Forward Plan reference number: FP/781/03/17
Report title: Chelmsford Local Plan – Preferred Options Consultation Document (Regulation 18), March 2017 Report to: Cllr David Finch, Leader of the Council Report author: Dominic Collins, Director Economic Growth and Localities Date: 11th May 2017 For: Decision Enquiries to: Kevin Fraser, Principal Spatial Planner kevin.fraser@essex.gov.uk , Ph: 0333 01 30558 County Divisions affected: All Divisions within Chelmsford City Council area
1. Purpose of Report
1.1 To approve the proposed Essex County Council (ECC) formal response to the Chelmsford Local Plan – Preferred Options Consultation Document, March 2017 (the Draft Plan).
2. Recommendations
2.1 To agree to send to Chelmsford City Council (CCC) the response in Appendix 1 regarding the Draft Plan.
2.2. To agree that ECC will continue to work with CCC through the duty to cooperate as CCC prepares its Pre-Submission Local Plan to ensure ECC is able to assist with the delivery of its key services and the provision of new funded infrastructure arising from the planned growth and towards the improvement and refinement of the emerging new Local Plan.
3. Summary of issue
3.1 The current Chelmsford Local Development Framework (LDF) covers the period from 2001 to 2021, and comprises a suite of documents (Core Strategy; Site Allocations and Development Management; Town Centre Area Action Plan (AAP); and North Chelmsford AAP), which were adopted between 2008 and 2012. CCC is now preparing a new Local Plan and once adopted, will replace the suite of LDF documents.
3.2 The preparation of the new Local Plan commenced with the publication of the ‘Issues and Options’ consultation (Winter 2015/16). It focused on the issues facing Chelmsford and a number of options on how these could be addressed, including potential levels of new development with possible locations and areas of search for growth. The consultation considered three Spatial Options for how 14,000 new homes and 13,000 new jobs could be distributed based on a set of nine Spatial Principles including protecting the Green Belt and ensuring new development is deliverable and served by necessary infrastructure. A Sustainability Appraisal (SA) assessed these issues against a range of social, environmental and economic indicators to help identify all the likely significant effects. The three Spatial Options presented were:
1 1: Urban Focus 2: Urban Focus + Growth on Key Transport Corridors 3: Urban Focus + Growth in Key Villages.
3.3 The ECC response to the earlier Issues and Options document can be viewed via the link.
3.4 ECC has continued to work with CCC as it prepares its Preferred Options Local Plan to ensure the full range of infrastructure requirements arising from growth and development options are appropriate and adequately assessed; and consideration has been given to ensuring that ECC is able to assist in the delivery of its key services and functions potentially arising from the planned growth. ECC continues to assess implications of growth on the transport and highway network and has identified requirements for how the additional primary, secondary school and early years and childcare places will need to be accommodated, the economy and economic growth is to be encouraged, appropriate provision is made for minerals and waste, and consideration given to surface water management issues, historic and natural environment issues.
3.5 Since the Issues and Options consultation, CCC has reviewed consultation comments, commissioned new evidence and held discussions with landowners and developers regarding their emerging plans and key issues. CCC has also considered the implications of the Housing White Paper (February 2017), and assessed that most of the proposals are reflected in the Draft Plan, but will continue to monitor its progress alongside preparation of the Pre Submission Plan to determine if further changes are required. ECC has assisted CCC throughout this time by undertaking transport modelling, assessing minerals impacts on emerging Local Plan site allocations, providing detailed assessment of education requirements arising from growth proposals for inclusion in site policies, provided informal feedback on emerging draft policies, supporting text and identified emerging infrastructure requirements as reflected in their Draft Infrastructure Delivery Plan.
CCC Preferred Options Local Plan (this consultation)
3.6 CCC has prepared a Preferred Option Local Plan and is undertaking consultation for 6 weeks from 30th March to 11th May 2017. The Draft Plan covers the period up to 2036. The aim of this consultation is to ensure that CCC is aware of all possible policy options and their implications before they proceed to the next and final stage of plan preparation and consultation (known as the Pre-Submission Plan). The Draft Plan is supported by a SA report with the purpose of providing a detailed assessment of the Draft Plan’s likely effects across the three dimensions of sustainable development (environmental, social and economic considerations) together with a range of topic based evidence reports.
3.7 Following this round of consultation, the Draft Plan will be revised by CCC to reflect a) comments received during consultation, b) updated evidence and c) any other required changes, such as national policy updates. The final revised document (the Pre-Submission Plan) is intended to be published in Autumn 2017, followed by a further period of public consultation and planned submission to the Government in Spring 2018, for public examination in Summer 2018 and subsequent adoption in Winter 2018.
2 Content / Structure of the Preferred Options
3.8 The Draft Plan contains ten sections comprising:- an Introduction; About Chelmsford – which provides the context for identifying the drivers for the Draft Plan for Chelmsford City; What are our Strategic Priorities – sets out the key issues to be addressed through the Local Plan including the development needed; Our Vision and Spatial Principles setting out the long term vision and principles for managing and accommodating growth; Creating Sustainable Development – sets out the approach that underpins the aim of securing sustainable development; How will future development growth be accommodated – which sets out the how much development is needed and the Spatial Strategy; Where will future Development Growth be Focused? – sets out the three Growth Areas and the proposed development sites; Protecting and Securing Important Assets – providing the policies which protect the countryside, heritage and natural assets; Making High Quality Places – which provides detail on design objectives; and Monitoring and Implementation section. The Proposals Maps provides the spatial representation for site allocations and notations on an Ordinance Survey base.
3.9 Vision and Spatial Strategy: The Draft Plan sets out the type of place Chelmsford will become in 2036. The Vision highlights Chelmsford’s existing strengths and how new development growth will further strengthen Chelmsford’s role as England’s newest city and the Capital of Essex. Development opportunities in the city centre will be maximised but supported by new sustainable neighbourhoods. The Vision is informed by the Strategic Priorities, which are set out in Section 3. These priorities are closely aligned with those of Chelmsford’s partner local authorities in North of Essex: Braintree, Colchester and Tendring.
3.10 Strategic Priorities: In turn the Vision and Strategic Priorities have been translated into 11 Spatial Principles to shape the Preferred Options Spatial Strategy. These are set out in Strategic Policy S1 and include: maximising the use of brownfield land for development; locating proposed new development at well-connected sustainable locations (utilising garden community principles); protecting the Green Belt and ensuring development is served by necessary infrastructure; and protecting the character of valued landscapes, heritage and biodiversity.
3.11 The Draft Plan contains 15 Strategic Policies (Sections 4 – 6) regarding Spatial Principles; Securing Sustainable Development; Addressing Climate Change and Flood Risk; Promoting Community Inclusion; Conserving and Enhancing the Historic Environment; Conserving and Enhancing the Natural Environment; Protecting and Enhancing Community Assets; Development Requirements; The Spatial Strategy; Delivering Housing Growth; Delivering Economic Growth; Infrastructure Requirements; Securing Infrastructure; The Role of the Countryside; and The Role of City, Town and Neighbourhood Centres.
3.12 Housing: Strategic Policy S8 identifies a housing requirement of 805 homes per year which totals 18,515 by 2036. In order to ensure flexibility in supply and significantly boost housing supply 20% has been added to this figure to total 22,162 new homes by 2036. Over 2,000 homes have already been built (2013 – 2016) and nearly 9,400 new homes have planning permission or are committed. This leaves the need for 10,875 new homes to be allocated on sites in the new Local Plan.
3 3.13 Employment: Strategic Policy S8 identifies a jobs requirement for the period up to 2036 of 725 new jobs per year (11,000 in total). Job growth will arise from both the intensification and diversification of existing businesses and from new employment allocations. To accommodate this growth, 55,000 sqm of employment floorspace and 13,400 sqm floorspace of additional convenience retail will be allocated at locations identified in the table on page 5.
3.14 Spatial Strategy: growth is focussed to the most sustainable locations, maximising previously developed land in the Chelmsford Urban Area. However, in order to meet the need for housing, significant growth is allocated at locations to maximise future infrastructure delivery, namely: Sustainable urban extensions forming new distinct neighbourhoods to Chelmsford and South Woodham Ferrers; and Development around the Key Service Settlements outside the Green Belt i.e. Bicknacre, Boreham, Broomfield, Danbury and Great Leighs.
