Comments on Strategic Housing Land Availability Assessment
I should like to make the following comments on the draft Strategic Housing Land Availability Assessment (SHLAA) for Uttlesford.
On 5 December 2007, I received a response from Roger Harborough to e-mails that I sent to Uutlesford District Council on 30 September and 12 November 2007. In that e-mail, he stated:
"For each of the Options included in the Preferred Options consultation, the anticipated infrastructure requirements are set. In relation to option 4, no new road other than an internal link road from Old Mead Road to Hall Road is identified as necessary. The roads used to access the development north east of Elsenham would therefore be the existing road network. How traffic would route over that network is under further consideration. In particular, the need to consider various “what if” scenarios is being looked at. This work is being carried out in parallel with the public consultation and views expressed in response to the consultation document will be analysed and may well lead to further technical work by the Council in conjunction with Essex County Council as the highways and transportation authority and the Highways Agency."
In responses to the public consultation held from December 2007 to January 2008, I and many others pointed out that, whatever the prospective developers might have "identified as necessary", the existing access roads to Elsenham are already inadequate and cannot possibly support the additional traffic that would be generated by a substantial development in the Elsenham area. The figures given on p 11 of the Fairfield Partnership's "Initial Road Link Capacity Assessment" (31/7/06, with addendum dated 26/9/07) are very obviously wrong, so that their conclusions as to the adequacy of the the existing roads are patently unreliable.
In relating to the SHLAA consultation, therefore, I should like to make the following response:
(1) Has the technical work and consideration of "what if" scenarios referred to in the above extract from Roger Harborough's e-mail yet been carried out? If so, have the results been published and where can I obtain a copy or see it online? If not, will it be available soon? If not, why not?
(2) In the Site Appraisal Information Sheet relating to Elsenham in SHLAA Appendix 8, the highway access to most sites is rated "Green", which I presume indicates that the road access to Elsenham is considered to be good and capable of carrying the increased traffic that would result from housing development. How is this rating justified, and what is the evidence upon which these ratings are based?
(3) In Paragraph 4.10 of the SLHAA it states
" . . . All the sites are considered achievable although a question mark is raised at Elsenham where it needs to be demonstrated that road access suitable for high volumes of traffic can be achieved, or that a significant shift to other modes of transport can be realistically achieved. "
How and when is it intended to demonstrate that suitable road access can be achieved? A shift to other modes of transport is manifestly unrealistic: we already have congested roads through Stansted Mountfitchet and these roads would not already be congested if the railway was capable of providing an adequate alternative. More houses in Elsenham can only make the problem worse.
(4) How it is possible for Uttlesford District Council to continue to support Option 4 in the 2007/2008 consultation as its "preferred option", when it has not yet been demonstrated that suitable road access to Elsenham can be achieved?
(5) Please refer to all of the other responses to the 2007/2008 consultation, explaining why "Option 4" is unsuitable and unworkable, and supporting the alternative strategy of providing small amounts of affordable housing in all towns and villages throughout Uttlesford, where it is needed. Now that the SHLAA has (a) acknowledged potential problems with substantial housing development at Elsenham and (b) assessed potential building land throughout Uttlesford, it is clear that this alternative strategy is possible and that it is time for Uttlesford DC to abandon its "preferred option" and start to look at its Core Strategy on housing completely afresh.