Vision
The plan feels pragmatic. The best that can be done with time running out and with the constraints the UDC is under. That should not mean that it can’t also have a long term vision.
Democracy is failing us at every level because of short termism. I would like to see a plan that manages the short-term expediencies as much as it can, but also sets out a long term vision. If it doesn’t do that, the next plan will be also be short termist and then next, and so on.
Ambition
The council set an ambitious target to reach zero carbon by 2030. There are massive constraints in planning law that hold us back from reaching that target, but this plan should still set out ambitions and aspirations, which can be activated as soon as planning law and Government regulations permit.
Chapter 1 Key Opportunities and Challenges
The list of makes no reference to the inadequacy of the transport infrastructure.
We have only one North/South railway line means that the most sustainable and efficient form of public transport serves only a narrow band of the district.
This plan continues to tie us to a fossil fuel dependent economy instead of developing a vision for an economy based on clean energy and new technologies -a post fossil fuel economy.
I understand the sense of urgency to regain control of planning, which has resulted in the essential pragmatism of this draft plan, but alongside the short term expediency, Uttlesford deserves a vision of a post fossil fuel future.
Chapter 3 Spatial Vision
The plan does not include any infrastructure that will deliver the claim of being 'well connected'. It claims that new development will link homes with jobs, but despite citing Chesterford Research Park as central to our economy, absolutely no homes are proposed nearby.
There is a presumption in the clause: 'Protect the highest quality agricultural land' as if our soil is currently in good condition. Has the quality of our soil been recently measured? This plan should have the objective of identifying and improving our degraded soil rather than being complacent about it.
Homes that are fully insulated are far more affordable leaky rental accommodation. To reduce the number of families having to choose between heating and eating, this plan should set the objective of tying in net zero energy consumption in its definition of 'affordable housing.'
Core Policy 1 Climate change
We acknowledge the sense of the powerlessness of the District Authority in the face of wholly inadequate Building Regulations that are not strict enough to for new homes to be net zero. There should also be an explicit expectation of an exponential reduction in the embodied carbon of building materials, not just a 'need to try to' but a quantified route to get to carbon negative by 2030.
'Biodiversity Net Gain' must be rigorously calculated to drill down into the health of our soils, on which we all depend? There is DNA technology that can now do this. The use of this technology https://www.naturemetrics.com at the first opportunity should be signalled in this plan.
Core Policy 2 Meeting Housing Needs
The strategic allocation for Saffron Walden is once again placed on the unsustainable side of town, on the opposite side to all the transport infrastructure. This forces all the traffic into narrow, congested, medieval streets, creating polluting traffic jams at peak periods. This plan should articulate the fundamental principle that housing allocation is premised on clean, sustainable transport infrastructure. This is not.
Core Policy 3 Settlement Hierarchy.
At the heart of the pragmatism of this plan is a flawed Hierarchy principle, which merely means adding to the largest towns, however much this unbalances them, while small villages stay small.
‘Smaller Villages’ are described as those with ‘a low level of services and facilities’. But this includes Wendens Ambo, which has the best served railway station in Uttlesford! An outstanding facility! No justification is given for this anomaly, which lies at the heart of all the traffic congestion of Saffron Walden.
Land around Wendens Ambo is managed by the Audley End Estate on behalf of distant relative of the late Lord Braybrooke, who lives abroad. The function of a Local Plan is to identify the RIGHT areas for development, not to try to second guess which landowners might wish to sell their land.
The Local Plan should be democratically led, not led by landowners and developers. If Wendens Ambo has land that can provide housing for commuters to London and Cambridge who could walk or cycle to the station, then that land should be identified, whatever the obstacles.
Reducing our carbon footprint must be the non-negotiable imperative.
Meanwhile, contrary to all principles of sustainability, Thaxted is given an allocation of 489 houses when there is no fast, efficient, clean transport infrastructure.
Core Policy 4 Business and Employment
Core Policy 5. Sustainable Infrastructure and Services
infrastructure lies at the heart of any strategy for sustainability, but this plan consistently confuses facilities with infrastructure. Facilities include schools, clinics, social centres etc; Infrastructure is by definition, the underlying structure: roads, railways, sewage and water supply systems, internet connectivity, local community energy generation, electric car charging points etc
By confusing the two terms, this plan attempts to give the impression that it is providing infrastructure when it is really only stipulating the provision of facilities.
The most urgent infrastructure requirement is a railway. See below.
Core Policy 22 Net Zero Operational Carbon
This section sets out laudable aims about reducing our emissions but in 9.15 it cites "The energy policies in this plan align with the available evidence on what is required to meet the UK's legally binding targets of five-yearly carbon budgets and
net zero carbon by 2050". But the council's target is to meet that goal by 2030. Is the plan deliberately ignoring that commitment, or is the intention to pass a subsequent motion to invalidate it?
New builds need to be net negative in their operation. This is the only way we can reach net zero, counterbalancing the vast quantity of older housing stock, with solid brick walls or medieval wattle and daub which are very hard to retrofit.
They should also be carbon negative in their construction That is:
All this is perfectly possible. A local company https://hemspan.com is pioneering it, and it should be part of a dynamic vision for Uttlesford. Developers will resist, citing building regulations, but Uttlesford should use this plan to pioneer the vision.