3.15 The Spatial Strategy seeks to allocate growth in the three Growth Areas below:
Growth Area 1 – Central and Urban Chelmsford – will accommodate around 3,200 new homes on brownfield sites, 800 at West of Chelmsford, 400 in East Chelmsford, 9,000 sqm of office and business space, 11,500 sqm of convenience retail and 5 Travelling Showpersons plots.
Growth Area 2 – North Chelmsford – will accommodate around 3,000 new homes at NE Chelmsford; 1,100 at Great Leighs; 800 at North Broomfield; 145 at east of Boreham, employment opportunities to provide 45,000 sqm of office/business floorspace and 14 Travelling Showpeople plots. In addition, a Gypsy and Traveller allocation for 10 pitches is proposed at Drakes Lane, Little Waltham.
Growth Area 3 – South and East Chelmsford – will accommodate over 1,000 new homes at South Woodham Ferrers, 30 new homes at Bicknacre, 100 new homes at Danbury to be allocated through its Neighbourhood Plan, 1,000 sqm of flexible business space and 5 Travelling Showpeople plots.
3.16 Within these Growth Areas the following types of Site Allocations will be provided:
4 3.17 Site Allocation Policies (see below): 40 policies are included in the Draft Plan for specific sites within the 3 Growth Areas. Strategic Growth Site policies identify requirements (including key infrastructure) and actions required to be met by any future planning application/development, such as development capacity; access requirements; infrastructure requirements (including education/early years); community requirements; open space; providing a mix of housing etc. The requirements are specific to each site allocation. Opportunity Areas in the Chelmsford Urban Area have their own policy, where a range of uses may be proposed, although they are required to make the best and most efficient use of brownfield land. In addition ‘Existing Commitments’ are deliverable sites previously allocated in the CCC’s LDF which have not yet been granted planning permission.
The Site Allocation Policies refer to the following:
Allocation Location Proposed Delivery Page of Number Development Period Draft Local Plan Strategic Growth Sites Chelmsford Urban Area 1a -g 1,965 homes Plan Period 91 - 108 West Chelmsford – 2 800 homes By 2031 118 Warren Farm 5 Travelling showperson East Chelmsford 3a 250 homes By 2026 121 – Manor Rationale Farm East Chelmsford 3b 5,000 sq m By 2026 125 – North Maldon Office/High-Tech Road Business Park Land south of Maldon 3c 150 homes By 2026 128 Road North East Chelmsford 4 3,000 homes By 2036 136 45,000sqm Office/High-Tech Business Park 9 Travelling Showpersons’ plots Moulsham Hall and 5 1,100 homes/ By 2031 141 North Great Leighs Travelling and Showpersons’ plots North of Broomfield 6 800 homes By 2031 146 East of Boreham 7 145 By 2026 150 North of South 8 1,000 homes By 2036 159 Woodham Ferrers 1,000sqm flexible business space 1,900sqm Food Retail 5 Travelling Showpersons’ plots Growth Sites Chelmsford Urban Area 1h - s 362 homes Plan Period 111 - 115 Drakes Lane TS1 10 G and T pitches By 2021 153 South of Bicknacre 9 30 homes By 2026 162 Danbury 10 100 homes Plan Period 164
5 Allocation Location Proposed Delivery Page of Number Development Period Draft Local Plan Opportunity Areas Former Royal Mail OS1a Mixed Use By 2021 116 Premises Rivermead OS1b Mixed Use By 2026 116 Railway Sidings OS1c Mixed Use By 2031 117 Existing Commitments Galleywood Reservoir EC1 200 homes By 2021 131 Land surrounding EC2 25 homes Within Plan 132 Telephone Period Exchange, Ongar Road, Writtle Land South and West EC3 200 homes Within Plan 154 of Broomfield Period Place and Broomfield Primary School St Giles, Bicknacre EC4 32 specialist Within Plan 166 residential Period accommodation
3.18 All Strategic Growth and Opportunity Sites will require the preparation of masterplans to ensure that a comprehensive approach is taken to the planning and delivery of each allocation, along with understanding the associated infrastructure requirements, and funding source/assumptions. Masterplans may also be required for Growth Sites, where the site is complicated in nature or to reflect its specific context. Masterplans will be produced by the applicants in partnership with CCC and other relevant stakeholders including infrastructure providers and statutory consultees such as ECC.
3.19 Special Policy Areas (Policies SPA1 - 6): six designated Special Policy Areas (SPAs) are allocated within the Green Belt or Rural Area, where ordinarily policy would constrain new development. Their designation enables the operational and functional requirements of these facilities or institutions to be planned in a strategic and phased manner. The SPAs are Broomfield Hospital; Chelmsford City Racecourse; Hanningfield Reservoir; RHS Hyde Hall Gardens; Sandford Mill; and Writtle University College.
3.20 Key Infrastructure Requirements (Policy S12): new development will create demand for additional infrastructure, be it transport, education, recreation, environment or community related. The growth allocated within the Draft Plan will provide the opportunity to address future transport infrastructure needs, and these are identified below (where known or in general terms):
Transport Infrastructure – includes Chelmsford North East Bypass; Beaulieu Park Railway Station; Improvements to the Army and Navy Junction; Strategic flood defence measures to protect Chelmsford City Centre; Improved road infrastructure aimed at reducing congestion and providing more reliable journey times along, for example, the A12, A130, A131 and A414; Junction improvements on the A12 and other main roads to reduce congestion; an additional new Radial Distributor Road in North East Chelmsford; a new Park and Ride site to serve West Chelmsford; a new Park and Ride site to serve Beaulieu Park Railway Station; Capacity improvements to the A132 between
6 the Rettendon Turnpike and South Woodham Ferrers; Transport links between new neighbourhoods and Chelmsford City Centre and employment areas The encouragement of public transport use, and provision of sustainable transport measures and other transport improvements in the locality or directly related to development; Cycle routes and footway improvements Bus Priority and rapid transit measures; Neighbourhood Centres – includes community, primary healthcare, retail and leisure facilities in the new neighbourhoods; Education – Early years, primary and secondary, and tertiary education provision to serve; new and existing communities; Other Infrastructure – including Open space and public realm enhancements; Green Infrastructure; Recreational provision; Cultural facilities; Community facilities across Chelmsford; Utility infrastructure (electricity, gas distribution and supply, water supply and waste water treatment, telecommunications and superfast broadband.
3.21 Safeguarded Infrastructure: the following infrastructure schemes will help relieve congestion or provide connections to new developments, and the Draft Plan allocates land for these schemes to be safeguarded from development and allocated on the Proposals Map. Such schemes include the safeguarded route for the Chelmsford North East Bypass; Area of Search for an additional Park & Ride in West Chelmsford; new Beaulieu Park Rail Station; Area of Search for an additional Park and Ride site to serve Beaulieu Park Railway Station; an additional new Radial Distributor Road in North East Chelmsford; and capacity improvements to the A132 between the Rettendon Turnpike and South Woodham Ferrers.
3.22 General Policies: Chapter 8 – Protecting and Securing Important Assets and Chapter 9 – Making High Quality Places, contains 31 general policies for Development Management purposes, and are broadly outlined below.
3.23 Securing the right type of homes: policies seek to provide an appropriate mix and type of housing by size of site consistent with Building Regulation standards, and include specialist accommodation and right to build (Policy HO1). CCC will require the provision of 35% of the total number of residential units to be provided and maintained as affordable housing within all new residential development sites which have a capacity of 15 or more dwellings; or comprise an area of 0.5ha or larger. Rural Exception Sites for affordable housing on small sites will be granted subject to set criteria being met in Policy HO2. Gypsy and Traveller and Showpeople pitches will be provided within the new allocations, and a criteria based policy will determine any applications above the identified need in relation to new sites, sub division of existing pitches and change of use sites/yards (Policy HO3).
3.24 Securing Economic Growth: within the Employment Areas as shown on the Proposals Map, CCC will seek to retain Class B uses or other ‘sui generis’ uses. It is recognised that businesses need flexibility to perform their economic function in today’s environment (Policy EM1). Policy is also provided regarding primary and secondary retail frontages (Policy EM2).
