Local Plan

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Representation 1659 on Preferred Options Local Plan by The Wivenhoe Society (secretary

Support / Object: OBJECT
Document Link: Preferred Options Local Plan - Open Space, DM17: Retention of Open Space and Recreation Facilities
Representation: This is worded in a similar fashion to current policy DP15. The wording of the last paragraph in the policy should be tightened up. It reads "Additionally development that would result in the loss of any small incidental areas of open space not
specifically identified on the Proposals Map but which contribute to the character of existing residential neighbourhoods, and any registered common, heathland or village green or which to contribute to green infrastructre will not be permitted"

Original submission

The main comments we wish to make are:

1. The overall housing target for Colchester seems to be based on trend predictions and it is questionable whether continuing the previous high rate of growth for Colchester is sustainable. Possibly Chelmsford should share more of the HMA overall allocation.
2. The proposed East Colchester/West Tendring garden settlement will have very severe traffic impacts for the already heavily congested A133 and no concrete measures are proposed to mitigate this nor seem to us to be feasible.
3. We query whether no alternative could be found for this suggested garden settlement which did not involve using agricultural land graded as excellent.
The Need for a Strategic Approach, 2.4 to 2.7
The Society accepts that a strategic housing approach looking at the North Essex region as a whole is a sensible one. It is unfortunate that Maldon has not participated. The Housing Market Area (HMA) consisting of Colchester, Braintree, Tendring and Chelmsford is analysed in the "Objectively Assess Housing Need Study" but Chelmsford is only tangentially mentioned in the Strategic Part 1 of the document. See more on this point in comments on Meeting the Need for New Homes, 2.32 to 2.40.
Meeting the Need for New Homes 2.32 to 2.40, SP2 Meeting Housing Needs
The Society recognises that the Country as a whole needs more new houses but the Objectively Assessed Housing Needs Study and the Demographic Forecasts for the strategic area all seem to be based on the assumption that past trends in net inward migration will continue in the HMA at the same level as in the past, with various degrees of sophistication in the assumptions made. A Strategic Plan should be pro-active and consider what is desirable and sustainable and not simply rely on past trends.
It could be appropriate for some parts of the HMA to grow faster and some at a slower rate than in the recent past. Colchester has been one of the fastest growing areas in the UK owing to the availability of suitable development sites in the last decade or so. This is one of the factors that have driven inward migration. It could be argued that inward migration has been housing supply led rather than demand driven. The question should be asked whether it is sustainable for this trend to continue indefinitely given the constraints on the road infrastructure, particularly in Central Colchester, and the fact that future development in the Borough will have to be on green field sites.
SP2 The table in this policy shows the proposed number of dwellings for the constituent parts of the HMA with the exception of Chelmsford. The Brett report suggests775 as the annual build rate for Chelmsford and this is consistent with the figures given in paragraph 2.37. Using the 2011 census figures for the housing stock a base comparison the figures given show the following annual percentage increase on the 2011 stock

Annual build %increase on 2011 stock
Chelmsford 775 1.09
Colchester 920 1.23
Braintree 845 1.35
Tendring 597 0.89

It is proposed that Braintree should grow at much faster rate than previously but building rates there have been relatively low in the past. Chelmsford is of a comparable size to Colchester but the proposed rate of increase is lower despite the fact that house prices are higher in Chelmsford (indicating a demand for housing there), that it is thought likely that employment will grow faster than elsewhere in the HMA and that it is closer to London.
Colchester is assigned the largest per annum target and this understates the actual figure as some of the housing proposed for the East Colchester/West Tendring garden settlement will effectively be part of Greater Colchester. Colchester has also grown fast since 2011 so if this growth is included the increase on the 2011 stock would be even greater. The annual build rate proposed of 920 for Colchester is requiring Colchester to take more than its proportionate share of overall government housing targets. This target should be reduced to recognise that Colchester has already provided more housing, proportionately, than other areas in the country and in the region. The growth proposed for Tendring shows a defeatist attitude about the potential for employment growth in the area.
It would be helpful if the proposed growth rates were compared to targets for England and the UK as a whole.
Infrastructure and Connectivity
Para 2.61 This paragraph and policy SP4 mentions the A133. The residents of Wivenhoe are concerned about the current levels of congestion on this route on Clingoe Hill and routes westwards from the Greenstead roundabout (used to access Colchester and the strategic road network). The policy talks of improved road infrastructure to reduce congestion and to provide more reliable journey times. No details are given as to how this might be achieved for the A133. Given the built up nature of the town to the west of Colne Causeway it is difficult to think of any feasible solution to the problem of peak hour traffic as no space for new roads or major road intersection improvements. The issue of greater use of public transport is discussed below in the section on the East Colchester Garden Settlement.

