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Representation 3104 on Preferred Options Local Plan by Marks Tey Parish Council (Mr. Allan Walker)

Support / Object: COMMENT
Document Link: Preferred Options Local Plan - How to Respond
Representation: For future community consideration and consultation, a plain English
summary of the proposed Local Plan should be prepared including heavy
and effective referencing to the many other documents and policies. It
would be helpful if this summary document was available electronically and
the references linked automatically to the relevant documents. Future iterations of the Local Plan the three authorities synchronise the
release of information and their political decision-making and effect an
electronic notification for town and parish councils and other interested
parties for key dates and information publication.

Original submission

Marks Tey Parish Council Response to Local Plan Preferred Options Consultation Page 1
Marks Tey Parish Council Response to Consultation on the Borough Council
Local Plan Preferred Options
Marks Tey Parish Council offers the following response to Colchester Borough
Councils Consultation on its 2017 to 2033 Local Plan Preferred Options. It does so
in general terms both noting our support and our concerns under four broad
headings of:
1. introduction and overall comments page 1
2. detailed comments on part one page 3
3. detailed comments on part two page 5
4. detailed comments on delivery concerns page 7
5. Conclusion page 8
.
1. Introduction, Summary and Overall Comments
1.1 Marks Tey Parish Council considers the proposal to absorb the growth
required of the local authorities within new Garden Communities proposed within
the Local Plan Preferred Options to be visionary and forward-looking. However, it
is extremely high risk with no identification or mitigation of the economic or delivery
risks. Also, at least in the short term, it is very detrimental, uniquely, to the
community of the parish of Marks Tey, again with no stated proposed mitigation.
1.2 Thus, as presented, Marks Tey Parish Council cannot support the
proposals as they are unlikely to be successful. This lack of support is also due to
the likelihood that it may be harmful to the Marks Tey community without
significant alteration in the approach..
1.3 The overall Local Plan Preferred Options document itself presenting this
information, together with its plethora of Evidence Documents, is extremely
complex, confusing, and mechanistic, and completely unsuited to the wide public
consultation that presumably was intended. Forensic concentration is needed to
weave between the relevant documents which grew in number over the
consultation period. This was not helped by seeking consultation over the summer
holiday months nor the lack of detailed synchronisation of the release of
documents and decision dates across the authorities.
1.4 Such a lack of detailed coordination between the three authorities at this
stage does not bode well for the efficient management of such a large project.
1.5 Whilst recognising the highly technical nature required to prepare a Local
Plan, little empathy seems to have been shown to the community who are funding
the Plan and for whose betterment it is presumably intended. This is shown by the
minimal community consultation (at least with the Marks Tey community) prior to
presenting the Preferred Options. This resulted in Marks Tey Parish Council
presenting its own unsolicited representation to CBC. Seeking public contribution
to the Local Plan Panel where contributions were sought either for or against
proposals that where only just introduced did not help, but did not seem to inhibit
the contributions (because everyone ignored it). Also in currently seeking
Consultation contributions based on specific Policy numbers in the document, the
process seems more geared to professional efficiency and constraints rather than
the public. These are not documents and approaches seeking contributions by the
Marks Tey Parish Council Response to Local Plan Preferred Options Consultation Page 2
public rather ones seemingly constructed to prevent it or at least presented for
professional efficiency. Marks Tey Parish Council has neither the professional skill
nor the resources to employ the required talent to respond in this way and thus
offers a community based view and critique of the proposals in broad terms.
1.6 Marks Tey itself has been significantly mis assessed and misrepresented in
the document in that the effects of the A12 and A120 on the community are
underrepresented and whilst the community is well provided with facilities, most of
these facilities are sustained by people outside of Marks Tey via proximity to
Junction 25 on A12. Movement around Marks Tey whether by local vehicles,
pedestrians or cyclists is severely compromised fragmenting the community with
the added imposition of noise vibration and pollution. At the same time the
community have reported through contributions to the Neighbourhood Plan that
what is good about Marks Tey is it smallness of size and access to the
countryside. The intention is to capture these existing community and
environmental strengths in our emerging Neighbourhood Plan, but whose forward
view of our community is rendered blind by lack of any clarity for the future in the
proposed Local Plan to which the evolving Neighbourhood Plan has to conform.
