1.1 The Harlow Local Development Plan (usually known as the “Local Plan” for brevity) sets out the long-term planning vision for the district and guides future development across Harlow during the Local Plan period1, and ensures that development in the district is sustainable and meets the needs of residents, businesses and visitors to the area. The Local Plan supersedes the Adopted Replacement Harlow Local Plan (2006) to become the basis upon which planning applications are determined. The policies and proposals in the Essex Minerals Local Plan and the Essex and Southend-on-Sea Waste Local Plan are the basis upon which Minerals and Waste proposals are determined by Essex County Council, unless there are material considerations which indicate otherwise.
1.2 The Local Plan takes into consideration the economic, social and environmental conditions of the district. The preparation of the policies contained within it were informed by the Evidence Base which details the future housing, retail and employment needs of Harlow, together with identification of the necessary supporting infrastructure. All this is balanced against the need to protect key environmental assets.
1.3 The strategic implications of the evidence were prepared and considered in collaboration with East Hertfordshire, Epping Forest and Uttlesford District Councils, and Essex and Hertfordshire County Councils, in accordance with the obligations of the Duty to Co-operate as set out in the Localism Act 2011. More information on the Duty to Co-operate can be found later in this chapter.
1.4 The Local Plan is underpinned by a number of key Strategic Objectives. These are supported by the Strategic Growth policies, which provide an overarching planning framework and set out the district’s development needs, together with Development Management policies. The Policies Map accompanies the Local Plan and illustrates the policy themes, areas where existing land uses will be protected and areas where growth and regeneration have been identified. The Local Plan must be read as a whole and alongside national policies.
1.5 The Local Plan has been prepared in accordance with national legislation and guidance, including the Town and Country Planning (Local Planning) Regulations 2012 (as amended), the National Planning Policy Framework (NPPF) (2012)2 and Planning Practice Guidance as it was in July 2018 when the new NPPF was published.
1.6 An Infrastructure Delivery Plan (IDP) has also been prepared to identify the infrastructure required to support the future levels of growth across the district.
A separate Area Action Plan is being prepared to provide a detailed planning framework to deliver growth and regeneration in and around Harlow Town Centre.
1.7 The components of the Local Plan are illustrated in Fig. 1.1.
Fig. 1.1: Components of the Harlow Local Development Plan
1.8 The Local Plan will be kept under review in response to changes in local needs and conditions and national policies. Its effectiveness will be monitored over time against a set of indicators.
1.9 In 2019/20, the Local Plan was examined by an independent Inspector to assess whether it was prepared in accordance with the Duty to Co-operate, legal and procedural requirements, and whether it is sound.
1.10 In the production of the Local Plan, consideration was given to responses received during a number of consultations, which are summarised below.
Issues and Options Consultation (2010)
1.11 The Adopted Replacement Harlow Local Plan (July 2006), which was based upon the concepts set out in Sir Frederick Gibberd’s original master plan for Harlow New Town, replaced the previous Local Plan adopted in 1995.
1.12 In 2010, the Council began the preparation of a new Local Plan and consulted on an Issues and Options document. This proposed a number of objectives for the district, based around five key themes: Placeshaping, Housing, Prosperity, Infrastructure and Lifestyles.
1.13 As well as seeking views on these key themes, the Council consulted on a series of potential growth options around Harlow, based on housing numbers identified in the now-revoked East of England Regional Spatial Strategy (RSS). These options, which were based on the potential need for 11,000 new dwellings in locations around Harlow, are set out in Fig. 1.2.
Fig. 1.2: Growth Options in the Issues and Options consultation (2010)
Option A RSS: Northern Led | Based on requirements set out in the RSS (undergoing the process of revocation at the time) which placed the bulk of the housing to the north of Harlow, with some more growth to the east but very little development to the west and south |
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Option B Policy-led |
Disbursed growth, evenly distributed around the edges of Harlow, thereby taking into consideration all alternatives |
Option D Regeneration-led |
Maximising regeneration potential, this option allocated growth to the north, east and south, with very little development to the west |
Option E Sustainable transport-led |
Growth would be concentrated along major transport routes or where transport would be enhanced, this mostly being to the east but with major growth also located to the north and west |
1.14 The responses to the Issues and Options consultation showed there was little support for the growth levels identified in the RSS but strong support for growth to meet local housing needs. The majority of respondents considered that growth should be located in areas that would maximise the ability to regenerate Harlow and, in particular, that protection should be afforded to the district’s Green Wedges. Transport and infrastructure issues were also highlighted as matters that required resolution before large-scale development took place.
1.15 Other issues raised included the validity of the growth figures considered in the RSS given that, at the time of the consultation, the RSS was undergoing the process of revocation; the desire for growth to be determined by local needs; and the fact that Harlow itself would be unable to allocate land for growth outside of its administrative boundaries.
Emerging Strategy and Further Options Consultation (2014)
1.16 The Council subsequently consulted on the Emerging Strategy and Further Options document in 2014. This document reflected the changes made to the plan-making system through the enactment of the Localism Act 2011, the publication of the NPPF and the revocation of the East of England RSS. This meant the future development needs of the district, based on an assessment of local social, economic and environmental conditions, would be determined through the preparation of a new Local Plan.