The most affordable way to build 'zero carbon in operation' new homes is by modular systems, build in factories in clean, warm environments to the highest standards. This relatively new industry should be encouraged both in this plan and in the Design Code and be part of a pioneering vision for Uttlesford.
A date must be put on the stipulation for no more gas grid connection.
The plan mentions embodied carbon in new builds, but the weak phrasing of the clause gives developers ample scope to disregard the targets or make the most sluggish possible transition to new, carbon negative building materials and practices.
‘Solar energy on commercial buildings should be made mandatory. We have built huge retail stores with not a single solar panel on them. It is too late to continue to miss this opportunity. This plan should set out the expectation clearly and assertively so that it can be implemented as soon as regulation permits.
This plan should set out a clear vision for Community Energy. Let us be ready for the moment when government removes the impediments and cheap clean electricity is priced independently of the international gas market.
No mention is made of wind farms. While current planning regulations make such developments virtually impossible, this plan should accommodate a likely future when they will be permitted and be of vital importance.
No mention is made of local, community owned geo-thermal energy, which is one solution to helping small remote villages move away from oil powered heating.
Core Policy 26 Sustainable Transport
This is the most disappointing policy. The most urgent infrastructure requirement is a railway. We have just one north-south line, but no east-west line. It is the constraint that has doomed successive plans to failure and puts massive constraints on the options for sustainable housing development
While it is clear that this plan cannot be premised on a railway that doesn’t exist yet, it should form part of Uttlesford’s long term vision. Otherwise it will never happen.
Para 46 says, ‘In the long term we will need to give consideration to one or more Garden Communities.’ I think 2040 is quite long term, so let me give you a vision of a sustainable future:
Of course such a railway is not in the gift of UDC, but unless you have the vision and the passion, it will never happen.
At the very least, draw the line on a map and ensure that nothing is built to prevent the line being built in the second half of this century when finally central government comes on board with your vision!
CP 28: Active Travel
No mention is made of the anomaly of the Flitch Way failing to cross the M11 to connect with Bishops Stortford. If there is to be a coherent cycling infrastructure that anomaly must be addressed. Of course it will require action by central government, but if this plan does not have the vision of a coherent cycling infrastructure, we are not going to get it.
There is no coherence in an aim of providing a coherent cycling infrastructure for as long as the Flitch Way ends in the middle of a field by Start Hill Farm and does not connect to Bishops Stortford.
I imagine that the Beeching line was not yet a public right of way when the M11 was built and so did not qualify for a bridge, but this makes active travel out of Bishops Stortford to the East and specifically to the green recreational gem of Hatfield Forest impossible. The massive M11 /A120 interchange is totally impassable to bicycles.
This local plan should include the vision and medium term aim to build a bridge for cycles and pedestrians to connect the stranded Flitch Way to Bishops Stortford. It is an anomaly that should have been resolved decades ago and it is time the UDC began the process in tandem with ECC to resolve the anomaly.
Core policy 33: Managing Waste
While this policy makes stipulations for developers, it does not seem to contain a vision for how waste is to be managed in the district as a whole.
What plans are there for the generation of bio-gas from kitchen and organic waste, as there is near Baldock?
What plans are there for the clean and sustainable disposal of plastic waste? Is the council planning with ECC an energy generating incinerator with carbon capture and storage so that massive pollution by plastic waste is eliminated, producing sustainable energy with no GHG or other polluting emissions? Our Local Plan should include a vision for a Zero Waste Society and strategic route map to get there.
Core Policy 49: Employment and training.
We are on the edge of a massive transition to a post fossil fuel economy, but this Plan makes no mention of that. We are going to need thousands of people skilled in retrofitting leaky homes; there are opportunities for new industries producing sustainable building materials such as cross laminated timber and hemp boards and insulation at scale; scope for recycling batteries; repair and upcycling skills will be needed and the workforce to combine with the new Technology ideas generated in the Chesterford Research park, financed by venture capitalists in the City and put into mass production in Uttlesford.
Core Policy 56 Affordable Housing
This is a lukewarm section which doesn't inspire confidence that developers will comply with even the low 35% target, while the 10 or more dwellings rule will still give developers a massive loophole.
The need for affordable homes is intense! It is a sociological disaster area and is putting our children at an appalling disadvantage. There should be clauses that apply the 35% rule to the total build of a developer across all the sites developed and a blacklisting policy for developers with a history of non-compliance. It is time local government put itself in the driving seat on this one!
The most affordable way to build new homes is by modular systems, build in factories in clean, warm environments to the highest standards. This relatively new industry should be encouraged both in this plan and in the Design Code. I am appalled that it doesn't appear as a Core Policy in this Chapter.
Let us encourage and pioneer genuinely affordable homes, built to the highest standards for our increasingly disadvantaged children.
In summary, this is a pragmatic and pedestrian Local Plan, devoid of a compelling vision to accommodate ecosystems which will be dramatically changed during the lifetime of the plan.
A long term vision should be set out clearly, alongside the pragmatism, to provide weight and validity when lobbying and engaging with the ECC and central government.
Our plan should be the road map to Uttlesford’s sustainable, fossil free future.
Edward Gildea