Memorandum submitted by Stop Harlow North
The Stop Harlow North campaign welcomes the
Committee's invitation to submit memoranda setting out our views
on the new Five Year Action Plan, Sustainable Communities: Homes
for All, published by ODPM in January 2005.
The draft East of England Plan (the Plan), which
is supposedly based on the principles of sustainable development,
includes specific references to development north of the Stort
and west of the M11 as an urban extension to the north of Harlow
of at least 10,000 dwellings. We are fundamentally opposed to
building north of the Stort and west of the M11 in the "heartland
of East Herts". Proposals to build in this area have been
rejected twice before through democratic planning processes (Hertfordshire
Structure Plan and SERPLAN).
The aim of the draft Plan to improve "the
quality of life for all" is, in fact, subjugated in the Plan
to growth aspirations that will seriously damage the environment
and the quality of life for a significant proportion of the residents
of the region.
The Sustainability Appraisal (SA) of the Plan
states, page 4 bullet point 3, "EERA (East of England Regional
Assembly) sought clarification of the basis for its figure of
200,000 extra homes, and how this was to be disaggregated between
regions and growth areas. No answers were forthcoming. The RSS
production therefore proceeded on the basis that Government was
seeking and expecting a major increase in housing provision (and
with the example of SERPLAN's abolition following its refusal
to support comparable growth in everyone's minds) but without
any quantified target."
The SA also states (page 57) "most of the
key decisions about development in the region were driven by central
government outside the RSS process". This flies in the face
of PPS1 and the need for community involvement in the planning
process.
The SA states (page 56) "We believe it's
a serious weakness of the RSS process that the possible sustainability
benefits of concentrating development in a new settlement have
not been examined" undermining the approach taken in the
RSS to urban extensions.
The SA is clear that the central government
policy of (page 57) "enabling and supporting housing and
economic growth in London" drove many decisions. The Plan
tries to accommodate massive unsustainable migration into the
region irrespective of the environmental consequences and lack
of infrastructure.
Section 2.4 of the SA clearly sets out the severe
limitations of the work possible in the time allowed. The whole
process is flawed. The various options for development around
Harlow do not appear, from the limited data in the public domain,
to have been subjected to a sustainability appraisal before options
were selected for inclusion in the Plan. They have certainly not
been the subject of any public consultation whatsoever.
Turning specifically to the proposals for Harlow,
paragraph 2.7 of the Plan states "The environment- the regions
key asset is to be conserved and enhanced . . . The region also
contains a high proportion of the country's best and most versatile
agricultural land". However, there has been no analysis of
the characteristics of the Green Belt and countryside north of
Harlow that the plan would see built over. The Plan recognises
its duty to restrict opportunities for development to protect
interests of acknowledged importance and in order to deliver the
environmental and sustainability objectives. It is therefore unclear
why the restriction of "no building north of the Stort and
west of the M11" included in the draft RPG 14 in February
2004, which was included to protect interests of acknowledged
importance and to protect and enhance the natural environment,
has been removed in the draft RSS at the last minute and without
consultation.
No subsequent studies identified building north
of Harlow as a sustainable proposal at the current level of housing
demanded by the East of England Plan, (ie after rejection of additional
18,000 dwellings requested by Lord Rooker). The two versions of
the Thompson report available on the EERA web site show significant
alterations which have no explanation.
The following study data seems to have been
disregarded:
— Land to the north of Harlow was considered
to be the most sensitive (compared to south, east or west) (A
Study of the relationship between Transport and Development in
the London-Stansted-Cambridge-Peterborough Growth Area- Colin
Buchanan and Partners & GVA Grimley, August 2004 commissioned
by ODPM).
— The Landscape Character Assessment
is one of "conserve and improve" (Hertfordshire County
Council landscape assessment).
The last minute change to the Plan to include
at least 10,000 homes to the north of Harlow has never been fully
explained on the basis of a thorough analysis of all the studies
available to EERA and GO-East. It is unclear why deliverability
("deliverable supply of land") is used as a criterion
in selecting growth areas, to the exclusion of all other policy
objectives, and why the Thompson study of studies promotes deliverability.
