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News  »  Hunsdon, Eastwick and Gilston Neighbourhood Plan Group response to the pre-application consultation held by the applicants Places for People and City & Provincial Properties.

   Hunsdon, Eastwick and Gilston Neighbourhood Plan Group response to the pre-application consultation held by the applicants Places for People and City & Provincial Properties.    24 March, 2019

Hunsdon, Eastwick and Gilston Neighbourhood Plan Group response to the pre-application consultation held by the applicants Places for People and City & Provincial Properties.


This letter has been sent to Places for People / City & Provincial Properties, East Herts Council, Gilston & Harlow Garden Town Board, Herts County Council, East Herts Council election candidates and Mark Prisk.


Dear xxx,


This letter is in response to the material shown at the planning pre-application exhibitions that took place in Harlow, Gilston and Hunsdon in the first half of March 2019. These correspond to four separate forthcoming planning applications.


This letter addresses issues of principles that apply to all applications and, under separate headings, matters relating to the individual applications.


1          The principle of working with the community


  • Centuries of organic and locally driven development have created the mosaic of fields, landscape and distinctive settlements that characterise the Gilston Area. Regrettably, in the rush to deliver houses at all costs, many of the areas in Hertfordshire and Essex are losing their identity and feel ‘invaded’ by inappropriate development. Real, active participation in the development of proposals is seen by Government and planning authorities as a critical step towards creating good places.
  • This is clearly indicated in the NPPF (2018, paragraph 125), which states: “Plans should set out a clear design vision and expectations, so that applicants have as much certainty as possible about what is likely to be acceptable. Design policies should be developed with local communities, so they reflect local aspirations, and are grounded in an understanding and evaluation of each area’s defining characteristics”.
  • In the EHDC District Plan (2018, Policy GA1) explicit reference is made to:
    • Prior to the submission of any planning application(s) further design work through the pre-application engagement process will be required in order to agree, among other things, the quantum and distribution of land uses, access and layout principles (II) – establishing that design includes, quantum of development, layout, etc.
    • strong vision, leadership and community engagement (III)
    • A community engagement strategy will be prepared, working with the two local parishes, which will include consideration of managing the effects on local residents, and opportunities for them to participate in the emerging new community. (IV)
  • The communities of Hunsdon, Eastwick and Gilston have offered again and again their availability and openness to a constructive and collaborative process. This has not taken place. The exhibitions earlier this month constitute mere ‘information’ (as indicated on Page 3 of the Application Guide on the Gilston Area website) and do not constitute a sufficient response to the requirements of the NPPF and of Policy GA1.
  • The communities, through the two Parish Councils and the Neighbourhood Plan Group are, once more, inviting the promoters of the Gilston Area development to a dialogue and on-going collaboration to achieve a better development that is distinctive and grounded in the area’s specific character, as advocated by the NNPF.


2          The Concept Framework and Development Charter


  • A year ago Places for People (PfP) and the community invested a lot of time and effort in the preparation of a Concept Framework, which included vision, objectives and principles of development that were agreed by all parties. We would have wanted the Concept Framework to go further, but still consider that it represents a good basis for the future of the Gilston Area.
  • We are therefore disappointed that neither the agreed Vision nor the Objectives and Principles of the Concept Framework are being referred to or addressed / answered as part of the pre-application exhibition. In some cases, they have been replaced with ‘marketing orientated’ messages such as ‘A Place to Grow, Explore, Innovate’.
  • The work jointly undertaken on the Concept Framework (and which was also supported financially by Places for People) is not even mentioned in PfP’s own Application Guide (Page 3), where other less successful ‘events’ like the workshop on transport, which left the community greatly dissatisfied, are given great prominence.
  • The presentation boards/information make reference to a Development Charter, which EHDC, under the banner of the Garden Town, started work on around six months ago. This was meant to be followed up with a series of monthly workshops which never took place. Given the lack of any follow up this feels like an abandoned initiative that should not be used as a basis for development.
  • In our view, all of the above demonstrates that ‘working with the parishes’, ‘leadership and community engagement’ and participation (as indicated by Policy GA1) have not taken place, and where they have, they are seemingly disregarded.
  • Because to the importance of the agreed principles of the Concept Framework, the Neighbourhood Plan Group (HEGNPG) (whose area covers the entire GA1 Policy Area) has agreed to adopt them as the foundation policies of the Neighbourhood Plan, currently in preparation and due for formal consultation by Autumn 2019.
  • We suggest that all marketing messages are stripped from the forthcoming planning applications and that the Vision, Objectives and Principles of the agreed Concept Framework are clearly addressed in the presentation of the proposals. This would go someway to recognising the work of the community and also respond to Policy GA1, where the Concept Framework is clearly referred to as a ‘benchmark’.