1.7 Marks Tey Parish Council Principal Recommendations
a. For future community consideration and consultation, a plain English
summary of the proposed Local Plan should be prepared including heavy
and effective referencing to the many other documents and policies. It
would be helpful if this summary document was available electronically and
the references linked automatically to the relevant documents.
b. Future iterations of the Local Plan the three authorities synchronise the
release of information and their political decision-making and effect an
electronic notification for town and parish councils and other interested
parties for key dates and information publication.
c. The affected communities get full involvement in the development of the
proposals and that the Marks Tey parish community get a full say in the
size of any surrounding development. How such community involvement in
the development of the Communities is to be effected should be
crystallised and stated in the Local Plan in order to improve on the vague
comments contained within the document.
d. Whilst it is accepted that further examination is required into the Garden
Communities, measurable undertakings should be given regarding this.
This should include specific details of this further examination plus fixed
timetables for what will be undertaken in this examination and by when.
Such undertakings should be included in all proposal documents (and
within the Local Plan itself if work is still outstanding) to give assurance and
security to all affected communities, particularly Marks Tey.
e. As Marks Tey is so affected by the Garden Community proposals no
changes to the parish/settlement should be proposed in Part 2 from what
currently exists, pending clarity on proposals for the Garden Community.
Also that innovative ways be sought in the same timescale to integrate the
evolving Marks Tey Neighbourhood Plan into the wider strategic plans to
form a Neighbourhood Plan 'Plus' that reflects the innovation intended for
the development of the Garden Community itself.
f. Due to the significant and underestimated affects of the A120 as a local
distributor to en route communities, investigations should be undertaken to
Marks Tey Parish Council Response to Local Plan Preferred Options Consultation Page 3
see if the release of land for residential development within the proposed
local plan initial period can also provide temporary early relief to the effects
of the A120 on Marks Tey, Coggeshall, Feering, and Kelvedon. No new
development should be occupied prior to the provision of such highway
improvement or an alternative. A clear and unambiguous statement should
be included within the Local Plan to this effect.
g. Assessment of the significant economic and delivery risk needs to be
undertaken for the Local Plan, together with contingency proposals to
overcome or reduce these else the provision contained within the Local
Plan, particularly Part 1, will only be aspirational and likely to fail. If Part 1
under achieves or fails then this is likely to cause failure of Part 2 due to
existing communities needing to pick up the additional housing load.
These points and more are covered in more detail in the following submission in
some cases with lengthy explanation where the CBC document seems to have
missed the point but in most cases with a suggested recommendation to mitigate
the identified issue.
2 Detailed comments on Part 1 - Shared Strategic Plan
2.1 Marks Tey Parish Council is still, as previously stated, supportive of new
communities to solve Colchester's growing need, of taking a 15 year view of how
this is to be provided and avoiding the 'spread' and merging of other communities.
We agree that this needs to be effected by innovative means with forward funding
and forward provision of infrastructure needs. Marks Tey Parish Council also feels
that some expansion of Marks Tey is needed if this solves Marks Tey's current
significant highways problems and deficits, but before any significant new housing
is added. Such development should add to Marks Tey's sense of place, providing
that this also protects the communities view of what is important to the community
as reflected in its developing Neighbourhood Plan.
Recommendation
* Relief from current significant highway problems, enhancement of Marks
Tey sense of place, and protection of current locality strengths as
expressed through the emerging Neighbourhood Plan are the factors that
should be used as the success measures on how the wider strategic
proposals or any significant growth affect the Marks Tey parish community.
2.2 The Garden Community approach, however, has the implication, of in effect
of imposing two Local Plans on the affected areas of which Marks Tey is the only
one involving the proposed inclusion of an existing 2,500 population community.
The Plan states that these Communities will take limited growth in the 2017 to
2033 period, with much more significant development after this (to possibly 20,000
dwellings in the case Marks Tey). Such an imposition on the community of Marks
Tey without clarification is unique and unfair.
Recommendation
* With Marks Tey as the only Colchester, Braintree, or Tendring community
likely to be fully absorbed within a proposed Garden Community, and in
effect the first phase of one of these Garden Communities, that its
community representation should be integrated into the ongoing process for
managing the development of the Garden Communities ideas and
implementation.
