CHELMSFORD DRAFT LOCAL PLAN PRE-SUBMISSION DOCUMENT JANUARY 2018

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REPORT of the DIRECTOR OF PLANNING & REGULATORY SERVICES to PLANNING & LICENSING COMMITTEE 1 MARCH 2018 CHELMSFORD DRAFT LOCAL PLAN PRE-SUBMISSION DOCUMENT JANUARY 2018 1. PURPOSE OF THE REPORT 1.1 Chelmsford City Council has published its Pre-Submission Draft Local Plan for consultation. The primary role of the Local Plan is to set out the required housing delivery growth and other land use requirements; to allocate sites to meet that growth, and to produce policies for the determination of planning applications up to 2036. It also includes proposals for strategic development, in and around the city, including a strategic growth site allocation at South Woodham Ferrers. The purpose of this report is to consider the Council s response to this Draft Local Plan (see Appendix 1 of this report). 1.2 The closing date for responses to be submitted is 14 March 2018. 2. RECOMMENDATION That Members views are sought on the draft response to the draft Chelmsford Local Plan and if required the draft response is revised to take into account views of the Committee and approved by Officers, in consultation with the Chairman of the Planning and Licensing Committee and submitted as the Council s formal response to the Consultation. 3. SUMMARY OF KEY ISSUES 3.1 When making a response this Council needs to consider whether the Plan is: Legally compliant Complies with the Duty to Co-operate Sound 3.2 In order to be considered 'sound' the Inspector must be satisfied that the plan is positively prepared, justified, effective and consistent with national policy. An explanation of soundness can be found in paragraph 182 of the NPPF. 3.3 This is the Local Plan which Chelmsford City Council intends to submit to the Planning Inspectorate for an independent Examination. All responses to the consultation will be sent on directly to the Inspector to consider in the Examination Our Vision: To make Maldon District a better place to live, work and enjoy

of the Local Plan. The consultation started on 31 January 2018 and closes on 14 March 2018. The Examination is expected to occur later this year. 3.4 This Committee report focuses on the issues this Council raised at the Chelmsford Local Plan Preferred Options consultation in spring 2017, and proposed developments that may have an impact on residents or businesses in Maldon District. 3.5 The identified Objectively Assessed Housing Need (OAN) for the Plan period (2013-2036) is 18,515 dwellings (805 per annum). The Plan identifies allocations and existing commitments for 21,893 dwellings, almost 20% above the OAN. The Plan fully meets the accommodation needs of Travellers and Travelling Showpeople, as identified through the Essex GTAA. Therefore, the city can provide for its full housing needs within its own borders. 3.6 The Strategic Growth Sites will be delivered in accordance with master plans to be approved by the Council (policy S9 Spatial Strategy). Policy S12 (securing infrastructure and impact mitigation) requires developers and land owners to work positively with the Council, neighbouring Local Planning Authorities and other infrastructure providers throughout the planning process to ensure that the cumulative impact of development is considered and then mitigated, at the appropriate time, in line with adopted policies. This ensures that Maldon District Council will be included in the process for those sites that could impact on the District (e.g. South Woodham Ferrers and Sandon). 3.7 Residential developments proposed within the Local Plan have the potential to result in a significant increase in recreational disturbance on Essex Estuaries Special Area of Conservation (SAC) and Crouch and Roach Estuaries Special Protection Areas (SPA). Measures required to mitigate the impacts of recreational disturbance on European Protected sites will be delivered as detailed in the Essex Coastal Recreational Disturbance Avoidance and Mitigation Strategy (RAMS). Any residential development that is likely to affect the integrity of European Sites, will be required to either contribute towards mitigation measures identified in the RAMS (and subsequent Supplementary Planning Document), or to identify and implement bespoke mitigation measures compliant with the Habitat Regulations. 3.8 Travel into and around the Chelmsford urban area is an identified problem. The Local Plan seeks to improve transport infrastructure and ensure that new development is accessible by sustainable forms of transport to significantly change how people make their journeys in and around the city. 3.9 The Plan requires that new development must be supported by sustainable means of transport to serve its need including walking, cycling and public transport modes. New highway infrastructure should help reduce congestion, link new development and provide connections in the strategic road network (policy S11), including: New Beaulieu Railway Station Chelmsford North East Bypass Additional Park and Ride sites to serve West Chelmsford and North East Chelmsford and safeguarding land for expansion of Chelmer Valley and Sandon Park and Ride sites