3.25 Protecting the Countryside: policies seek to balance the requirement for new development within the countryside to meet identified needs, to support thriving
7 rural communities with protecting the environment. These policies seek to protect the openness and permanence of the Green Belt; protect the role, function, character and appearance of the Green Wedges along the main river valleys, protect the distinctive and valued landscape along the Green Corridors, and protect the intrinsic character of the rural areas (Policy CO1). Policies also seek to control appropriate development in these areas regarding new build, replacement dwellings, extensions, infilling, and change of use (Policies CO2 – 8).
3.26 Protecting the Historic Environment: policies seek to provide for the protection of valued historic assets, be they designated (Listed Buildings; Conservation Areas; Registered Parks and Gardens; and Scheduled Monuments) in Policy HE1 or non- designated in Policy HE2. A further policy seeks to protect, enhance and preserve sites of archaeological interest and their settings (Policy HE3).
3.27 Protecting the Natural Environment: a policy seeks to provide a framework for conserving and enhancing biodiversity assets, which will support the creation, restoration, retention and enhancement of biodiversity interests (Policy NE1). A policy seeks to take into account the longer-term relationship between trees and a development (Policy NE2). In addition, a site-by-site basis assessment will be required to consider the importance and contribution that existing non-protected landscape features make to the appearance of the locality (Policy NE2). New development will be required to consider the impact of, and impact upon, all types of flooding, along with a requirement to provide safe access/egress, attenuate surface water run-off, and locate development in least vulnerable areas of flood risk. All development will be required to incorporate sustainable drainage systems (Policy NE3). Renewable and Low Carbon Energy is supported subject to its impact on residential amenity, local wildlife/habitats, highway safety; and its setting (Policy NE4). New Community Facilities will be supported subject to access to sustainable transport links, vehicle access commensurate to the scale of development, impact on the local character, appearance and amenities, and access for people with disabilities (Policy CA1).
3.28 Making High Quality Places: Policies MP1 - 4 seek to ensure that Chelmsford is a high quality place to live and work by requiring all new development to meet the highest standards of built and urban design. This will require the use of masterplans by developers and CCC will implement design codes where appropriate for strategic scale developments. All development will be required to comply with the vehicle parking standards set out in the Essex Parking Standards - Design and Good Practice (2009), or as subsequently amended (Policy MP5). The city centre will be subject to pressure for tall buildings (6 storeys or more), and Policy MP6 provides criteria against which new proposals will be assessed. All new properties (residential and non-residential) shall allow for the provision for superfast broadband in order to allow connection to that network as and when it is made available (Policy MP7).
3.29 Making Places and Protecting Amenity: new development will be considered against its impact on neighbouring uses, and criteria is provided to consider this impact in terms of overlooking, overshadowing, pollution emissions etc (Policy PA1). Promoters of development will be required to fully assess the impact of development through appropriate assessments to include the impact upon the environment, air quality, and public health and safety (Policy PA2). The Council
8 has designated an Air Quality Management Area (AQMA) arising from road traffic emissions on the Army and Navy roundabout and surrounding roads.
Policy objectives
3.30 ECC aims to ensure that local policies and related strategies provide the greatest benefit to deliver a buoyant economy and great places for the existing and future population that live, work, visit and invest in Essex. As a result ECC is keen to understand, inform, support and help refine the formulation of the development strategy and policies delivered by Local Planning Authorities. Involvement is necessary and beneficial because of the ECC role as: a. a key partner within Greater Essex and Chelmsford City area, promoting economic development, regeneration, infrastructure delivery and new development throughout the County; b. the strategic highway and transport authority, including responsibility for the delivery of the Essex Local Transport Plan and as the local highway authority; c. the education authority; Minerals and Waste Planning Authority; Lead Local Flood Authority; lead advisors on Public Health and major provider of a wide range of local government services throughout the county of Essex; and d. an infrastructure partner, that will seek to ensure that the development allocations proposed are properly funded by the proposed development, realistic and do not place an unnecessary (or unacceptable) cost burden on ECC’s to deliver unfunded infrastructure.
3.31 The ECC response will seek to ensure the following ECC policy objectives are reflected in CCC’s emerging Draft Plan: Vision for Essex 2013-2017; ECC Outcomes Framework (2014); Economic Plan for Essex (2014); Essex Transport Strategy, the Local Transport Plan for Essex (June 2011); ECC Independent Living Programme; ECC Developers’ Guide to Infrastructure Contributions (2016); Essex Minerals Local Plan (2014); Replacement Essex and Southend-on-Sea Waste Local Plan (2016); Commissioning School Places in Essex 2016-2021; and Recommendations arising from the Essex Economic Commission.
4. Options
4.1 The ECC response to the Draft Plan identifies the additional infrastructure and service provision requirements arising from the proposed growth, including new primary and secondary school places and early years and childcare (EYC) provision; and amendments in certain areas to reflect ECC priorities, programmes and relevant evidence, and consistency with national planning policy. Specific requirements around education and EYC will be further addressed in the emerging CCC Infrastructure Delivery Plan (IDP). ECC will continue to work with CCC as it prepares its Pre-Submission Local Plan for consultation in Autumn 2017, particularly around infrastructure requirements and refinement of its Draft IDP to ensure a deliverable and viable plan. The full ECC response is set out in Appendix 1 and summarised below.
9 Duty to cooperate including strategic elements and policies of the Draft Plan
4.2 It is recommended that ECC continues to work collaboratively with CCC to progress the Draft Plan through to submission. This will include the undertaking of further transport modelling to identify appropriate junction mitigation (where possible), their cost and potential sources of funding. It is also recommended that ECC supports the strategic objectives contained in Chapter 3 (‘What are our Strategic Priorities?’ namely ensuring sustainable patterns of development; meeting the needs for new homes; fostering growth and investment and providing new jobs; protecting and enhancing retail, leisure and commercial development; delivering new and improved strategic infrastructure; delivering new and improved local infrastructure; protecting and enhancing important environmental and heritage assets; creating well designed and attractive places, and promoting healthy communities; and reinforcing Chelmsford’s regional role as ‘Capital of Essex’).
4.3 ECC has been consulted informally on several iterations of the Draft Plan before formal consultation commenced. The outcome is that many of ECC service area requirements have been incorporated into specific policies and supporting text. Specific infrastructure requirements regarding education (EYC, primary and secondary) have been identified and largely incorporated within the relevant Strategic Site, Growth Site, and Opportunity Site policies. ECC has also provided assessment of minerals safeguarding and preferred highway access on proposed allocations.
4.4 With regards highway matters ECC has undertaken a significant amount of modelling work including the transport impacts arising from the three spatial options in the `Issues and Options’ consultation (2015) and subsequent assessment of three alternative Spatial Options. Transport modelling of the proposed strategic sites in and around the administrative area, along with ‘non- strategic’ sites is being progressed to identify where mitigation is required at specific junctions, and how it can be funded and delivered. A summary note titled `Transport Impact of Local Plan Preferred Spatial Option Summary Note’ has been prepared by ECC to support the consultation.
4.5 ECC will continue to provide information to inform the evolving IDP. The IDP will need to support the Pre-Submission Plan, and identify the infrastructure required arising from the growth proposals. ECC will work with CCC to identify requirements arising from the growth proposals as the Draft Plan is reviewed following this round of public consultation. This relates to our role as a provider of key services and subject to statutory responsibilities, for example minerals and waste; highways, education (primary, secondary, and early years and childcare), flood and water management, public health and adult social care.
4.6 ECC will continue to be an active member of working groups to progress the Draft Plan to Submission. These include joint meetings with Highways England (HE); the Heart and Haven Transport Board; and ECC Community Infrastructure Group. In addition regular Local Plan / Duty to Cooperate meetings for wider ECC service requirements are held. Both authorities are active in responding to, and lobbying for strategic highway improvements necessary to deliver the housing required by Government (eg. England’s Road Investment Strategy (RIS): 2015 to 2020).
10 4.7 ECC supports reference in paragraphs 1.24 to 1.30 to the policy context provided by the Essex Minerals Local Plan (2014) and the Essex and Southend-on-Sea Waste Local Plan, as these form part of the development plan for CCC.