1.17 As a result of emerging evidence and the need to identify a suitable housing number for Harlow’s local needs, the consultation contained a number of potential housing options. These options were based on work undertaken by consultants who concluded that to make Harlow a sustainable place to live, work and visit, it would require a high level of growth to boost regeneration and to attract investment. The consultation document presented five development scenarios and housing target figures as set out in Fig. 1.3.
Fig. 1.3: Growth Scenarios in the Emerging Strategy and Further Options Consultation (2014)
Scenario A – Do Nothing More: 3,929 dwellings and loss of 1,207 jobs |
This option assumed that no more housing is built in Harlow other than those locations which already benefit from planning permission |
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Scenario B – Meeting Development Needs: 7,485 dwellings and 3,057 jobs | This option reflected demographic modelling undertaken at the time |
Scenario C – Jobs Led: 11,490 dwellings and 8,060 jobs |
This option looked to provide enough jobs in Harlow to meet the district’s economic aspirations and a level of housing set to ensure sufficient people of working age |
Scenario D – Growing Centre: 15,000 dwellings and 12,099 jobs |
This option assessed the approximate level of development set out in the RSS |
Scenario E – Transformed Centre: 20,000 dwellings and 18,121 jobs |
This option was based upon sufficient growth to support a ‘transformed’ Harlow Town Centre (particularly in retail and leisure) |
1.18 Respondents to the consultation identified the need for Harlow to provide for high levels of growth in order to tackle existing issues around affordability, infrastructure provision, regeneration needs and investment opportunities. Respondents also recognised the need for the Council to work closely with its neighbouring authorities through the Duty to Co-operate to facilitate such growth.
Development Management Policies Consultation (2017)
1.19 In 2017, the Council invited comments on the emerging Development Management policies. The policies will guide future development across the district and provide a regeneration strategy up to 2033. These provide a detailed planning framework which will be used to assess planning applications and underpin a number of overarching Strategic policies that will be contained in the Local Plan.
A number of responses were received and, where appropriate, the policies were modified.
Pre-Submission Publication (2018)
1.20 In 2018, the Council published the Pre-Submission Publication version of the emerging Harlow Local Development Plan, which was the final version before it was submitted for Examination.
1.21 The Council invited comments on whether the Local Plan meets the following four tests of soundness, as set out by the National Planning Policy Framework (2012):
1.22 The responses received informed a number of minor changes which were proposed by the Council and submitted – along with the Local Plan, Policies Map, Evidence Base and other accompanying documents – to the Secretary of State in October 2018. The Examination subsequently took place in 2019-20.
1.23 Following the Examination, the Inspector wrote to the Council to advise that subject to a number of modifications, the Local Plan had been found sound. After consideration and implementation of the Inspector's findings, the Council adopted the Local Plan at the Full Council meeting on 10 December 2020.
1.24 The Local Plan has been developed around a number of themes and these are reflected, where appropriate, in the allocations and designations shown on the Policies Map.
Placeshaping
1.25 The Policies Map shows the extent of the Green Belt in Harlow together with the network of Green Wedges and Green Fingers, as well as protected biodiversity assets in the district.
1.26 The Policies Map also indicates the boundaries and locations of some of Harlow’s heritage assets and historic environment, including Conservation Areas, Scheduled Monuments and a Registered Park and Garden.
1.27 The Environment Agency regularly updates flood zone areas and areas susceptible to surface and ground water flooding in the district. The Council’s website provides links to more up-to-date information provided by the Environment Agency on flood warnings, river levels and flood risk maps.
Housing
1.28 Housing sites, including the Strategic Housing Site East of Harlow (part of a new Garden Community), are allocated on the Policies Map. The boundaries indicate the extent of the allocation areas, but they do not necessarily reflect the extent of the land that will be developed; this will be subject to a detailed assessment as part of a planning application or masterplanning exercise. The northern part of the Strategic Housing Site East of Harlow extends into the adjacent district of Epping Forest; the extent of the part in Epping Forest will therefore be allocated in the Epping Forest Local Plan.
Prosperity, Lifestyles and Infrastructure
1.29 The Policies Map outlines the hierarchy of retail centres across the district including Neighbourhood Centres and Hatches. A separate Harlow Town Centre Area Action Plan is being prepared which will be accompanied by a Policies Map showing major regeneration areas in the town centre, as well as primary and secondary frontages.
1.30 Other Open Spaces, cultural and recreation facilities, and other community buildings and facilities are not shown on the Policies Map because they can vary in size and scale. They are, however, protected through the policies in the Local Plan.
1.31 Where appropriate, the locations of the key infrastructure needed to support development are identified on the Policies Map.
1.32 The Local Plan has been informed by a number of key pieces of evidence which are available for inspection on the Council’s website at www.harlow.gov.uk/evidence
1.33 The Local Plan has been subject to a Sustainability Appraisal (SA) which has assessed the potential economic, environmental and social effects of the Local Plan. In addition a Habitats Regulation Assessment and Equalities Impact Assessment have been undertaken.
