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From Stephen Robinson

Lib Dem Parliamentary Candidate 2005 West Chelmsford

14 Paradise Road, Writtle, Chelmsford, CM1 3HP.

19 December 2005

FREEPOST RLSX-RGZH-BBHS

Planning Policy, Chelmsford Borough Council

Civic Centre, Duke Street

Chelmsford CM1 1JE

Our Ref: LDF 0007064

Chelmsford Local Development Framework - Preferred Options

Response from Chelmsford Liberal Democrats

Following the numbering of the questionnaire supplied with Borough Life.

Summary

The Liberal Democrats place sustainability in the widest sense at the heart of their approach to future development. We stand by the principles, policies and arguments as set out in the previous draft Local Plan, which was withdrawn by the new Conservative administration of the Borough Council in 2003. In particular we oppose the continued, incremental development of Chelmsford to the north east. There are more sustainable options.

The development set out in these Options places too great a strain on already stretched infrastructure. We therefore oppose all three Options.

Local policies need to be crystal clear about HOW the infrastructure needs will be met. New railway station, bus routes, secondary school, healthcare facilities, library, community centres and neighbourhood shopping facilities all need to be delivered. This new infrastructure and new jobs must precede new housing development.

Chelmsford must meet its obligations to provide homes for the growing number of smaller households, as average household size declines. Unmet, local demand means price rises that put housing out of reach of young people and key workers. However, 14,000 is too many homes and will contribute to a growth in population due to householders coming in from outside the Borough. The Council should be challenging this number and not just accepting it.

This Preferred Options document does not truly understand the meaning of developing sustainable communities.

The Questionnaire

The "Key Guiding Principles", "Strategic Objectives - Five Themes" and "Strategic Approach" set out many fine words, with which it is difficult to disagree. However, these are not in fact carried through to the detailed proposals. For instance, the Broomfield extension in Option 1 fails to meet KGP2 - Sustainable locations. The Strategic Objectives from page 15 onwards are not SMART and, although there is reference to monitoring on page 49, this seems to be an afterthought.

Question 4

The Liberal Democrats STRONGLY DISAGREE with both questions. The Council was wrong to reject other options. Option 1 is not the best option.

The justification for the Broomfield extension is very weak. This site would not be required within the plan period and there are much better options. The suggested 1000 houses is far larger than can possibly be required for hospital-related staff and existing facilities such as local schools and the road network would come under greater pressure. We oppose the major road proposal and stand by the proposal for a single-track, shorter route and a low-impact Park & Ride facility that were in the now-withdrawn local plan.

We oppose Option 3 as it would be an environmental and community disaster. It fails to meet any of the Key Guiding Principles.

We oppose Options 1 and 2 as Chelmsford cannot continue to be stretched incrementally in its north east corner. This location is too far from the centre of Chelmsford to be justified as an extension of an existing settlement. Option 2 is marginally preferable to Option 1, because of the weaknesses of the Broomfield option and because Option 2 would make community infrastructure slightly easier to provide as part of the package.

Under either Option 1 or 2, the housing development must be focused on, and start near, the new station and all neighbourhoods MUST connect with it directly by bus, cycleways and footpaths. This infrastructure MUST come ahead of the houses, if we are to see genuine, local communities. However, there remains an option preferable to all of these.

The more sustainable option

The Option that was set out in the now-withdrawn draft Local Plan (a new settlement north of the railway and A12 north of Boreham) remains our preferred option. Having considered many alternative sites in the 2001 period, this was identified as the most sustainable option to be progressed within the plan period.

The area for gravel workings (arguably a brownfield site) could provide a new settlement and is the Borough's greatest chance of achieving the improvements in infrastructure so desperately needed, including a new secondary school. A properly-designed, truly sustainable community can be provided on this site and nearby and is capable of accommodating most if not all of the greenfield requirement.

If there is a housing requirement beyond what is sustainable at this site, other options (better than the Springfield extension) were considered in 2001 and remain possible.

Question 5

The sustainability appraisal is of little or no benefit. With an appraisal restricted to just five or six sentences on each option, there is little of substance on which to comment. Entec's third sentence of their comment on Option 1 is misleading if not wrong. Far from being an opportunity to "strengthen existing services" Option 1 is in fact an opportunity to overload existing services and facilities.

The Entec comment on Option 2 (third sentence) highlights a major danger: it might lead to improvements in facilities for the Springfield area; but there is a real danger that it will not benefit the whole of the parish. Springfield has been let down before when new development has come.

The Entec comments on Option 3 demonstrate that this Option fails to meet the sustainability objectives.