Strategic Priorities and North Essex Memorandum Co-operation
4.8 It is recommended that ECC confirms its support and involvement in the ‘Memorandum of Co-operation: Collaboration on Strategic Priorities in North and Central Essex’ (MOU) completed in 2016, which has been signed with North Essex Districts (Braintree, Colchester and Tendring), CCC and ECC. ECC acknowledges the close linkages between Chelmsford City and the North Essex Districts (Braintree, Colchester and Tendring), which form its Strategic Housing Market Area, and their collaborative work regarding identifying their Objectively Assessed Housing and Job Numbers over the period 2013-2036. ECC acknowledges reference in paragraph 2.18 to the MOU, Paragraph 2.14 refers to the North Essex Districts preparing a shared strategic plan, and acknowledging CCC is not being part of this process given their local plan preparation timetable. North Essex authorities (paragraph 3.1) will be publishing their Pre Submission Local Plans for consultation starting 12 June 2017. CCC has incorporated relevant aspects of Section 1 of the North Essex Districts Local Plans into their objectives, policies and allocations, and this is supported.
4.9 It is recommended that ECC generally supports the Strategic Priorities (SPs) for Chelmsford, which are aligned to the strategic objectives of the North Essex authorities. In order to address the adult social care requirements ECC recommend CCC to amend Policy SP2 to refer to Independent Living accommodation for older people (55+) and adults with a disability, and SP7 with regards heritage designations, including Scheduled Monuments.
The Spatial Strategy
4.10 It is recommended that ECC support Strategic Policy S9 which outlines the proposed spatial strategy, settlement hierarchy and key development locations post 2021 – 2036. It is also recommended that ECC supports focussing growth in, and adjacent, to the higher order settlements of Chelmsford and South Woodham Ferrers and Key Service Settlements outside of the Green Belt to maximise access to a range of key services and facilities. It is recommended that ECC supports the aim to maximise development, where appropriate, on brownfield land within the Chelmsford Urban Area, especially where their existing use is not being fully utilised. This will help regenerate those areas, improve the townscape, as well as, minimise the need to travel by car and encourage walking and cycling. ECC acknowledges that additional growth at greenfield communities, adjacent to the urban areas, is necessary, and these will help in maximise the delivery of, and/or financial contributions to future strategic infrastructure. In addition, these new communities will enable the use of the Green Wedges and Corridors to maximise opportunities for walking and cycling into the City Centre, and is supported.
4.11 The Draft Plan considered an alternative from the preferred Spatial Strategy by substituting North East Chelmsford (Location 4) with a new settlement east of the A12/north of the A414 (known as ‘Hammonds Farm’). ECC acknowledges that this has been discounted by CCC as it is not supported by the Plan evidence base including the Landscape Sensitivity and Capacity Assessment and Preferred
11 Options SEA/SA (paragraph 5.3.59). ECC notes the site is severed from central Chelmsford by the A12 Chelmsford Bypass, which is close to capacity and experiences congestion and delays to traffic. The growth proposed in this alternative spatial strategy, along with background growth in the plan period, requires a detailed assessment to be undertaken to ascertain the impact on the capacity of the junction 18 and A12 carriageway, along with possible mitigation options. ECC acknowledges that Park and Ride is a key strategy in managing the volume of longer distance journeys from outlying developments along congested corridor routes into the city centre. However an additional Park and Ride is likely to have an effect on the viability of the neighbouring Sandon site, Chelmer Valley and the potential additional two sites proposed in the Local Plan. Although the Hammonds Farm site is fairly close to the proposed new rail station at Beaulieu Park travel between the two would be via the A12 which, as explained above, currently experience congestion or by rat running though minor roads to the north of the site which would not be acceptable.
4.12 It is recommended that ECC supports the provision of existing housing commitments and some small scale housing development, alongside the new communities to enable a regular 5 year supply of housing. Development at North East Chelmsford and Great Leighs will be underpinned by Garden City principles. It is recommended that ECC supports the aim of the strategy to provide for mixed use development schemes.
4.13 ECC notes the identification of Special Policy Areas on the Proposals Map, and the need for policies to enable their specific functional and operational requirements.
Housing provision (and Specialist Housing)
4.14 It is recommended that ECC welcomes CCC’s work that seeks to meet the currently identified and agreed housing and other development needs in full over the plan period and the joint working of the local planning authorities across the Strategic Housing Market Area (Braintree; Colchester and Tendring). However, ECC acknowledge highway network constraints and in our role as Highway Authority will continue to provide the necessary assessments to determine impacts (including cross boundary impacts) and appropriate mitigation, funding and delivery measures.
4.15 It is recommended that ECC fully supports the aim of meeting the housing needs in full, namely 805 homes per year, along with providing an allocation of housing sites to provide some 20% flexibility in supply. Some 22,122 homes are to be provided between the period 2013-2036, of which some 10,875 new allocations will be allocated for post 2021. The five year housing supply up to 2021 will be met through existing allocations, and sites with planning permission. ECC acknowledges 805 homes per year will be used to calculate the rolling five-year housing land supply for the area. In addition, it is recommended that ECC welcomes the need to provide housing for a range of needs, including the Gypsy and Traveller community and independent living for older people (55+) and adults with a disability (and their necessary support services).
4.16 ECC acknowledges the provision of Gypsy Traveller and Travelling Showpeople requirements, which is consistent with the evidence contained in the Essex wide
12 Gypsy and Traveller Accommodation Assessment (2016, and its update). ECC notes that CCC is planning to meet its identified needs through a series of site- based locations at Strategic Growth Sites 2, 4, 5 and 8 and Growth Site TS1.
4.17 It is recommended that ECC supports the policy approach in seeking to provide for an appropriate mix of dwelling types and sizes that contribute to the future housing needs, as identified in the Strategic Housing Market Assessment (SHMA). This identified a projected increase in older people and subsequent demand for such specialist housing. Paragraph 8.8 of the Draft Plan refers to the need to consider the latest assessments of need for specialist residential accommodation (including independent living), and the commitment to work with ECC to identify the need, and secure its provision. It is recommended that ECC seek amendment to Policy HO1 (Section C, criteria ii) so that specific reference is made to Independent Living requirements as part of Specialist Residential Accommodation, which would assist when dealing with pre-application enquiries and planning applications for schemes with a residential element.
4.18 It is recommended that ECC supports Strategic Policy S10 – Delivering Housing Growth in terms of fully meeting the needs for market and affordable housing, maximising previously developed land in sustainable locations, providing a mix of size, type and tenure of housing, and ensuring that strategic sites follow a masterplanned approach supported by necessary infrastructure. It is acknowledged that CCC will need to demonstrate the deliverability of the Strategic Growth Areas, and its supporting infrastructure, in the Pre Submission Plan, and the supporting IDP. ECC supports a partnership approach between landowners, developers and infrastructure providers (including ECC service areas) in bringing the sites forward, and ensuring ECC needs and priorities are considered at an early stage. The proposed strategy by CCC to deliver and support this growth effectively and in a timely way is of particular importance to ECC as it will need to be satisfied that the impact of any planned scale and distribution of growth can be accommodated by ECC areas of responsibility, or be given the opportunity to identify what additional facilities or mitigation is required to make the strategy sustainable on social, economic and environmental grounds.
Economic growth
4.19 It is recommended that ECC supports Strategic Priority 3 – Fostering Economic Growth and investment and providing new jobs, and the aim of the Draft Plan to ensure a flexible rolling supply of employment land (paragraph 3.8, 6.48). ECC, together with its partners, will also implement the economic vision and objectives as outlined in the Economic Plan for Essex (2014) and any updated economic plan/strategy. The Economic Commission (January 2017) concluded there was a need to provide additional supply of suitable commercial space for offices in some districts, in order to provide opportunities to attract new business and facilitate the expansion of existing businesses. Consequently, it is recommended that ECC supports the roll forward of 40,000 sqm Office/Business at Beaulieu Park/Channels in the Draft Plan, along with additional allocations. These include a high quality new business park (45,000 sqm) in North East Chelmsford to provide accommodation for medium – large sized businesses and the new MedTech campus. Further, office space is allocated in the Chelmsford urban area (4,000 sqm), a High Tech Business Park at East of Chelmsford (5,000 sqm), and flexible business space at South Woodham Ferrers (1,000 sqm).