Improvements to the Army and Navy Junction Improvements to A130 (Essex Regiment Way) and A131 Junction improvements on the A12 and other main roads to reduce congestion Capacity improvements to the A132 between the Rettendon Turnpike and South Woodham Ferrers, including necessary junction improvements to be brought forward as early as possible Multi-user bridge across the B1012 in South Woodham Ferrers Growth Area 1 Central & Urban Chelmsford 3.10 The Plan focusses development in the Chelmsford Urban and Central Growth Area on the regeneration of previously developed sites in Urban Chelmsford. The Plan makes provision for a total of 4,014 new homes in Growth Area 1 with around 1,200 new homes focused at sustainable new neighbourhoods on the edge of Urban Chelmsford linked to the City Centre by public transport, cycling and walking. The remainder of new homes will be located on predominately previously developed sites within the urban area. Provision is also made for 9,000 sqm floorspace of offices and 11,500 sqm of food retail. 3.11 If the allocations come forward as expected, there will be significantly fewer public and private car parking spaces available in the city centre. This will discourage car use in and around the city centre and encourage people to use the Park and Ride and other forms of public transport. Development proposals for allocated sites are expected to provide Travel Plans, an approach that has been successfully used in the new suburbs being built to the north of Chelmsford. The sustainable transport related elements of policies S3 and S11 apply to all allocations. Growth Area 1 Key diagram

Sandon 3.12 Adjacent to the Sandon Park and Ride site on Maldon Road, the Plan proposes development comprising 400 homes, 5,000 sqm B1 office space, a country park, early years nursery and a safeguarded extension to the Park and Ride. Main vehicular access to the sites north of Maldon Road will be from a new junction at Maldon Road/Sandford Mill Lane. None of these sites are expected to come forward before 2020/21. The policies for the Sandon allocations emphasise the need to provide appropriate improvements to the local and strategic road network. All the allocations in this location will be subject to a master plan to be approved by the City Council. 3.13 The largest site, (Strategic Growth Site 3a East Chelmsford (Manor Farm)) will provide a country park, the new junction at Maldon Rd/ Sandford Mill Lane, a safe multi-user crossing on Maldon Road, and high-quality landscape-led residential development of around 250 new homes. Strategic Growth Site 3c East Chelmsford land south of Maldon Road, will provide 100 new homes, whilst Growth Site 3d East Chelmsford land north of Maldon Road, will provide 50 homes. The emerging Neighbourhood Plan being prepared in Sandon is envisaged to help to shape the two smaller allocations (3c & 3d). Extract of the draft Chelmsford Local Plan Policies Map 1. (Note: As the Chelmsford Plan shows allocations on a base layer, to make this map extract easier to read, road names have been added and the route of Maldon Rd has been highlighted in yellow.) 3.14 Strategic Growth Site 3b East Chelmsford land north of Maldon Road, adjacent to the P&R site, will provide around 5,000 sqm (net) new Use Class B1 floorspace, a stand-alone early years and childcare nursery and safeguard land for the future expansion of Sandon Park and Ride site. 3.15 The emerging Neighbourhood Plan being prepared in Sandon is envisaged to help shape this site allocation.

