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Harlow Local Development Plan Examination Matter 4: Strategic Housing Site East of Harlow Epping Forest District Council Hearing Statement

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Harlow Local Development Plan Examination Matter 4: Strategic Housing Site East of Harlow Epping Forest District Council Hearing Statement HARLOW LOCAL DEVELOPMENT PLAN EXAMINATION MATTER 4: STRATEGIC HOUSING SITE EAST OF HARLOW HEARING STATEMENT ON BEHALF OF EPPING FOREST DISTRICT COUNCIL MARCH 2019 Harlow Local Development Plan Examination Matter 4: Strategic Housing Site East of Harlow Epping Forest District Council Hearing Statement INTRODUCTION 1. Epping Forest District Council ("EFDC") submits this statement in response to the Inspector's Matters and Questions. 2. This statement concerns Matter 4: Strategic Housing Site East of Harlow and EFDC's responses are limited to addressing the Inspector's Questions 4.3, 4.5, 4.6, 4.7, 4.8, 4.10 and 4.11. 3. It is important to note that EFDC did not make Regulation 20 representations at the publication stage and does not object to the HLDP, or seek any changes to the version of the HLDP submitted to the Secretary of State for independent examination. 4. To a very large extent, EFDC has addressed these matters within its Hearing Statement for the Epping Forest District Local Plan ("EFDLP") Examination and/or through the ongoing discussions with Essex County Council (“ECC”) relating to a Statement of Common Ground (“SOCG”). 5. All documents referred to in this statement are listed in Appendix A of this statement together with links to the relevant document included within the Examination Library. 6. Attached to this statement (at Appendix B) are the relevant Hearing Statements prepared for the EFDLP Examination, as follows: • Matter 1: Legal Compliance • Matter 4: The Spatial Strategy / Distribution of Development • Matter 8: Garden Town Communities 7. Wherever possible, HLDP Examination Library document references are used throughout this statement for consistency and convenience. Alternatively, EFDLP Examination document reference are provided and weblinks are included within Appendix A to this statement, Harlow Local Development Plan Examination Matter 4: Strategic Housing Site East of Harlow Epping Forest District Council Hearing Statement Inspector's Question 4.3 Is the allocation effectively part of a single proposal with the allocation for 750 dwellings in Epping Forest District? Have the Councils been co-operating effectively to plan and co-ordinate the delivery of the whole site? Are the main elements of the development clear, including the elements required in Harlow as opposed to Epping Forest? Is a single masterplan required for the whole site? Response to Question 4.3 8. EFDC and Harlow District Council ("HDC") have worked together to ensure complementary proposals for the East of Harlow area. A Memorandum of Understanding ("MoU") has been prepared and signed by Epping Forest, Harlow, East Hertfordshire and Uttlesford District Councils about the distribution of housing across the West Essex/East Hertfordshire Housing Market Area (HEBDTC1). 9. A Garden Town Developer Forum has been established that meets regularly with the promotors and developers of the Garden Town strategic sites. There also have been ongoing Duty to Co-operate discussions at Officer and Member level, including through the Co-operation for Sustainable Development Member Board and, subsequently, the Garden Town Member Board, to consider cross-boundary issues; both Princess Alexander Hospital Trust ("PAHT") and Essex County Council ("ECC") have been party to these to ensure a consistent approach to infrastructure delivery. 10. The requirements contained within HLDP Policy HS3 only relate to the allocation site HS3 as shown on the HLDP Policies Map. The requirements contained within Part H of EFDCLP Policy SP 5 relate to Site Allocation SP 5.2, forming part of the area of the East of Harlow Masterplan Site and situated within the administrative boundary of Epping Forest District. The only exception to this is the requirement for the relocation of the hospital site and the proposed secondary school, which is contained within HDC Policy HS3 to ensure the delivery of these key pieces of infrastructure. However, the location and provision of the hospital and secondary school sites will be determined through the Strategic Masterplanning work and, therefore, may be located in either Harlow or Epping Forest District. 11. As stated within the EFDCLP hearing statements, EFDC and HDC have worked together through the Garden Town Delivery workstream to consider and establish an appropriate approach for bringing forward plans for the EFDLP SP 5.3 East of Harlow site allocation,1 including having one strategic Masterplan. A report to EFDC Cabinet 1 See Part A. of EFDLP Policy SP 5 Harlow Local Development Plan Examination Matter 4: Strategic Housing Site East of Harlow Epping Forest District Council Hearing Statement on 18 October 2018 (EFDLP Examination Library ref: EB133) states (at paragraph 28) that: “… at the site specific level, aligning a consistent approach across each local authority area is particularly important. From an EFDC perspective this is vital to shape the delivery of the East of Harlow site, where a single Masterplan will straddle both Harlow and EFDC’s administrative boundary. A report considering the approach to the determination of planning applications on the East of Harlow site was taken to the Garden Town Member Board on 18 June 2018 (see Appendix 3), and concluded that it would be preferable for two separate (but otherwise identical) planning applications to be submitted to each respective local authority. It is therefore important that the Strategic Masterplan is given equal status and weight in each authority area to enable planning decisions to be made that are consistent”. This approach was agreed by Epping Forest District Members. 