13 4.20 It is recommended that ECC welcomes the intention to retain existing employment space in principle (subject to compliance with NPPF) in the interests of promoting the local economy and sustainability. It is recommended that ECC supports reference to `sui generis’ uses as being appropriate uses in employment areas in Policy EM1, and supporting paragraphs 8.27 – 8.28. This will enable consideration to be given to waste management facilities in these areas, and is consistent with the `Areas of Search’ approach in the Essex and Southend on Sea Waste Local Plan.
4.21 It is recommended that ECC supports reference in paragraph 8.31 of the need to provide businesses with sufficient flexibility for them to function. ECC has undertaken a feasibility study (2016) to explore the need for employment ‘Grow- On Space’ within the County, which has been shared with CCC and concluded there was a lack of such available space. Whilst there is provision of incubation / start-up space in various forms across Essex, this work explains that once established these businesses have struggled to find suitable properties to move on from their incubation / enterprise centres / start-up spaces which also prevents businesses from freeing up the units for other potential start-ups.
4.22 The ‘Grow on Space Feasibility Study’, paragraph 6.25, concluded that due to the differences in characteristics and circumstances across Essex, there is not a single set way to resolve the grow-on space issue. The Study identifies a range of strategic options/interventions. The Essex Economic Commission also provides evidence of the inadequate supply for Grow-on Space, and that this is holding back successful businesses that want to expand and grow. ECC would therefore recommend a proportion of employment land allocations coming forward to be dedicated and protected for Grow-on Space businesses to provide one means to support the business economy of Chelmsford. ECC welcome the opportunity to engage with CCC in considering which interventions are the most appropriate and viable to ensure the Council provides flexible local employment space (such as flexible tenure) to meet the employment and economic needs of the District. This may lead to an amendment to Policy EM1 – Employment Areas and Strategic Policy S11 – Delivering Economic Growth moving forward.
Transport and Highways (including Sustainable Transport)
4.23 ECC, as Highways Authority, is undertaking considerable modelling of the Draft Plan, and its implications for the Chelmsford urban area, and the wider network. The outputs of this modelling will identify the mitigation required to facilitate the delivery of the proposed housing and employment growth. ECC, and its consultants, will continue to work closely with the City Council to ensure that this work is robust and that the outputs and mitigations identified are incorporated into the Pre-Submission Plan and its supporting Infrastructure Delivery Plan.
4.24 The policy of ECC is that housing growth should occur in conjunction with the development and delivery of appropriate infrastructure. It is therefore in the spirit of cooperation that we raise three issues which against this policy we believe need to be taken into account and require further consideration. Firstly, infrastructure projects such as CNEB were originally due for delivery in the current plan. Significant housing growth has already occurred and we must work together to create a scheme that can be delivered well within, rather than by the end of, the next planning period. Secondly, the totality of infrastructure investment required
14 will exceed the funding capacity of Essex and Chelmsford councils even allowing for significant developer contribution. Delivery of the schemes will require the attraction of government funding. Thirdly, the new Beaulieu Park station scheme is ultimately dependent on the prioritisation it is given by Network Rail. While the aspiration of delivery in 2022 remains, there are considerable numbers of planning and administrative processes still to be navigated.
4.25 Recognising the scope for increasing highway capacity is limited within the city centre core, the plan requires two key infrastructure developments:
Firstly, the creation of additional capacity to facilitate a reduction in the number of vehicles coming into the town. Hence, this is another reason why the Chelmsford North East Chelmsford Bypass, and enhanced junction 19 are both critical for the earliest possible delivery. It should also be noted that the widening should extend to junction 17. It should also be noted that the widening of the A12 between junction 17 and 19 should be developed in partnership with Highways England. Secondly, the plan requires significant modal shift and allows for investment in improved facilities for walking, cycling and bus use including park and ride. However, provision of these facilities is only one part of the story; plans to achieve behavioural and cultural change, particularly in relation to walking and cycling will be a further focus for cooperation.
4.26 ECC fully endorses the delivery of key infrastructure as set out in Policy S12 in order to enable sustainable delivery of the proposed growth, specifically the vital delivery of strategic infrastructure such as the Chelmsford North East Bypass and Beaulieu Park Railway Station. The CNEB, in conjunction with improvements to Boreham Interchange, is considered vital infrastructure to achieving the long term sustainable growth across Chelmsford, and wider afield, and a missing link in the strategic network. Paragraph 7.126 refers to the potential for a phased approach to delivery of the CNEB to provide suitable junctions to development opportunities in the locality, and this is being investigated through additional modelling currently being undertaken by ECC, and discussions with the North Essex Developers Consortium, in order that the route can be delivered as soon as practicable. It is recommended that ECC support the Safeguarded Route Corridor (SRC) for North East Bypass, which following consultation, will be identified on the Local Plan Policies/Proposals Map. The amended SRC does not change the alignment, but provides a safeguarded corridor to ensure the bypass can be built, connect to the local road network and provide land for environmental mitigation. In addition, the proposed safeguarded corridor identifies the land required for junctions, structures and other key highway features, such as local road diversions.
4.27 Transport Modelling undertaken to date suggests that improvements to key junctions and strategic highway interventions will need to be significantly supplemented by sustainable transport measures and a change in travel behaviour. ECC has recently undertaken public engagement upon its ‘Future Transport Network’ concept for Chelmsford (Table 9, page 79 of the Draft Plan). This seeks to minimise unnecessary vehicle trips into the central urban area based on an outer, mid and central zonal approach. Schemes are being identified through the Chelmsford City Growth Package and will be implemented by March 2020/21. In addition, this concept will require the emerging CCC car parking
15 strategy to fully align with this approach, and car parking at proposed allocations will need to consider the impact on citywide travel patterns.
4.28 ECC strongly advocates reference to providing new cycle routes within the new allocations, and to key destinations beyond. The existing cycle network provides connections between different parts of Chelmsford. There are significant improvements planned for the cycling network (subject to funding) through the £15 million Chelmsford City Growth Package and the Chelmsford Cycling Action Plan, which seek to assist an increased level of cycling to work for shorter journeys. It is recommended that ECC further supports the requirement for Strategic, Growth and Opportunity sites to maximise opportunities for sustainable transport modes including new/enhanced walking, cycling and public transport links in the locality or directly related to the development, footway improvements, bus priority measures, rapid transit measures, and dedicated car clubs for residents and businesses.
4.29 Park and Ride is a major component of the ‘Future Transport Network’ concept, and is a key strategy in managing the volume of longer-distance journeys from outlying developments along congested corridor routes into the city centre. The adopted Site Allocations DPD identified an ‘Area of Search’ around Widford for an additional site, which is crucial to support Chelmsford’s future transport network and the Draft Plan and was therefore supported by ECC. Further modelling is being progressed to consider the impact of the potential Park and Ride sites at West Chelmsford (A414 between London Road and Margaretting Road) and Boreham (off General’s Lane at J19 A12 Boreham Interchange). It is recommended that ECC supports the safeguarding of land at Strategic Growth Sites 3b and 4 for potential expansion of existing Park and Ride sites.
4.30 It is recommended that ECC supports the Spatial Principle of locating development at well-connected sustainable locations, and the policy references and requirements for sustainable transport in the Draft Plan. ECC welcomes reference in paragraph 1.32 requiring a Transport Assessment and Travel Plan to be submitted, where relevant, as part of the validation of planning applications process.
Infrastructure Requirements
4.31 It is recommended that ECC supports the identification of key infrastructure in Strategic Policy S12, which is considered necessary to support the needs arising from the development. ECC has provided some infrastructure requirements to inform the Draft Plan, and this will be modified/expanded following the consultation, and completion of additional on-going evidence base. This relates to our role as a provider of key services and subject to statutory responsibilities, for example minerals and waste; highways, education (primary, secondary, and EYC), flood and water management, public health and adult social care.
4.32 The Spatial Strategy will place increased pressure on existing infrastructure such as education. However, the spatial strategy enables the growth at locations, where spare capacity exists, and where new facilities can be secured, as opposed to locations requiring the transportation of pupils to the nearest school.
