A VIGOROUS RESPONSE TO A SHABBY APPLICATION – ONTO THE NEXT STAGE
What a splendid response to that shabby application from Landsec. Many thanks to all who have written such excellent comments in response which provide UDC with an impressive range of arguments to encourage them to reject this shameful application and plenty for the Inspector to consider should Landsec take an ill-judged decision to Appeal.
We are very grateful to you all for your support and for the effort that has so clearly gone into producing comments of this quality, especially given the difficulty encountered by so many in lodging their comments. It is particularly pleasing to see the passion evidenced in these submissions; a passion to preserve for those that follow the unique asset that is Easton Park, the Richmond Park of northwest Essex.
Equally, we are, as ever, extremely grateful to Great Dunmow Town Council and Little Easton Parish Council for their excellent submissions. Throughout this vexed process that started back in April 2017 when the last draft Local Plan was issued by the previous administration, GDTC have led with exceptional and highly professional submissions focusing on the key technical issues with support from expert lawyers and consultants. We are equally grateful to LEPC who have supported with equally targeted messages focusing on issues relating directly Little Easton notably highlighting the exceptional heritage. Meanwhile, we at SEP have sought to complement this work by reflecting the concerns of the wider local communities free from the constraints that inevitably restrict formal bodies. The SEP comments on this application in which we seek to highlight the cynical opportunism of Landsec and the shortcomings of their submissions are below.
This application can only been seen as an attempt to capitalise on UDC’s lack of a five year housing supply in order to advance Landsec’s aspirations to build a new town at Easton Park. It sits uncomfortably with the front page of the Landsec website which trumpets “Let’s talk sustainability” and “For us at Landsec, sustainability is personal” and their support for Mental Health Awareness Week. But it is interesting to note that there does not appear to be a single reference to Easton Park in 244 pages of their Annual Report issued in May. This must surely indicate a certain lack of confidence in this project.
We now wait for the response from UDC confident that they will dismiss this application as the sham that it is.
Meantime, UDC are now progressing the analysis that will underlie the next draft Local Plan due to be published early next year. This involves the drafting of key underlying documents such as the Sustainability Appraisal and the assessment of responses to the Call for Sites. The process will evolve over the months to the end of the year when the key decisions will be taken.
Under the current administration, UDC is seeking as much engagement as possible with the local communities, a welcome change, first through the public consultation, the Community Stakeholder Forum which closed in April, but also through the Local Plan Leadership Group which meets about once a month to review progress on key documents and issues. These meetings are open to the public by Zoom and comments can be submitted. We would encourage you to follow these meetings. The agendas and documentation are available on the UDC website and the meetings are recorded on YouTube. The next meeting is scheduled for 7.00 pm on 29 July.
Our objective is to ensure that Easton Park is not allocated under the next draft Local Plan that its unique qualities are recognised as a vital resource for the Uttlesford District and for future generations. The Richmond Park of northwest Essex.
We need your continued efforts to garner support through word of mouth, written contributions to the local press and social media and by your active participation over the next six months. We have been pursuing our mission for over four years but now is the crunch time to secure this ancient haven for those that will follow, just as the great parks of London were reserved 500 years ago and now provide essential respite for that great city.
As ever, with our thanks.
The SEP Committee
11th July 2021
LAND EAST OF HIGHWOOD QUARRY, LITTLE EASTON, ESSEX UTT/21/1708/OP – SUBMISSION FROM STOP EASTON PARK
This application should be seen as nothing more than a cynical attempt by the applicant, Land Securities, to capitalize on the current lack of a five-year housing supply in Uttlesford as a means to further its ambitions for the development of a new town at Easton Park. It is the thin edge of the wedge designed to achieve its larger ambitions based on an approach that was dismissed on appeal in 2016. It is an attempt to bully UDC into submission by drowning it with a weight of documents without regard to their quality in an attempt to distract from the all too apparent weakness of the application.
This application should be dismissed out of hand since it cannot be seen as sustainable and defies common sense in the following key regards:-
Coalescence – The proposal would entirely remove the historic divide between Great Dunmow and Little Easton to the detriment of both. It would be a further example of runaway urban sprawl in the south of Uttlesford without regard to the cohesion of existing settlements. The site is an isolated and exposed rural location outside the current development limits of Great Dunmow and Little Easton, which contributes to the rural quality and character of the area (particularly around the village of Little Easton). The proposed development would involve considerable intensification of the built form that would significantly alter the character of the surrounding locality and have an urbanising effect that is out of context with the existing pattern of development within Little Easton in particular.
