel set up to examine the draft East of England Plan, and should critically appraise the judgements of the former Secretary of State in the light of the new policy direction.

54. With the anticipated disappearance of the East of England Plan from the Development Plan, Harlow Council and East Herts Council will need to agree an approach to the land north of Harlow, whether that approach is one based on development or non-development.

55. East Herts Council has received more than 2000 individual objections to development of the land north of Harlow in response to its own Issues and Options consultation, and this scale of local opposition should also be weighed in the balance. As Robin Thomson noted in his RPG14 Strategy Review ‘the strength of opposition to the 18,000 dwellings amongst the local authorities in the corridor is itself a weighty consideration.’ (2005, page 3).

56. Harlow Council should acknowledge that, in the absence of the East of England Plan requirements, the recent Harlow Options Appraisal by Scott Wilson Consultants Ltd recommended Option C as the best option, taking account of the combined cumulative ‘bottom-up’ considerations.

57. Setting aside the objections in principle to development north of Harlow, there are many outstanding issues in relation to infrastructure delivery and funding which would need to be satisfactorily resolved, before any potential development north of Harlow could be seriously countenanced.

10 Appendix A

East Herts Council’s submission to Matter 8H1 at the Examination in Public on the East of England Plan

EAST OF ENGLAND DRAFT PLAN

EXAMINATION IN PUBLIC

Matter 8H1: Stansted/M11

SUBMISSIONS BY EAST HERTS COUNCIL

i) Vision and Strategy

1. The Vision is starkly clear – that there is too much development assigned to the southern part of the Stansted/M11 sub-region. In its original submissions, East Herts Council registered its support for Policy ST3 and the proposals for the regeneration of Harlow. It is the Council’s view that growth on the scale proposed, especially to the north of the town, will hinder, rather than assist, the local regeneration process. The strategy for this part of the sub-region should be focussed firmly on the regeneration of Harlow. The emphasis should be conveyed in Policy ST1, changes to which were suggested by East Herts Council in it’s submissions.

2. No robust argument has been advanced for the level of development proposed for this part of the sub-region. The vision set out in the Plan is inappropriate. The area around Harlow is extremely congested and the proposed level of development would result in the loss of greenfield land, much of which is designated as Green Belt.

3. In order to assess whether growth on the scale proposed will assist or hinder the regeneration of Harlow, it is necessary to assess the regeneration needs of the town. Evaluation of the regeneration needs of Harlow from the published reports indicates that the following measures will be appropriate:

i) improving the access of lower skilled people in Harlow to employment offering prospects of betterment; ii) improving and diversifying the housing stock, for its own sake and in order to provide opportunities for higher skilled groups to remain in or move to Harlow; iii) improving the town centre and other services for residents, iv) improving the layout of the town; v) improving the industrial and business premises offer.

11 Appendix A

4. Nowhere in the plan or supporting documents has the linkage between growth and regeneration been clearly and convincingly spelt out. It has been suggested that a larger town would justify higher order services. Whilst a larger settlement is more likely to attract such services as a university and a departure store, there are other factors at play, for example the image of the town and the spending power and habits of its residents; conversely there are many smaller towns that have such facilities because they are attractive in other ways than pure size. An example is Cranleigh in Surrey which has a population of 10,000 and a viable department store.

5. It has not been identified that any services are missing or deficient in Harlow for which the extension would provide the critical population increase. Indeed the converse is more likely to apply. The proposed population increase risks taking demand for services beyond their capacity without providing the funds to increase their capacity e.g. the identification by the Environment Agency of the sewage treatment works serving Harlow as very vulnerable.

6. The assumption is that it is both possible and desirable to change fundamentally the role and character of Harlow, in effect to gentrify the town with an injection of high income people. The more likely outcome of developing the area north of Harlow on the scale set out in the Plan, is that the new suburb will develop its own facilities to suit the spending and tastes of its residents, or that its residents will travel to other centres e.g. Cambridge to find higher quality services.

7. In relation to the economic performance of towns, PACEC in their report on city/town size, growth and benefits to residents and firms in Harlow (in support of the Harlow Regeneration Strategy), conclude that “there are potentially both economic and social benefits to be exploited from increased city/town size and more rapid growth” (para 1.4.1). This work is of little help in defining an appropriate scale of development to achieve the regeneration of Harlow for a number of reasons, primarily because, as the authors themselves state, “the analysis does not imply a categorical causal relationship between size/growth and the indicators”.

8. It is accepted that the housing mix in Harlow is a significant factor in the health of the town; a more diverse stock would be valuable. However the growth proposals for Harlow in the plan will only perpetuate the present imbalance. If 20,700 additional housing units are built with 30% affordable housing, then the overall proportion of social housing would drop only to 33% (cf 35% now). If alternatively, say, 8,000 open market houses were developed, this being the reported capacity of the urban area of Harlow and east Harlow, then

12 Appendix A

the overall affordable proportion would fall to 27%. The Plan proposals pose a real risk of a conflict of priorities between growth and regeneration. There is a real risk that growth will be given priority and regeneration left to follow, or not. This is considered further under (iv) Housing.

ii) Environment/Culture

9. The strategy has had little regard to the environment and culture of this part of the sub-region. This has been pointed out by East Herts Council in its original submissions, especially on paragraph 5.136 of the draft plan, and in its further submissions on Matters 1D and 5A. The pressures on the environment have been outlined in the SEA report, and are reinforced by a number of other studies. These include the Hertfordshire Landscape Character Appraisal of 2003 and the MORI-assisted poll of public opinion on landscape values (2004). East Herts Council is particularly concerned about the degree of specificity in allocating land to the north of Harlow in paragraph 5.136 of the Plan. Such a development would have an extremely damaging effect on longstanding Green Belt and landscape goals in this part of Hertfordshire.

