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Representation 1944 on Preferred Options Local Plan by Mrs A Stubbins

Support / Object: OBJECT
Document Link: Preferred Options Local Plan - Sustainable Settlements, Copford and Copford Green
Representation: I object to the Hall Road development for the following reasons:
1. The area is currently a greenfield site, it is agricultural land with environmental stewardship on it. The area is used for recreation and improves wellbeing.
2. If considering Copford alone, this site represents a 25% growth excluding protected copford green - the greatest growth of any village in the plan.
3. It does not represent an infill site.
4. There are less environmentally damaging alternatives.
5. The access is inadequate and possibly dangerous.
6. There are no services in the village such as doctors, shops, enough schools. This is not sustainable.

Original submission

Reasons for objection to the Hall Road development site (Copford)
Density - The proposed density of this green field site would lead to the densest housing in Copford (eg. when compared to Queensberry Avenue). This density is not 'in keeping' for this site as the field only backs on to 14 houses. This links to your statements in section 2.74 onwards and SP5 of the local plan 'creating quality places'.
The % growth in Copford is stated as 18%. By my calculations, the % is actually 18.897% and therefore rounded up, it is equivalent to Langham and the highest % growth of all the parishes. When considering that Copford green is to be protected from development, you could argue that the % development in Copford alone is 26% when you consider 120 new houses in an area of 456 houses. This would be the most amount of growth by some distance of any parish.
Development boundary - I disagree with where the development boundary has been placed as it includes an area of greenfield in contradiction to section 5.10 'aim to protect open stretches of countryside' and policy ENV1 to conserve and enhance the environment. The current Local Plan does not include the area off Hall Road within the settlement boundary.
The settlement boundary principles say that 'Open spaces should generally not be within settlement boundaries. However, if effectively enclosed by built development, they can be included'. Another principle is that 'farms should generally be excluded'. Hall Road development does not meet these principles. The Hall Road site does not represent an 'infill site' because the surrounding land on 3 sides is either open farmland or gardens with only London Road being developed with a single row of housing.
6.127 of the Local Plan also notes about Hall Road that 'to the east to discourage growth in areas where the character is more rural/or is open countryside'. I believe that Hall Road site goes against this statement.