Growth Area 2 North Chelmsford 3.16 North Chelmsford will continue to be the location for significant new development growth. Growth Area 2 includes the Beaulieu Park and Channels developments, and new allocations in North Chelmsford, Great Leighs and Broomfield. Growth Area 2 key diagram 3.17 A new allocation for 3,000 homes in North Chelmsford, alongside other developments at Great Leighs, will help to deliver strategic infrastructure including the Chelmsford North East Bypass. Development north of Broomfield will deliver a new access road into Broomfield Hospital. Growth Area 2 will, in total, provide 7,219 homes (existing permissions and new allocations), Traveller pitches and Travelling Showpeople plots, and 85,000sqm office/business Park development. 3.18 The new Beaulieu train station and park and ride site, along with the planned improvements to the A12 and the north east Chelmsford bypass providing enhanced access to the A120 and M11 corridors will improve access into and around Chelmsford for residents and businesses based in the north of Maldon District. Growth Area 3 South and East Chelmsford

Growth Area 3 key diagram 3.19 Growth Area 3 comprises South Woodham Ferrers, Danbury & Bicknacre, and will provide 1,162 homes, 5 Travelling Showpeople plots, 1,000sqm office space and 1,900sqm food retail. The vision for growth in South and East Chelmsford is for sites which will support and strengthen South Woodham Ferrers important local role and to help deliver improvements to the A132 corridor. In addition, small allocations in the Key Service Settlement of Bicknacre and Danbury will help to support the villages' services and facilities. South Woodham Ferrers 3.20 The draft Local Plan allocates a Strategic Growth Site (number 7) to the north of South Woodham Ferrers. This allocation is for around 1,000 homes, a Travelling Showpeople s yard (5 plots), and a Neighbourhood Centre incorporating provision for convenience food retail, (1,900sqm), flexible neighbourhood scale business (1,000sqm) and community and healthcare provision. The detailed policy for the Strategic growth Site 7 is on page 171 of the draft Plan.

3.21 The Retail Capacity Study identified a need in South Woodham Ferrers for an additional 1,900 sqm floorspace for food retail. There is an extant planning permission for a supermarket (the site for which has been cleared) and healthcare facility to the north of South Woodham Ferrers (area outlined in blue). At Preferred Options stage, this Council expressed concern that if the retail allocation was in addition to the retail floorspace already granted permission, it could impact on retail provision in Maldon District. The draft Local Plan makes it clear that this allocation is not in addition to the existing retail permission. Extract from the draft Chelmsford Local Plan 3.22 At the preferred options stage, this Council raised concerns regarding the potential landscape impact of development on the escarpment south of Bushey Hill and that extensive landscaping would be expected along the edge of the allocation bordering Maldon District. This has been considered in the draft Plan, in that development extents should be limited to areas within the site with lower topography and/or where excessive visibility can be mitigated. Further, that the character of the development must exhibit a sufficiently open and green character, with greenways and open spaces within the layout and appropriate buffer and strategic landscaping to the outer margins. 3.23 The Plan provides for capacity improvements to the A132 between the Rettendon Turnpike and South Woodham Ferrers, including necessary junction improvements to be brought forward as early as possible. In addition, a multi-user bridge across the B1012 in South Woodham Ferrers is proposed (policy S11 Infrastructure requirements). At the Preferred Options stage this Council raised concerns regarding the potential impact developments on the A414, and A132 / B1012 corridors could have on Maldon District residents and businesses, and that the earlier plan showed improvement only applying for the stretch between the Rettendon Turnpike and the Shaw Farm junction at South Woodham Ferrers. The