10. East Herts Council has a fundamental objection to the amount of development proposed in this part of the sub-region. The process for determining the location of development is flawed and has taken no account of the landscape and environmental thresholds of the area around Harlow.

11. The Harlow Area Study – Masterplanning Principles and Sustainability Criteria, completed in April 2005 by Matrix Partnership in association with Halcrow and Levett Therivel, refers to the New Town Master Plan and the design principles of Sir Frederick Gibberd. Essentially, the layout of the town was designed as a semi-circle, with the River Stort as the base line. In the New Town Master Plan, Gibberd emphasised the key role of the river valley with the “Hertfordshire Hills” beyond.

12. In responding to the proposals by the former Commission for the New Towns in 1976, Gibberd was keen to maintain the principles of his design, and favoured development to the west and east, rather than to the north or south. Any future growth should be carried out with respect to the Gibberd design.

13. The Harlow Area Study has begun to look at other options for development locations around Harlow. These include the area to the

13 Appendix A

west of the town, much of which has been designated as a Countryside Conservation Area by Epping Forest District Council in their

Local Plan. Despite this, in reality this tract of countryside is characterised by urban fringe pressures and in parts shows signs of degradation, with areas of disused greenhouses, farm fragmentation, horse paddocks, sporadic housing and commercial developments, landscape deterioration, and high volumes of traffic.

14. East Herts Council would wish to emphasise the intrinsic landscape and environmental qualities of the Stort Valley. Its significance has long been recognised. In a 1980 study, completed jointly by Hertfordshire and Essex County Councils, a number of important features were outlined, including herb-rich meadowlands, historic landscapes and gardens, and areas of nature conservation value. As a result of the study a number of these features were protected from development and engineering works.

15. In more recent times, the importance of the valley has been further acknowledged by the Hertfordshire Landscape Character Assessment, as well as the Stansted/M11 Corridor Development Options Study (Colin Buchanan December 2003). In addition the recently produced Harlow Green Infrastructure Plan (Chris Blandford Associates) strengthens the importance of the Stort Valley, for ecology, landscape and historic environment. The Green Infrastructure Plan has been ‘steered’ by a committee made up of interested parties: Countryside Agency, Groundwork, Go-East, Harlow, Herts and Essex County Councils.

16. There are also considerable concerns about the effects of development upon the rural area to the north. The Ropemaker proposal illustrates the scale of the effects:

 The loss of a large area of Grades 2 and 3A agricultural land.  The engulfing of the rural settlements at Eastwick, Gilston, Pye Corner and High Wych.  An effect on 16 County Wildlife Sites, three Scheduled Ancient Monuments, six Areas of Archaeological Significance, and several historic gardens.  The proposed extension of the A414 to the north of Harlow would have a devastating effect on the landscape integrity of the Stort Valley.  The so-called eco-bridge across the Stort Valley and any attempts at enhancing the biodiversity of the gap would be off-set by the

14 Appendix A

pressures caused by the scale of the development itself, in particular on the integrity of the Hunsdon Meads SSSI downstream.  The development of a significant area of greenfield Green Belt countryside, which has an important function in preventing the coalescence of towns within the main transport corridor of the M11/Stort Valley.

17. Harlow North is under the landing flight path of Stansted Airport, which is set to expand significantly. There are noise and safety issues, and to locate major housing development under the flight path does not represent safe and sound planning practice.

18. In summary, East Herts Council considers that environmental effects of the proposals for the Stansted/M11 sub-region are a major failure of the Plan. This has been pointed out in the SEA report (see Table 3.2h), which cites the major weaknesses of the Plan with regard to the scale of development in the south of the region. East Herts Council would urge the Panel to recommend the diversion of growth away from the south and to consider other options. iii) Employment/Economy

19. The Plan proposes 40,000 net additional jobs in the Stansted/M11 sub- region. If Harlow was expected to generate the same share of additional sub-regional jobs as its housing share, the number would be 23,600 net additional jobs in Harlow. This assumed correlation

seems consistent with the principle of the Plan that major housing proposals are employment-led. The scale of growth indicated for Harlow, as opposed to any other scale of growth, is nowhere justified or subjected to sustainability appraisal.

20. However the scale of employment growth is very questionable for a number of reasons:

 The sectors and types of development targeted in ST3 are all highly mobile investments. They will be able to choose from a wide range of alternative locations in the region (“regional offices”), in the UK (many of the activities identified) and in continental Europe (“European headquarters”). Given that Harlow is neither eligible for grant assistance to encourage inward investment nor an attractive investment location (witness the low level of rents for industrial and business premises), the town will struggle for many years to attract this quality of investment in significant volumes. The plan itself

15 Appendix A

identifies many locations in the region to which inward investment will be encourage by agencies such as EEDA in competition with Harlow:

. Key centres: Cambridge, Colchester, Chelmsford, Stevenage . Regeneration areas: Bedford/Kempston, Colchester, Stevenage and parts of Cambridge . Potential large new settlement (SS2) . Maintaining vitality of market towns . Supporting economic well-being of rural villages.

 Some of the competing centres have a strong growth record already, e.g. Cambridge. In contrast Harlow has a poor track record of attracting investment, evidenced by low industrial and commercial rents in the town, which, together with the poor image of the town, will be a competitive disadvantage for Harlow in attracting investment which is heavily influenced by confidence.