Access – Access is limited to the High Wood Quarry entrance. Topographical and other restraints preclude additional access points. A single point of access is totally inadequate for a development of this size.
Congestion – The proposed application site is poorly connected and 1,200 new homes created by this development would be heavily reliant on car travel for most journeys, particularly adults travelling to work (low levels of unemployment in Great Dunmow demonstrate the absence of local work opportunities) and older children travelling to secondary school. The site is approximately 1.4km from the centre of Great Dunmow. Consequentially, each new family home is likely to have at least 2 cars. The proposed single point of access gives onto the gravel pit roundabout on the B1256, the main exit/access from Great Dunmow. This primary exit from Great Dunmow will already be overloaded thanks to the extensive building that is approved and in hand along the B1256 Bishops Stortford Road. In the morning rush hour, traffic exiting from this proposed development would have priority at this roundabout thereby bringing traffic exiting from Great Dunmow to a standstill. Great Dunmow does not have a train station with those who require train services for commuting to and from work and education reliant on the stations in Bishops Stortford or Stansted, meaning that this exit from Great Dunmow onto the A120 is of vital importance for the current population and any amount of increased traffic on the B1256 will cause gridlock and will significantly increase noise and air pollution.
Excessive expansion of Great Dunmow – Great Dunmow has been expanding at an alarming rate which will continue with approval for a further 2,000 new homes, some 4,500 people to add to the existing population of 9,000. This application would add a further 1,200 homes or some 3,000 people whilst the 149 hectares involved would increase the developed area of Great Dunmow by some 48%.
Such development would overwhelm both the historic market town of Great Dunmow and the equally historic centre of Little Easton.
Landscape – The proposal would destroy the landscape accessing the historic centre of Little Easton by Park Road. This aspect gives an exceptional view of the Conservation Area which includes the Grade 1 church and the Grade 2 Manor with surrounding almshouses, buildings and lakes, as well as providing access to the key features of the Easton estate – Gardens of Easton Lodge, stables, water tower, stable yard, laundry, west wing, footprint of Easton Lodge, rectory, manor house, church, alms houses and, of course, the deer park.
Environment – the excessive expansion of Great Dunmow already referred to above, including the new homes already being constructed along the B1256, is and will continue to result in the destruction of important habitat for local wildlife, in particular the deer who reside in and around the medieval deer park of Easton Lodge. In addition to the deer, the countryside around Great Dunmow and Little Easton is home to a great number of other species including badgers, reptiles, owls, kestrels, buzzards, bats, and hedgehogs. The proposals fail to provide sufficient ecological information as to how protected species will be safeguarded and how the existing ecology and natural habitats found on the site will be protected and enhanced. No new opportunities for increasing biodiversity are included as part of the proposals.
Agriculture – The proposal would result in the loss of further high-quality arable land needed for food production.
Infrastructure – The proposal would lead to excessive strain on limited infrastructure in the area including schools, GP surgeries and other support facilities. Great Dunmow and the surrounding villages are already at breaking point given the excessive recent expansion of the town without a corresponding increase in essential facilities such as medical establishments, schools, shops and public transport.
Loss of Footpaths and Bridleways – the proposed development will result in a loss of amenity for walkers, cyclists and horse riders. The proposal fails to make adequate provision for the preservation of existing public rights of way. The increase in traffic that the development will bring will make the country roads around Great Dunmow and Little Easton busier and more dangerous for vulnerable road users. This is a rural community with a high volume of equestrian traffic (equestrianism playing a significant part in the local economy to which a network of safe riding routes is essential). The proposal fails to explain how the existing bridleways will be protected and enhanced.
This application is supported by a mountain of documentation in the hope that it will evidence a well thought through proposal. This is not the case firstly because none of this documentation addresses the key limitations above and secondly because much of it is substandard. This can be evidenced by two of the key documents, The Sustainability Statement and the Landscape and Biodiversity Management Strategy which should go to the heart of the matter but fail to do so.
The Sustainability Statement (SS), which runs to 65 pages, has been produced by “Bioregional Development Group, a sustainability charity …. with 25 years’ experience advising on sustainable development across the world.”
Pages 6 and 7 give a summary of Bioregional and One Planet Living but para 1.2 on page 5 states that “This development has not been endorsed or assessed through Bioregional’s One Planet Living ‘leadership recognition process…..”. So, one has to query the relevance of this facade. The following 60 pages regurgitate a wide range of policies and platitudes to little obvious benefit. At no point does the document address the fundamentals of the application and anomalies are immediately apparent. For instance:-
➢ Section 7, Culture and Community, page 26, Development objective 12, “Development that respects regional identity and existing local communities”. Page 27 notes “Implement a landscape strategy that respects the setting of relevant focal points such as the Gardens of Easton Lodge, Little Easton and Great Dunmow based on a landscape character assessment and historic environment assessment.” However, there is no mention of the immediately adjoining Conservation Area comprising the Grade 1 church, the Grade 2 Manor House and Almshouses, other listed buildings and the exceptional lakes that is the historic centre of Little Easton. Either this is done deliberately to overlook one of the most obvious concerns or it demonstrates such a lack of understanding of the locality as to render the 65 pages worthless.
