Neighbourhood Plan Steering Group finds Local Plan ‘unsound’

On 29th January 2018 at 5pm, the Regulation 19 consultation on the District Councils Local Plan ended. The Local Plan sets out the proposed strategy for meeting the District’s needs up to the year 2033, and guides where future development will go.   The proposals in the Local Plan for North Weald Bassett include the following land allocations:

  • North Weald Village – 1,050 homes

NWB.R1 Land at Bluemans – Approximately 223 homes

NWB.R2 Land at Tylers Farm – Approximately 21 homes

NWB.R3 Land south of Vicarage Lane – Approximately 728 homes

NWB.R4 Land at Chase Farm – Approximately 27 homes

NWB.R5 Land at The Acorns, Chase Farm – Approximately 51 homes

  • Thornwood – 172 homes

THOR.R1 Land at Tudor House – Approximately 124 homes

THOR.R2 Land east of High Road – Approximately 48 homes

  • Latton Priory – 1,050 homes

The regulation 19 consultation gives local people and any interested stakeholders the opportunity to comment on the policy content of a draft Local Plan within a specific remit, that remit being the four ‘Tests of Soundness’, namely that the Local Plan is:

  1. Positively prepared – the plan should be prepared based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development;
  2. Justified – the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence;
  3. Effective – the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities; and
  4. Consistent with national policy – the plan should enable the delivery of sustainable development in accordance with the policies in the Framework.

The Steering Group met on 25th January to consider the content of the Local plan, and to form a view based on the evidence as to whether or not the plan was ‘sound’.    Over the past 6-8 months, the Steering Group has conducted a number of high level public consultations and pop up events throughout the Plan Area (which covers North Weald Village, Thornwood and Hastingwood), and the overriding issue identified by local residents was that infrastrucutre was the most important factor to consider when deisigning and building new homes. Infrastrucutre was also identified as already currently lacking, with many roads already crawling on a daily basis, insufficient and unreliable bus services, and a lack of doctors and social infrastcuture.

When reviewing the Local Plan, the Neighbourhood Plan Steering Group could not clearly identify any firm committements or fixed infrastrcuture that had been planned for to support the high level of housing growth expected for the Plan Area, and felt it had no option (considering the consultation feedback) than to find the plan ‘unsound’ for its failure to demonstrate that sufficient infrascturue will be in place and has been planned for our area.

The Steering Groups response to the consultation was as follows:

The Department for Communities and Local Government publication entitled ‘Neighbourhood Planning’ states that “Neighbourhood planning is a new way for communities to decide the future of the places where they live and work. They will be able to:

  • choose where they want new homes, shops and offices to be built; and
  • have their say on what those new buildings should look like and what infrastructure should be provided and grant planning permission for the new buildings they want to see go ahead.” 

The North Weald Bassett Neighbourhood Plan Steering Group was established to support the production of a Neighbourhood Plan for the area (which encompasses North Weald Village, Thornwood and Hastingwood) with this aim in mind. The Steering Group has undertaken high level consultation within the Plan area. In light of the responses we received, it feels that the infrastructure planned within the Local Plan is insufficient to support growth in the Plan area, and as a result we must find that the plan is unsound due to failing to meet the tests of soundness.

The research undertaken by the Steering Group indicates that just over 45% of those who responded to the question ‘What issues do you feel are most important when designing new homes and places?’ identified Infrastructure. This was the highest collective response. This was followed by Lack of facilities, Current and Increase in Traffic, Parking and Doctors.  

The National Planning Policy Framework (paragraphs 152, 156, 157, 162, 173) emphasises the importance and requirement for Local Planning Authorities to plan for the appropriate infrastructure to support development as part of the Local Plan process.

Page 10 of the Infrastructure Delivery Plan that supports the Local Plan states the following:

“The Schedule presents the infrastructure needed to ensure that all development is policy compliant, in relation to the level of social and physical infrastructure required to serve the needs of the additional population. In reality, service delivery is complex, and limited by financial constraints. It will be for providers to decide how best to deliver services and meet new infrastructure demands.”

The last sentence clearly shows that it is being left to ‘providers’ to meet new infrastructure demands, which by default implies that the Local Plan itself has not adequately planned for the demands.

In addition, the provision of various forms of open space throughout the Plan Area is classified only as ‘Desirable’ (the lowest priority) in the Infrastructure Delivery Schedule, with the meaning described as ‘This type of infrastructure would improve operational capacity, and deliver other wider benefits, but would not prevent or delay the delivery of further development’.

The feedback received from residents within the Plan area clearly shows that infrastructure is the most important factor when considering new homes. Residents have clearly stated that acceptance of the level of development proposed in the Local Plan is contingent on securing the right infrastructure to cope with not only current shortfalls in provision, but to manage the increased demand.

The Steering Group feels that the Local Plan fails the test of being consistent with National Planning Policy as demonstrated above.

In terms of the required changes that would be necessary for the Plan to be ‘sound’, more specific detail would be needed to show that the infrastructure needed to support sustainable development had been secured in terms of who, how, and when, and for the Local Plan to make a firm commitment within the Plan document itself that without the necessary infrastructure, permission for housing will not be granted.

The Steering Group would like the opportunity to represent the residents of the Neighbourhood Plan Area at any subsequent hearing as part of the examination in public.

For more information, go to:

EFDC 14th December Council meeting full agenda including Submission Version of Local Plan – http://rds.eppingforestdc.gov.uk/ieListDocuments.aspx?CId=296&MID=9455#AI63797

EFDC Local Plan information – http://www.efdclocalplan.org/technical-information/

Department for Communities and Local Government publication entitled Neighbourhood Planning – https://www.gov.uk/government/publications/neighbourhood-planning