 Much (probably around 70%) of the increase will need to come from service industries (e.g. distribution and administration). By definition most of this type of employment arises in response to the service needs of the local population and local “export” employers. It is therefore logically inconceivable that this large sector of employment will lead development.  A number of the targeted sectors, which are the non-service or “export” activities, are currently well represented in Harlow e.g. R & D, but employment in this sector declined 12.5% 1998-2003, and manufacturing generally which declined by 28.9% 1998-2003. Overall employment declined 1% in the same period. It requires a major transformation to go from decline to a net increase of over 60% in the Plan period.

21. Most of the employment is population-driven. This means that a net increase in overall employment of some 60% will need to be driven by rapid growth (early in the Plan period) in the highly mobile export sectors for which Harlow is competitively weak. If that growth is not achieved then the jobs will not be available for the population. People will then choose to live elsewhere or live in Harlow and commute to jobs elsewhere. Whichever way the supposedly linked regeneration of the town will not be achieved. iv) Housing

16 Appendix A

22. In respect of the jointly agreed Hertfordshire County and District Councils (excluding Stevenage) housing provision figure of 66,000, East Herts total amounts to 11,400 dwellings.

23. East Herts Council does not accept that the district level distributions and phasing of housing are appropriate or achievable. They are inappropriate in that they will hinder the objective of regenerating Harlow (see i) above).

24. Furthermore there is a real risk that growth will be given priority and regeneration left to follow, or not:

 There is a natural tendency to address new development first. It is in some ways simpler and it delivers very visible results compared to regeneration, especially people-oriented programmes, such as education and training.

 Commercially developers will need to develop and sell new housing before tackling regeneration obligations, as it is the new housing that will generate the capital for investment in regeneration.

25. Linked to this priority issue is the pace of development that is required to achieve the plan targets: 10,000 committed units to be built 2003- 2021 and 20,700 units to be built 2007-2021 equates to over 2000 units per annum. This compares with the peak output in Milton Keynes, where there was a strong new town development corporation in place, the market was favourable and town was successful in attracting jobs, of 1800 dwellings per annum. There is no realistic prospect of the housing growth targets being achieved.

26. Developers tend to reduce the pace of development in order to maintain prices. Those prices are fundamental to the level of s.106 resources, available to fund very heavy demands including regeneration.

27. There is clearly a risk that either the rate of development will fall short of the target, or that prices will be undermined by the scale of the supply, both having the effect of reducing the s.106 product available for regeneration.

28. The sub-regional housing provisions are clearly not based on sound assumptions about previously developed land and urban

17 Appendix A

capacity. No assessment has been made of the sustainability of development on the scale proposed for Harlow, versus other locations within the sub-region, or of the sustainability of the locations selected around Harlow, versus alternatives within the immediate Harlow area. Specifically no assessment has been made of the sustainability of rebalancing the mix of housing in Harlow, by developing more affordable housing in locations beyond Harlow town that are accessible to the town by different forms of transport.

29. East Herts Council does not accept that the broad locations for development at Harlow are appropriate, in that specifically the scale of development proposed to the north of the town will impede the regeneration of Harlow. That location could be made regionally strategic if the link to the M11 were made and if adequate infrastructure capacity were provided (see v) below). However these improvements would tend to detach the development even more from Harlow and make it a freestanding development, dependent for jobs and services on those within its bounds, or on centres elsewhere in the region/London.

30. East Herts Council does not accept that the land to the north of Harlow is capable of delivering sustainable development. The Harlow North Ropemaker proposal is contrary to the East Hertfordshire Local Plan Second Review, as well as PPG2 Green Belt and PPS7 Sustainable Development in Rural Areas. In their proposals Ropemakers allege that their development would be linked to Harlow across the Stort Valley, principally by means of a “Living Bridge”.

31. Both Ropemaker and the RPG14 Strategy Review (para 9.24) are persuaded by the same point, that development to the north of Harlow would put the stations (and the town centre) at the centre of the town, a more accessible location and therefore, they assert, more sustainable. This argument does not stand up to scrutiny:

 The barrier is very significant (some 500 metres) and it is indeed consolidated in the Ropemaker proposals through the development of an “Ecological Park” in the floodplain. The barrier effect will be exacerbated by the plan RSS proposal to create a northern bypass linking to a new junction on the M11.

 It is nowhere claimed, neither could it be, that the new development or any significant part of it would be within reasonable walking distance of the town centre or the station.

18 Appendix A

 The proposed development ironically perpetuates the urban form of Harlow, which is widely criticised as being inefficient and unsympathetic to public transport usage (RSS para 5.138 and Ropemaker 2.2.1).

 The proposed northern bypass will open up very attractive alternative opportunities for the population of the new development: real choices between going to Harlow for work, shopping, leisure etc and going to nearby centres that are more attractive e.g. Bishop’s Stortford and Cambridge.

 Ropemaker lay great stress on the introduction of a new population that is of much higher socio-economic status than the current Harlow population. This, together with the distance to the main town and the understandable quest for self-containment within the extension, will make it very attractive to provide suitable shops, leisure facilities and public services within the development. The submission is conspicuously silent on the scale and composition of a district centre to serve the new development.

 The need to market the new development at a very high rate (800 dwellings per annum over a long period of years within a wider Harlow market where over 2000 dwellings per annum will be being marketed) and to market it to higher socio-economic groups which are not “naturals” to the town, will put irresistible pressure on the developers to stress the distinctiveness of the development, not its integration with Harlow:

. It will be given a name in order to identify it as a distinctive offer. . The services available within the development will be enhanced: e.g. a high quality supermarket and separate secondary and primary schools serving the community. . Employers currently under-represented in Harlow will see the attraction of locating where they have good access to a range of skills and to better local services than those in the town centre.

