APPENDIX 1 Maldon District Council Response to the Chelmsford City

Home , Bicknacre, Boreham, Great Leighs, Maldon, Rettendon, South Woodham Ferrers

APPENDIX 1

Maldon District Council response to the Chelmsford City Council Local Plan Issues and Options Consultation

The Chelmsford City Council (CCC) Local Plan Issues and Options consultation includes 30 questions covering all sections of the Plan. The interests of Maldon District Council (MDC) do not require a response to all consultation questions, however for clarity all 30 questions are set out below.

Question 1 Do you think that Section 3 provides an adequate range of facts and figures about Chelmsford today? If no, please explain why. Where possible, please support your answer with reference to any evidence.

No comment.

Question 2 Do you support what should drive the new Local Plan Vision? If no, please explain your answer and suggest any changes.

No comment.

Question 3 Do you agree with what should be covered in the Vision? If no, please explain your answer and suggest any changes.

No comment.

Question 4 Do you have any comments on how the Council has calculated its Objectively Assessed Housing need? Please explain your answer. Where possible, please support your answer with reference to any evidence.

No comment.

Question 5 Do you have any comments on the housing number (930 homes per year) used for testing in this consultation? Please explain your answer. Where possible, please support your answer with reference to any evidence.

The housing target of 930 dwellings per annum is based on a 20% uplift to the Council’s objectively assessed housing need (OAHN) of 775 dwellings per annum. The Joint OAHN Study (Peter Brett Associates, 2015) identifies that the CCC area is relatively unaffordable compared with country, regional and national ratios, and the CCC Strategic Housing Market Assessment for the area also identified significant need for affordable housing (DCA, 2013) which has not been met during a period of lower housing completions since 2009/10. The

1 / 10 APPENDIX 1 purpose of the uplift is therefore to allow the Issues and Options consultation to continue while a further assessment of the need for affordable housing in the CCC area is undertaken.

The 20% buffer across the Plan period presents an increase of 3,100 dwellings from the OAHN target, and therefore represents a significant proportion of housing allocations which are required to be located on greenfield sites. Through the Duty to Cooperate Maldon District Council (MDC) is keen to review further assessment work on the affordable housing need in the CCC area to gain an understanding of how this will impact upon the Local Plan housing target.

It is acknowledged that the 20% buffer represents a rough estimate for testing purposes at this stage. The results of the additional work may require amendments to potential levels of growth across the CCC area. MDC would therefore like to work closely with CCC to ensure that the implications of any amendments are fully assessed and understood.

Question 6 Do you have any comments on how the new Local Plan could meet the accommodation needs of Travellers?

No comment.

Question 7 Do you have any comments on how the Council has calculated its job requirement number? Please explain your answer. Where possible, please support your answer with reference to any evidence.

No comment.

Question 8 Do you have any comments on the job requirement number (887 jobs per year) used for testing in this consultation? Please explain your answer. Where possible, please support your answer with reference to any evidence.

No comment.

Question 9 Do you have any comments on how the Council has calculated its retail capacity forecasts? Please explain your answer. Where possible, please support your answer with reference to any evidence.

No comment.

Question 10

2 / 10 APPENDIX 1

Do you have any comments on the retail floorspace requirements used for testing in this consultation? Please explain your answer. Where possible, please support your answer with reference to any evidence.

No comment.

Question 11 Do you have any comments on how the Council has calculated its office need forecasts? Please explain your answer. Where possible, please support your answer with reference to any evidence.

No comment.

Question 12 Do you have any comments on the office floorspace requirements used for testing in this consultation? Please explain your answer. Where possible, please support your answer with reference to any evidence.

No comment.

Question 13 Do you think that we have missed any issues related to future employment and economic development to be addressed in the new Local Plan? If yes, please explain why. Where possible, please support your answer with reference to any evidence.

No comment.

Question 14 Do you think that we have missed any issues related to highways, transportation and accessibility to be addressed in the new Local Plan? If yes, please explain why. Where possible, please support your answer with reference to any evidence.

Paragraphs 5.43 onwards set out how highways, transportation, and accessibility have been considered within the production of the Local Plan Issues and Options consultation document. This section refers to key corridors within Chelmsford City Centre, the railway station, and sets out a vision for the CCC areas transport system to offer enhanced connectivity and access to opportunities for residents, commuters, visitors and business. A number of objectives are listed in order to present ‘strategic zonal focuses’ which will inform the identification of future projects to achieve the overarching vision.