12. The Harlow and Gilston Garden Town Vision (HEBGT2) and the Harlow and Gilston Garden Town Design Guide (HEBGT3) provide a consistent overarching basis for planning the HDC HS3 and EFDLP SP 5.3 East of Harlow site across administrative boundaries. Pages 26 and 28 of the Vision and page 46 of the Design Guide confirm the collaborative working that has taken place between the three District Councils (Epping Forest, Harlow and East Herts) in the preparation of the Vision and Design Guide, along with more detailed guidance and delivery of the Garden Town. 13. A joint Statement of Common Ground ("SoCG") has been agreed between EFDC, HDC and Miller Homes (Appendix C), who are promoting the majority of the East of Harlow strategic site within the administrative boundaries of both Epping Forest and Harlow Districts. This confirms that Miller Homes have been engaged in ongoing dialogue and discussions with EFDC, HDC and ECC, along with other stakeholders in relation to the future delivery of this cross-boundary strategic site. Inspector's Question 4.5 Is the Access Route for Strategic Housing Site East of Harlow in Policy SIR1 necessary and justified? How would it be delivered? Would there be any adverse effects? How does the development relate to the new M11 Junction 7a? Response to Question 4.5 14. Part C (ix) of EFDLP Policy SP 4 states that: "Each Garden Town Community must … ensure that on-site and off-site infrastructure is provided in a timely manner, subject to viability considerations, ahead of or in tandem with the development it supports to mitigate any impacts of the new Garden Communities, meet the needs of residents and 4 Harlow Local Development Plan Examination Matter 4: Strategic Housing Site East of Harlow Epping Forest District Council Hearing Statement establish sustainable travel patterns". However, EFDC is proposing an amendment to insert following text after paragraph 2.117 of the EFDLP to ensure that this position is further clarified within the Plan: "The growth plans for the Garden Town require the implementation of a new junction (Junction 7A) on the M11. This new junction is planned to be operational by 2023, prior to the occupation of the strategic developments. In order to maximise the promotion of use of sustainable transport measures, it will be necessary for key elements of sustainable transport provision to be available when new developments are first occupied. This will be required in order to prevent the establishment of unsustainable travel behaviour, and to provide viable alternatives to private car use. The Council will secure the necessary measures through the use of planning obligations or other relevant mechanisms as appropriate." 15. The highway and transport improvements required to support the development of the East of Harlow Strategic site will comprise a combination of physical works and financial contributions, and EFDC considers that EFDLP Policies SP 4 and SP 5 make this sufficiently clear. 16. Contributions will be sought for off-site highway and transport works which are to be, or are being, provided by Essex County Council as the Local Highway Authority, or by Highways England as the statutory body with responsibility for the Strategic Road Network (SRN). The improvements expected are set out in the EFDC IDP (EFDLP Examination Library ref: EB1101B). Section 8.4 of the EFDC IDP (pp 21-22) provides details of the works and / or financial contributions required strategically to support growth across the Garden Town. Sections 8.5 – 8.8 (pp 23-33) provide details of the works and / or financial contributions required to support each of the planned Garden Town Communities. 17. Part C of EFDLP Policy SP 5 specifies the requirement for infrastructure to be delivered at a rate and scale to meet the needs arising from the proposed development, in accordance with the EFDC IDP with proportionate contributions for the delivery of improvements to M11 Junction 7 and other strategic infrastructure requirements. The Policy also sets out the highway and transport improvements that are required from each of the Garden Town Communities strategic site allocations (see SP 5.1, SP 5.2 and SP 5 3). 18. The delivery of M11 Junction 7a is already fully funded and is not therefore dependent on financial contributions from the development of site allocations within the EFDLP. Further details are provided in section 5.1.5 of the EFDC IDP (p 24) (EFDLP Examination Library ref: EB1101A) and Reference DW3 of the IDP Schedule (p 17) (EFDLP Examination Library ref: EB1101B).
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