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Appendix 1

Chelmsford City Council’s response to Uttlesford District Council Regulation 19 Pre-Submission Local Plan

Chelmsford City Council (CCC) welcomes the opportunity to comment on the Uttlesford District Council (UDC) Regulation 19 Pre-submission Local Plan prior to its submission to the Secretary of State for examination.

Officers at CCC have been working collaboratively with UDC through the Duty to Co-operate as outlined in paragraph 1.4 of the Pre-Submission document. CCC has responded to consultations on previous versions of the Uttlesford Local Plan including the Draft Local Plan in 2017.

CCC has the following comments on the consultation documents:

Duty to Co-operate

UDC and CCC have engaged on strategic cross boundary matters. For example, CCC is a Member of the Co-operation for Sustainable Development Officer Board which is co- ordinating joint working on strategic planning issues within the West and East Housing Market Area (HMA). A Protocol for dealing with unmet housing needs requests has also been agreed between Essex Local Planning Authorities through the Essex Planning Officers’ Association which has resulted in an effective joint mechanism being put in place. Furthermore, both Councils have also been involved in a joint the Gypsy, Traveller & Traveller Showpeople Accommodation Assessment with relevant other Essex Local Planning Authorities. CCC do not raise objections under Duty to Co-operate and will continue to work with UDC through the Duty to Co-operate.

Housing Market Area

The Local Plan sets out that Uttlesford lies within the West Essex and Housing Market Area (HMA). Whilst Uttlesford District is also part of two other sub-market housing areas (the sub-market area in the north and the Chelmsford sub-market area in the south-east) the Local Plan states that the Strategic Housing Market Assessment (SHMA) 2015 has concluded that this represents the most appropriate 'best fit' for Uttlesford. CCC supports the extent of the Housing Market Area (HMA).

Housing

The Local Plan sets out a housing requirement figure of at least 14,000 over the Plan period of 2011 to 2033. This is based on household projections published in July 2016 and includes a market signals uplift and adjustment to take into account the need for growth in communal residential establishments, such as care homes.

It is noted that UDC proposes to meet its own housing need within its administrative boundaries and has not approached neighbouring authorities under the Duty to Co-operate to request other authorities help accommodate any unmet needs.

Is it also noted that the 2016 Gypsy and Traveller Accommodation Assessment (GTAA) identified that there is no need for any additional pitches and, that this will be kept under review and any need that arises during the Local Plan period will be considered against a criteria based policy, or if it proves necessary in the future, through the preparation of a specific site allocations Local Plan.

Overall CCC is supportive of this approach in the UDC Local Plan and do not raise any objections under soundness or legal compliance.

Employment

The Functional Economic Market Area (FEMA) for Uttlesford is the same as the Housing Market Area. Policy SP4 makes provision for a minimum net increase of 14,000 jobs in the period 2011-2033 to maintain a broad balance between homes and jobs and to maintain a diverse economic base. Of these, the majority will be in non-B use class uses such as retail, education and other services. The B use class jobs (offices, industrial and warehouses) will provide around 10% of the overall jobs growth in the District over the Local Plan Period. The Local Plan allocates additional employment land at key locations as an integral part of garden communities and other areas of housing growth. The existing Employment Areas of North Stansted and Chesterford Research Park will also be expanded. In addition, other policies in the Local Plan seek to safeguard existing employment land and provide for a mix and range of employment sites.

Overall CCC is supportive of this approach in the UDC Local Plan and do not raise any objections under soundness or legal compliance.

The Spatial Strategy

The Spatial Strategy primarily focuses growth within three new garden communities (North Uttlesford, Easton Park and West of Braintree) together with some additional growth in existing communities including the District’s two main towns market towns ( and ) together with more limited growth on sites in larger villages (including and in proximity to Chelmsford City Council’s administrative area).

The Local Plan states that the West of Braintree garden community will deliver a minimum of 970 homes to the housing supply of Uttlesford District by 2033. It is noted that the Inspector’s Report into the North Essex Authorities Strategic (Section 1) Plan concludes that the document requires significant further work in order for it to be made sound and legally- compliant. As such, although CCC support the Spatial Strategy, UDC will need to be satisfied that this specific allocation is deliverable.

Relevant Site Allocations

Policy SP3 identifies the locations at which new development will be located. For Chelmsford, sites of interest are the Garden Communities of Easton Park and West of Braintree, Great Dummow, Felsted and . Policy SP5 sets out that Development Plan Documents will be prepared for each Garden Community. The Development Plan Document (DPD) will provided further detail and be a site-specific document for each garden community.

Easton Park (Policy SP6) comprises 10,000 new dwellings, of which a minimum of 1,925 homes will be built by 2033. It is noted the aspiration to achieve significant use of sustainable transport, with trips by active modes and public transport making up 60% of all trips. The DPD would include policies/measures for achieving this. CCC is supportive of this approach and would wish to continue engage in the process as the DPD is developed.

West of Braintree (Policy SP8) - this garden community straddles the District boundary with Council and will comprise 10,500-13,500 new dwellings. Of which 3,500 will be located in Uttlesford with a minimum of 970 homes contributing to the housing supply in Uttlesford District by 2033. The policy includes a requirement for the early delivery phase of the garden community incorporate a package of measures to provide transport choice. Overall this allocation is supported by CCC especially due to the proximity of the A120 and transport infrastructure to Braintree and links with Chelmsford. CCC would wish to be engaged in the process and the DPD supporting the site allocation is developed. However, as stated above, in view of the findings of the Inspector’s Report into the North Essex Authorities Strategic (Section 1) Plan, UDC will need to be satisfied that this specific allocation is deliverable.

Around 750 dwellings will be provided on new Local Plan allocations in Great Dunmow and around 130 dwellings are allocated on smaller villages including Felsted and Little Dunmow. CCC is supportive of these site allocations.

Paragraph 3.143 Policy SP11 makes provision for Stansted Airport to respond positively to future growth opportunities and continue to make significant sub regional and national contributions to economic development, jobs and wealth creation while setting a clear environment and transport framework with which to regulate future growth. The North Stansted Employment Area is included within the Strategic Allocation for a range of Use Class B employment development. CCC is supportive of this approach.

Transport

The Local Plan acknowledges that transport is a key issue in the District with above average long distance car commuting and impacts on strategic and local transport infrastructure. Paragraph 7.11 states that the Transport Study concludes the new garden communities have the least traffic impact, the best accessibility and have the most potential for sustainable transport compared with other alternatives. It notes that the impact on the Strategic Road Network, including that outside the District, is considered including the need for a proportionate approach to improvements. The Local Plan states it will ensure that developments that generate significant movement such as the new garden communities are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised. Policy TA2 – Sustainable Transport encourages sustainable transport to promote accessibility and integration into the wide community and existing network.

CCC is supportive of this approach and do not raise any objections under soundness or legal compliance.