The CCC area has strong commuting links to surrounding areas, and in particular with Maldon District where CCC’s overall commuting flows are third highest with Maldon District, including the second highest in-commuting flows of the 6 areas represented in Figure 8 of the Plan. Although connectivity for commuters is recognised within the vision, this is not reflected in the Strategic Zonal Focus within Table 3. It is therefore recommended

3 / 10 APPENDIX 1 that improving connectivity for commuters from Maldon District and other surrounding areas with the CCC area should be included as an aim within the ‘Outer’ section of Table 3.

Transport links between Maldon District and the CCC area were considered in detail during the production of the Maldon District Local Development Plan (LDP). The A414 between Maldon and Chelmsford and the A132 / Rettendon roundabout were recognised as key transport routes for commuters within both Maldon District and the CCC area where there are high levels of congestion at peak periods. These transport links are therefore highly sensitive to proposals for growth which could increase the use of these routes at peak periods.

Through the Duty to Cooperate MDC would like to work closely with CCC to consider the impact of proposals for growth in the south east of the CCC area which could have implications for the A414 between Maldon and Chelmsford, and the A132 between the Rettendon roundabout and the B1012 Burnham Road.

Question 15 Do you think that we have missed any issues related to protecting the environment to be addressed in the new Local Plan? If yes, please explain why. Where possible, please support your answer with reference to any evidence.

No comment.

Question 16 Necessary infrastructure will be needed to support development in the new Local Plan. Do you think that we have missed any issues? If yes, please explain why. Where possible, please support your answer with reference to any evidence.

It is acknowledged that the need for new or improved transport infrastructure will be assessed further once the preferred locations for new development have been identified. MDC would welcome further information on the potential impacts of growth options on the highways network to assist in the detailed consideration of sites for strategic growth. Through the Duty to Cooperate MDC would like to work closely with CCC to consider the impact of proposals for growth in the south east of the CCC area which could have implications for the A414 between Maldon and Chelmsford, and the A132 between the Rettendon roundabout and the B1012 Burnham Road.

In relation to education, healthcare, community facilities, recreation and leisure, there are strong links between the two authority areas where needs for key services and facilities are satisfied across the local authority boundaries. Through the Duty to Cooperate MDC would like to work closely with CCC to consider the impact of proposals for growth in the south east and east of the CCC area which could have implications for infrastructure provision in relation to education, healthcare, community facilities, recreation and leisure facilities which is accessed by residents of Maldon District.

4 / 10 APPENDIX 1

Question 17 Do you agree with the proposed settlement hierarchy i.e. City or Town, Key Service Settlement, Service Settlement and Small Settlement? If no, please explain why. Where possible, please support your answer with reference to any evidence.

No comment.

Question 18 Do you agree with the classification of individual settlements within the Settlement Hierarchy? If no, please explain why. Where possible, please support your answer with reference to any evidence.

No comment.

Question 19 Do you support the proposed Spatial Principles?

The Spatial Principles in section 6 of the Local Plan consultation document have been used to guide the identification of locations for growth. MDC supports the Spatial Principles identified, particularly in relation to maximising the use of brownfield land and locating development in well connect sustainable locations.

When considering locations for strategic growth, an important consideration should be opportunities to use available existing infrastructure capacity within the District. Using existing infrastructure capacity, rather than developing additional infrastructure items, presents the most sustainable approach to delivering growth.

In relation to the principle of ensuring that new development is served by necessary infrastructure, it is therefore recommended that this should go further to seek to identify locations where there is available infrastructure capacity which can be used to accommodate future growth.

Question 20 How do you think that new development growth in Chelmsford should be provided in the new Local Plan?

The consultation document sets out three spatial options for accommodating the 14,000 dwellings required to meeting the areas objectively assessed needs for housing. MDC provides the following comments on each of the options:

Option 1 – Urban Focus

This option seeks to concentrate new development at locations within and/or close to the existing urban areas that are within Chelmsford. These are the urban areas of Chelmsford, where the majority of new development would be planned, on land to the north of the town of South Woodham Ferrers and on land to the north and east of Great Leighs which is two miles

5 / 10 APPENDIX 1

south of Braintree and which would provide linkages to development planned in Braintree District.

