Purpose

Purpose: 
To
agree the proposed response to Uttlesford Local Plan (Regulation
19) Submission Draft consultation. 
 
Uttlesford District Council is carrying out consultation on its
Submission Draft Local Plan between 8 August and 14 October
2024.  
 
The
consultation materials are available online: 

Local Plan (Regulation 19) consultation - Uttlesford District
Council
 
Given
the proximity of Uttlesford to South Cambridgeshire, the contents
of the Uttlesford Local Plan could in principle impact on the
emerging joint Greater Cambridge Local Plan, and a joint response
from Greater Cambridge is recommended.
 
Background: 
 
The
Submission Draft is the final stage in the preparation of this
plan. Uttlesford District Council previously consulted on the Draft
Plan (Regulation 18) in November to December 2023, to which joint
responses were made by Cambridge City Council and South
Cambridgeshire District Council. Responses to this final submission
draft will be sent alongside the Local Plan and supporting evidence
to be examined by an independent inspector appointed by the
Secretary of State. 
 
The
Local Plan contains planning policies and allocations for the
growth of Uttlesford over the plan period from 2021 to 2041. It
contains the council’s Spatial Vision and Strategic
Objectives grouped under the ‘environmental’,
‘economic’ and ‘community/social’ headings
that run throughout the plan. The Spatial Strategy identifies the
appropriate locations for development, the level of housing to plan
for, the amount of employment land to meet their needs to maintain
and develop the local economy and to provide a range of services,
as well as the facilities and infrastructure needed. It also seeks
to address the challenges of climate change, support biodiversity
Net Gain, achieve sustainable development and protect the
environment.
 
The
Spatial Strategy is underpinned by five core policies; addressing
climate change; meeting our housing needs; settlement hierarchy;
meeting business and employment needs; providing and supporting
infrastructure services. The Plan identifies four Area Strategies
and also includes a series of district-wide policies.
 

Main Issues:
 
Content in the Uttlesford Local Plan
(Regulation 19) Submission Draft relevant to Greater Cambridge
includes:? 
 

Exceeding their objectively assessed development needs –
the identified need is for 13,500 homes in the period April 2021 to
March 2041 and 14,741 homes have been planned for, to provide for
flexibility and contingency and help maintain a five-year land
supply (Core Policy 2). 
No
strategic housing allocations proposed close to the South
Cambridgeshire boundary. 
Growth
is directed to the most sustainable settlements which have the
existing infrastructure and/or capacity to expand infrastructure
and reduce the necessity of car use wherever
possible. 
Provision of employment land to meet the employment needs
assessment, including office and R&D (19 hectares) and
industrial and logistics (38.5 hectares) (Core Policy
4).
Great
Chesterford Research Park, close to the South Cambridgeshire
boundary, is allocated for R&D (13.5 hectares) (Core Policies 4
and 6).
The
plan recognises the issue of water stress in the district and wider
area and the impact this is having on chalk streams, and proposes
measures which seek high standards of water efficiency for new
residential and non-residential development (Core Policy
34).  
The
plan seeks to address the climate and ecological emergency,
including by requiring higher energy standards than Building
Regulations Part L requiring that new buildings are designed and
built to be Net Zero Carbon in operation, and 20% Biodiversity Net
Gain (Core Policies 1 and 40).

 
Water
The
Councils’ response to the Uttlesford (Regulation 18) Draft
Plan consultation raised concern over whether
the overall demand for water resulting from the growth proposals in
the Draft Local Plan has been considered in relation to regional
water plans and Affinity Water's latest WRMP24, and that the level
of abstraction required to support development proposed in the
draft Local Plan is sustainable.
 
The
Councils’ Regulation 18 response also suggested Core Policy
34 could be more explicit on how a development must contribute to
achieving 'good' status and must not lead to a reduction in
groundwater levels or flows in watercourses. The policy does not
provide any required levels of water efficiency for new
non-household developments, which should be included. The benefits
of integrated water management in new development could be drawn
out more in the policies. The Policy could seek opportunities for
aquifer recharge through appropriate land management.
Uttlesford District Council has published updated evidence for
the Regulation 19 Submission Draft Plan (Water Cycle Study and
Chalk Stream Evidence) which provides
clarification on a number of issues raised in the Councils’
Regulation 18 response and amendments have been made
to Core Policy 34 Water Supply and Protection of Water Resources to
reflect the updated evidence. The evidence base shows water supply
has been considered with the Environment Agency and takes account
of water company plans; the wording in Core Policy 34 is now
firmer, requiring demonstration of measures to minimise
consumption; supports developments that achieves at least 90l/p/d
for residential and now includes a requirement of non-residential
to achieve at least 3 credits in BREEAM Wat01. In addition,
Policy 35 seeks to protect and enhance watercourses including
valuable chalk streams; with further clarity provided in the
supporting text at paragraph 9.136 which details the types of
mitigation responses and paragraph 9.137 outlines ways of improving
ecological condition of waterways which are encouraged.
 