Question 6

The consultation is flawed in that the Options are unnecessarily restricted. The notional grounds on which the previous draft plan was withdrawn have been undermined by the long delay to the implementation of an LDF. The arguments in that draft plan for the "north of Boreham" option still apply. Option 3 is only there to "make up the numbers" and to make Options 1 and 2 look more palatable.

As regards the actual consultation documents, the questionnaire could have made it clearer (e.g. by reference to page numbers) as to which policies were addressed by each section. The questionnaire with Borough Life should have followed the same numbering of questions as the ones with the full documents.

Question 7

Yes we wish to be kept informed, and wish to take part in the public enquiry.

Question 9

No, the Core Strategy fails to adequately consider the results of previous consultation.

Question 10

No, the document as it stands will NOT enable the Strategic Objectives to be achieved. In the main, this is because there is insufficient detail to know for sure; but where specifics can be identified, they will not help.

For instance, Options 1 and 2 will not help EPE1, EPE2 or EPE3 - Protect natural and built resources; reducing pollution; enhance environmental quality. The area around New Hall will be fundamentally damaged, as will the Chelmer Valley with a scar on the landscape that is the proposed new, major road.

The money available for infrastructure will inevitably be limited. If this plan really does intend to enhance the environment, the investment in a new station must be prioritised over this new road.

By way of further example, 14.17 (economic development) is so vague as to be truly meaningless. It is noted on page 9 that Chelmsford has a very high rate of out-commuting. If the stated objectives on sustainability were genuinely meant, there would be a policy to reduce this. Liberal Democrats believe that any growth in population should be met and preferably exceeded by the growth in jobs in the Borough.

The current administration of the Borough Council said in 2003 that it "agreed with 90% of the withdrawn draft local plan". If so, where are the proposals that really would enhance the local environment like the formerly proposed country park?

Conclusion on the LDF

The Borough Council must not miss the opportunity presented to make a break with the past policy of incremental / peripheral development. If we continue in that direction, we risk greater congestion, a poorer sense of community and an environmental impact that will do nothing to meet wider objectives on genuine sustainability.

If the now abandoned Borough Plan had not been discarded in 2003, it would now be in place. It is deeply regrettable, therefore, that this local development framework may not have passed through all its stages until 2009. Until then Chelmsford remains in planning limbo.

Comments on the Town Centre AAP

Question 11

The strategy on p.26 is acceptable as far as it goes, which is not very far. It and other sections on pages 26 to 28 are at odds with some of the detailed policies. For instance, page 26 bullet 5 "…the imperative of environmental sustainability…" is undermined somewhat by the proposals to build new roads and demolish High Bridge Road on p.62.

Question 12

Much of the detail on the town centre is welcomed, such as pedestrianisation where appropriate; public spaces; cycle friendly etc. A mixed-use town centre, with housing at higher densities than hitherto, community facilities and with an enhanced public realm, is critical to a sustainable town centre. A mixed use community will be a safer, more welcoming community.

Higher density does not necessarily mean tall buildings. However, properly planned as part of the urban realm these could enhance the town.

The Army & Navy junction must be improved but the specific road proposals on p.62 are NOT acceptable due to impact on the floodplain, the navigation and the fact it creates a new through-route. Other solutions, based on variants of the p.63 options, could be explored.

Options such as town centre circular bus routes should also be considered, along with links to more Park and Ride services. These would provide real alternatives to the private car. Modal shift should be encouraged through car park pricing and reviewing short/long term designations.

Economic activity

It is critical to making Chelmsford a sustainable, regional centre that higher skill / higher pay jobs are attracted to Chelmsford. Relying on retail expansion is not anything like enough. The document recognises this with comments such as that on p.14 but this needs to be carried through into the detailed policies.

Transport

The town centre suffers from traffic congestion. This is recognised on page 15 and elsewhere but, again, fails to deliver in the detailed policies. In fact, by proposing new roads and routes through the town centre could make the situation worse. This is not a way to build a leading edge, sustainable regional centre.

Question 13

The first question is lacking in meaning: there is little of the town centre NOT identified for redevelopment activity.

On specifics: where is the strategy for delivering the arts/cultural venue on p.83? The previous council had a worked-up strategy for waterside that included this.

Question 14

Entec's comments on Transport (p.2) make our points: "..wider approach to demand management.. .…may not reduce congestion over the long term". Road building programmes never do.

Questions 15 and 16

See 6 and 7 above.

Stephen Robinson - on behalf of Chelmsford Liberal Democrats

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