32. Ropemaker implicitly confirm the tendency to make the extension self- contained and separate in their emphasis on the need to regard 10,000 dwellings as the first stage of further development to say 25,000 dwellings.

19 Appendix A

33. The Council, in its representation on the Draft Plan, has already referred to the reports which concluded that land in and adjacent to Harlow on the south, east and west sides of the town should be developed in preference to the land to the north of the town. In particular the Harlow Options Study concluded that the Sub-Regional Focus Scenario, which had the strongest focus on the regeneration of Harlow, did not require development on land north of the town to meet either of their preferred growth targets. These conclusions still stand. Only the RPG14 Strategy Review (2004) has come to a different

conclusion, apparently based on very little evidence and without a full comparison of the alternative locations around Harlow.

34. It follows from the Council’s analysis of the development that is proposed in the Green Belt that East Herts Council does not consider the Plan has demonstrated the exceptional circumstances that could justify a review of the Green Belt. There has been no review of alternative ways of achieving the development that is proposed; no assessment of the effects on the purposes for which Green Belts are designated; and no measurement of the benefits of the proposed development against the damage caused to Green Belt policy. There certainly does need to be an assessment of alternative locations, both within Harlow for that portion of the housing development that will contribute directly to its regeneration, together with limited growth for local needs.

v) Key Infrastructure

35. East Herts Council has noted the concerns of many other participants with regard to the infrastructure deficit in the region. With the pressures of development and activity in this part of the region, there is already a problem. Transport is a particular concern. It is the view of East Herts Council that these problems should be addressed by concentrating on investments in public transport, walking and cycling.

36. In terms of strategic infrastructure, the railway lines which serve the towns in the Lee and Stort valleys are at capacity. Local services to and from Cambridge, Bishop’s Stortford and Hertford East have to compete for track space with the Stansted Express service. Provision of additional tracks on the main line is essential, especially with the potential further expansion of Stansted Airport. The Plan makes no firm provision for any rail improvements in this corridor.

20 Appendix A

37. In Harlow, internal movements are the main problem. The emphasis in this part of the sub-region should be on regeneration, coupled to limited growth for local needs. In terms of transport investment, this should be coupled to the provision of public transport, either in high frequency bus services or a guided bus network. This type of solution is outlined in the Harlow Area Study and would utilise the green corridors, which exist in the town.

38. The proposed northern bypass would do little for transport problems locally, in addition to the environmental harm it would cause. There would be more merit in a distributor road to the south and west of the town, which would be far more effective in providing for locally- generated traffic in the commercial areas, and accessing potential new housing areas to the south and west.

39. There are other problems with strategic infrastructure in this part of the sub-region. The scale of development would exceed the threshold of local sewage treatment plant at Rye Meads, near Hoddesdon. Additional water provision would be difficult in an area which already has supply problems. It is noted in paragraph 5.148 that “public funding and developer contributions will be needed to provide the necessary finance for transport and other community infrastructure”. This is too vague – the Plan should include far more specific proposals for infrastructure investment, rather than a reliance on “special arrangements”.

vi) Delivery arrangements

40. East Herts Council supports the democratic model of delivery arrangements set out in Policy ST7 and paragraph 5.147 of the Plan and would reject any suggestion for an Urban Development Corporation or a similar body. The Area Regeneration Partnership should be

“open, transparent, and democratically accountable”, as suggested in Policy ST7. It should take a holistic approach to regeneration across local authority boundaries, but with a firm focus on Harlow. There should be no bypassing of the planning process in the delivery of the Plan, or indeed as is suggested in Policy ST4, the use of master planning studies instead of Local Development Documents.

41. One argument advanced for northward expansion of Harlow is that the land is mainly owned or controlled by a single landowning interest. This is no guarantee, however, of the delivery of development, as it

21 Appendix A

may be in the landowner’s interest to manage the release of land to maximise the financial returns from the investment. Ease of implementation, based on a single land ownership, would set a dangerous precedent for the purchase of large areas of countryside on the assumption that planning permission would be forthcoming.

22 Appendix B

Extract from The East of England Plan Examination in Public - Report of the Panel - June 2006

STANSTED/ M11 SUB-REGION

Characteristics and role of the Sub-Region

5.78 Within the sub-region the two principal economic foci are Stansted Airport in the northern part and Harlow in the southern part. The third economic focus is London, both as a destination for commuting to central London and through more complex local linkages between the Lee Valley towns in the southern part of the sub-region and the neighbouring parts of north east London. Although the Cambridge Sub-Region is also a major influence to the north, its importance for this sub-region as a source of economic growth or direct employment is debatable.

5.79 The urban structure is varied, from the London fringe areas in the south to the sparsely settled countryside of East Herts and North Essex beyond Stansted. Harlow New Town is the only major urban concentration. The sub- region possesses regionally important environmental assets including Epping Forest, Hatfield Forest and the Lee Valley Regional Park as well as extensive tracts of farmland. There is also an important and varied built heritage comprising the historic fabric of older settlements, including a very large number of listed buildings in Uttlesford district as well as the planned New Town of Harlow.

5.80 As its title implies the sub-region is characterised by the movement corridor formed by the M11 and the West Anglia main line, both of which link London, Harlow, Bishop’s Stortford, Stansted and Cambridge. However south of Harlow the railway forms part of the separate radial movement corridor of the Lee Valley including the A10. From east to west the sub-region is traversed only by highways, M25 in the south, in the middle the A414 from Chelmsford through Harlow to Hertford and further north the A120.