draft Local Plan requires that impacts from development on the local and strategic road network must be mitigated and this has been extended to the junction with the B1012 as requested by Maldon Council. 3.24 This now should include appropriate road and junction improvements along Burnham Road, the roundabout junctions at the B1418, Ferrers Road and Rettendon Turnpike, and the A132 and local junctions between the Town and the A130, in line with the Highway Authority requirements. It specifically states that impacts of development in the adjoining Maldon District need to be part of this consideration. 3.25 The emerging Neighbourhood Plan being prepared in South Woodham Ferrers is envisaged to help shape this site allocation. Danbury 3.26 The draft Plan allocates 100 homes for the Danbury Neighbourhood Plan, although it does not identify the location of this allocation. This was raised at the Preferred Options stage as a concern, due to its potential impact on the A414. However, Danbury Parish Council are well aware of the A414 s capacity constraints and are unlikely to allocate sites in the Neighbourhood Plan that exacerbate existing issues, as that would have an immediate impact on their own residents. Bicknacre 3.27 The draft Plan allocates a site for 30 homes on the southern edge of Bicknacre, on the road to South Woodham Ferrers. This is unlikely to have a significant impact on the highways network. Duty to Cooperate 3.28 The Duty to Cooperate (DtC) on the draft Local Plan has been met. - Chelmsford City Council requested and held three DtC discussions with this Council in 2017 regarding the contents of the draft LP. A further meeting is being held on 1 March 2018 and a verbal update will be given of that meeting. 4. CONCLUSION 4.1 The draft Chelmsford Local Plan has been published for consultation. The majority of Maldon District Council s previous concerns expressed at the Preferred Options stage have been addressed in the draft Local Plan. In particular, Policy S12 ensures that neighbouring authorities are involved in the planning process to ensure that the cumulative impact of development is considered and then mitigated. This will enable Maldon District Council to contribute in the master planning and infrastructure planning processes for the Strategic Growth Sites in Sandon and South Woodham Ferrers. Therefore, there are no substantive reasons for objecting to the draft Chelmsford Local Plan.

5. IMPACT ON CORPORATE GOALS 5.1 The level of development proposed in the draft Chelmsford Local Plan has the potential to affect the corporate goals of protecting and shaping the District, and creating opportunities for economic growth and prosperity. 6. IMPLICATIONS (i) (ii) (iii) (iv) (v) Impact on Customers The proposals may impact on residents and businesses using either the A132/A12/A130 or train services, through increased traffic flows and passenger numbers. Impact on Equalities The proposals would have a positive impact on equalities, through the Plan s support for the provision of affordable housing and specialist residential accommodation, suitable for older people, students, Travellers and Travelling Showpeople and people with disabilities. The Plan s support for energy efficient development will help reduce the number of households living in fuel poverty. Impact on Risk The proposals would not have a direct impact on risk. Impact on Resources (financial and human) The proposals would not have a direct impact on resources. Impact on the Environment The growth area proposals could result in impacts on designated European sites in the District through increased recreational activity. The Essex wide RAMS project will identify mitigation measures to reduce any potential impacts. Background Papers: The draft Chelmsford Local Plan is available at: https://www.chelmsford.gov.uk/planning-and-building-control/planning-policy-and-newlocal-plan/new-local-plan/developing-the-new-local-plan/ Enquiries to: Leonie Alpin, Planning Policy Officer, email: leonie.alpin@maldon.gov.uk

APPENDIX 1 Maldon District Council Comments on the draft Chelmsford Local Plan At this Pre-Submission consultation, the questions to be answered are: Do you consider the Local Plan is legally compliant? Y/N Does it comply with the Duty to Co-operate? Y/N Do you consider the Local Plan is Sound? Y/N If no, on what grounds you do not consider the Local Plan is sound: Positively Prepared Justified Effective Consistent with National Policy Do you wish to participate in the oral part of the examination? Y/N Do you consider the Local Plan is legally compliant? Does it comply with the Duty to Co-operate? Do you consider the Local Plan is Sound? Do you wish to participate in the oral part of the examination? MDC comments Yes, Maldon District Council considers the Plan to be legally compliant. Maldon District Council considers that the Duty to Cooperate requirement has been met. Maldon District Council would wish to participate in the master planning and infrastructure planning processes for the Strategic Growth Sites at Sandon and South Woodham Ferrers. Yes, Maldon District Council considers that the Plan is sound. No, Maldon District Council does not wish to participate in the Examination.