3          Garden City Principles


  • Garden City Principles are at the foundation of allowing development in the Gilston Area. They have always been presented by the promoters as their guiding approach, and they are implicit in the whole Gilston and Harlow Garden Town initiative. They are also explicitly referenced in Policy GA1 (III), put forward by the developers themselves at the time.
  • The exhibition material no longer makes any reference to the Garden City Principles, either as proposed by the TCPA or as indicated in District Plan Policy GA1.
  • The Policy (GA1-III) makes clear reference to Land Value Capture and Community Ownership of Community Assets. The need for a clear mechanism to deliver community stewardship and local resident participation is very explicit, in GA1-VII. Land Value Capture, a key component of Policy GA1 must mean more than the existing S106 or CIL established mechanisms. These have consistently been key undertakings made by EHDC and endorsed by the applicants and are immensely important for the community. So far, our requests for clarification are still unanswered.
  • We strongly advocate that these matters, which must be explicitly addressed in the planning application process, are discussed with the community as soon as possible. We propose a meeting with the Parish Councils and Neighbourhood Plan Group to address this complex issue, and help the promoters explain their approach to the community more widely.


4    Main Proposals (PfP and CPC)


  • From the exhibition, there was no clarity between what was for marketing / illustrative purposes and what is being applied for. This lack of clarity makes it very difficult for the community to respond in a constructive and meaningful way.
  • Some issues that matter to the community were not sufficiently clear or explained:
    • The components of the strategy for sustainable and integrated transport (Policy GA1 III and V(j), V(l)) including the setting of clear targets for use of sustainable transport and integration with Harlow. Existing communities also need to understand how enhanced provision will help them.
    • The plan for infrastructure delivery to ensure that infrastructure is provided ahead or in line with need, including addressing the ‘significant needs’ referred to in the District Plan.
    • How the project will be phased, with a plan showing the interrelationships of what will happen when, the Local Plan allocation extends beyond the current Plan period but there seems to be no reference to this.
    • A strategy to limit disturbance during construction to all residents and wildlife.
    • A commitment to protect and enhance the existing areas of woodland and other green infrastructure across the site, which is in need of attention now after years of neglect (a possible ‘early win’ with the community).
  • We assume that not all parameter plans were presented and made available on the Gilston Area website. The Parish Councils and Neighbourhood Plan Group would like to see that the objectives and principles of the Concept Framework are clearly respected and that additional detail is provided as part of the Outline Planning Application:
    • Clear boundaries defining each of the seven villages with ‘appropriate landscape buffers in order to protect the individual

character and integrity of Eastwick and Gilston villages’ and protection of key views (Policy GA1 V(n) and (o)) clearly ensuring that the buffers are meaningful and manageable as significant natural open space