1.34 The Localism Act 2011 places a duty on Councils to co-operate on planning issues that cross administrative boundaries, particularly those which relate to strategic priorities. The Government expects joint working on areas of common interest to be diligently undertaken for the mutual benefit of neighbouring authorities.
1.35 The Council has worked closely with neighbouring authorities, statutory bodies and other interested parties in preparing the Local Plan. In order to deliver the wider growth strategy for Harlow, a number of key pieces of evidence have been jointly prepared with other local Councils. This includes a Strategic Housing Market Assessment (SHMA) which sets out the housing need for the Housing Market Area (HMA) and a Site Selection Report which appraised all the development sites around Harlow.
1.36 The Council has also worked closely with other authorities to assess the cumulative impact of growth on the strategic highway network, leading to the identification of a number of mitigation measures. A joint Memorandum of Understanding (MoU) with Highways England, Essex and Hertfordshire County Councils and East Hertfordshire, Epping Forest and Uttlesford District Councils has been prepared endorsing improvements to the highway network, including the new M11 Junction 7a.
1.37 Additionally, a MoU has been prepared, focussing on the management of growth from development on the Epping Forest Special Area of Conservation to ensure no adverse effects on the integrity of the SAC.
1.38 The MoU is required because development within Harlow may, in combination with development in other areas, affect the integrity of European Sites which lie outside the district. This MoU will ensure the co-operation needed to implement Policy WE4.
1.39 A MoU has also been prepared with East Hertfordshire, Epping Forest and Uttlesford District Councils which sets out the distribution of the Objectively Assessed Housing Need across the area. The MoUs are available to view on the Council’s website.
1.40 The Council has held a series of meetings and discussions with infrastructure providers to ensure the right level of infrastructure and investment are in place to deliver the growth in and around Harlow. This includes transport infrastructure (both public and private), education, healthcare provision, utilities, social care provision, waste and crematorium space. The information gathered from these discussions has led to the creation of the Infrastructure Delivery Plan (IDP).
1.41 Harlow, Epping Forest and East Hertfordshire District Councils and strategic partners have come together to facilitate growth through the development of new Garden Communities, which are to be delivered as part of the Harlow and Gilston Garden Town. This will enable the development and identification of clear design principles tailored to the unique characteristics of Harlow and the Gilston area.
1.42 This is based upon a common set of values, objectives and a commitment to secure the delivery of growth across the area, reflecting close cross-boundary working between Harlow, Epping Forest, East Hertfordshire District Councils and strategic partners. Harlow and Gilston Garden Town lies in the core area of the London Stansted Cambridge Corridor.
1.43 Upon receipt of a valid planning application, the proposed development will be determined using the relevant Local Plan policies. The Essex Minerals Local Plan and the Essex and Southend-on-Sea Waste Local Plan, adopted by Essex County Council and Southend-on-Sea Borough Council, are the relevant Local Development Plans in respect of minerals and waste matters in Harlow. The Harlow Local Plan does not duplicate the Minerals Local Plan or Waste Local Plan. Furthermore, the policies in the Harlow Local Plan do not repeat national guidance or policies; therefore, where a policy in the Local Plan is absent or silent, it is because adequate national planning policies exist.
1.44 Supplementary Planning Documents (SPDs), such as the Council’s Design Guide, support and provide more detail to certain policies which may be a material consideration in the assessment of planning applications.
1.45 Each planning application will be assessed on its own merits, taking account of all relevant planning policies and material considerations. While an application may be supported by any single policy, this does not mean that permission will be granted. An application must satisfy relevant Local Plan policies, both Strategic and Development Management. Matters of interpretation on whether a policy is relevant and whether an application satisfies relevant policies are for the Council to determine.
1.46 When considering development proposals, the Council will take a positive approach that reflects the presumption in favour of sustainable development as set out in national policies and guidance. The Council will work proactively with applicants to find solutions to secure development that improves the economic, social and environmental conditions in the district. The Council may grant permission with planning conditions attached which ensure that the development accords with the Local Plan policies.
1.47 Planning applications which accord with the policies in the Local Plan will be approved, unless material considerations indicate otherwise. Where there are no policies relevant to the application or relevant policies are out of date at the time of making the decision, the Council will grant permission unless national policies or material considerations indicate otherwise, taking into account whether any adverse impacts of granting permission would significantly and demonstrably outweigh the benefits.
1.48 There may be some instances where a proposal may not satisfy all policy criteria, but may be deemed acceptable when considered against all material considerations. Alternatively, there may be occasions where an application satisfies all policy criteria, but due to overriding material considerations, may still be considered unacceptable.
1.49 The Council will monitor and review the Local Plan policies in order to assess their performance in relation to delivering the Council’s Core Priorities. The policies will be reviewed in the Council’s Authority Monitoring Reports (AMRs).
1 The Local Plan period is 1 April 2011 to 31 March 2033.
2 Paragraph 214 of the NPPF (2019) states “The policies in the previous Framework will apply for the purpose of examining plans, where those plans are submitted on or before 24 January 2019”. The policies of the 2012 NPPF, therefore, applied to the examination of the Harlow Local Plan, which was submitted in October 2018.
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