NORTH FAMBRIDGE PARISH COUNCIL Clerk: Mrs. Christine Wakeling 9 St. Stephens Road Cold Norton Chelmsford Essex CM3 6JE Tel: 01621 828244 Email: [email protected] 12th December 2016 Mr Simon Berkeley Planning Inspector c/o Andrea Copsey, Programme Officer Examination Office Longcroft Cottage Bentley Road Weeley Heath Clacton-on-Sea Essex CO16 9BX Dear Mr. Berkeley, North Fambridge Parish Council has already made a response on the Main Modifications to the Local Development Plan (LDP) as they related to North Fambridge but wish to comment on the response of Plainview Planning to the Inspector's questions. (Document ref: Proposed Main Modifications 1520/ARCIW). We are of the opinion that these comments are not in answer to the Inspector's specific questions but feel that we cannot avoid providing a further response as the suggestions made by Plainview Planning substantially affect North Fambridge. 1. It is incorrect to suggest that the sustainability appraisal is retrospective (para 3.1 Plainview Planning) as an Infrastructure Delivery plan was undertaken in 2012 identifying sites including North Fambridge. Whilst we disagree with the findings of the sustainability appraisal on the basis they should be negative rather than neutral we do not consider it to automatically render the local development process unsound. 2. Statements made by Plainview Planning do not necessarily demonstrate the full picture. For example 'all residents are well within 10 km of key services', in fact Burnham-on- Crouch is 13.1966 kilometres in distance (the town where many residents are registered with a G.P surgery), Maldon is 10.94 kilometres (where many bank) and it is only South Woodham Ferrers which is 8.8 kilometres away. Maldon is inaccessible by train and bus, and all the above areas are generally accessed by car. It is a long walk from the train station to the centre of South Woodham Ferrers where chemists, supermarket, banks etc. are located. Maldon is the centre for local authority services. 3. Although residents use the train service for commuting any increase in this will impact on other communities. The train service cannot be greatly increased due to congestion at Liverpool Street station and short platforms prevent longer trains. The dangers of an increase in traffic along the B1010/1012 were dealt with by us in our response to the Examining Inspector's Matters and Questions Paper in December 2104. This road has a higher number of accidents than could be expected. There have been recent accidents at the bend near the village including the demolition of the garage of the house immediately adjacent to the turning at the entrance to the village. 4. The provision of a new primary/ junior school will not necessarily occur with the proposed additional housing. The local Education Authority prefers a two form intake and that will not automatically be provided by the proposed housing. 5. There is no indication that a large amount of affordable housing is required in North Fambridge nor a demand for it. No such demand was identified in the Parish Plan. The community is isolated, the cost of accessing services is a deterrent to anyone without a car, running a car is increasingly expensive as are train fares to local centres. Hospital visits are almost impossible on public transport and take difficult journeys with several bus changes. There are no regular, frequent bus services within the village. Doctor's surgeries in Maldon and Burnham-on-Crouch are full and the closure of another surgery in South Woodham Ferrers has put pressure on the ability to accept new patients. The community only has a public house and a church. To put reliance on an outline planning application to provide all the necessary facilities within the early stage of the LDP is not sufficient to demonstrate viability or to outweigh the detriment. The recent case of East Bergholt Parish Council v. Babergh District Council, 14th December 2016 has established, inter alia, that the needs of the local area differed from those of the wider district, and that Babergh had incorrectly conducted an exercise to decide whether land development on the land within the Dedham Vale Area of Outstanding Natural Beauty had an exceptional reason to overrule the ordinary prohibition on development. The needs of North Fambridge do not require additional development of the scale proposed in an area so near to a Ramsar site, SSSI's and an Essex Wildlife Trust Reserve . l 6. There may be low crime levels as against areas of higher population which is not unusual in rural areas. However there have been 2 burglaries in the last 2 months and given the reduction of policing in the area there is likely to be an increase. 