APPENDIX 2 Maldon District Council s previous comments on the Preferred Options consultation Chelmsford City Council - Local Plan Preferred Options - Response by Maldon District Council Date 11 th May 2017 Q1 Q2 Q3 Q4 Do you agree with the Strategic Priorities (Section 3 of the Plan)? Notwithstanding comments below, Maldon Council has no comments on the Strategic Priorities which appear to cover the expected priorities for the Chelmsford Borough. Do you agree with the Vision (section 4 of the Plan)? Maldon Council has no comments on the Vision Do you agree with the Spatial Principles (Strategic Policy S1 of the Plan) Maldon Council has n comments to make on any of the Spatial Principles, per se. The Council does have comments on individual site allocations as set out below. Do you agree with the Strategic Policies that set out how future development will be accommodated? Strategic Policy S9 the Spatial Strategy see comments on Growth Area 3 below Spatial Policy S12 Infrastructure Requirements As per Maldon District Council s representations to the Issues and Options Consultation, Maldon District Council will continue to want to work with Chelmsford City Council, and other organisations, to ensure that the development proposals in Chelmsford do not impact negatively on Maldon residents and businesses through inadequate infrastructure Investment. Maldon has strong economic ties with Chelmsford, supported by east / west transport links. Therefore the A414 (including connections to and through the Chelmsford city centre) and the A132 / B1012 corridors are essential for free movement. Furthermore, Maldon Council will be concerned of any proposals to restrict access for Maldon residents for commuters at Beaulieu Park Station. Strategic Policy S15 the role of City, Town and Neighbourhood Centres the proposal for an additional 1,900 sqm of convenience retail as part of the North of South Woodham Ferrers urban extension and effectively an out of town location, on top of the 4,900 sqm already granted and new Co-op store in SWF town centre, could have a negative impact on retail provision in Maldon. Therefore, consideration must be given through the plan process to these strategic impacts. Maldon Council would wish to discuss this further through the Duty to Cooperate. Our preference would be for no further retailing at South Woodham Ferrers. Q5 Do you agree with the site allocations policies that set out where future development growth will be focussed? Growth Area 1 Central and Urban Chelmsford Maldon Council understands that a priority for the Council is maximise the use of urban land. However, by its own admission, Chelmsford central road network is close to saturation. Further development must therefore be supported by mitigations to alleviation congestion. Maldon and Chelmsford have a close economic relationship, and accessibility to jobs growth in Chelmsford, and cross boundary business to business trade must be as unimpeded as possible. With regards to the specific sites for the Central and Urban Chelmsford area, Maldon Council would like to work with Chelmsford on master planning for the 3a to 3c sites (north of Great Baddow), together with the new Country Park and improvements / expansion of the Sandon Park and Ride, and the impact on the A414. The new Commercial site will need to be