Cross Boundary Garden Communities: Para 2.82 onwards
The Wivenhoe Society does not object to the concept of garden communities as such. There are advantages from forward planning for the long term for necessary infrastructure. However traditionally new garden cities were developed by growing an existing small settlement. This has the advantage that there are some existing facilities to serve the initial stages of development before enough housing has been built to support additional infrastructure. This would seem to be the case for the suggested development based around Marks Tey but would not be the case for the East Colchester/West Tendring proposed garden community.

The Wivenhoe Society has several concerns about this eastern garden settlement.
SP8: East Colchester/West Tendring New Garden Community
The land concerned lies mainly in Tendring but the new development would effectively be an expansion of Colchester with residents looking to Colchester for all but very local services. The proposals for the plan period up to 2033 provide for 2,500 homes to be built in this location and the longer term suggestion is for 7,000 to 9,000 dwellings or even 11,000 for one of the possible options. The potential developers, in discussions with the Wivenhoe Neighbourhood Plan group, spoke of developing the site north of the A133 at a rate of about 300 houses a year. There is no existing infrastructure on the site and in the early years the suggested build rate would not provide a sufficient base for the provision of new local infrastructure, including public transport, and it would take a long time for it to develop into a viable semi self-sufficient community. Some discussion and explanation of transitional arrangements is required particularly with regard to school place provision.
SP8, D transportation
A major concern is the adequacy of the road network. The A133 is already subject to severe congestion at peak times. It is the only route for cars into Colchester from Wivenhoe given that Boundary Road is a through route only for buses. Greenstead roundabout is a pinch point. It only takes one accident for severe problems to arise. When it had to be closed recently for road markings to be replaced, the official diversion involved a distance of 23 kilometres (there was a shorter but nonetheless lengthy diversion for those with local knowledge). The unpredictability of journey times means that for crucial appointments a safety margin for possible delays has to be allowed when planning trips. The congestion on the A133 and frequent hold-ups is a problem not only for Wivenhoe residents but all those who have to use Clingoe Hill and the Greenstead roundabout. Building 2,500 homes feeding on to this route will cause severe problems and it is difficult to see how a potential settlement of up to 9,000 dwellings is feasible. A route connecting the A133 to the A120 could provide some alleviation. This is not specifically included in the proposals in SP8 though access off the A120 is mentioned. An A120 link is shown on the Tendring map but not on the East Colchester map. Such a link would not help with increased vehicle demand for those wishing to travel to Colchester.

Section D of SP8 speaks of measures to mitigate the transport impacts and of longer term transport interventions. Without any concrete proposals this would seem to be an empty promise. We urge the Borough to explain what mitigation measures could be put in place given the physical constraints. The section also talks of the development of a public rapid transit system and some red lines are shown on the map for East Colchester. It is difficult to see that there is any possible route into central Colchester to the west of Colne Causeway that could deliver a reliable service with predictable journey times. Without detailed proposals this would also seem to represent wishful thinking and some concrete and feasible proposals need to be included.