7. The problems with the B1010/1012 have been outlined above and barring a very few households a car is essential, as can be seen by the number of cars on driveways in the village. It is not unusual for one adult to commute and the other(s) to use a car. The provision of a very limited amount of future employment in the village will not improve this situation and existing employers do not use much village labour. The proposed increase in housing would lead to further use of cars and be of detrimental effect on the environment. 8. We cannot agree that the substantial allocation of housing will not affect the Ramsar site, SSSI's and Essex Wildlife Trust, Blue House Farm. The provision of an additional c.125 houses with planning permission and concomitant impact is considerably less than 1,000 plus in a considerably smaller area than Burnham on Crouch. 9. To propose such a substantial increase in housing would clearly affect the nature of the village which is identified as a small village in the LDP and consists of currently c.330 houses. It is not appropriate to compare a small village with existing towns with all their facilities. Recent refusals of planning applications within the village have given as a reason for refusal the effect on the countryside by the urbanisation of the development. 'Concluding on the main issue, the proposed development would cause considerable harm to the character and appearance of the surrounding area through the urbanisation of a rural, green and tranquil landscape.' (APP/X1545/W/16/3142557). This was for a development of 5 houses not over 1,000. This appeal also concluded that Maldon District Council could demonstrate a 5 year housing supply. Also see APP/X1545/A/14/2213766. In the Landscape Character Assessments, (relevant extract in Appendix D), it was stated that 'Potential new development either within the area, or within adjacent character areas, may also disturb the strong sense of tranquillity. The area also contains several internationally and nationally important sites for wildlife (in particular, wildfowl). Overall, this character area has high sensitivity to change.' and 'The open nature of the area is visually sensitive to new development (especially in close proximity to the sea wall), which would be visible within views from adjacent character areas. There is a sense of historic integrity, resulting from a distinctive co-axial rectilinear field pattern and a dispersed historic settlement pattern. Potential new development either within the area, or within adjacent character areas, may also disturb the strong sense of tranquillity. The area also contains several internationally and nationally important sites for wildlife (in particular, wildfowl). Overall, this character area has high sensitivity to change. 10. North Fambridge is an unsuitable area for development as is stated by the Parish Council in 2013 (Appendix A). A large proportion of the village is on flood plain and exits from the village would be blocked in the event of flooding (see paragraph 1 of Appendix A). 11. The existing problem of sewage and surface water has not been completely addressed by the proposals contained in Appendix B of Plainview Planning's submission. Although upgrading of the sewage system within the village could improve the situation regarding the 30 houses at Manor Farm it does not address the response of the Environment Agency on page 2 to an application FUL/MAL/15/01336 (Appendix B). This confirms the Joint Statement with Anglia Water (Appendix C) with its approximate costings. No further discharge into the Rier Blackwater is acceptable to the Environment Agency. Anglian Water admit that the upgrade would not cope with surface water entering the system a recognised current problem. The reasoning for removing the additional 75 from the proposed LDP remains. The Chelmsford Council emerging LDP identifies South Woodham Ferrers as an area for growth which in itself will put further pressure on the proposed alternative of the treatment works at South Woodham Ferrers. Conclusion North Fambridge has a number of negative reasons cited above which would prevent the sustainable allocation of additional housing to the village. The proposed main modifications from Plainview Planning are effectively a re-writing of the Local Development Plan as far as North Fambridge and the plan is concerned. There has never been a proposal within the emerging LDP to substantially increase the housing in North Fambridge. In many cases landowners have put forward land to be developed but this does not imply that using that land is a sustainable or viable possibility. Our understanding of the hearings by the Inspector in January were to examine the proposed LDP not to re-write it. Appendix A North Fambridge Parish Council Maldon District Council MDC Local Development Plan Preferred Options Consultation Princes Road Maldon Essex CM9 5DL 9 St Stephens Road Cold Norton Essex CM3 6JE October 2013 Dear Sir Draft Local Development Plan 2014-2029 (MDCLDP) Much of the response below repeats comments made to the original proposed development plan of 2012.