Policy CLT3 - Secondary Education

Will extra transport be provided to the secondary schools?

Question the policy regarding the catchment areas for students in the village who are transferring to secondary education.

Parking facilities for cars and public transport have in the past been badly thought out. We must ensure better provision in future.

HPPG believes that there are not adequate school places with redevelopment of Eldon Way for housing

In order to facilitate the addition residential units proposed for Ashingdon, it is important that King Edmund School can be expanded in order to accommodate the additional children generated by the new housing.

Policy CLT3 - Secondary Education
Summary: The Respondent finds the document to be unsound in its present form, however were the amendments set out in these representations to be incorporated then it is considered that the document will be sound. No objection is raised to the principle of extending the size of the King Edmund School grounds, subject to the provision of robust evidence as to the need and scale of the extension.
Full Text: The respondent owns the majority of the available land surrounding the school and is thus in the best position to facilitate the expansion. However, it is not clear how the land will be acquired, or whether it will form part of a much wider, mixed use allocation in the Allocations DPD. The CS refers to the Essex Schools Organisation Plan, which identifies a need to increase secondary school places in line with housing growth. It is accepted that housing growth and school places are inextricably linked and that the King Edmund School is at capacity and will require extension in the future. What is not clear from the evidence base is where the identified need for 3 hectares has come from. Reference is made to the Essex Schools Organisation Plan; however, this document does not look beyond 2013 and does not consider the residential allocations presently proposed in this CS.
The respondent has substantial interests in the land identified in the broad locations set out in H2 and H3. It is considered that the school expansion should be part and parcel of the development that comes through in the Ashingdon allocations. An indicative masterplan is attached to these representations, which illustrates a growth option combining urban extensions with the enhancement of King Edmund School.
Amendment to Policy CLT3:
Reference to the need for 3 hectares should only be included if this area can be properly demonstrated.

Masterplan/Facilities plan Council ref AE22

Iceni submitted representations to the Core Strategy Strategy Submission (CSS) document on behalf of Colonnade Land LLP (CLLLP) in October 2009. In reviewing the document, it was considered that the document consistently fails to meet the tests of soundness set out in the table following Paragraph 4.52 of PPS12 particularly with regard to the requirement to find the document justified, that is 'founded on a robust and credible evidence base'; effective, that is 'deliverable and flexible' and consistent with national policy. To clarify this matter further, the representations of CLLLP confirm that:
* The plan fails to cover at least 15 years from the date of adoption since the CSS should look to plan for the provision of housing up to 2026 at the earliest.
* At the time of the submission of representations to the CSS, the Strategic Housing Land Availability Assessment 2009 had not been published. As a consequence, representations to the CSS did not include an opportunity to comment on the information contained within this document. In this regard, the CSS consultation document was not supported by a robust, transparent and credible evidence base.
*The Stambridge Mills site is identified within the CSS policy H1 for high density residential development. The site lies wholly in Flood Zone 3 and identification of this site is considered inappropriate as there is no evidence provided within the consultation package that the Sequential Test and the Exception test have been applied. The absence of an evidence base means that poligy H1 is not justified, effective, or consistent with national policy (in particular the requirements of paragraph 14-20 of PPS25).
*The CS is not supported by a compliant Strategic Flood Risk Assessment (SFRA). The CSS is reliant on the Thames Gateway South Essex SFRA which was produced in accordance with PPG25. In the absence of a PPS25 compliant SFRA the CSS is neither 'justified' nor consistent with national policy and is therefore unsound.
*As a consequent of the two points above, Stambridge Mills is not considered to be deliverable within the context of paragraph 54 of PPS3. Consequently the CSS is not consistent with PPS3 and is not flexible enough to ensure the CSS can meet minimum housing targets contained within the East of England Plan.

The full case of the CLLLP is set out in the representations to the CSS and separately in representations to the SHLAA which we understand were not registered by the Council.

It is also noted that representations submitted by the Environment Agency indicates similar concerns in relation to the Stambridge Mills site in the context of the lack of sufficient evidence to justify the underlying assumption that protecting Green Belt land should take preference to avoiding high density development in areas within Flood Zone 3 which would pose risk to life and property.

In order to produce a legally compliant and sound CSS, the Council should:
To make the document jusfitied:
*Re-open the consultation on the CSS in order that the Strategic Housing Land Availability Assessment can be considered within the consultation package;
*Delay the Core Strategy in order that the Council can produce an up to date and PPS25 compliant SFRA
To make the document effective:
*Undertake a Sequential Test and Exception test to ensure that the Stambridge Mills site is suitable for residential development and conforms with the requirements of PPS 25
To make the document in accordance with national policy:
*Identify sufficient sites in the event that identified housing sites are found to be undeliverable or undevelopable in accordance with PPS3;
*Undertake the sequential and exception tests as required by PPS25
*Produce an SFRA as required by PPS25

Iceni, on behalf of CLLLP seek the opportunity to present their representations in full on the Core Strategy due to the wide ranging implications and significant nature of the objections to date.