Marks Tey Parish Council Response to Local Plan Preferred Options Consultation Page 4
2.3 There is no examination in the Proposed Options document nor easily
found within the Evidence Documents, of the viability of forward funding for
needed considerable infrastructure development nor of the delivery options to
provide these, which are of course all innovative and new and for which none of
the authorities have any significant previous experience.
Recommendation
* Significant delivery risk examination needs to be undertaken (see detailed
comments on deliverability concerns below).
2.4 There has to be grave suspicion about the economic viability of a proposed
Garden Community sited around Marks Tey (SP9) which does not have the
established employment generators of Stansted Airport nor the University of Essex
as with its western and eastern proposed counterparts. Yet SP9 is proposed
ultimately to be the biggest of all three proposed new communities. No significant
additional employment related land use allocations are mentioned within the Local
Plan period to 2033 and those that do exist are suggested to be diluted (mixed use
of Andersons site). This risks the new Community becoming a larger commuter
community or even failing. However the A12/A120 location is good, the
examination and timing of improvement of the A12 and A120 and planned capital
investment in the A12 are all well suited for fitting in with the proposed Local Plan,
and this could enhance employment generation by providing an early opportunity
to provide possibly temporary new highway access from a new junction to relieve
the infrastructure deficit and access new employment land.
Recommendation
* It would seem prudent to make early investment for employment
generation. The option should be investigated for bringing forward into the
current local plan period 2017 to 2033, additional employment land in Marks
Tey accessed from immanent A12 highway improvement.
2.6 The differing sizes of the new Communities are illogical and no evidence
given to support the relevant sizes. The 7 to 9000 of east Colchester seems
contrary to the stated self-sustaining principals. The potential of 20,000 dwellings
for Marks Tey, the least economical of the sites, swamps the existing community
and threatens Coggeshall.
Recommendation
* Even sizes of self-sustaining new communities would seem more logical
and some statement be given on the relative priority of each Community or
whether these are to be simply commercially driven.
2.7 The Parish Council would like to have an active involvement in the
proposals going forward not only to help to advance and communicate the vision
as it has been trying to do throughout the Consultation period, but also to deliver a
community view into the development of the new Communities as the only
community so far fully engulfed by the proposals. The Parish Council are surprised
that given the implications on Marks Tey that the Borough Council had not
consulted or discussed these issues prior to publication and that all initiatives to
seek discussion have come from the Parish Council.
Parish Council involvement would seem a useful offer particularly as the CBC
approach to date does not seem community aware. If the new communities are
Marks Tey Parish Council Response to Local Plan Preferred Options Consultation Page 5
established and start to grow, those communities are likely to be fully involved in
their development. Marks Tey is in effect proposed to be the first phase of a new
Community. It seems illogical for the University of Essex to be a member of the
Project Board developing the Garden Communities initiative and deciding on
things that will affect Marks Tey but not any community interest from Marks Tey
itself. The Parish Council have repeatedly pressed CBC for involvement but so far
to little effect.
Recommendation
* That a Marks Tey Parish Council, community representative or a
representative of any heavily affected community be invited to join the
Project Board to give community context.
3 Detailed Comments on Part 2 - Local Plan for Colchester
3.1 The CBC Settlement Boundary Review (comments already sent to CBC by
MTPC) as it affects Marks Tey is weak and subjective. The Local Plan proposals
pick arbitrary and non evidenced issues to be undertaken by the Neighbourhood
Plan some based on wrong information for which there has been no prior
discussion with Marks Tey. However, the proposed Local Plan and a proposed
new Garden Community has a huge and significant effect on Marks Tey but
without clear detail or procedures and timescales. This lack of detail is hugely
prejudicial to the community of Marks Tey and to its formulation of its
Neighbourhood Plan, more so than any other settlement within the Colchester
Borough. Thus to treat Marks Tey's evolving Neighbourhood Plan the same as any
other community is illogical and ignores the pressures upon it. Similarly, the parish
being treated in the same way as other Colchester's settlements is unfair and
there is neither recognition of these pressures within the document nor any
proposals to take them into account. With this in mind there is no point in
allocating provisions within SS13 just for the sake of it and the removal of the
settlement boundary around Little Tey is nonsense while so much is over
shadowing the area.
