Council Offices, London Road,
Saffron Walden, CB11 4ER / 1 October 2013
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Dear Sir or Madam,
Ref: Planning Application UTT/13/2423/OP– application for 167dwellings and mixed use employment developmentby Ridgeons Limitedon land north of Ashdon Road, Saffron Walden(the “RidgeonsDevelopment”).
I am writing to OPPOSEthe Ridgeons Development, which is in breach of local and national planning policies for the reasons set out below. I do not oppose the proposal to develop different employment uses, but I oppose the loss of existing employment provision and the application for change to residential use.
- The application is unsustainable: The National Planning Policy Framework (NPPF) requires that development be sustainable and the proposed development is unsustainable. The evidence base assembled by UDC as part of its Local Plan and summarised in its February 2010 housing strategy is clear that the most sustainable housing strategy for Uttlesford is to build a new settlement for the bulk of the forecasted housing need, and to permit only limited development in the existing settlements. The location of the Applicant’s site is inherently unsustainable; it is in the most inaccessible part of Saffron Walden, on completely the wrong side for access to jobs, schools, the railway station, other facilities and major transport links, and the Transport Assessment shows that the site is remote from almost all day to day facilities, particularly schools and the town centre. There is little play area and no sports provision, and there are no such areas within easy walking or cycling distance for children;
- This application is against the existing Local Plan: In 2011 UDC members stood and were elected on the Local Plan basis that new housing would be focused in a single new settlement; and that is still UDC’s adopted Local Plan. Whilst soon after the election the UDC Cabinet started developing an emerging plan that would disperse housing into existing settlements, that plan has not been adopted; the evidence base for it has been completely contradicted by the 2012 demographic forecasts, it has been rejected by 99% of respondents in the 2012 Public Consultation, and is still has to be reviewed by the Planning Inspectorate. Until that time applications must be judged against the current, single-settlement plan. This housing application for Saffron Walden falls outside of the current adopted Local Plan, and therefore should be refused;
- Loss of employment land:The proposed development is on land (“the Ashdon Road Commercial Centre”) which is designated by UDC as key employment land to be safe-guarded against change of use under Local Plan policy SW6. SW6 policy requires that “The larger existing employment areas in the town will be safeguarded from redevelopment or change of use to other land uses. Policy E2 will apply.” This site is the largest site identified in policy SW6 in the town and should be preserved as employment land, especially as the Applicants identify a need. The site is 12.83ha, but the Application proposes that only 3.28ha would be retained as employment land, a loss of almost 75% of the employment land. UDC have just approved the loss of the protected employment land at the Kilns site, and have identified the protected employment land at the SIA / Willis & Gambier site for housing development. The Application would result in the loss of more than half of Saffron Walden’s protected employment land;
- Loss of sports and open space provision: at the front of the Ridgeons site is a large area of open space, which forms a large part of the current site. As well as being open space, this area is used as a football pitch by local teams. The Ridgeons Development proposes that all of this land will be lost and housing development built on it. No replacement provision is to be provided, and nor is any sports provision to be provided for the additional 167 new homes;
- Underplayed impact to highways and lack of sustainable transport provision:The Transport Assessment accompanying the Application concludes that the development will not create significant additional levels of traffic compared with the existing use. I do not believe that this is correct. Both the proposed new employment and the new home development will generate significant traffic. The traffic claimed by the Applicant is completely different from their job creation claims and cannot be believed. The trip profile will also be very different profile from any previous commercial traffic as it will tend to cluster around peak commute times when the nearby Radwinter/Thaxted Rd junction choke point is more congested. The traffic from the development should not be permitted without significant junction improvements at the Thaxted Rd junction, and a detailed assessment showing that there will be no material impact on the other road junctions in Saffron Walden. The Transport Assessment considers only traffic from the proposed development and the Persimmon development, and does not include any permitted but un-built development, such as the proposed Tesco extension and the Granite development or any of the recent or current housing applications, and a proper cumulative Transport Assessment should be provided. It also has no proper assessment of the impact on the Ashdon Road, particularly combined with the Persimmon housing. There is currently no provision for sustainable transport or any proposals to reduce reliance on motor car use from the site, in breach of Local Plan and NPPF requirements;
- Full traffic context known but not considered:UDC commissioned a full Highways Assessment for Uttlesford in 2012. At the June 2013 UDC Area Forums the UDC Leader stated that even though the report was in draft status, it was complete for Saffron Walden. However UDC has refused to publish the draft or use it for planning decisions by the Planning Committee, even under Freedom-of-Information requests. Given the huge traffic congestion issues in Saffron Walden, and the associated air pollution, this is material information which must be published and scrutinised before a proper assessment of the development can be made. Neither UDC Councillors nor the public can properly assess the Application without this fundamental background report;
- Air Qualityobligations not met and application will cause illegal levels of pollution: Air pollution at the Radwinter/Thaxted Road junction and the High Streetalready significantly exceeds legal limits, and is predicted by ECC to continue to do so for the foreseeable future. Paragraph 124 of the NPPF requires that development should contribute to compliance with legal limits – instead the proposed development would increase traffic at all the main junctionsover the traffic that the site generates today or is permitted to generate and will therefore worsen air pollution. Paragraph 124 of the NPPF also requires a cumulative impact study of air pollution of this and all the other proximate developments, which the Applicant has not provided.ThisApplication should be refused until a credible and proper cumulative air quality assessment for all the major proximate junctions is prepared and submitted in accordance with the DEFRA interim advice note 170/12;
- Unsustainable for Education: Irrespective of any Section-106 obligations levied on the Applicant, there are no school places and no plans for additional space. Based on standard ECC Education calculations, the proposed 167new homes would be expected to result in an additional requirement for 15 pre-school, 37 secondary, 55 primary school and 8 6th Form places. Both the catchment area primary and secondary schools are already over or forecast to be at capacity. As ECC Education has recently suggested for other applications in the town, the application should be refused unless and until there is a clear and deliverable programme for providing the additional school places. An education contribution without a deliverable plan for providing the additional school places before the development is completed makes the proposed development unsustainable and unacceptable and it should be refused;