In fact the development is not readily deliverable; although most
of the land is in the ownership of a large pension fund, extensive
infrastructure investment, including water supply, is required
prior to house building and this is neither committed or a likely
prospect. The Planning and Compulsory Purchase Act gives sufficient
powers to allow planning authorities to acquire necessary land
for strategic development when, and if, required.
The Plan jumps to the conclusion of development
north of Harlow as a site specific proposal without analysis.
There is no evaluation of the landscape and the setting for the
present Harlow. There is no assessment of its agricultural, recreational,
archaeological, wildlife or any other value. The area is currently
unspoiled, traditional mixed countryside, comprising high quality,
arable farmland interspersed with pockets of ancient woodland
and parklands. It envelopes two small, historic villages (Eastwick
and Gilston) which date from the Domesday book, the southern fringe
of land (nearest Harlow) is designated Metropolitan Green Belt,
and to the north, east, and west it borders other traditional
Hertfordshire villages (Hunsdon, Widford, Much Hadham and High
Wych) and the town of Sawbridgeworth. Development will lead to
the coalescence of these areas in total contradiction of established
Green Belt policy. The area has extensive natural flora and fauna
and its proximity to the northern fringes of London—as well
as to Harlow—ensures it is widely used for rambling, bird-watching
and other recreation.
The Tyms Hertfordshire Housing Study Final report
states in 9.21 "developing to the north of the existing urban
area . . . could cause a loss of contiguity with Harlow. In addition,
development of the whole area would cause coalescence of several
existing villages" and in the summary "the urban containment
effects of the Green belt development would preclude land release
in these locations".
There is no appreciation of the long-term damage
imposed on Harlow's regeneration and the countryside north of
Harlow. In suggesting at least 10,000 houses be built there a
critical threshold (the Stort Valley) will be breached. Once development
north of the Stort is established in principles there will be
no effective way of resisting the 25,000 houses aspired to by
Ropemaker Properties Limited. Green Belt policy, once overridden,
can be overridden again and again. The Plan contains no proposals
to contain development to 10,000 houses by eg establishing a new
Green Belt.
There is a need to strengthen the Metropolitan
Green Belt around Harlow to tackle the increasing threat of urban
coalescence, the unrestricted sprawl of large built-up areas and
to safeguard the countryside from encroachment.
The Plan fails to understand the value of the
Green Belt policy. This most widely understood and supported planning
policy, is seriously undermined because the Plan takes the view
it can be set aside without good cause and without looking at
alternatives. If it is to be Government policy that Green Belts
can be ignored then a much wider range of options for the future
should be considered.
The Green Belt review proposals seem to imply
a release of land but they do not demonstrate how any such release
would support the reinvestment and regeneration of the existing
communities. On of the key purposes of a Green belt is to ensure
urban regeneration and so avoid inner urban decay at the expenses
of easy green field development options. The downtown experience
of American towns is salutary.The nature and scope of these reviews
is not described; nor is the ability for democratically elected
representatives to contribute. Some parameters need to be set
to guide the scope of the reviews.
The draft proposals in this Plan reverse that
strategy which has proven to be successful and robust over 60
years. It encourages the poaching of potential job growth from
other regions, provides for associated migration and turns development
back in towards London. This will be at enormous cost to the principles
of sustainability and to the quality of life and the environment
in those areas closest to London. Moreover the draft strategy
poses a threat to the economy through overheating and increased
the levels of congestion. It is timely now to consider further
extension to the Green Belt.
At time of writing East of England Regional
Assembly has suspended its endorsement of the draft East of England
Plan.
"The East of England Regional Assembly deplores
the Government's grossly inadequate funding of the transport infrastructure
costs associated with the additional 478,000 houses planned for
this region between (the years) 2001-21.
Bearing in mind that the Assembly's acceptance
of this massive growth was conditional upon adequate government
provision of the necessary infrastructure; and mindful of Lord
Rooker's repeated written assurances that growth will not be imposed
without the associated infrastructure, this Assembly wishes to
make clear that it now regards its endorsement of the draft East
of England Plan as suspended, pending a re-examination of the
Government's willingness to support its own aspirations adequately
in financial terms."