Even if a rapid transit system could be developed it is not clear that this would be sufficient to deal with traffic issues. Firstly Central Colchester is not necessarily the desired destination, particularly for journeys to work. Secondly it is uncertain how many people would use the system. Wivenhoe has a frequent and relatively fast bus service to central Colchester (as part of the route uses Boundary Road). It also has a railway station with direct trains to London. However the 2011 census figures showed that 61.9% of journeys to work were by car/van and only 7.2% by bus. There is no reason to believe that residents of the proposed settlement would be more likely to use public transport than those in Wivenhoe.

One of the merits of the garden settlement concept is that it allows forward planning for infrastructure and amenities and for provision to take place at an early stage. There is a real danger that if the first phase of 2,500 dwellings are built it will then be found that it is not possible to mitigate the traffic impact on the A133 and that the suggested post-2033 additional development is not feasible.

SP8 C :Employment
SP8,5 Provision of land for expansion of the Knowledge Gateway is supported on the site towards the south and would be supported even if the garden settlement does not go ahead.
SP8,6. It is not made clear whether there will be a link to the A120 for the businesses suggested for the north of the site.

SP8 E: Community Infrastructure
SP8,13, 14 the provision of health facilities and schools is welcomed but the residents of Wivenhoe are concerned about the timing of such provision and whether there will be adverse impacts on facilities in Wivenhoe in the early years of the development before a critical mass of housing is built.
SP8, 15 The provision of a country park is welcomed.
SP8, 16 Some indoor leisure facilities should be provided on the site. Contributions towards sports facilities at Broad Lane Sports Ground managed by the Wivenhoe & District Sporting Facilities Trust, as proposed in the Wivenhoe Neighbourhood Plan, would be welcomed, especially for a new Sports and Recreation Hall.

SP8 F: Other Requirements
SP8, 18,19, 20 and 21 are all proposals to be supported if the site is developed.

General comment on the sustainability of the East Colchester/West Tendring new garden community

The NPPF lays stress on sustainability. The Preferred Options document does not directly refer to the Sustainability Appraisal for Part I. Sustainability objective 2 in this latter document is labelled "impacts" which covers Acceptable impacts on high quality agricultural land, important landscape features, townscape features, sites of nature conservation interest and heritage assets. It would seem more usual for the impact on agricultural land to be a separately assessed. Almost all of the land proposed for the new community is rated as excellent by Natural England. There is only a limited area of "excellent" land in the region and this is concentrated mainly just to the east of Colchester. The Sustainability Appraisal gives an amber rating for objective 2 but this is only because the impact on agricultural land is masked by the assessments for the other impacts - landscape features etc. This is rather like hiding the rotten cherries at the bottom of the punnet.

If a garden settlement to the east of Colchester is necessary then the Wivenhoe Society urges Tendring and Colchester to reconsider its suggested location. An obvious possibility is for Weeley to be expanded. Weeley has a railway station and with a larger settlement, it would be feasible for more of the through trains to London to stop there. There is a link to the A120 quite close to Weeley. Less money would need to be spent on trying to provide transport fixes. The land is of lower agricultural value than that immediately to the east of Colchester and in terms of impact on the landscape, heritage, wild life sites etc the impact would be no greater and possibly lower. A pro-active approach to attracting employment would be necessary. The future for high value employment is in knowledge based industries. It should be pointed out that Weeley is as close to the University of Essex as the Cambridge Science Park is to downtown Cambridge. A development at Weeley could also be expected to help the economy of Clacton, particularly with respect to services and retailing.

A second strategy would be to put the suggested East Colchester/West Tendring on hold until 2033. This would have the advantage that experience in developing garden settlements would be gained in the meantime though it is difficult to see how the road access issue could ever be satisfactorily resolved.