4.33 ECC supports the ambition to provide for the development needs in the plan area supported by necessary infrastructure. ECC welcome the proposed partnership
16 approach in plan preparation and the masterplanning of the Strategic and Growth Sites. ECC has provided information regarding education requirements to inform the emerging IDP. Further highway modelling work is on-going to inform necessary junction improvements. ECC support the proposed strategy of proposing development at locations, which will maximise developer contributions to necessary infrastructure. CCC has an adopted Community Infrastructure Levy (CIL), and has collected monies from completed development which has been pooled and will contribute towards key infrastructure delivery. CCC will commence a review of CIL informed by the infrastructure requirements necessary to deliver the emerging new Local Plan. ECC recommend consideration be given to the Strategic Growth/Growth Sites being allocated a ‘zero’ rate, where this enables infrastructure contributions from developers to be maximised. However, it is clear that a collaborative approach with partners (including ECC) will be necessary to lobby Central Government for additional funding on key strategic projects (ie CNEB/A12 improvements) if CCC is to deliver the ‘boost’ in housing required by Government. The Preferred Option is not the appropriate time to consider the ‘viability’ of the whole plan, as ongoing evidence work is being progressed and the spatial strategy may be amended following a review of consultation responses.
Primary, Secondary and EYC
4.34 The allocations in the Preferred Options Plan are likely to generate demand for up to 15fe (approx. 3,150 pupils) of primary school places and 14fe (approx. 2,100 pupils) secondary school places. These requirements may change as the Draft Plan progresses, and more detail is known regarding housing mix etc. These will generate the need for expansion of existing schools, where there is scope, to be funded through developer contributions or the Community Infrastructure Levy, and the need to provide new schools requiring developers to provide land for this use.
4.35 ECC has, and will continue to provide more detailed information on school provision as CCC refines its IDP in line with a final housing trajectory. Specific primary and secondary school infrastructure requirements have been identified, and largely incorporated within the relevant Strategic Site, Growth Site, and Opportunity Site policies, and are supported. Where new development triggers the need for land to accommodate a new school (or EYC facility) the developer will be required to undertake a Land Compliance Study (LCS) alongside their planning application, as set out in the ECC `Developer’s Guide’. Where new schools are required this council will be looking for school sites to be identified at the outset, and safeguarded.
4.36 Primary Education – in order to accommodate the pupil product arising from growth the following requirements have been identified by ECC, as Education Authority, namely a new primary school (2.1 ha) and developer contributions will be required in the Chelmsford Urban area on the Essex Police HQ (Policy 1b). additional developer contributions/CIL will be necessary to undertake expansion projects at existing schools in the Chelmsford urban area. a further 6 new primary schools (co-located with EYC facility) will be required at particular Strategic Growth sites at Broomfield (Site 6), NE Chelmsford x 2 (Site 4), West Chelmsford (Site 2), Great Leighs (Site 5) and South Woodham Ferrers (Site 8). Provision of these is likely to be necessary in the early phases of development.
17 4.37 Secondary Education – in order to accommodate the pupil product arising from growth the following requirements have been identified by ECC, as Education Authority, namely a new secondary school (8.6 ha) at North East Chelmsford, with land to enable future expansion, in addition to the facility already secured at Beaulieu Park. the remainder of the growth can largely be accommodated at existing secondary schools, which either have available capacity, can increase capacity through expansion projects, or through the review of existing catchment areas. growth at Great Leighs will be considered in conjunction with growth in the Braintree Local Plan, and it is expected this could be accommodated through a contribution to enable the expansion of Great Notley High School.
4.38 It is recommended that ECC support Strategic Growth Site 1d – Former St Peter’s College where the provision of two new special schools (D1 use), as part of the mixed use development is proposed. ECC supports the adopted Planning Brief for St Peter’s as the framework for the future development of the site. Whilst ECC in general supports new community provision, this should support and enhance, not compete with existing local facilities, and those currently on site.
4.39 Early Years and Childcare - in order to accommodate the demand for places the following requirements have been identified by ECC, and included in site specific policies where new primary schools have been identified on Strategic Sites it is recommended that they also provide a co-located 56 place early years and childcare facility. These are identified at Site 1b – Essex Policy HQ; Strategic Growth Site 2 – West Chelmsford; Strategic Growth Site 4 – North East Chelmsford (2 new schools); Strategic Growth Site 5 – Great Leighs; Strategic Growth Site 6 – North Broomfield; and Strategic Growth Site 8 – South Woodham Ferrers. within the Chelmsford Urban Area (approx. 2,000 new homes) there is limited available EYC places to meet the demand arising from growth. Paragraph 7.27 acknowledges a need to provide a further three stand-alone 56 place EYC nurseries in the Urban Area, but sites have not been allocated for these. It is recommended that ECC supports the reference to CCC working closely with ECC as proposals come forward to ensure facilities are provided to cater for the additional needs generated. This need may be required to be met either through new sites or expansion of existing facilities. outside of the Chelmsford Urban Area, a requirement has been identified to provide for an additional 5 EYC stand-alone facilities. These will be located at Strategic Growth Site 4 – North East Chelmsford (2 facilities); Strategic Growth Site 5 – Great Leighs; Strategic Growth Site 6 – North Broomfield (new 30 place facility); and Strategic Growth Site 8 – South Woodham Ferrers. An additional 2 stand-alone facilities will be required in the Chelmsford Urban Area at Strategic Growth Site 2 - West Chelmsford; and Strategic Growth Site 3b - Land north of Maldon Road, Great Baddow.
4.40 Some EYC provision is also generated by levels of local employment, although the actual demand depends on the specific employment use, its density, and hence the number of jobs generated. Local authorities are required to provide the provision of sufficient, sustainable and flexible childcare that is responsive to
18 parents’ needs. Consequently, it is important to provide a range of sites in areas where a lack of provision has been identified. Consequently, ECC welcomes the allocation of a new 56 place stand-alone facility at SGS 3b, adjacent to the Sandon Park and Ride, which is allocated as a high-tech office/business park. In addition, new facilities will also be provided in the Chelmsford Urban Area to meet the needs of planned development growth.
4.41 In addition, Policy GR1 – Growth in the Chelmsford Urban Area requires financial contributions towards early years, primary and secondary education. Other development sites, outside of the urban area will also be required to contribute to contributions for education provision, including Policy 3a, 3c, and these requirements will inform the IDP to support the Pre Submission Plan.
4.42 It is recommended that ECC welcome the proposed partnership approach in plan preparation and the masterplanning of the Strategic and Growth Sites. Further highway modelling work is ongoing to inform necessary junction improvements. ECC support the proposed strategy of proposing development at specified locations, which will maximise developer contributions to necessary infrastructure. CCC has an adopted Community Infrastructure Levy (CIL), and has collected monies from completed development, which has been pooled and will contribute towards key infrastructure delivery. CCC will commence a review of CIL informed by the infrastructure requirements necessary to deliver the emerging new Local Plan. However, it is clear that a collaborative approach with partners (including ECC) will be necessary to lobby Central Government for additional funding on key strategic projects (ie North East By Pass/A12 improvements), if CCC is to deliver the `boost’ in housing required by Government.
4.43 ECC has prepared an ‘exemplar’ policy with regards to developer contributions and CIL to ensure a consistent approach and framework for the delivery of relevant infrastructure from developers. This approach would bring together the individual policy requirements and support the provision of further supplementary planning documents and/or CIL Regulation 123 Charging Schedule. It is recommended that ECC seek a review to Policy S13 – Securing Infrastructure in the light of the `exemplar’ policy. CCC has commenced a review of its CIL, and is preparing a ‘Preliminary Draft Charging Schedule’ by the Autumn 2017 (Local Development Scheme 2016-2019), which will need to consider the infrastructure identified in the Plan. ECC recommend consideration be given to the Strategic Growth/Growth Sites being allocated a ‘zero’ rate, if this enables contributions from developers to be maximised.