  • Density of each village and within each village, following the agreed principle of denser core and soft edges
  • Number of units and employment within each village
  • Maximum heights presented in a comprehensible way and not confused with issues related to terrain and ridge views. Heights should be set as a maximum and in line with a clear approach to village character. The maximum of 18m above ground level (6 floor equivalent) for all centres is openly at odds with the concept of a village, and the limitation to 11m above ground level only at the key fringes only is insufficient to provide clarity of what it is proposed. We have been assured that ‘Hertfordshire villages’ would be created; such villages are mainly 2 to 3 stories not the higher scale developments found in town centres.
  • More needs to be explained about the future status and regime for the land to the north and west of the high-tension cables (including the former wartime airfield) and how this will be managed as a community asset and as an early win.
  • Additional information is needed regarding the interface between the proposals and the surrounding areas:
    • Between the proposals and the existing community
    • Between Village 7 and Villages 1-6 and the rest of the area, in terms of boundary, infrastructure and sustainable and integrated transport. The two proposals may be separate applications, but clearly have to be considered jointly.
    • The continuity of the ‘green corridors’ beyond the red line of the outline application boundary
    • The relationship with the Stort Valley corridor, partly owned by the applicant, which was prominently presented as an asset for recreation in the Concept Framework and previous workshops and now no longer mentioned.
    • The improvements to access and public realm with Harlow Town Station, a key gateway for the project. Providing a means to arrive to the station without any improvement is not considered appropriate.
  • We understand that village master plans will follow to present in more detail the design approach to the development. We assume therefore that visual representations of the sites (other than in the parameter plans) is for illustrative purposes only. However, we consider that some of the detail presented is premature and counter-productive in absence of the overall design framework and rationale for the seven distinctive villages. The illustrative material presented did not respond to:
  • The NPPF (Section 12), which clearly states that proposals should set out a clear design vision, which should be developed with local communities and reflect local aspirations.
  • The Gilston and Harlow Design Guide (page 40 for the Gilston Area) which suggest the patterns, scale and layout of the existing villages should be used as a cue for the future ones and that densities and rooflines should be fragmented to reflect local character.
  • The requirement for distinct villages with beautifully and imaginatively designed homes (Policy GA1)
  • The treatment of Church Lane through the village centre will potentially route significant traffic through a pedestrian priority area, creating problems from the outset – this needs to be studied in detail with the community in conjunction with a clearly stated design ambition.
  • The community overall considers that the information presented at the beginning of March is either incomplete or misleading. We are looking forward to further opportunities to understand more clearly what it is being applied for and how the applicants intend to ensure that the proposals gain local support. Once again we reiterate our wish to work collaboratively for an attractive and imaginative development, which is appropriate to this part of Hertfordshire and is in line with the agreed Concept Framework.