If Colchester persists with its proposals to build 920 dwellings a year the total of 1,250 dwellings currently allocated for the East Colchester settlement would need to be relocated. Our suggestion would be that the Marks Tey Garden settlement should be developed at a faster rate which would allow the infrastructure to support the new development to be put in place at an earlier date. To compensate for the loss of potential dwellings on the East Colchester site, Tendring could up its allocation for Weeley (more than one scenario for Weeley is discussed in the Tendring Preferred Options and supporting documents) and possibly expand some of the settlements served by the rail line. To counter a possible charge of NIMBYISM the primary concern of Wivenhoe residents is the impact of the suggested garden settlement on the A133. If there were any feasible ways of improving/not worsening journey times and reliability for travel to Colchester then Wivenhoe residents would be much less opposed to the proposal. Residents would regret the loss of the attractive green countryside to the north of the A133, would have some concerns about the impact on facilities in Wivenhoe in the early years and would question the wisdom of using agricultural land graded excellent. However they would possibly, even if reluctantly, accept that the country needs more houses and that the proposals for a country park and landscape buffers would offset some of the impact on neighbouring communities. The impact on the road network is however the great stumbling block.
Comments on Part Two
Coastal Areas Policy, para 5.14
Reference is made to an updating of the Coastal Protection Belt made in 2016. No map is provided for the proposed protected area and the review does not appear in the Borough evidence base documents. In the Neighbourhood Plan survey it was clear that residents valued the open countryside and the views down the estuary from the land to the east of the Wivenhoe settlement area and to the south of Alresford Road as well as the green slopes to the west of the settlement. The land to the east is also close to a Special Protection Area and an SSSI. We would urge that this area should continue to form part of the Coastal Protection Belt.

EC1 Knowledge Gateway and University of Essex Strategic Economic Area
Zone 1: The Society supports the proposal to assign land for expansion of the Knowledge Gateway on land to the north of the A133 and would support this whether or not the Garden Settlement goes ahead.
Zone 2: This area is in Tendring and does not seem to be shown for University Use on the Tendring maps. The Colchester produced East Colchester map shows a de-allocation of land currently assigned for University expansion lying to the south and west of Boundary Road with an area to the east of Colchester Road, south of the A133 (the Tendring land) being allocated instead. There does not seem to be a reference to the de-allocation in the text. This de-allocation is strongly supported. The policy, as worded, for zone 2 includes the word "housing". If housing means student residences then the Wivenhoe Society would be happy with this but we do not consider it a suitable location for general housing. If the decision is made that the Garden Settlement to the north of the A133 is not going to be put forward then possibly some of the land adjacent to that allocated for Knowledge Gateway expansion would be a better location than the suggested zone 2

SS18 - Wivenhoe
The Wivenhoe Society welcomes the fact that the Local Plan is in accord with the draft Neighbourhood Plan though this has yet to go to referendum.

(Small data/factual points paragraph 6.237 : The paragraph refers to a number of new homes within the Parish which will be allocated in the University Garden Village. The administrative area, Wivenhoe Parish, is the land to the south of Boundary Road. The land to the north of the A133 lies in Wivenhoe Ward but not Wivenhoe Parish. The number of existing dwellings is underestimated.
The combined wards of Wivenhoe Cross and Wivenhoe Quay, which now form Wivenhoe ward, contained 3,595 dwellings in 2011 and Wivenhoe Parish which includes the Town had 3,482 dwellings in 2011. There has been some building since 2011.)

Policy DM10 - Housing Diversity
Whilst this policy as presently worded mentions CBC's aspiration to 'secure a range of housing types and tenures' it is not clear how CBC 'will require developers to demonstrate how their proposal will be capable of meeting and adapting to the needs of its increasing numbers of older residents'. This policy needs to be strengthened in some way.

DM17 Retention of Open Space
This is worded in a similar fashion to current policy DP15. The wording of the last paragraph in the policy should be tightened up. It reads "Additionally development that would result in the loss of any small incidental areas of open space not specifically identified on the Proposals Map but which contribute to the character of existing residential neighbourhoods, and any registered common, heathland or village green or which to contribute to green infrastructure will not be permitted"

At two recent planning appeals the inspector interpreted "contribute to the character of existing residential neighbourhoods" as being solely concerned with visual appearance and not relevant to the recreational value of the incidental open space. If the policy is intended to protect small play/amenity spaces not shown on the Proposals Map could we suggest it is made clear that the amenity value as well as visual appearance is to be protected?

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