TIP12: Comprehensive Development

Policy TIP12: Comprehensive Development has been positively prepared and represents a ‘sound’ overarching planning policy to guide the site allocations.

We note that ‘Part C’ has been inserted in this latest version of the Tiptree Neighbourhood Plan. This criteria states: Planning applications must be accompanied by Transport Assessments, the scope of which must be agreed with ECC Highways in advance of any application. In particular, the Transport Assessments must demonstrate that the new link roads will satisfactorily mitigate traffic impacts of the proposed development and address existing road congestion issues in Tiptree village.

It is our understanding that this policy has been developed following extensive discussions with Essex Highways.

This criterion is ‘sound’ and fully complies with national planning policy and DfT Circular 02/2013 ‘The Strategic Road Network and the delivery of sustainable development’ (the Circular).

Of particular note, paragraph 109 of the NPPF states:
Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.

Paragraph 9 of the Circular states: Development proposals are likely to be acceptable if they can be accommodated within the existing capacity of a section (link or junction) of the strategic road network, or they do not increase demand for use of a section that is already operating at over-capacity levels, taking account of any travel plan, traffic management and/or capacity enhancement measures that may be agreed. However, development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.

In the context of Policy TIP12 of the Neighbourhood Plan, any planning application for development at the site allocations will need to be accompanied by a transport assessment that has been prepared in consultation with Essex Highways, to demonstrate and mitigate its impact upon the highway network. This meets national policy requirements and does not need to be expanded any further within this or any other policy.

This policy is supported as it will ensure that the new developments will integrate with one another and the village.

A. Applications for development on the site allocations contained in Policies TIP13 and TIP14 should be accompanied by overarching indicative masterplans. These masterplans are to have been informed by a process of active engagement with the community of Tiptree and with the other land owners/developers involved in the plan. These masterplans should demonstrate, where necessary, that they will not prejudice the delivery of the ‘primary street’ and will contribute towards the delivery of the overall vision for Tiptree.
B. These masterplans will set out general design principles and provide an indicative framework to guide the development of the area in accordance with the aspirations of the Neighbourhood Plan and demonstrate an understanding of the intrinsically semi-rural nature and evolution of the Tiptree settlement pattern.
C. Planning applications must be accompanied by Transport Assessments, the scope of which must be agreed with ECC Highways in advance of any application. In particular, the Transport Assessments must demonstrate that the new link roads will satisfactorily mitigate traffic impacts of the proposed development.

This policy seeks to ensure that the proposed residential development comes forward in a coordinated way. However, it is unclear how the requirement for an overarching masterplan should be provided. If applications are submitted by individual landowners with indicative masterplans for the remaining areas of the allocation, this should be considered acceptable by the local planning authority. Otherwise it is unclear what status or process is to be used to consider the overarching masterplan.

There will need to be an element of coordination across the differing land ownerships in order to ensure that the ‘primary street’ is delivered in a coherent manner. However, any particular landowner should not be prevented from bringing forward an application on their land provided they meet the relevant policy requirements on land within their control. Provided that an individual application does not prejudice the overall delivery of the ‘primary street’ then this should not be used as a reason to withhold planning permission.

Finally with regard to criterion C, it is important to note that planning applications for new development cannot provide contributions to address existing deficiencies or existing problems. Therefore we think that the requirement in criterion C that a Transport Assessment which demonstrates that the new link roads will address existing road congestion issues in Tiptree is unreasonable.

A. Applications for development on the site allocations contained in Policies TIP13 and TIP14 should be underpinned accompanied by overarching indicative masterplans. These masterplans are to have been informed by a process of active engagement with the community of Tiptree and with the other land owners/developers involved in the plan. These masterplans should demonstrate, where necessary, that they align with one another, particularly with regard to the connectivity will not prejudice the delivery of the ‘primary street’ and will contribute towards the delivery of the overall vision for Tiptree.
B. These masterplans will set out general design principles and provide an indicative framework to guide the development of the area in accordance with the aspirations of the Neighbourhood Plan and demonstrate an understanding of the intrinsically semi-rural nature and evolution of the Tiptree settlement pattern.
C. Planning applications must be accompanied by Transport Assessments, the scope of which must be agreed with ECC Highways in advance of any application. In particular, the Transport Assessments must demonstrate that the new link roads will satisfactorily mitigate traffic impacts of the proposed development and address existing road congestion issues in Tiptree village.

Policy TIP12 requires applications for development on the allocated sites to be underpinned by overarching masterplans, to be informed by engagement with residents and other landowners/developers. The masterplans for the two allocations are expected to align with one another.

We have significant concerns regarding this approach. The NP should provide sufficient guidance for the development of the sites to come forward and should not seek to unnecessarily constrain development from being delivered.

With multiple landowners and developers involved in the two allocations, producing a masterplan agreed by all parties will take a considerable length of time, if indeed a mutual agreement is even attained, and it is unclear what this is intended to achieve that could not be achieved through individual planning applications.

With the site allocations being physically separated from one another, it is for the NP to set any necessary overarching design guidance and not for landowners or developers. With the NP containing design guidance, we consider it does provide sufficient guidance for sites to be developed and planning applications submitted, without the need for a lengthy masterplan process.

Criteria B of Policy TIP12 states that the masterplans should demonstrate an understanding of the intrinsically semi-rural nature and evolution of the Tiptree settlement pattern, but the NP has already done this through decisions in where to allocate sites. Planning applications can then provide greater detail on the specific nature of the development in terms of the design of dwellings, and so on.

We remain unclear as to the intention of the masterplans and consider this requirement will unnecessarily constrain development, particularly when some sites are ready to come forward in the short term and start delivering homes and infrastructure within Tiptree. Such a requirement places a disproportionate and unnecessary burden on the site allocations and will delay achieving sustainable development.

Criteria C has been added since the previous iteration of the NP and now requires applications to be accompanied by a Transport Assessment, which must demonstrate that the new link roads will satisfactorily mitigate traffic impacts of the proposed development and address existing road congestion issues in Tiptree.

We consider this is outside the scope of a Transport Assessment - the role of which is to assess the impact of a development on the existing road network only. Any new planning applications should not be expected to address existing road congestion issues as a necessity. In safeguarding land for a link road, the NP should be supported by sufficient evidence to demonstrate that this is necessary and will alleviate existing congestion.

This requirement could also cause a delay for applications to be determined, as if one site seeks to come forward ahead of the other allocations, it will be difficult for the Transport Assessment to demonstrate how the link road will mitigate existing road congestion issues as it will only form part of the link road.

It could also place a disproportionate burden on the first site to come forward, as the extent of highways work required to demonstrate how the existing traffic issues will be mitigated will be significantly greater than for subsequent proposals which will benefit from the initial data and from having part of the link road delivered.

With part of the link road being outside of the Tiptree NP area and no proposals or allocations for this to be delivered, we have concerns over whether it will be possible for individual applications to demonstrate that their part of the link road does mitigate existing congestion.

We consider that these are matters that should already have been addressed within the NP and that they are not for individual planning applications to consider.

Whilst we appreciate the need for masterplanning and cohesive development, the expectations of masterplanning work should be managed. There may be opportunities to demonstrate opportunities for links between sites, basic development parameters and general design principles for example, but a masterplan should not expect the designation of specific unit numbers, nor should it be expected to serve as a commitment to matters that would ordinarily be dealt with through individual planning applications.

The NP should respect the planning application process and the ability at this point to ensure that individual developments appropriately respond to those around it so as to not hinder the delivery of sites through overly prescriptive pre-planning requirements and commitments.