Memorandum by Gillian Williamson, Chairman
of the Uttlesford Group of the Council for the Protection of Rural
England (CPRE) (SHC 56)
1. SUMMARY OF
OUR POSITION
1.1 We support the responses of the Council
for the Protection of Rural England and the Council for the Protection
of Rural Essex.
1.2 We do not consider that the proposals
for large-scale housing development in or near Uttlesford are
sustainable within the terms of the Government's own policies
and guidance contained in PPG's 1, 3, 7 and 13. In particular,
it would entail the destruction in perpetuity of large areas of
countryside.
1.3 We do not consider that the proposal
for a large, effectively new, settlement in or near Uttlesford
would be likely to reduce house prices in the south east of England
or Uttlesford significantly nor that it would make a contribution
to the sustainable solution of the problems of affordable housing
for low-income households, especially those in the London area.
1.4 We do not consider that there is a mechanism
by which local planning authorities can ensure an adequate supply
of affordable housing even for the needs of the local population.
This is exacerbated by relatively high market prices in areas
such as Uttlesford.
2. THE CHARACTER
AND QUALITY
OF THE
ENVIRONMENT IN
UTTLESFORD
2.1 Uttlesford is the district council area
within which Stansted Airport falls. It also forms part of the
"Cambridge/Stansted corridor". It is geographically
large, covering approximately 64,000ha, and situated some 40 miles
to the north of London and 15 miles south of Cambridge.
The population is relatively low, at something
over 70,000. The largest settlement is Saffron Walden with a population
of only 15,200. This is an attractive historic market town catering
for the daily needs of surrounding residents but without, for
example, large-scale retail or leisure facilities. The mediaeval
street lay-out constrains development and leads to considerable
traffic problems even at its current size. The only other settlements
with any of the features of urban development are Great Dunmow
(population 6,700) and Stansted Mountfitchet (5,750).1
The remaining 60% of the district population
is scattered thinly throughout 54 administrative parishes, many
in isolated dwellings or small hamlets. Built development is similarly
scattered: 40% of the district has a density of 25 buildings or
lower per square mile.2 The district is therefore characterised
by pleasant rolling countryside typically in agricultural use.
2.2 While there is "space" within
Uttlesford, it is countryside and valuable as a resource "for
its own sake" (PPG7). Government planning advice and the
Essex Structure Plan and Uttlesford District Plan rightly seek
to protect this resource against unsuitable and unsustainable
development. We consider that it is already developed to the limits
of its capacity and that the proposed scale of housing development
would be out of all proportion to existing population, settlements
and infrastructure.
3. AVAILABILITY
OF SITES
CONFORMING TO
GOVERNMENT ADVICE
ON SUSTAINABLE
DEVELOPMENT IN
PPGS 1, 3 AND
13
3.1 The rural nature of the district and
the small scale of its towns means that there is little brownfield
land available for redevelopment. Such brownfield sites as do
exist are generally small and widely scattered. Many do not "qualify"
for residential development under PPG3 as they are agricultural
and therefore specifically, and in our opinion rightly, excluded
under Annex C.
3.2 The total area of land in employment
use in the two largest settlements, Saffron Walden and Great Dunmow,
is 46.76ha with a further 17.36ha planned by 2011.3 Even if all
this were redeveloped for housing at the highest density suggested
in PPG3, there would only be the capacity for fewer than 4,000
units. This would, of course, entail the destruction of almost
the entire local employment base, with all the consequences for
traffic generation etc.
3.3 Any large-scale development in Uttlesford
would therefore have to take place on greenfield land in direct
conflict with the Governments' advice in PPG's 3 and 7. It would
undermine the aim of regenerating brownfield sites elsewhere in
economically disadvantaged areas of the south east and London;
increase long-distance commuting and destroy for ever a large
area of open countryside.
3.4 Apart from the M11 and main line rail
services (see 5. below), public transport links within the district
are poor, centred on the few larger settlements, with little choice
of destination and almost no off-peak services. Furthermore, the
rail line is "shared" with the Stansted Express service
to the airport. It can probably be regarded as already running
close to capacity in terms of points, crossings etc.
The road network is dominated by minor routes
which already suffer from rat-running and speeding.
The district is not therefore a sustainable
location in transport and access terms for large-scale development.
4. HOUSING NEED
IN UTTLESFORD
4.1 Following Uttlesford District Council's
urban capacity study, the revised deposit draft of the Uttlesford
Local Plan (Oct. 2002) makes provision for some 4,620 dwellings
over the period 2000-11, in line with Structure Plan requirements.
Of these, some 70% are in urban extensions and two major settlement
expansions. We consider that government advice has been properly
followed as closely as possible given the scale of the requirement
in a rural district with the constraints identified in 2 and 3
above.
4.2 There is a very sizeable need identified
by Uttlesford District Council for affordable housing within the
district to meet local need: 2,880 units 2000-11, over 60% of
the total housing allocation.
New-build houses tend to be more expensive than
those on the "secondhand" market and are therefore unlikely
to meet the local affordable need in the District.4
4.3 The commercial pressure on developers
in an area of high market prices is to provide low-density "executive"
homes. The planning system makes it extremely difficult, if not
impossible, for the local planning authority to ensure the provision
of an adequate supply of affordable housing in such a district.
5. ECONOMIC POSITION
OF UTTLESFORD
5.1 Uttlesford is a prosperous area. The
1991 census showed 55% of the population to be economically active.
Unemployment is exceptionally low at 0.7%.5 Household incomes,
car ownership etc are higher than average. There is already a
"significant" level of out-commuting to work,6 primarily
to London but also towards Cambridge, facilitated by the M11 and
rail services on the Cambridge to London Liverpool Street main-line.
There is no need for economic regeneration in the area.
5.2 Distance from London, the cost of rail
travel and poor off-peak services (journey time is around one
hour and an annual second class season ticket costs over £3,000
from Audley End station, for example) will make the district unattractive
to low-paid workers in the London area, especially those working
outside 9 am to 5pm, even if affordable housing can be delivered.
5.3 Increased use of the M11 for commuting
would run counter to the Government's aims of reducing travel
by private car (PPG13) and add to existing congestion problems
in London and the south east.
5.4 Stansted Airport is indirectly the district's
largest employer. There is no evidence, however, that any constraints
in the local housing market are restricting airport employers'
ability to hire staff.7
6. THE ROLE
OF THE
LOCAL PLANNING
AUTHORITY
6.1 We believe that the district council
is right to resist development pressure within the countryside;
to seek to protect this resource for its own sake, and to contain
residential development to the housing allocation figures within
the constraints of urban capacity and Government advice.
6.2 It is not possible within the existing
planning structure to ensure delivery of the affordable housing
already identified as needed by the local population. There is
therefore a continued drift towards lower density, high priced
private sector housing on such sites as are sustainable for residential
development.
6.3 We strongly believe that any proposed
expansion must take full account of local considerations and concerns.
Gillian Williamson
18 November 2002
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