Agenda for the sub-region 5.81 Against the above background, and in the light of the discussion of Matter 8H, the main agenda for the sub-region would appear to be: - to secure a major addition of housing as part of the SCP growth agenda; - to accommodate the development needs associated with Stansted Airport; - to provide employment growth to match the housing increase, exploiting the growth of Stansted; - to exploit the sub-region’s links with outer London, the Olympic sites and Stratford in a mutually beneficial way; - to secure urban and economic/social regeneration at Harlow; - to rationalise and improve the sustainability of the Lee Valley settlements; - to protect and promote the key green infrastructure assets and the rural character of much of the sub-region; - to maintain the role of the Green Belt; and

23 Appendix B

- to resolve movement and infrastructure problems for Harlow and for rail commuting.

5.82 This is a long and wide ranging agenda, reflecting the central position and disparate nature of the sub-region. We consider that the strategy reflected in the draft Plan successfully brings together many of these issues. The focus on Harlow as a growth point is sound as it enables growth to complement regeneration, and to build upon and enhance the town’s sub- regional status. Given the uncertainty surrounding the scale and likely timing of job growth and housing needs associated with the expansion of Stansted (discussed further at paragraphs 5.99-5.103 below), we would not favour calls for the balance to be shifted towards more growth close to the airport, at least in the short term.There is currently no natural urban focus for major regional growth there, while there is both the foundation and the need for such growth at Harlow. In line with the approach we have taken to the Spatial Strategy as a whole, we do not consider there is a need for an extensive sub-regional strategy for the whole Stansted/M11 area as set out in Policies ST1 to ST7 of the draft Plan. As the major focus for growth we propose that Harlow is dealt with as a “regional growth point”, while the guidance we consider necessary in relation to Stansted Airport is contained in the revised version of Policy E14 which we recommend at R6.13.

Harlow and North Weald 5.83 For Harlow itself there are important questions about whether the proposed strategy is sound in terms of the scale and locations for growth and in providing for sustainable and deliverable development, especially over the longer term. The original Gibberd Plan for Harlow is much revered, both for the layout with green wedges which separate the urban development and for the way in which the town was designed to be contained by the landscape. The principles of Gibberd’s Plan remain relevant, but inevitably mean that there are limited options for extending the town without running up against serious landscape constraints. The east side is generally accepted to be the least constrained direction for growth. To the south the landscape setting is defined by a prominent ridge. This limits the extent to which Harlow could extend southwards, although opinions differ about how much capacity would be possible with or without appropriate landscaping. To the south west and west the immediate fringe of Harlow is less well defined. There is a strong argument for the need to maintain spatial and visual separation from Roydon and Nazeing and the lower lying land towards the Lee Valley but there are areas of PDL close to the urban edge of Harlow that contribute little to this separation. What is needed is a comprehensive local strategy for a mix of development, landscaping and greenspace that will define better and more enduring boundaries in this area. To the north the Stort Valley and the floodplain define the boundary to the town, and any major growth would need to be beyond this on the northern slopes of the valley.

5.84 Any growth options also have to contend with the transport problems which Harlow currently faces. The original structure and circulation system of

24 Appendix B

Extract from The East of England Plan Examination in Public - Report of the Panel - June 2006 the new town is ill adapted to today’s traffic, and the strategic road system has evolved quite differently from that envisaged in the Gibberd master plan. The West Anglia railway, although providing important links to London, Stansted and Cambridge, is recognised as being under pressure on capacity and is identified as a high priority in the Regional Planning Assessment for the Railway (TRN97, page 108).

5.85 Any future expansion of Harlow is also complicated by the fact that the town is tightly bounded by its administrative borders, and growth other than within the town or to the east would involve either Epping Forest or East Hertfordshire councils, both of which are hostile to any expansion of Harlow on their territory.

5.86 The options for growth in and around Harlow have been the subject of a number of studies (eg documents SRS6, SRS10, SRS16, TRN29, and TRN29A-J). There is a general perception, which we share, that Harlow has a need for significant additional housing, and that growth is required to support regeneration priorities for the town. Opinions differ, however, about whether the 20,700 additional homes proposed (together with a further 6,000 at North Weald) will support or hinder regeneration. The arguments relate as much to the form and location of development as to its quantity. There is evidence for the general proposition that in principle the more growth there is the greater the prospect that it will support increases in local employment, an expanding role for the town centre, the provision of infrastructure and resources for economic regeneration. However, for all that to happen there is in our view a need for the growth to be of such a form, and carried out in such a way, as to ensure that it is part of the town and does not acquire a separate identity and momentum which could undermine the progress of the town itself. This we would take to be part of the definition of a sustainable urban extension.

5.87 Turning to the draft Plan’s proposals, paragraph 5.136 refers to development within and to the east of Harlow to provide 8,000 dwellings and “some more limited development” to the south and west of Harlow, assumed to be 2,700 dwellings. The key growth proposals are major urban extensions to the north to provide for about 10,000 dwellings. To this must be added the proposal for 6,000 dwellings at North Weald. Both the Harlow north and North Weald proposals also involve strategic employment growth. These two major proposals are trenchantly opposed not only by the local authorities in whose areas they fall, but also by very substantial local residents’ movements. Developer/landowner participants, other than those with a direct interest in the proposals concerned, have raised doubts about whether they can deliver sufficient housing at an early stage, and call for growth to be spread among a greater number of locations, both at Harlow and other parts of the sub-region.

