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We act on behalf of Rydon Homes Ltd who own land at St Botolph's Farm, Braiswick Road, Colchester . Their landholding extends to about 3.1 ha and lies to the north of Braiswick Road. The site is proposed as a residential allocation in the Colchester Preferred Options Local Plan (CPOLP). Rydon support this proposal and related policies of the Plan. We are therefore instructed to submit the follow ing representations in response to the consultation on the CPOLP.
Policy SG1:- Colchester 's Spatial Strategy - The strategy focusses upon the urban area of Colchester as being the most accessible and sustainab le location in accordance with the Spatial Strategy for North Essex and the Settlement Hierarchy in the Borough. Rydon agree with this spatial strategy because it will reduce the need to travel. Most facilities for housing, jobs and services are available within a short distance of any part of the town or its immediate outskirts and many can be reached by wa lking, cycling or public transport. For journeys chosen or required to involve the use of the private car the length of any journey will be short. Town centre uses such as retail, offices, leisure, culture/entertai nment and food/drink establishments are currently established in Colchester and relevant policies can continue to direct them there so that the accessibility advantage will be long-term. Any alternative strategy which involved a focus of development away from this major town wou ld be likely to give rise to significant environmental harm and unsustainable transport patterns.
Policy SG2:- Housing Delivery - Rydon acknowledge that the supply of previously-developed land upon which development growth has relied in the past is now limited and diminishing . There is still a need, in accordance w ith Government policy, to encourage the effective use of land by reusing land that has been previously developed (brownfield land) provided that it is not of high environmental value (NPPF Paragraph 17). However, in order to deliver sufficient housing to meet objectively assessed housing need, new greenfield sites will also have to be identified and Rydon agree that such sites should be selected on the
basis of the most sustainable locations and deliverability. This primarily means in and adjoining the urban area of Colchester. A range of sites is required in order to provide housing choice and to optimise deliverability. Large neighbourhood sites can provide large housing numbers but also need supporting infrastructure and are sometimes lethargic in delivering housing numbers because of the inertia and complications associated with such large projects. Smaller sites can make important contributions to strategic housing numbers collectively but can also produce completed dwellings more quickly, maximising the better use of existing infrastructure and offering a more bespoke and intimate local character which some people prefer to the impersonality of large new neighbourhood schemes. A proportion of smaller sites therefore adds to the quality and choice offered by new housing allocations and enhances the prospects of early delivery.
Policy NC3:- North Colchester - Rydon Homes Ltd welcome the proposed allocation of Land at St Botolph's Farm, Braiswick for development of up to 50 new dwellings. They are promoting housing development on this site and agree that it is capable of delivering up to 50 new dwellings of a mix and type of housing that would be compatible with surrounding development. This can be achieved on the eastern part of the site without the need to include the lower land to the west, parts of which fall within an area of flood risk. Rydon's vision for the site would be not only to retain the existing belts of trees along the western and northern periphery but to manage them and enhance their biodiversity and, if possible, to link the area to the local public footpath network. The site enjoys an extensive frontage to Braiswick Road (B1508) and Rydon are satisfied that a suitable new priority junction can be formed to provide direct access.
Rydon are not aware of any constraints that would delay the commencement of development and the site can therefore be considered to be deliverable in full within a five year period.
Initial assessments have provided reassurance that the traffic generated from this development site will result in only a very small percentage increase in traffic using local roads and therefore any impact upon traffic conditions on the local highway network is likely to be imperceptible.
The main site, where the housing will be built, does not obviously demonstrate any special ecological value but the preservation and enhancement of the woodland areas of the site will have a positive effect on ecology and biodiversity. Rydon will carry out ecological studies and present an environmental management plan as part of a future planning application.
There are very few existing residential properties adjoining the site and therefore its development will have a very limited impact on the amenities of existing residents. This is an unusual advantage for a site that lies within the confines of the Colchester urban area. Any local impact can be addressed by the site layout in due course.
Rydon also support the proposed residential allocations on land north of Achnacone Drive and land south of Braiswick Golf Club which also form part of Policy NC3. These sites share the same locational and sustainability advantages as St Botolph's Farm. Means of access to the Golf Club site is not clear cut but the layout of development on the St Botolph's Farm site could make provision for access to comprehensive development of land parcels to the east including the Golf Club site.
Evidence Base - Having reviewed the evidence base supporting the CPOLP Rydon query some of the conclusions reached following assessment of the Policy NC3 sites. The Colchester Borough Strategic Land Availability Assessment July 2016 (SLAA) has considered a number of sites across the borough put forward by promoters through the Call for Sites. The assessment process involved two rounds of initial sieving before considering the sites against 'Suitability', 'Availability' and 'Achievability' criteria in order to determine the sites' overall deliverability. Appendix 3 of the SLAA applies a RAG (Red Amber Green) rating to all five stages of assessment as well as the 'Overall' outcome for each site (see relevant extract at Appendix A to these representations).
The SLAA includes assessment of the following three sites which are now contained as proposed allocations within CPOLP Policy NC3 :
* COLlO St Botolph's Farm, Braiswick - up to 50 dwellings
* COLll Braiswick Golf Club Site A, North of Achnacone Drive - up to 30 dwellings
* COL12 Braiswick Golf Club Site B, South of Braiswick Golf Club - up to 8
These three sites are fairly similar in terms of characteristics, location and sustainability and, therefore, it would be reasonable to anticipate that all three would display the same rating outcomes following the SLAA process. All three sites receive a Green rating in four of the five categories. However when it comes to assessing 'Suitability' COLlO and COL12 receive an Amber rating. Without justification COLl land COL12 then receive a Green rating as the overall outcome, whereas COLlO receives an Amber.
The SLAA methodology and generic evaluation criteria is very transparent and the RAG ratings and outcomes are presented clearly. However, there is an absence of site specific assessment against the criteria for each stage within the evidence base. We would expect to see this element of evidence and request that it is made available in order to understand criteria scores given and the difference in overall outcome of the NC3 sites. As this evidence is currently unavailable there is no explanation for the variation in overall outcome between the sites. Rydon questions why COlO receives an Amber for 'Suitability' and Amber for 'Overall' and C012 also receives an Amber for 'Suitability' yet then receives Green for 'Overall'. In applying the assessment criteria to COLlO ourselves (see Appendix
B) Rydon reach the conclusion that the site should receive Green for 'Suitability' and therefore Green for 'Overall'.
Rydon has analysed the Council's Sustainability Appraisal Environmental Report (SAER) for Part 2 of the Local Plan Preferred Options. Rydon supports the conclusions reached at paragraph 15.6 that the St Botolph's Farm site does not have any major constraints and is considered suitable, available and achievable in light of the reasonable alternatives, resulting in the site's selection for allocation in the Local Plan. However, in assessment of COL1O and COL11&12 (which the SAER considers jointly) it is worth noting at this stage that there appears to be inaccuracies in the conclusions reached on COL1O and inconsistencies between the assessment of COL1O and COL11&12. Greater detail and transparency behind the application of assessment criteria would be helpful in determining the accuracy of results.
If there are any matters arising from these representations that require clarification or expansion please contact our Mr Hough. Rydon are focussed upon the delivery of housing from the St Botolph's Farm site at an early stage and are confident that a sustainable, high quality housing development can be provided in accordance with the full range of policies in the CPOLP.