The
updated evidence base and amendments to policy address the
Councils’ previous concerns.
 
Chesterford Research Park employment allocation
 
In
response to the Regulation 18 consultation the Councils sought
clarification on the transport impacts of the employment
allocation, noting the Transport Evidence Topic Paper and
Infrastructure Delivery Plan made no reference to the impact of
additional job provision on travel patterns or infrastructure
need.
 
Further
transport evidence has been published alongside the Regulation 19
Submission Plan which shows the Local Plan site allocations,
coupled with employment growth within South Cambridgeshire (at
Wellcome Genome, Babraham Research, Granta Park and Cambridge
Biomedical Campus), will have an impact on M11 Junction 9a Stump
Cross. The evidence reports this is expected to add to queuing and
delays on the southbound slip and that it is likely an improvement
scheme will need to be delivered with National Highways, Essex
County Council and South Cambridgeshire District Council. It also
reports that a mitigation scheme to widen the slips could alleviate
the Local Plan growth back to the Reference Case (committed growth)
scenario, but the approaches to the junction would remain over
capacity and that these would not be the responsibility of
Uttlesford District Council since it is caused by increasing
committed and background traffic flows rather than the Local Plan
traffic.
 
There
is no further detail within the Regulation 19 Submission Plan in
relation to the transport impacts of Chesterford Research Park
allocation. Core Policy 4 Meeting Business and Employment Needs has
been amended to support development at the allocated sites where
they meet the requirements set out within the Site Development
Frameworks, as well as being in accordance with the Area
Strategies. The Chesterford Research Park Site Development
Framework (in Appendix 2b) incorporates a Framework Plan and a
series of issues that should be addressed by any design proposals,
under broad headings; Design Principles, Transport, Heritage,
Landscape and Green Infrastructure and Biodiversity. In transport
terms this seeks to ensure improved accessibility by active modes
and public transport, although also listed are; delivering
improvements to junctions as identified in the transport evidence,
and seeking contributions to transport and highway infrastructure
identified in the Infrastructure Delivery Plan. However, there are
no references in Plan Policy or Infrastructure Delivery Plan on to
the need to improve M11 Junction 9a. 
 
Officers are exploring the transport implications with
Cambridgeshire County Council as local highway authority and
Cambridgeshire and Peterborough Combined Authority as local
transport authority, but at the time of writing had not received a
response. As such the proposed response notes that this issue is
currently unresolved, and notes that the Councils’ response
to the issue will be led by the comments of Cambridgeshire County Council and Cambridgeshire and
Peterborough Combined Authority, as the local highway and transport
authorities for Cambridgeshire.
 
Climate
and biodiversity policy approaches
 
The
Councils supported the ambitious climate and biodiversity policy
approaches, including a requirement for 20% Biodiversity Net Gain
as these align with the Councils’ own priorities and
ambitions.
 
Statement of Common Ground
 
The
Localism Act 2011 sets out the Duty to Co-operate and as part of
its duties Uttlesford District Council has prepared a Statement of
Common Ground (SoCG), which is a publicly accessible document of
whether agreement has been reached between the Councils on
cross-boundary strategic issues. The purpose of the SoCG is to
document the cross-boundary matters being addressed and progress in
co-operating to address them. As the content of the SoCG is a
factual representation of the comments the Councils make to the
Regulation 19 Submission Draft Local Plan officers have delegated
authority to sign-off the content and it does not form part of this
decision.
 
Proposed main response points: 
The
proposed response, set out in Appendix A, focuses on matters which
could impact on Greater Cambridge and include water stress and the
impact this is having on chalk streams, housing and employment
growth and allocated sites (in particular Chesterford Research Park
employment allocation), addressing the impacts of climate change
and nature recovery.

Content

For the
Joint Director for Planning and Lead Cabinet member for Planning
Policy and Delivery agree the response to the Uttlesford Local Plan
(Regulation 19) Submission Draft consultation as set out in
Appendix A.
 
A
parallel decision is being considered by Cambridge City Council to
be agreed, and delegated authority is given to the Joint Director
for Planning to agree any minor amendments to the response agreed
by the City Council that are consistent with the response at
Appendix A.
 
For the
Joint Director for Planning and Lead Cabinet member for Planning
Policy and Delivery to note that the content of the Statement of
Common Ground will reflect the agreed response (at Appendix
A).

Reasons for the decision

To
provide the Councils’ comments to this consultation in
recognition of the opportunities it provides to influence the
Uttlesford Local Plan.

Alternative options considered

Option
1: To not agree the proposed response to Uttlesford Local Plan
(Regulation 19) Submission Draft consultation.
 
Reason
for Rejection: the consultation offers the opportunity for the
Council to make comments on a neighbouring local authority’s
Local Plan to ensure the Councils interests are appropriately
represented. The Council is also a statutory consultee and Duty to
Cooperate body in the plan making process.