We would recommend the report "The Costs
& Funding of Growth in South East England" June 2005
by Roger Tym & Partners to the Committee. (http://www.tymconsult.com/news_pages/p_news_view.html).
The Committee might also wish to reference "Harlow
Regeneration Strategy July 2005" by Pacec and Halcrow Group
Limited which indicates that £800 million would be needed
to complete the ambitious regeneration plans for Harlow. (http://www.harlow.gov.uk/Default.aspx?sID=962).
This study includes a northern or southern bypass
to ease the massive traffic congestion problems of the town many
of which exist now. This road plan is unfunded and not prioritised
despite being recognised by EERA as a prerequisite for growth.
The proposals for Plan Monitor and Manage in
the Plan lack the necessary definition and power to prevent building
if infrastructure is not forthcoming. The over bidding for resources
is a recipe for chaos at it provides no rational basis for the
allocation of scarce resources.
The Plan has no cross reference to relevant
forecasts in other regional plans and in particular at the Regions
boundaries. This matter concerns not only London and the South
East, it also concerns other regions which will continue to see
a drain of people and jobs if high migration forecasts of EERA
are fulfilled. There is no justification for EERA's attempt to
secure twice the current share of national job creation cake.
Paragraph 2.9 of the Plan states "Water
is likely to become scarcer in summer months . . ." Water
supply and subsequent drainage to the Stort and Lea Valleys are
known to raise massive investment and environmental issues. There
is a limited supply of potable water from Graffham Water, 80 miles
away. Harlow was known to be "dry" when originally built.
Expanding the town in such a dry area is utter folly.
Page 31 table 33 of the SA states "in some
areas surface and groundwater extraction already exceeds sustainable
limits", "Summer surface water is fully committed to
meeting existing demand with no significant further resources
readily available." And "Lack of water availability
is likely to be a major constraint to further development in the
region".
On 6 October 2005 Three Valleys Water wrote
to local councils stating "This year we have seen 10 consecutive
month of below average rainfall, with the result that many of
the underground aquifers and associated streams are at their lowest
level for many years. Continued low rainfall this winter will
cause severe distress to the environment and will force us to
consider introducing water reduction measures starting with hosepipe
bans but also banning non essential water use by commercial and
institutional users". The deliverability of tens of thousands
of new houses must be highly problematic.
The demise at the end of the 16th century of
the royal city at Fatehpur Sikri should be a lesson for us all.
After 15 years of construction it was abandoned as there was an
inadequate water supply. Let us not repeat this mistake.
As stated in the SA of the Plan "the Regional
Spatial Strategy (RSS) lacks the powers to ensure that development
meets true sustainability standards. The scale and pace (and we
believe location) of growth envisaged is likely to be highly environmentally
damaging . . . and is likely to have serious negative impacts
on water resources biodiversity, tranquillity, air quality, recreational
access and congestion".
The whole Plan is based on "aspirations"
(ie wishful thinking). Moreover these aspirations are put forward
without any reference whatsoever to the issues the Plan claims
to give "priority" to: sustainability, environment,
infrastructure provision and quality of life. As an example the
needs of rural communities in the Region are totally overlooked.
Reference to these other critical issues should have had the effect
of introducing constraints into the forecasts. The Plan should
have been—but clearly wasn't—an iterative process
whereby forecasts were compared with other constraints, modified,
run again, modified etc until a good fit was obtained between
the desiderata.
The proposals for building north of Harlow,
if they were to be justified by broad strategic needs, should
only be included in the Plan (a) as the result of analysis proving
an over-riding need to breach Green Belt policy (b) proper evaluation
of alternatives (c) proof that the proposal will aid regeneration
of Harlow (d) proper evaluation of the impact of development on
the functioning of the town, on the environment, on transportation
and other infrastructure and not least of all on sustainability
including water supply and commuting issues. None of this has
been done.
November 2005
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