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However this is a cautionary tale – ambition is a great thing, but when we face a national housing crisis, that ambition must be matched by convincing evidence of future delivery.
The three proposed GCs are:
Each of the North Essex Authorities (NEAs) also prepared a ‘Section 2’ Local Plan, setting out other allocations and development management policies.
In isolation each of these GCs would require robust justification, evidence and assessment, but in this case 43,000 new homes were proposed on just three sites, to be delivered over a number of decades running towards, if not beyond, the end of the century.
The Examination of the Section 1 Local Plans commenced in January 2018. In June 2018 the Inspector wrote to the NEAs to set out numerous concerns regarding the Plan and its evidence base and in particular, the delivery, viability and sustainability of the GCs. In the case of the Colchester/Braintree Borders GC, an existing railway station was in a peripheral position which would integrate poorly with the structure of the GC. There was a proposal to relocate the station, but the viability appraisal showed that the funding to achieve this might not be available until 30 years into the build programme. The concerns did not just relate to the GCs themselves, but to the associated infrastructure as well.
Even at that point, the Inspector mooted (as one of three options) that perhaps the NEAs should withdraw the Plans from Examination. However they collectively voted to continue with the Examination, essentially looking for solutions on the fly.
This culminated in a consultation in summer 2019 on ‘Suggested Amendments’ and a wide range of updated documents, all designed to overcome the Inspector’s concerns and demonstrate the deliverability, viability and sustainability of the GCs.
During the course of recent years, the NEAs would have also been comforted by the fact that the Tendring/Colchester Borders and Colchester/Braintree Borders GCs had been granted HIF funding of nearly £400m, whilst the West of Braintree GC was identified on the list of new Garden Towns.
The examination sessions resumed in January 2020, two years after they first opened. To all those attending the resumed sessions it would have been abundantly clear that the Inspector recognised the importance of these Plans and would ensure that they were robustly examined. A reasonable approach given that these schemes would be delivered over such a significant timeframe.
Undoubtedly the outcome of the Uttlesford Local Plan (itself found unsound in January 2020) had a significant impact on the NEAs’ plans. The West of Braintree was partly within Uttlesford District, with that area providing a critical connection on the Rapid Transit System route from Braintree towards Stansted Airport.
The Inspector’s post hearings letter was published on 19 May 2020 (dated 15 May) and he has evidently not been convinced by the updated evidence and retains concerns about the viability, deliverability and sustainability of the Plan. Significantly, and perhaps unsurprisingly, the Inspector addressed the timeframe for delivering the GCs:
“In my view, the Plan could not be considered to be sound if I were to find that the proposed GCs were justified having regard to their ability to provide for strategic development over many decades to come, but reached no finding on whether or not they were deliverable beyond 2033.”
This is also a case which highlights the need for joined up, consistent evidence. The GCs themselves were complex, but underpinned by complex and costly infrastructure which was necessary to make them sustainable. If the infrastructure was not viable and could not be delivered, evidently this would have knock on consequences for the sustainability of the GCs.
Ultimately, the Inspector found that only the Tendring / Colchester Borders GC should be retained and that the other two GCs should be removed. Alternatively, that the Plans should be withdrawn from examination.
The planning system, and Local Plans in particular, play a hugely important role in redressing the housing market and crisis which currently exists. Whilst we fundamentally support the principles of planning for large scale growth characterised by new garden communities, where plan making authorities are planning for potentially undeliverable growth this is effectively aiming for a false horizon. An alternative approach of utilising a broader range of more deliverable and more readily sustainable solutions may have led to a dramatically different outcome in this case. Similarly a more balanced and comprehensive spatial strategy, with less specific reliance upon the GCs to be the main drivers of overall delivery in the early years of the trajectory, may have also been more successful.
We wait to see how the NEAs will respond. They are said to remain committed to the “principles that made the garden communities so beneficial to the community”. How that commitment now manifests itself over the coming months and years may have significant spatial consequences for North Essex over the longer term.
21 May 2020
Senior Director, Head of Sustainability
Director, Head of Economics