Growth proposed on land to the north of South Woodham Ferrers is likely to have the largest impact on residents of Maldon District. The B1012 Lower Burnham Road leading to the A132 around South Woodham Ferrers and the Rettendon roundabout is an important transport link for residents of Maldon District. The Lower Burnham Road, junctions on the A132 along the northern boundary of South Woodham Ferrers, and the Rettendon roundabout experience high levels of congestion at peak periods.

It is acknowledged that the need for new or improved transport infrastructure will be assessed further once the preferred locations for new development have been identified. MDC would welcome further information on the potential impacts of growth options on the highways network to assist in the detailed consideration of sites for strategic growth. Through the Duty to Cooperate MDC would like to work closely with CCC to consider the impact of proposals for growth in South Woodham Ferrers where this could impact on journey times for Maldon District residents travelling west towards the A130 and beyond.

Due to the location of South Woodham Ferrers close to the south eastern boundary between Maldon District and the CCC area, there are strong links between the two authority areas in relation to the use of services and facilities such as education, healthcare, community facilities, recreation and leisure facilities. Through the Duty to Cooperate MDC would like to work closely with CCC to consider the impact of proposals for growth in South Woodham Ferrers which could have implications for infrastructure provision in both local authority areas in relation to education, healthcare, community facilities, and recreation and leisure facilities which are accessed by residents of both authorities.

Proposals for growth in South Woodham Ferrers include 1,000 sqm of floorspace and 1,900 sqm of floorspace for food retail (convenience goods). The submitted Maldon District Local Development Plan has allocated 3.4 hectares of employment land in Burnham on Crouch. The Maldon District Retail Study (July 2015) identified residual capacity in Maldon District for between 1,900 and 2,700 sqm of convenience goods floorspace, which the Study recommended should be directed towards Burnham on Crouch. It is acknowledged that the purpose of including 2,900sqm of employment and retail floorspace within proposed options for growth in South Woodham Ferrers is to support the proposed development of 2,000 dwellings. However, if South Woodham Ferrers is taken forward as a preferred option for growth, MDC would like to work with CCC through the Duty to Cooperate to consider further the potential impact of additional retail and office floorspace in South Woodham Ferrers on the provision of employment and retail facilities in Maldon District. Through this process, MDC would seek clarification that the level of office and retail growth in South Woodham Ferrers would not inhibit the ability to locate such facilities in sustainable locations for residents of Maldon District in the future.

Option 2 – Urban Focus and Growth on Key Transport Corridors

This option also promotes development at locations within and/or close to the existing urban areas, but to a lesser extent than contained in Option 1. The remaining development would be planned at locations on the key transport corridors serving the CCC area, notably the A130/A131 and A132. Option 2 includes new development to the north of South Woodham Ferrers and Rettendon Common.

6 / 10 APPENDIX 1

Growth proposed on land to the north of South Woodham Ferrers and Rettendon Place is likely to have the largest impact on residents of Maldon District. The comments provided in relation to Option 1 regarding the B1012 Lower Burnham Road, leading to the A132 around South Woodham Ferrers and the Rettendon roundabout, are equally relevant for Option 2. Through the Duty to Cooperate MDC would like to work closely with CCC to consider the impact of proposals for growth in South Woodham Ferrers and Rettendon Common where this could impact on journey times for Maldon District residents travelling west towards the A130 and beyond.

As outlined in relation to Option 1, through the Duty to Cooperate MDC would like to work closely with CCC to consider the impact of proposals for growth in both South Woodham Ferrers and Rettendon Common which could have implications for infrastructure provision in both local authority areas in relation to education, healthcare, community facilities, and recreation and leisure facilities which are accessed by residents of both authorities.

Similarly, comments provided in relation to Option 1 for employment and retail growth in South Woodham Ferrers are also relevant for Option 2. MDC would like to work with CCC through the Duty to Cooperate to consider further the potential impact of additional retail and office floorspace in South Woodham Ferrers on the provision of employment and retail facilities in Maldon District. Through this process, MDC would seek clarification that the level of office and retail growth in South Woodham Ferrers would not inhibit the ability to locate such facilities in sustainable locations for residents of Maldon District in the future.