In 6.130 there is also an unfinished sentence 'and to.' I would suggest given the summary in SS5, I would suggest that the missing text is 'screening to minimise visual impacts to the local setting', screening should be included to the north of the site between the existing historic building, Brewer's cottage as well as School road.
In keeping with the local area - The density is not appropriate or in keeping with the surrounding area. The plan refers to 'in keeping' with the local area and maintaining the setting of historic listed buildings on London Road. Careful design, natural buffers and a reduced density would help to ensure a more appropriate and sustainable development. The height of any new builds should also be in keeping with the local houses, if not lower so as to minimise impacts to sight lines.
Services and Amenities - The local plan is meant to be sustainable as per section 4.20 of the local plan. There are known capacity issues at the sewerage works as well as the primary school being near capacity as well as the nearest secondary school. There are no health facilities in Copford, with the closest being in Stanway and there is no village shop. This is all stated within the settlement boundary evidence base. Unless conditions are put in place to ensure that better services support the additional growth in the village, it could be argues that this is not sustainable development (noted in 2.70 of Local Plan).
The Village Hall is located nearer to Copford Green and some distance from the proposed growth areas. Such amenities should be considered as to whether the development is planned in the right area.
Access and designated greenspace - If considering the play areas at Queensberry avenue and on school road near the village hall, there is no designated open space to accommodate the area of growth in the east of Copford. This should be considered and ideally conditioned by any development that may take place in the East of Copford. Access by way of public footpaths already exist on and near to the Hall Road site, this should be maintained and expanded to improve the sustainability of any new development. By building a housing development on Hall road, it will take longer for people in the existing village to access open space. This is an important point as it is well documented that access to open space and green infrastructure is important for our well-being. By moving or lengthening access by even a short distance the use of these open areas may decrease, in the worst case leading to a loss of social wellbeing and a potential increase in anti-social behaviour. The greenspace to the south of Copford is accessed by dog-walkers, runners and cyclists by Hall Road. It is important that this access remains useable by pedestrians in the form of footpaths if the road is to become busy with traffic.
Hall Road - is currently a historic protected lane and is single-lane. It is not heavily used by cars but it is used by pedestrians and cyclists. The opening up of this road would have a significant impact on local residents. The junction with London road is quite a sharp one and it may be difficult for cars to get onto London Road in times of peak traffic. Safety should be considered as to whether the junction and road are appropriately sufficient for all users. Hall Road is a protected lane as shown in the current adopted plan.
Sustainability appraisal - There were more constraints than opportunities on this site and therefore to state it is a 'logical' option is not defensible.
Separation between Copford and Stanway - In your previous plan, it was noted that Colchester at Stanway and Copford should not coalesce therefore buffers/boundaries should be in place as well as ensuring the character of the two areas remain separate. Any new development in Copford should take this into consideration.
Infrastructure - The impact of this development as well as others in the local area that are planned or ongoing should be considered together, including in neighbouring parishes. London Road can become heavily congested at peak times and the addition of 120 extra houses as well as houses near Tollgate, Sainsburys, Wyvern Farm and at Marks Tey near the Bungalow Café will mean that the road will be far from free-flowing at peak times. This in combination with parking on both sides of London Road should be considered and infrastructure issues resolved prior to any construction.
It is likely that all the new houses will have at least one car as there are not many local jobs within walkable distance. It is likely that a proportion of people from the new developments will be using the A120 and therefore will contribute to the existing problem of congestion, noted in section 2.60 onwards and SP4 of the local plan. Therefore building work on the Copford sites should not take place until improvements to the A120 can be made as well as to MarksTey station as there will not be enough parking or cycling storage (and safe infrastructure) for the proportion of new Copford residents that will need to use these services.
Jobs - For a development to be truly sustainable, job creation is essential in the local area. Currently there are few job opportunities in Copford and it is likely that people will travel to nearby Stanway or commute to Chelmsford/Colchester or London for jobs. This draws money away from the local area.
Wildlife - The Hall Road site is itself under an environmental stewardship agreement. It would be a shame to build on land that is currently receiving funding to enhance the environmental credentials of the land. The Hall Road site is surrounded on the roadside by hedgerows which are important habitats for wildlife (5.4 in Local Plan). The hedgerow should be surveyed prior to removal of any part of it (5.6 in Local Plan). European protected species such as certain species of bats are likely to use the Hall road site for foraging from the Pits Wood Local Wildlife Site. Linear features such as hedgerows are important to bats as flight paths, this should be surveyed and mitigated prior to any construction. Arable hedge margins are also a Biodiversity Action Plan habitat to be considered in any development. Hedge margins are very difficult to recreate. Section 5.18 and ENV3 in relation to green infrastructure apply to this site.
The site is also close to the Pits woods Local wildlife site and the roman river valley conservation area . The impacts to these areas should be considered and mitigated for prior to any construction. Enhancements should be considered and additions in terms of wildlife areas and open areas if a development is going to take place on a greenfield site. It should complement the diversity of the neighbouring Local Wildlife site. Farmland birds are declining and those such as Turtle doves and Lapwing have been targeted for protection and management by the Bird Conservation Targetting Project in the area of Hall Road. Pits Wood is a Local Wildlife Site and disturbance impacts should be considered accordingly. Ancient woodland is clustered around the countryside conservation area of the Roman River Valley also therefore air quality during construction should be monitored.
The Conservation of Habitats and Species Regulations 2010 and The Wildlife and Countryside Act 1981 - I would have expected to see a habitats regulation assessment which will be a necessary part of assessing the viability of the local plan. The Evidence base does mention this. The Issues and options document states a screening exercise has taken place but I could not find this in the documents. It also states that an appropriate assessment will be published with the draft local plan however, I also could not find this. With Abberton Reservoir being extremely important internationally for birds, it is important to see the impacts of this strategy to Natura 2000 sites.
There was only broad reference to assessing Sites of Special Scientific Interest through the WCA 1981. This is also a necessary assessment of a strategic plan such as this.
Inconsistencies - There are some inconsistencies between justifications given for why some sites have not been proposed for development whereas others have. In some of the issues and options for example, sightlines were noted as a reason not to develop as well as 'greenfield' 'areas close to sewage works' and 'areas are considered inappropriate in terms of density and out of keeping with the surrounding rural character'. I would suggest that all of these reasons apply to Hall Road despite it being a preferred option.
There is also a settlement boundary principle that 'Open spaces should generally not be within settlement boundaries. However, if effectively enclosed by built development, they can be included'. Another principle is that 'farms should generally be excluded'. Hall Road development does not meet these principles.

Lack of neighbourhood plan and alternatives - The parish council have regrettably decided to disband the neighbourhood plan. This decision did not have support from all local residents. In light of this, I do not believe that the parish council represents the views of its residents. There appear to be alternative sites that would affect less people and improve the quality and visuals of the village when compared to developing on the Hall Rd site. These include the old nursing home site that has sat empty for some years. The brownfield site at the industrial units on London Road behind Monthind Clean has potential. This area is close to a large area of jobs in Copford too. Lastly, the land used for the car boot sale was discussed at the parish meeting as the owner would like to develop his land. I believe that by developing a proportion of the site to the east, and leaving an open area of field as separation between Copford and Stanway, this is a feasible area to develop sustainably. Alternatively a site linking Allendale and London Road is also an option which seems to be part of the same field. STN27 adjacent to hall road field and STN 11/18 School rd are also alternatives, it is difficult to distinguish why the preferred options were as proposed and not these other sites from the 'Call to sites' exercise as much of the justification for inclusion or exclusion was the same for different sites.I believe the alternatives link to policy ENV1 part a - areas where less damage will occur to the environment.
Archaeology - As remains have been found in the field and surrounding area, I am glad that this features in the council's local plan as essential investigation that needs to take place prior to development.
Water and Waste water treatment - I am pleased that this is within the emerging local plan. It also featured as an issue in the existing local plan with a condition that this issue is resolved prior to development and I would hope this same condition will be taken forward in the emerging local plan.

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