5.88 While Herts CC firmly opposes the Harlow north proposal, Essex CC accepts it and the North Weald proposal as the “least worst” options, and Harlow Council supports them. Apart from the general benefits of growth in meeting housing and other development needs, one of the main advantages

25 Appendix B

Extract from The East of England Plan Examination in Public - Report of the Panel - June 2006 claimed for these proposals is in the delivery of transport improvements. Both would assist the creation of a new High Quality Public Transport (HQPT) “spine” linking Epping, North Weald, Harlow, Harlow North and Stansted. However, opponents of the proposals point out that such a spine is only rendered necessary by the proposals themselves and their location detached from the town of Harlow. Improvements to public transport, walking and cycling are certainly needed, but it is arguable that solutions could be delivered in tandem with regeneration and development elsewhere at Harlow.

5.89 A further advantage of growth to the north is seen to be that it would facilitate the creation of a northern by-pass relieving the A414 through the town and providing a new access to the M11. This is supported by ECC and, like the HQPT spine, is regarded as a prerequisite to accepting the development. The road proposal is, however, highly controversial in itself and at this stage is far from guaranteed. The Highways Agency has reservations about creating an additional motorway access, and suggests that alternative means of resolving peak hour congestion on the network in Harlow be considered. HCC and others have also argued in favour of a southern bypass, but that too would be fraught with landscape and other objections. There is clearly no easy answer to the highway issues surrounding Harlow. While that in itself is not a reason for failing to find a solution, we find that the choice of a northern route (or a southern one) has not so far been sufficiently demonstrated to be acceptable or deliverable for the Plan to be made dependent upon it. In fact this is recognised in the draft Plan itself as the RTS shows the proposal as being of only third priority and status “proposed for investigation” (draft Plan Table 8.3/I page 169). The time period of 2006-10 for the scheme also now appears highly unlikely.

5.90 Looking more specifically at the Harlow north proposal, a number of participants argue that it was included in the draft Plan at a fairly late stage in the process, for reasons which are not entirely clear. It was favoured by the Robin Thompson study (SRS7, RPG14 Strategy Review), but prior to that the growth studies, and the “banked draft” RPG14 had considered urban extensions (albeit of a lesser scale) to the east, south and west of Harlow. It may be that reaction against those proposals influenced the decision to set aside the landscape and other considerations which had previously been taken to rule out development to the north. One merit claimed for the northern option is that it rectifies the asymmetric layout of Harlow in which the town centre and railway station lie at the northern edge of the town. It is argued that development to the north would have closer access to the town centre and railway than other directions which would tend to spread the town further away from them. Another argument in favour of the north is that there is a large area of land in single ownership which could ensure delivery of major growth. Although it is inappropriate for us to enter into the merits of specific development proposals, we note that the landowner/developer Ropemaker has put forward some detail of its proposals. The landscape barrier of the Stort Valley would be turned to advantage as a piece of strategic green infrastructure separating the urban extension from the town, but traversed by

26 Appendix B

Extract from The East of England Plan Examination in Public - Report of the Panel - June 2006 a so called “living bridge”, and biodiversity would be integrated into the development. It is also argued that the development can be designed to minimise environmental impact by reducing water use, minimising carbon emissions, sustainable waste management and transport.

5.91 As SHN and others argued, some of the merits claimed for the Ropemaker proposals are not exclusive to the Harlow north location, and in some respects the nature of the proposals reinforces scepticism about what the development would contribute to the town of Harlow and its regeneration. As well as being physically separate from the rest of the town, and beyond reasonable local walking distance, Harlow north would have its own direct connection to the M11 via the proposed northern by-pass. At 10,000 dwellings the development would be of such a size as to support many of its own jobs, shops, schools and other services, which would not be readily accessible from other parts of Harlow. The impression that a separate town would be created is strengthened by indications that it would be regarded as the first stage of a development up to 25,000 homes, although we note that neither EERA nor Harlow DC support growth beyond 10,000.

5.92 Looking at North Weald, some of the same arguments apply. As noted above, the separateness of the location from Harlow means that development would be crucially dependent on the HQPT spine to connect the jobs it would provide with the workforce of the town, and to bring inhabitants of the new housing to the town centre and other facilities in Harlow. Even so, links southwards to Epping, London and further afield via the M11 and M25 would form a significant counter attraction. This raises serious questions about whether HQPT would be viable or effective in making North Weald part of Harlow. One distinguishing feature for North Weald is that the airfield would form a major previously developed site, although the full proposals being promoted by developers Lend Lease also involve significant greenfield land. The airfield is currently in use, however, and a persuasive case was made for its retention for general and business aviation and on account of its heritage value.

5.93 We consider at Chapter 9 concerns that remain unresolved about water supply and wastewater treatment to serve the strategic development proposed in the Plan. These concerns apply both to Harlow north and North Weald, although the local circumstances are not identical. Nor are the concerns about water supply and wastewater treatment confined to these locations, as any development within the sub-region of a comparable scale will require solutions to the same difficulties. Our recommendation on the way forward on the strategic water cycle issues is given at R9.9.

5.94 In conclusion we recognise that the proposals at Harlow north and North Weald would be capable of producing a large amount of additional housing in due course, as well as jobs and supporting infrastructure. However, in view of the need to invest in the HQPT and resolve the strategic water cycle issues

27 Appendix B

Extract from The East of England Plan Examination in Public - Report of the Panel - June 2006 we would not see either location making a major contribution until the latter half of the Plan period. Even then, and assuming water cycle and transport issues could be resolved, there are also objections on landscape and other environmental grounds, particularly for Harlow north, and there remain questions about whether the dynamism of relatively self-contained development at both locations could be made to support the functioning and regeneration of Harlow. The proposed strategy, in relying on “satellite” settlements rather than urban extensions integrated with the town, runs the risk that these will function as rival attractions in terms of the housing market and economic activity.

