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I am writing on behalf of the Irvine Road Area Residents' Association (IRARA) in response to the consultation on Colchester Council's Draft Local Plan. The comments below relate to the area of land known as the 'Irvine Road Orchard' referred to in Section 6.88/89 and policy WC4 of the Preferred Options consultation document.
IRARA has long campaigned for the Orchard not to be developed but to be managed to preserve and enhance the land's existing wildlife interest. If managed appropriately the Orchard could become a valuable asset for the local community and more widely, for example, by allowing use by local schools. We therefore object to the allocation of the Orchard for development.
The views of IRARA's committee have been formulated through consultation with the local residents and have been echoed by individuals from outside the Irvine Road area. IRARA and many individual Colchester residents have already made these views explicit in responses to the Council's earlier consultation on the Issues and Options. These responses can be found on the dedicated page on your own website - http://www.colchester.gov.uk/article/16038/Consultation-Responses-Irvine-Road and make clear:-
the unparalleled strength of feeling of your constituents as suggested by the need to create a separate page to hold the 300 individual responses in addition to a 400 strong petition asking you to protect the Orchard. No-one can be in any doubt as the community's commitment to the Orchard.
the value of the Orchard which is recognised in its three designations within the current Local Planning regime. It is a County Wildlife Site due to the mosaic of old fruit trees, the unimproved grassland, the mature hedgerows and the range of insects like the Stag Beetles that live there. It is Private Open Space, adding to the network of greenspace extending to the west and is an important part of the character of the area. The trees are subject to Tree Preservation Orders due to their veteran nature.
the further strong protection afforded by the National Planning Policy Framework (paragraphs 73 & 74) which states that "Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless a set of tests are met which, in the case of the Orchard they are not ie
- an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements; or
- the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or
- the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss.
For these reasons, we object to policy WC4 of the Preferred Options consultation document.
The draft Plan proposes that 40% of the Orchard be allocated for development. It is our fear and belief that the proposed policy will facilitate development of the remainder when conditions designed to protect and preserve the land, that we would expect to be attached to any initial development, either expire or are superseded.
Without the long-term guaranteed protection that the Local Plan should afford, we believe that the complete loss of the Orchard is inevitable while the land remains in the ownership of developers. If the Council chooses to retain the draft policy WC4, which, for the avoidance of doubt, we restate our objection to, measures are need to guarantee the long-term security of the remaining Orchard land. This must be guaranteed and can be effected by ensuring any development proposal is only approved if the ownership of the remaining undeveloped land is transferred to a body with the Orchard's wildlife and value to the community at its heart.
on behalf of IRARA