considered with regards to Maldon Council s plans for a new commercial zone south of Maldon and the regeneration of the Causeway area. Growth Area 2 North Chelmsford Maldon council welcome the proposals for the north east Chelmsford relief road which will improve access to the A120 and M11 corridors. Growth Area 3 South and East Chelmsford The proposal for 1,000 new homes, plus commercial (1,000 sqm) and retail, amongst others on land north of South Woodham Ferrers will have the largest impact on Maldon District. The site is in an area and has landscape features which are part of the Crouch Valley and characteristics similar to the ridge on the southern edge of the Dengie peninsula. It is not clear from the Policies Maps, which parts of the site will be developed, but concerns will be raised if the development includes the escarpment south of Bushy Hill (aka Radar Hill) and destroys the open character of the area to the immediate north east of South Woodham Ferrers. How the development boundary where it borders Maldon District is of concern and the Council would resist the development taking place in such a way as to put pressure for further growth within the District. In this regard the Council would expect a soft edge with extensive landscaping to ensure that a clear limit to development is established. We note that Chelmsford City Council proposes to take a master planning approach to this development, and Maldon Council would welcome involvement in that process. With regards to the highway network, undoubtedly an additional 1,000 dwellings at SWF will produce greater traffic flows in to Maldon District as well as along the A132 corridor. During the preparation of the Maldon District Local Development Plan, Chelmsford City Council raised concerns of the impact of additional housing in Maldon and Burnham on the B1012 and A132. That development is now consented. Given the importance of the B1012 and A132 for strategic movements from Maldon District, for both freight and private vehicles, it is vital that the infrastructure works as a result of the new growth at SWF takes account of the strategic movements between the two districts. On this basis, whilst improvements need to be considered the A132 from Shaw Farm to the A130 at the Rettendon Turnpike, congestion on the Burnham Road (SWF by-pass is not confined to that stretch. Therefore, the highways investment needs to consider improving capacity and alleviating congestion at the following junctions: The Shaw Farm roundabout B1012 Burnham Road with the B1418 B1012 Burnham Road with Hullbridge Road, which acts as an alternative access to SWF B1012 Burnham Road with Ferrers Road /Hamberts Road B1012 Woodham / Lower Burnham Road with the Woodham Road to Cold Norton The Council would welcome discussions with Chelmsford City Council and Essex County Council on agreeing a strategy and investment plan to alleviate the congestion in this area for the benefit of SWF and Maldon residents. Due to the location of South Woodham Ferrers close to the south eastern boundary between Maldon District and the CCC area, there are strong links between the two authority areas in relation to the use of services and facilities such as education, healthcare, community facilities, recreation and leisure facilities.

Through the Duty to Cooperate MDC would like to work closely with CCC to consider the impact of proposals for growth in South Woodham Ferrers which could have implications for infrastructure provision in both local authority areas in relation to education, healthcare, community facilities, and recreation and leisure facilities which are accessed by residents of both authorities. Proposals for growth in South Woodham Ferrers include 1,000 sqm of business floor space and 1,900 sqm of floor space for food retail (convenience goods). The submitted Maldon District Local Development Plan has allocated 3.4 hectares of employment land in Burnham on Crouch and a further 1.8 hectares at Stow Maries. The Maldon District Retail Study (July 2015) identified residual capacity in Maldon District for between 1,900 and 2,700 sqm of convenience goods floor space, which the Study recommended should be directed towards Burnham on Crouch. It is acknowledged that the purpose of including employment and retail floor space within proposed options for growth in South Woodham Ferrers is to support the proposed development of 1,000 dwellings. Through the duty to cooperate process, MDC would seek clarification that the level of office and retail growth in South Woodham Ferrers would not inhibit the ability to locate such facilities in sustainable locations for residents of Maldon District in the future. Whilst Maldon Council can understand the reason for deferring the allocation of 100 homes at Danbury to the Neighbourhood Plan, this does create uncertainty in a location with highway capacity issues on the A414 and in an area currently subject to appeals for major new development. The Council would seek for Chelmsford to reconsider this proposal if the current appeals are allowed. Special Policy Areas -No comments Q6 Q7 Q8 Q9 Do you agree with the other local plan policies that cover housing, employment the environment and design? As a general issue, greater cooperation is needed between Councils to ensure that development proposals remain on course and housing trajectories can be met. On-going discussions are required through the appropriate cross-boundary bodies to ensure that this is the case and the development industry achieves objectives to minimise the continued speculative and unplanned development. It is vital that new development at SWF responds well to its context. There are clearly defined boundaries to the existing SWF settlement. With environmentally sensitive areas to the south, east and west of the town, expansion can only take place northwards. However, this erodes the wedge with Woodham Ferrers and takes development into very open countryside. Do you agree with the Proposals Maps? See earlier comments regarding the scope of the A132 / B1012 improvements necessary to support growth at SWF. The Proposals Maps should reflect the area from the Cold Norton junction on the B1012 to Rettendon Turnpike. Do you have any comments on other sections of the Local Plan Preferred Options Consultation document or its evidence? The Council reserves the right to comment further on specific issues in the evidence base and Sustainability Appraisal through duty to cooperate and further representations at the Submission stage. Do you wish to comment on anything else? No comments