5.95 We therefore conclude that the strategy should refocus on the opportunities within Harlow and other directions of growth to the east, south and west of the town, reflecting the conclusions of the Growth Area Study (SRS10 paragraph 11.6.21) and the proposals originally contained in the “banked draft” RPG14. Although this also means a reduction in the overall housing provision allocated to this part of the sub-region, we do not consider it should impair the achievement of an early gain in housing output. On the contrary, we would see a strategy concentrating on a number of directions for growth, while avoiding the distractions of planning for major “satellite” settlements as capable of producing early progress in development and securing gains for regeneration within the town.

5.96 It is important not to overlook the fact that other options for growth at Harlow are also the subject of strong local objection, primarily on landscape and environmental grounds. We were impressed by the submissions of Harlow Civic Society (HCS) about the options for locating development at Harlow, although we consider that settling the precise amount of development provided in each direction should be a matter for the LDD process. There will undoubtedly be some opportunities for housing gains within the town centre and other parts of the existing built up area. Beyond that the largest and least constrained options are to the east, where there is opportunity for employment, as well as housing development for which there would appear to be capacity for more than the 3,000 dwellings envisaged in the draft Plan. To the west we note that there have been proposals to complement earlier neighbourhood developments by crossing the former Development Corporation boundary. While mindful of the landscape and other considerations noted in paragraph 5.83 above, we consider that some development in these directions should be provided.

5.97 The strategy for Harlow needs to include key elements of housing and employment provision, regeneration, transport priorities and the network of multi-function greenspace. We consider that this can be done at a sufficient level of detail for RSS in a much more concise form than draft Plan policies ST1 to ST7 and paragraphs 5.121 to 5.149. Our recommendation R5.10 sets out the provisions which we believe to be necessary for Harlow as a growth town within the regional strategy. Much of the detail is already being put in place with support from initiatives such as the Harlow Regeneration Strategy

28 Appendix B

(ECN23-26) and the Green Infrastructure Plan (ENV27, 27A, 27B). In relation to housing, we consider that a total provision of some 13,500 dwellings should be made within and adjacent to Harlow. As noted above, the precise amounts in various locations should be settled through the LDD process. It is clear, however, that a portion of the housing provision, probably about 3,000 dwellings, will be met outside the Harlow District boundary in Epping Forest District. Any portion of the Harlow figure provided in this way would be additional to the provision for Epping Forest District in our proposed changed Policy H1. Our proposed policy makes this clear.

5.98 Effective delivery arrangements will be particularly important in ensuring that development not only comes forward but is also bound into achieving the regeneration and other objectives for Harlow. Matters have moved on since draft Plan Policy ST7 proposing an Area Regeneration Partnership was first drafted, although as we note from Harlow DC’s submission for Matter 8H1 discussions on a LDV have been hampered by lack of agreement on a common approach to the development and regeneration of Harlow. It is to be hoped that those disagreements will be resolved by finalisation of the RSS, and that a partnership approach involving the relevant local authorities, English Partnerships and other stakeholders can make rapid progress. If not, we share Harlow DC’s view that recourse may be needed to a stronger LDV on the UDC model. Urgent consideration also needs to be given to the benefit of pursuing a joint LDD approach to putting the planning strategy in place.

RECOMMENDATION

R5.10 Delete Policies ST1 to ST7. Include a policy for Harlow as a Key Centre for Development and Change in the sub-regional chapter of the RSS as follows:

Harlow

The strategy for Harlow as a Key Centre for Development and Change is:

(1) To promote the renaissance of the New Town through developing its role as a regional housing growth point, Regional Retail Centre and Strategic Employment Location. Regeneration, redevelopment and new urban development will be combined with transport measures and enhancement and conservation of green infrastructure to fulfil this strategy.

(2) LDDs will provide for a total of 13,500 additional dwellings between 2001 and 2021, including some development outside the administrative boundary of Harlow district.

Significant additional housing will be provided:

29 Appendix B

- within the existing area of the town through selective renewal and redevelopment, including mixed use development in the town centre; - through urban extensions to the east to make optimum use of land between the existing built up area and the M11 motorway; - through smaller scale urban extensions to the south, south west and west; and - development will provide for a full range of housing types, sizes, tenures and costs and support development of a skilled and more inclusive local labour force.

(3) The Green Belt will be reviewed to accommodate the new urban extensions. New Green Belt boundaries will be drawn so as to maintain the purposes of the Green Belt, specifically to maintain the integrity of the principles of the Gibberd Plan and landscape setting of Harlow and the physical and visual separation of the town from smaller settlements to the west.

(4) LDDs will provide for the creation and maintenance of a network of multi-function greenspaces within and around the town, taking forward the principles of the Green Infrastructure Plan for Harlow. This network should:

- maintain the principle of “green wedges” penetrating the urban fabric of the town; - provide for enhanced recreational facilities; - protect and maintain designated wildlife sites and provide for urban biodiversity; and - contribute to a visually enhanced character and setting to the town.

(5) The town centre and employment areas will be developed to:

- enhance the role of Harlow as a key centre for higher education and research based institutions; - provide for growth of Harlow’s established sectors and clusters; - attract employment related to the growth of Stansted Airport which does not need to be located there; and - assist the growth of small and medium sized enterprises and the attraction of new economic development and innovation.

(6) The transport priorities for Harlow are:

- achieving a major increase in the use of public transport, walking and cycling within Harlow; new development at the eastern, southern and western edges of Harlow to be used to facilitate improvements for these modes through the town and to the town centre, employment areas and schools;

30 Appendix B

- resolving traffic congestion for movement within and across the town without encouraging an increase in car use, particularly in peak hours; - improvements in accessibility by public transport from Harlow to London, Stansted and Cambridge, including priority for capacity and service improvements on the West Anglia main line; and - improved access from key employment sites to the strategic highway network, including consideration of an east-west bypass in the medium to longer term.