5          Eastern and Central Crossings


  • The community appreciates that the design has been changed following consultation and that proposals try to be ‘compact’ and the alignment is slightly better for the residents of the Terlings Park area of Gilston.
  • The community is at a loss in understanding the rationale and the impacts resulting from the proposals. The applicants have been allegedly instructed by EHDC and HCC to work on the assumption that the eastern crossing has to carry traffic to the new J7a on the M11. However, both HCC and EHDC have stated that they have done no assessment of the options or detailed appraisals of the existing route, as this was being done by the developers.
  • HCC A414 Strategy, to which we strongly objected, realigned the A414 through Pye Corner and closed to traffic the other existing river crossing. The solutions presented by PfP are for a different approach. The rationale and design parameters of either proposal are not being explained. Impacts in terms of traffic, noise, pollution, and light pollution have never been quantified and presented.
  • The fundamental issue of principle is that it is not right to align a major through road through the middle of a residential community, seemingly without any assessment of the benefits and impacts or analysis of options. The relief to the Edinburgh Way retail parks is likely to be minimal, compared with the severity of impacts created by rat-running through Gilston. These proposals seem to be in direct contradiction with the aims of sustainable communities, reducing segregation, promoting sustainable travel.
  • Modelling (strategic and local) has been done of the proposals, and the community is keen to discuss the outcomes of the modelling work and understand what parameters have been used to determine the outcomes.
  • Additional issues specific to the area of Pye Corner needing further clarification:
  • The entrance to Terlings and Pye Corner requires CPO for land and will result in unacceptable impact in terms of segregation from the rest of Gilston and environmental impact (air quality, noise and light pollution) on the residential communities. It is not clear what is the scale of the impacts and how they are proposed to be remedied.
  • The ‘sweep’ of the road away from the Terlings Park houses appear to indicate a design speed which is not appropriate to the location close to the heart of Gilston village.
  • The overall impacts of the proposals on the C161 in both directions (Eastwick Roundabout and High Wych) should be explained.
  • Access to homes and businesses from Pye Corner to St Mary’s Church needs to be better understood.
  • The interface with Burnt Mill Lane is poorly explained and ‘greyed out’.
  • The A414 Strategy proposed that the central crossing would be linked directly to the sustainable transport corridor of Harlow and dedicated to public transport, cycling and pedestrians only – as a pillar of the sustainable transport strategy for the Garden Town. The proposals presented have constrained pedestrian crossings (six stages before being able to cross diagonally?), an elevated cycle bridge (a solution widely discredited since the 1970s) and a single bus lane in one direction. These proposals appear to be contrary to the aspiration for sustainable travel, as they actively discourage walking, cycling and using the bus.
  • The cycling over bridge is unacceptable, as it creates significant visual intrusion and only result in cyclists using the road with no safety measures, its exposure to the prevailing south westerly winds again makes it likely to be poorly used.
  • Additional issues specific to the area of Eastwick Roundabout needing clarification:
  • The benefit of replacing the roundabout with a signalled crossing is not clear: will there be a reduction in delays? How much delay will there be off peak, when now one can rapidly go through?
  • What would be the noise, pollution and light pollution derived by the proposals?
  • We note that the promised ‘improved access’ to Harlow Town Station and additional northern entrance are no longer part of the proposals. They should be included in the detailed application for the crossings and constitute an early win. The Harlow Garden Town Board has set an ambitious Vision for Harlow, the currently poorly managed station interchange is at complete odds with that Vision; it cannot be right that these issues are simply ignored.
  • The community expects that the detailed planning application for the road crossings will include:
  • Clear design rationale and design parameters, such as assumed design speed
  • Complete assessment of options and of benefit of the proposed solution
  • Cycle route provision and how routes will connect and serve the wider area
  • Realistic video of micro-simulation modelling of the existing situation (base and with development) and of the proposed solution, so that lay people will be able to understand the future movement patterns
  • Detailed landscape design of the areas within the red line of the application
  • Detailed engineering design with clear identification of carriageways, road markings, signals, road signage, street lighting, control boxes, etc. including the approach used to minimise clutter and visual intrusion
  • Clear identification of environmental impacts and mitigation strategy.
  • It is clear that the information provided to the community at this stage is very superficial and inadequate to understand the proposals and their merit. In the interest of collaboration, and with the objective of identifying the best practical solution, we would like to hold a technical meeting between a restricted group of community representatives, assisted by our consultants, and Places for People transport experts where options and technical data are presented in confidence. We believe that, with greater understanding of the transport issues and constraints, we can greatly help explain your proposals to the wider community.



6          Conclusion


It feels that there is much work still needed, or that not much has been shown. We believe that the time has now come to re-engage in constructive engagement with the Parish Councils and the Neighbourhood Plan Group, and be prepared for greater community participation going forward. As work on the Neighbourhood Plan is starting, based on the Concept Framework and with a view of Reg. 14 Consultation in Autumn 2019, the Neighbourhood Plan Group expects to play an active part on behalf of the community in the shaping of the area as a whole. (Note - As a Community we have asked to meet the Garden Town Design Review Panel to make our views known but sadly all our approaches have to date been rebuffed despite the Local Plan statements on the importance of Community engagement).


We look forward to hearing from you and establishing the mechanisms for collaboration and interface, which will lead to better development and an easier planning process for all of us.



Anthony Bickmore, Chairman, HEG NPG

24th March 2019

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