Recommendation.
a. The Policy for Marks Tey (SS13) should be unchanged from existing until
further clarity on the wider strategic implications are clear and a fixed date
should be given for the latter.
b. Investigation should be undertaken to explore innovative ways by which
the evolving Neighbourhood Plan can link into the wider strategy to form a
Neighbourhood Plan 'Plus'.
3.2 The Options document seriously under assessment the current
infrastructure deficit/highway problems in Marks Tey, an issue that unites most of
the residents of Marks Tey. The A120 currently performs two separate functions,
both badly:
* it is an overloaded strategic trunk road carrying through traffic from
Braintree to the A12;
* it is also a local distributor serving the communities of Marks Tey and
elsewhere on its route.
On the latter it has a disastrous effect on community life from the point of view of
noise, vibration, and pollution, to the curtailment of movement through the
Marks Tey Parish Council Response to Local Plan Preferred Options Consultation Page 6
community, for the numerous adjoining roadside properties, and severely limiting
local vehicle, pedestrian, and cycling movement fragmenting the community.
Even the A120s use as a trunk road is compromised by traffic wanting to go south
on the A12 forming a "rat run" through Coggeshall and Feering/Kelvedon. Current
attempts to get future acceptance of an A120 improvement in the 2020 to 2025
road building programme (a significant risky assumption) will not produce a new
road available to traffic and to relieve any current problems within the next 10 to 15
years and could be longer. Localised en route improvement is unlikely to aid the
local distributor problems and could have negative environmental effects on
existing communities that might undermine environmental improvement that is
sought in the longer term through the current Plan. Thus whilst consultees may
say that there is potential with local improvement to increase strategic trunk road
capacity on the A120 such a move would be catastrophic to the existing en route
communities yet the Preferred Options document suggests that residential
expansion is possible.
Recommendation
* The Local Plan should commit to exploring in conjunction with the imminent
A12 upgrade, and the decision on a route for an improved A120, for early
options to release the effects of the A120 on Marks Tey (and Coggeshall
and Kelvedon/Feering) and should not commit to any occupation of new
dwellings before the existing infrastructure deficits have been overcome.
Again, clear and unambiguous statements should be included within the
Local Plan to this effect.
3.3 Marks Tey is currently a largely commuter settlement with a lot of local
people living in the estate and using the railway. With increasing traffic and danger
to pedestrians and cyclists on the A120 the once heavy number of pedestrians
walking or cycling to the rail station has greatly reduced with these people now
presumably driving or getting a lift. This is an assumption being tested in our
Neighbourhood Plan but it is a trend that is totally contrary to what CBC is seeking
to achieve in its Policies.
Recommendation
* Ways are sought within the Local Plan 2017 to 2033 to enhance footpath
and cycleway provision through Marks Tey, to aid mobility and connectivity
through the fragmented community. This will, no doubt also be picked up in
the evolving Neighbourhood Plan.
3.4 There is a general need to apply transitional arrangements to many of the
Preferred Options document individual Policies i.e. Sustainable Transport,
Changing Travel Behaviour, Parking. Many of these policies are written with an
assumption that when they are introduced they are effective. Evidence from the
likes of Park and Ride shows the changing behaviours takes time and that for
instance new development can be flooded with parked cars because reduced
provision has assumed different behaviours from the start. The same need for
transitional arrangements will apply to the new Communities and recognition and a
view should be presented on this in the Local Plan.
Recommendation
* The Local Plan needs to address this transitional issue with, for instance,
interim highway provision pending more permanent solutions or in the case
of parking in new developments perhaps a fixed short-term use of amenity
Marks Tey Parish Council Response to Local Plan Preferred Options Consultation Page 7
land to be used for additional parking while the landscape provided for the
area develops and alternative transport options takes over. This would
seek to avoid policies failing from the start.
4 Comments on Delivery Concerns
4.1 The delivery of the Local Plan as written is high risk with delivery of Part 1
and the Garden Communities very high risk. The Local Plan assessment of risks is
confined to ecological and environmental and Local Plan Policy monitoring. Little
or no consideration is given to the risk factors for the delivery of the Local Plan
itself or the Garden Communities in particular. These risk factors are economic,
political, and professional capacity issues amongst others.
Recommendation
* With the Preferred Options document having been prepared to cover all of
the professional areas and policies required of a Local Plan that additional
effort be put in to ensure its practical delivery, the risks to this, and
mitigation of these risks.