Countryside
4.44 It is recommended that ECC supports the Spatial Principles, which seek to protect the Green Belt and the character of valued landscapes, heritage and biodiversity (Policy S1). These Spatial Principles are incorporated within Policy S14, which seeks to ensure the countryside, through a number of national and local designations, and for its own ‘intrinsic’ character, is protected from inappropriate development, is sensitive to change, but may provide some opportunity to provide for sustainable development. ECC is developing a Great Green Essex vision, which seeks to enhance the quality of place in terms of development and the scale and integrity of green space to make the County a great place to live and work. The Draft Plan includes a range of opportunities to inform the emerging vision
19 including the protection of the Green Belt, high-quality environment with recreational space , Green Flag accredited parks, complemented by an extensive network of Green Wedges, Green Corridors, gardens, new Country Parks and nature reserves. The Green Corridors follow the river corridors of the River Chelmer, Chelmer and Blackwater Navigation, and the River Can/Wid valleys outwards to the edge of the City administrative boundary, and provide a range of habitats and high level biodiversity sites. ECC welcome further discussion with CCC to see how accessibility to green spaces can be optimised, and to consider how the Green Corridors have the potential to link with other green networks beyond the administrative boundary. ECC will work with CCC to see how accessibility to green spaces can be optimised.
4.45 In addition, the Strategic/Growth Site allocations and policies require developers to improve and enhance public access into the Green Wedges, Green Corridors and provide opportunities for sustainable travel (cycling and walking) from the sites into City Centre services and facilities, along with contribute to the healthy living agenda.
Comments regarding Specific Development Sites
Overarching Comments
Mineral and Waste Consultation Areas
4.46 A number of the Strategic and Growth Locations in Table 11 are located within 250m of safeguarded operational or permitted minerals and/or waste developments. It is recommended that ECC advise CCC that future development proposed at these locations must have reference to the requirements of the Essex Minerals Local Plan (2014) (MLP) and Essex and Southend-on-Sea Replacement Waste Local Plan (examination hearings concluded in October 2016). ECC, as Mineral Planning Authority (MPA) and Waste Planning Authority (WPA), is required to be consulted on any development proposed within 250m of safeguarded sites. ECC will need to be consulted on the planned development at the following sites, in order to ensure their impact on existing operations can be considered or mitigated.
Mineral Sites Blackley Quarry – SGS 6a and 6b Bulls Lodge – SGS 4
Waste Sites Blackley Quarry – SGS 6a and 6b Bulls Lodge – SGS 4 Essex Regiment Way – SGS 4
Waste Management
4.47 ECC is the Waste Disposal Authority (WDA) responsible for the disposal of municipal waste in the Draft Plan area. Chelmsford City Council is the Waste Collection Authority and is responsible for the collection of this municipal waste. In 2008 the Essex Waste Partnership (consisting of ECC, the twelve district and
20 borough councils and the unitary authority of Southend-on-Sea Borough Council) adopted the Joint Municipal Waste Management Strategy (JMWMS) which sets out how the Partnership will tackle municipal waste over the period 2007 to 2032. Within the JMWMS there is the identification of an integrated network of new waste facilities needed to manage waste over this period. This includes provision of a small number of large processing and treatment facilities across the County. In order to minimise the transportation distances and its associated costs and environmental impacts a network of Waste Transfer Stations (WTS) was identified in the JMWMS.
4.48 ECC acknowledges that there is sufficient waste sites in the short term (first five years) to meet growth. This covers the ‘non-strategic sites’ that are not covered in the Waste Local Plan, prepared by ECC as the WDA. The Municipal Waste Strategy is in the process of being updated and ECC is in consultation with the Essex districts, including Chelmsford. The Strategy will review current sites (smaller waste facilities and recycling centres for household waste) and may result in changes to their location, rationalisation, and/or increased capacity. However, the new strategy has not yet been prepared or agreed with all parties. It is expected to be adopted after the first five years of the emerging Local Plan being adopted.
Flood risk, Drainage and Surface Water Management
4.49 ECC acknowledges that CCC has produced a Level 1 Strategic Flood Risk Assessment (February 2017), which takes account of the Environment Agency updated climate change guidance (February 2016). It is recommended that ECC supports the following reference in Strategic Site Policies and supporting text requiring the developer to consider ‘appropriate flood mitigation measures and SuDS’.
4.50 It is recommended that CCC ensure developers are engaged in pre-application discussions with ECC (in its role as Lead Local Flood Authority). ECC has assessed the Strategic, Growth and Opportunity Sites in the Draft Plan against the Surface Water Management Plan/Critical Drainage Areas, and the Environment Agency Risk of Surface Water Flooding Map, to identify the potential need to provide sustainable drainage systems to enable the disposal of surface water (see Appendix 2 of the CMA).
4.51 It is recommended that ECC supports reference to surface water management/SuDS in Policies NE3 – Flooding/SuDS; Policy S3 – Addressing Climate Change and Flood Risk and Policy S5 – Conserving and Enhancing the Historic Environment.
Strategic Growth Site 4 – North East Chelmsford
4.52 SGS 4 is located within a sand and gravel mineral safeguarding area, and is therefore subject to Policy S8 of the MLP. It is recommended that ECC welcomes the requirement for the development to provide a Minerals Resource Assessment (MRA).
4.53 It is recommended that ECC advise CCC that the allocated (largely with planning permission) and potential new development area at North East Chelmsford is
21 presently subject to two extant mineral permissions with a long-term programme for extraction. Any future development at North East Chelmsford in terms of its capacity and phasing will need to consider the timetable for mineral extraction at Bulls Lodge and Park Farm/Boreham Airfield under current permissions, and the process and timetable for the re-phasing of existing permissions with relevant mineral operators. The latter will also need to consider its impact on the route and delivery of the North East by-pass (as amended).
4.54 It is recommended that ECC supports Policy S10, bullet 2 which proposes that all strategic sites will be progressed through a masterplanned and landscape-led approach. ECC would require a MRA covering the new site allocation in order to confirm the coverage of mineral deposits, and whether prior extraction is viable.
Strategic Growth Site 5 – Moulsham Hall and North of Great Leighs
4.55 It is recommended that ECC supports reference to the need for a MRA to be undertaken. In addition ECC would require any new development to take account of the permitted minerals and waste development allocation at Blackley Quarry, as it is located within 100 m of the quarry, and thereby located within a Waste Consultation Area. ECC would seek to be included in any masterplanning process regarding mineral issues with respective landowners and promotors with interests in the Great Leighs proposed development. This is particularly important given that the quarry phasing arrangements will see the area located closest to the Great Leighs allocation completed after 2040, as permitted.
Strategic Growth Site 8 – North of South Woodham Ferrers
4.56 It is recommended that ECC supports the allocation at this location for mixed use including residential, flexible business space, and convenience retail. ECC supports reference in the policy regarding the need to provide a new primary school co-located with a 56 place EYC facility, and an additional stand-alone early years facility. ECC supports reference to ensure the new community integrates with the existing community, and new cycling and safe pedestrian routes are provided to existing community uses, including secondary education. Reference to specialist residential accommodation is supported, and in particular older persons and those with disabilities in paragraph 7.179. Given the requirement of the NPPF to significantly boost the supply of housing, It is recommended that ECC welcomes the approach to identify the appropriate quantum, extent of the site, and land uses through the new Draft Plan, rather than neighbourhood plan process. Further modelling is being progressed to consider the likely traffic impact on local junctions to the proposed development in order to identify appropriate mitigation.
Opportunity Site OS1c – Railway Sidings Brook Street
4.57 It is recommended that ECC advise CCC that this allocation is located immediately adjacent to the Brook Street Railway site, which is a safeguarded Chelmsford Rail Depot mineral transhipment site, and recognised as being of strategic importance by the MPA. Policy S9 – Safeguarding mineral transhipment sites and secondary processing facilities in the MLP requires the site ‘shall be safeguarded from development which would compromise their continued operation’. ECC would seek to ensure it is consulted upon any future development proposals which may compromise the operation of the transhipment site.
22 Policy SPA1 – Broomfield Hospital Special Policy Area
4.58 It is recommended that ECC supports the strategic objective in the Draft Plan to address the healthcare needs, and the commitment of CCC to work with partners in the NHS and local health partnerships to ensure the adequate provision of healthcare facilities to support the new and growing communities. The population of Chelmsford continues to grow and is predicted to increase by some 27,000 persons to 198,000 in 2036. The City Area is also expected to be characterised by an ageing population, with the population over 65 projected to increase by approximately 58% by 2037, which will place additional pressures on healthcare provision. Consequently, ECC supports the policy to enable the strategic planning of the Hospital site given its unique operational and functional requirements.