Option 3 – Urban Focus and Growth in Key Villages

This option promotes a more dispersed approach to planning for new development within and/or close to the existing urban areas, but to a lesser scale that Options 1 and 2. Option 3 continues to recommend large scale growth in South Woodham Ferrers. The remaining development would be distributed to settlements outside of the Green Belt that provide existing local services and facilities which includes Boreham, Danbury, Howe Green, Bicknacre and Rettendon Place.

Option 3 presents the highest number of locations for growth in the south east of the CCC area. Growth proposed in the south east of the CCC area is likely to have the largest impact on residents of Maldon District. The comments provided in relation to Options 1 and 2 regarding the B1012 Lower Burnham Road, leading to the A132 around South Woodham Ferrers and the Rettendon roundabout, are equally relevant for Option 3. Through the Duty to Cooperate MDC would like to work closely with CCC to consider the impact of proposals for growth in the south east of the CCC area which could have implications for the A414 between Maldon and Chelmsford, and the A132 between the Rettendon roundabout and the B1012 Burnham Road.

7 / 10 APPENDIX 1

There are strong links between settlements in the south east of the CCC area and Maldon District in relation to the use of services and facilities such as education, healthcare, community facilities, recreation and leisure facilities. Through the Duty to Cooperate MDC would like to work closely with CCC to consider the impact of proposals for growth in south east of the CCC area which could have implications for infrastructure provision in both local authority areas in relation to education, healthcare, community facilities, and recreation and leisure facilities which are accessed by residents of both authorities.

Similarly, comments provided in relation to Options 1 and 2 for employment and retail growth in South Woodham Ferrers are also relevant for Option 3. MDC would like to work with CCC through the Duty to Cooperate to consider further the potential impact of additional retail and office floorspace in South Woodham Ferrers on the provision of employment and retail facilities in Maldon District. Through this process, MDC would seek clarification that the level of office and retail growth in South Woodham Ferrers would not inhibit the ability to locate such facilities in sustainable locations for residents of Maldon District in the future.

Question 21 If you ticked 'None of the above', can you suggest any alternative or additional Option that should be considered in the new Local Plan? Where possible, please support your answer with reference to any evidence.

No comment.

Question 22 Which location(s) do you support for new development growth in the new Local Plan?

No comment.

Question 23 Are there any alternative or additional locations for new development growth that should be considered in the new Local Plan? Where possible, please support your answer with reference to any evidence. If you are promoting a site for development and did not submit it as part of the ‘Call for Sites 2014’ please follow the instructions at www.chelmsford.gov.uk/shlaa

No comment.

Question 24 Do you have any comments on the following road and transportation improvements as shown on the Spatial Options plans?

Highways capacity improvements to the A132

The B1012 Lower Burnham Road leading to the A132 around South Woodham Ferrers and the Rettendon roundabout is an important transport link for residents of Maldon District. The

8 / 10 APPENDIX 1

Lower Burnham Road, junctions on the A132 along the northern boundary of South Woodham Ferrers, and the Rettendon roundabout experience high levels of congestion at peak periods.

It is acknowledged that highways capacity improvements to the A132 will be assessed further once the preferred locations for new development have been identified. MDC would welcome further information on the potential impacts of growth options on the highways network to assist in the detailed consideration of improvements that may be required to the A132. Through the Duty to Cooperate MDC would like to work closely with CCC to consider improvement options to the A132 where these works could impact on journey times for Maldon District residents travelling west towards the A130 and beyond.

Question 25 Do you have any comments on the approach of discounting development growth in the Green Belt in the new Local Plan?

No comment.

Question 26 Do you have any comments on the approach of discounting a large new settlement in the new Local Plan?

No comment.

Question 27 Do you have any comments on the issues that the new Local Plan policies need to cover? Please explain your answer.

No comment.

Question 28 Do you have any comments on the existing six Special Policy Areas?

No comment.

Question 29 Do you think there are other large facilities or sites which should be considered as Special Policy Areas? Please explain your answer

No comment.

Question 30 Have we missed anything? Please indicate what other matters should be considered and why.

9 / 10 APPENDIX 1

No comment.

10 / 10