(7) The strategy for Harlow should be delivered through a partnership approach based on the Area Regeneration Partnership. Harlow DC and Epping Forest DC should prepare a joint LDD to establish the planning framework for new urban extensions and the Green Belt reviews. The aim will be to bring forward development simultaneously at various locations so as to facilitate a significant increase in housing delivery at an early stage.

Note: Policy H1 whole District allocations are: - Harlow 13,500 - East Herts 12,000 - Uttlesford 8,000 - Braintree 7,700

The supporting text should refer to the possibility of seeking a stronger delivery mechanism should the ARP not produce the looked for results.

31 Appendix C

Extract from Schedule of the Secretary of State’s decisions to recommendations by the Panel, December 2006.

Panel Recommendation:

R5.10 regarding the Stansted M11 Sub- Region: deletion of Policies ST 1- 7 in draft RSS and replacement with a policy for Harlow as a Key Centre for Development and Change.

32 Appendix C

33 Appendix C

34 Appendix C

35 Appendix C

36 Appendix C

37 Appendix C

38 Appendix D

Harlow Area Landscape and Environment Study Chris Blandford Associates, 2004 Extract from Volume 2, section 2: Northern Fringes

2.6 Key Opportunities and Constraints to Growth

2.6.1 The main landscape and environmental issues associated with conservation and development within the Northern Fringe are highlighted below.

The River Stort Valley Corridor and its Tributaries 2.6.2 The River Stort Valley is a significant landscape feature containing important habitats and a number of protected or notable species. The river valley is already widely used for recreation and river based leisure pursuits. Access in some areas is constrained, with roads and railways being significant barriers to north-south crossing of the valley. The river corridor landscape and its associated vegetation are important to the setting of Harlow and provide significant screening in the wider landscape for the existing riverside industrial development. The minor tributaries of the Stort are important elements of landscape pattern, and are relics of an ancient landscape that offer an ecological potential as reserves for wildlife and as corridors for species movement.

The Historic Parklands and Rural Lanes around Gilston Park and Eastwick

2.6.3 Gilston Park and the surrounding landscape have a rich heritage that is both visible and attractive. The historic trees and hedgerows are important for biodiversity and together with the network of rural lanes and public rights of way, are important elements of the landscape character of the area and provide a sharp contrast to the modern urban area of Harlow.

The Slopes and Ridges around High Wych

2.6.4 The visually significant slopes between Gilston and High Wych are part of the setting of Harlow and its visual containment to the north. Trees and hedgerows have been lost to changes in agricultural practice and Dutch Elm disease, resulting in an open landscape low in biodiversity.

Key Conservation and Enhancement Opportunities

 Conserve and enhance wetlands habitats and woodland along the River Stort corridor and ensure that connections with tributaries are protected.

 Improve access and transport links for pedestrians, cyclists and equestrians along the River Stort valley linking into adjacent green spaces and public rights of way networks and ensure that movement is not impeded or discouraged by new infrastructure.

 Improve facilities and access for waterborne users of the River Stort and their craft.

39 Appendix D

Harlow Area Landscape and Environment Study Chris Blandford Associates, 2004 Extract from Volume 2, section 2: Northern Fringes

 Utilise Aggregates Levy Sustainability Fund (ALSF), to seek landscape and ecological improvements in the area related to past mineral extraction.

 Conserve and strengthen the natural hydrology and vegetation of the minor river valleys, removing culverts where possible.

 Promote restoration and management of historic parkland landscapes including conservation of characteristic estate boundaries, replanting and perpetuation of specimen parkland trees and maintenance of distinctive estate buildings and cottages.

 Protect the character and setting of historical features and the historical parkland around Gilston Park and Eastwick and ensure ecological interest is sustained.

 Avoid intrusive development on the visually prominent open ridges and slopes around High Wych that are important as the countryside backdrop to the setting of Harlow.

 Following historic field patterns, plant new woodland blocks and hedgerows on the ridges and slopes around High Wych, connecting and enhancing existing features and linking potential areas for wildlife.

 Safeguard Gibberd’s Garden including its landscape setting.

 Maintain a landscape buffer around historic settlements.

Key Opportunities and Constraints for Development

 Desirability of retaining the rural character of largely undeveloped/open countryside to the north of the Stort Valley, and avoiding an increased sense of urbanisation through erosion of individual identity of rural settlements and their dispersed pattern within the landscape.

 Scope for mitigating visual impact of development within landscape through careful siting of urban elements within undulating ridge and valley topography.

 Undeveloped, hidden and ‘green’ character of Stort Valley maintained by avoiding development within the floodplain.

 The potential major beneficial contribution of the Stort Valley as a new ‘green wedge’ providing a visual separation buffer between new and old urban areas.

40 Appendix D

Harlow Area Landscape and Environment Study Chris Blandford Associates, 2004 Extract from Volume 2, section 2: Northern Fringes  Scope for linking Stort Valley with new and existing green wedges/corridors to the north and south to provide a connected network of accessible open space and habitats for wildlife as part of a green infrastructure plan to deliver a new landscape framework of woodland blocks, hedgerows and hedgerow trees - with a strong focus on tributary river valleys.

 Scope for retention and linking of small nature conservation and historic environment sites and features such as woodland blocks and hedgerow field boundaries as significant elements of an overall green infrastructure plan for any urban extension.

 Desirability of maintaining and enhancing the character and fabric of sensitive historic landscapes within areas of designed parkland not currently recognised through formal designation.