Comments regarding Draft Plan Policies
4.59 Policy CO2 – New Buildings and Structures in the Green Belt - It is recommended that ECC supports Section A, criteria iv and paragraph 8.49, which enables expansion of education premises as an exception to inappropriate development in the Green Belt, where an immediate local need can be demonstrated.
4.60 Policy CO3 – New Buildings and Structures in Green Wedges and Green Corridors – It is recommended that ECC seek an amendment to Section A, criterion ii, to provide clarification that education is a `local community facility’, which could be permitted in the Green Wedges/Corridors, where a local need can be demonstrated.
4.61 Policies HE1 – Designated Heritage Assets/HE2 – Non-Designated Heritage Assets/HE3 – Archaeology – It is recommended that ECC seek amendment to the Historic Environment policies to ensure compliance with the NPPF and welcomes further discussion to discuss the review of these policies to be included in the Pre Submission Plan.
4.62 Policy MP1 – Design and Place Shaping Principles – It is recommended that ECC supports the policy as it seeks to require all new development to meet the highest standards of built and urban design. New development will be progressed through the use of masterplans and design codes on strategic scale developments. It is recommended that ECC welcome the requirement for new development to minimise energy consumption and provide resilience to climate change.
4.63 It is recommended that ECC support principle 12, which seeks to provide opportunities to promote healthy living and to improve health and wellbeing. This is consistent with Strategic Priority 8, paragraph 3.34. It is recommended that ECC also supports reference to the Local Validation List requiring a Health Impact Assessment to be provided with planning applications.
4.64 Whilst the Draft Plan does not include an explicit policy on health and wellbeing within the main body of the plan it does make numerous references to health and wellbeing, and the promotion of healthy lifestyles, which is supported. Some of these include promoting mixed use schemes; adoption of Garden City Principles at NE Chelmsford and Great Leighs; proposed improvements to public transport and walking and cycling (including through Green Corridors and Wedges), as well as
23 the protection of existing green infrastructure including open space and recreational facilities and new provision.
4.65 It is recommended that ECC seek reference to the most up-to date health profiles from Essex Insight and Public Health England (2016) - Chelmsford - Health Profile, to supplement the CCC Public Health Strategy (2012). These health profiles present a set of health indicators that show how the area compares to the national average, and are updated annually.
4.66 It is recommended that CCC consider the ten principles promoted by Sport England and Public Health England in the publication - Active Design principles; Planning for health and wellbeing through sport and physical activity”, which include walking communities, connected walking and cycling routes, co-location of community facilities, network of multifunctional open space, high quality streets/spaces, appropriate infrastructure, and active buildings.
4.67 Policy MP5 – Parking Standards – It is recommended that ECC welcomes reference to the need for all development to comply with the ‘Essex Parking Standards – Design and Good Practice (2009), or as subsequently amended. Paragraph 9.27 recognises that urban locations with high levels of public transport accessibility will be required to minimise pressure on land and encourage alternative modes of transport, and hence may be supported for relaxed parking standards, which is consistent with recommendations in the White Paper (2017). Such an approach is consistent with the need to supplement improvements to key junctions and strategic highway interventions with sustainable transport measures, particularly in the city centre, and a change in travel behaviour. ECC is seeking to implement this requirement through its ‘Future Transport Network Strategy’ for Chelmsford and Chelmsford Growth Package, which needs to balance minimising unnecessary trips into urban Chelmsford, with the emerging CCC car parking strategy, and proposed car parking at proposed allocations.
4.68 Policy MP7 – Provision of Broadband – It is recommended that ECC welcomes a specific policy regarding the provision of broadband, in particular the clear requirement for all new development (residential and non-residential) to allow for the connection to superfast broadband.
4.69 It is recommended that ECC seek amendments to paragraphs 9.33, 9.34 and 9.35 of the Draft Plan to strengthen the requirement on developers to engage with network operators; require connection now, and to acknowledge there are other network providers to British Telecom.
5. The following documents have been used to inform the ECC response (web-links provided).
Chelmsford Draft Local Plan - Preferred Options Consultation Document, March 2017. Our Planning Strategy to 2036 Chelmsford Draft Local Plan Sustainability Appraisal Report Habitats Regulation Assessment Transport Impact of Local Plan Spatial Options, March 2017 National Planning Policy Framework (2012) Planning Policy Guidance (2014) Vision for Essex 2013-2017
24 ECC Outcomes Framework, Sustainable Economic Growth for Essex Communities and Businesses (Commissioning Strategy) (2014) Economic Plan for Essex (2014) Essex Transport Strategy, the Local Transport Plan for Essex (June 2011) Super Fast Essex Broadband ECC Developers’ Guide to Infrastructure Contributions ECC SuDS Design Guide ECC Independent Living Position Statement, September 2016
6. Issues for consideration
6.1 Financial implications:
6.1.1 There are no direct financial implications in respect of ECC’s response to the consultation.
6.2 Legal implications:
6.2.1 The duty to co-operate is contained in the Planning and Compulsory Purchase Act 2004, as amended by the Localism Act 2011. It requires Local Planning Authorities to engage constructively, actively and on an on-going basis to ensure that the preparation of the Local Plan has regard to key strategic matters addressing social, environmental and economic issues which can only be addressed by effectively working with other authorities beyond their own administrative boundaries.
6.2.2 Guidance issued on 6 March 2014 stresses that close cooperation between District Councils and County Councils in two tier areas will be critical to ensure that both tiers are effective when planning for strategic matters.
6.2.3 As recorded in section 4.9, ECC entered into a relevant MOU to ensure this took place.
6.2.4 Although a Local Plan may be found unsound at Examination if the duty to co- operate has not been properly undertaken and the implications of this require careful consideration, the duty is not a duty to reach agreement. ECC is carrying out its functions properly in submitting comments on specific issues of concern or objection, where necessary, at this stage.
7. Equality and Diversity implications
7.1 The Public Sector Equality Duty applies to ECC when it makes decisions. The duty requires us to have regard to the need to: a. Eliminate unlawful discrimination, harassment and victimisation and other behaviour prohibited by the Act. In summary, the Act makes discrimination etc on the grounds of a protected characteristic unlawful b. Advance equality of opportunity between people who share a protected characteristic and those who do not c. Foster good relations between people who share a protected characteristic and those who do not, including tackling prejudice and promoting understanding.
25 7.2 The protected characteristics are age, disability, gender reassignment, pregnancy and maternity, marriage and civil partnership, race, religion or belief, gender, and sexual orientation. The Act states that ‘marriage and civil partnership’ is not a relevant protected characteristic for (b) or (c) although it is relevant for (a).
7.3 An Equality Impact Assessment has been undertaken by CCC to inform the new Local Plan. It concluded that the Local Plan has no negative impacts and there is a low risk of negative impact on the affected groups. Impacts will continue to be monitored and if particular issues are identified, appropriate action will be taken. This could include changes to their consultation approach and activities. It is considered that all opportunities will be taken to advance equality through the Local Plan.
8. List of appendices
8.1 Appendix 1 – full proposed ECC response to the Chelmsford Local Plan – Preferred Options Consultation Document, March 2017.
8.2 Appendix 2 – assessment of the Strategic, Growth and Opportunity Sites in the Plan against the Surface Water Management Plan/Critical Drainage Areas, and the Environment Agency Risk of Surface Water Flooding Map, to identify the potential need to provide sustainable drainage systems to enable the disposal of surface water.
9. List of Background papers
None
I approve the above recommendations set out above for the reasons set out in the report. 18th May 2017
Councillor Cllr David Finch, Leader of the Council
In consultation with:
Role Date Executive Director for Corporate and Customer Services (S151 18th May 2017 Officer)
Nicole Wood Director for Financial Services on behalf of
Margaret Lee Monitoring Officer 16th May 2017 Paul Turner
Paul Turner, Director Legal and Assurance Executive Director, Economy, Localities and Public Health 10th May 2017
Dominic Collins, Director of Economic Growth and Localities on behalf of
Mark Carroll
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