➢ Section 10, Local and Sustainable Food, page 41, Development objective 22, “The development supports local food production and celebrates regional agricultural knowledge and identity”. However, 149 hectares of prime agricultural land would be sacrificed to this ill- conceived proposal. Again, one has to query the value of these 65 pages.
The Landscape and Biodiversity Management Strategy (LMBS) suffers from similar weaknesses: –
➢ Section 3 covers the Existing Landscape but fails to give any proper analysis of the land in question or its immediate setting. The only reference to Little Easton is in para 3.4 where the sole reference is “…while to the north is the small village of Little Easton.” There is no reference in the document to the Little Easton Conservation Area which adjoins the proposed site comprising the Grade 1 listed church, the Grade 2 listed Manor House, almshouses and other dwellings or the exceptional landscape view approaching this historic centre from Park Road and the entrance to Easton Park. Nor is there any mention in Section 3 of the main part of Little Easton lying some half mile further to the north nor to the historic Easton Park adjoining the proposed site to the west, one of the great medieval deer parks of Essex dating back 700 years and more and still retaining the same identifiable shape and exceptional flora and fauna.
➢ Section 4 covers Vision, Aims and Objectives and includes under 4.2 “a clear and simple vision” as “The Proposed Development will be an attractive place to live, with a clear sense of place and landscape and visual amenity value that enhances the biodiversity and nature conservation value of the site, assimilated into the existing landscape setting.” Para 4.3 sets out the Aims and Objectives including Aim 2 “Retain Protect and Enhance Existing Features”, Aim 3 “Enhance the Biodiversity and Ecological Value” and Aim 4 “Enhance the attractiveness and sense of place of the landscape setting”. All these are admirable objectives but the complete lack of analysis or appreciation of the rare setting in question, both historically and in terms of the landscape visions and biodiversity, makes these Aims worthless.
The same weaknesses are evident in the Environmental Statement notably in the failure to recognize the exceptional merits of the historic centre of Little Easton :-
➢ Vol 1, Chapter 6, Landscape and Visual Amenity, where para 6.38 again glosses over Little Easton whilst para 6.48 incorrectly records the church as Grade 2 listed whereas it is Grade 1.
➢ Vol 1, Chapter 7, Historic Environment comprises 28 pages but again the great majority is a recitation of legal context whilst the analysis is woefully deficient. Para 7.34 refers to 67 listed buildings but fails to highlight that the concentration in the area immediately adjacent to the proposed housing whilst para 7.45 makes the extraordinary claim that “there would be no significant change to the above historic environment base line.” Paras 7.52 to 7.59 by focusing on the Gardens of Easton Lodge and the Little Easton Conservation area gloss over the key fact that both these are intrinsic elements of the Easton Lodge Estate along with Easton Park and several other notable buildings which together provide an exceptional example of a major country estate at the turn of the 19/20th centuries. Equally, Likely Significant Effects by highlighting individual assets, fails to recognize the devastating impact this proposal would have on one of the key historic sites of the District and some of the best landscape vistas.
In a considered application, it is reasonable to assume that key documents, such as the SS and LMBS, and the Environmental Statement, should address the fundamentals of the location in question and the impact on its surroundings. Evidently, they do not. Indeed, they present a facade of ‘compliance’ whilst hiding the reality. So, it can only be assumed that they have been written with the intention of influencing parties who are not familiar with the detail of the site, such as an Inspector on appeal.
Equally, there is no reference in these documents to the key point that this application, as confirmed to Little Easton Parish Council, is the first phase of a larger proposal for some 8,500 houses at the adjoining Easton Park which has now been submitted to UDC under the Call for Sites for the new local plan though details have yet to be made public.
This application should be rejected on its fundamentals and be seen for what it is, a cynical attempt to capitalise on the lack of a five-year land supply with a view to opening the way for both this proposal and a far larger one at Easton Park to the benefit of Land Securities and to the great detriment of the local communities of Great Dunmow, Little Easton, Canfield, Takeley and Thaxted which are in bad need of the open space that the restoration of Easton Park would provide.
STOP EASTON PARK
5 July 2021