4.2 On the economic factors, putting aside the risk of increased or decreased
demand for housing growth as predicted in the Local Plan, there is considerable
economic uncertainty over the 15 to 30 year period that the Plan envisages. The
economic effects of BREXIT are not likely to be known for the next two to three
years at the earliest, the World economy is at best volatile, and the effects of these
are likely to have an influence on the growth and viability of the new settlements.
Recommendation
* Each phase of any new development or of the new Communities is made
self sufficient so that it adds to existing communities, has it's own
economic viability and employment provision and can be both an end in
itself if circumstances require it to be so as well as contribute to a greater
vision..
4.3 On the political aspects, the Local Plan timescale encompasses many
political cycles both locally and nationally. Colchester Borough Council is a
coalition administration between the two smaller parties with the majority party
excluded. CBC plans for the development at Tollgate have met political resistance
and have been the subject of fierce politic debate within CBC and wider. This must
indicate considerable political risk to the Local Plan.
Recommendation
a. Mitigation of this might be to secure all political parties commitment to the
Local Plan in each Authority and to secure the continued partnership
commitment and funding of both the County Council and of Central
Government to the plan and its continuous monitoring.
b. The other mitigation would be to secure the development proposals by Act
of Parliament, or other statutory means, much as the New Towns were
effected previously, or as Essex and Kent CC did for the second Dartford
Tunnel.
4.4 Relative to professional risk and resource capability, the three new
communities, encompassing some proposed 49,000 new dwellings all in north
Essex, are an untried initiatives on many levels. Such large scale new community
provision is not happening anywhere else in the UK and is the largest since the
Marks Tey Parish Council Response to Local Plan Preferred Options Consultation Page 8
creation of the New Towns. Current Garden Communities, Ebbsfleet, and Bicester
are single communities of around 15,000 dwellings being developed independently
of each, other and Cranbourne and Poundbury are significantly smaller at 3,000
and 2,500 dwellings respectively. Colchester's experience to date is with 5 year
duration Local Plans and some of the longer scale planning that has been
undertaken, i.e. the Hythe and town centre Vinyard St development, have been
subject to economic uncertainty which has resulted in these plans not realising
their objectives as quickly as envisaged and leaving the environment in the mean
time in a state of obvious partial completion or worse. Braintree have pursued
some of the garden community principles (through the Essex Design Guide) with
the Notley Village and Black Notley developments, but again these are only of
5,500 residents (say 2,000 dwellings) and 2 to 300 dwellings respectively. The
new Garden Communities initiative put the authorities in the national spotlight and
requires a national level of excellence and commitment.
4.5 All of this again indicates political and resource risk that could equally apply
to the new Local Plan. None of this of course diminishes the vision contained
within the Local Plan, but without recognition and mitigation of the risks being
included as part of the Local Plan, the Local Plan becomes aspirational and rather
meaningless.
4.6 Whilst the risk is largely to the Garden Communities (i.e. Part 1 of the
proposed Local Plan) these communities are proposed to carry a significant part of
the 2017 to 2033 identified housing growth (17%) so that if they fail this would
need to be transferred to the existing communities within each Authority and this in
itself threatens the viability of Part 2's plans for those existing communities.
4.7 Even at "Preferred Options" stage it is illogical not to examine and state the
practical delivery risks and to indicate to the public how it is intended to mitigate
and minimise these risks.
5 Conclusion
Marks Tey Parish Council recognises that there is good in the Preferred Options
proposals but not at any price and the proposals create much worry and concern
for residents. No attempt has been made to address issues in any of the other
Evidence Documents, and the Parish Council have many issues, i.e. with AECom
Ltd's Garden Community Concept Feasibility Study. MTPC would seek to discuss
these with CBC and, of course, more information and ideas can be provided on
the issues that the Parish Council mentions above. The Parish Council wants to
stay fully engaged in the process as the proposals have so fundamental an effect
on the future of Marks Tey (and the Borough) and look to the Borough for active
and meaningful discussions on a way forward.
Allan Walker MBA, BSc(Hons), Dip Arch.
Chairman, Marks Tey Parish Council
01206 211424
chairman@marksteyparish.org.uk
For Marks Tey Parish Council - 16th September 2016


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