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1.1 This representation on the Colchester Draft Local Plan (DLP) Preferred Options
Consultation 2016 is submitted by Strutt & Parker LLP on behalf of Mr Charles Gooch.
1.2 As the Council will be aware from our previous submissions in October 2014 (in respect of the Call for Sites) and February 2015 (in respect of the Issues and Options Consultation) Charles Gooch is the owner of the land at Elmstead Road and Colchester Road, Wivenhoe and is actively promoting the site for residential development.
1.3 For completeness a map showing the submitted site is provided as Appendix 1 to this submission.
1.4 The sites are located immediately adjacent to the current settlement boundary of Wivenhoe, shown in the Adopted Plan. It should be recognised that the settlement
boundaries contained within the adopted Colchester Local Plan were predicated on
the need to accommodate significantly less development than currently required for
the Borough, and the sites are located in a sustainable position adjacent to the
1.5 This representation includes a commentary on Colchester Borough Councils approach to allocating a quantity of development to meet its objectively assessed housing needs, an assessment of the locational apportionment of development within the Borough and the specifics of the two sites and their sustainability for allocation for residential development.
1.6 As set out in previous submissions to the Council, land at Elmstead and Colchester Road constitute a sustainable and deliverable development opportunity, subject to allocation, to contribute towards meeting housing needs.
1.7 In addition to commenting directly on the Preferred Options, this representation also includes submissions pertaining to the Sustainability Appraisal / Strategic
Environmental Assessment (SA/SEA) which is published alongside this iteration of the Local Plan.
2 STRATEGIC HOUSING POSITION
Local Plan Vision
2.1 We support the vision (paragraph 3.5) to maintain a good housing delivery rate over the plan period to meet objectively assessed housing need. As per paragraph 182 of the NPPF, it is essential that the Local Plan includes a deliverable and justified strategy that will enable objectively assessed housing need to be met. In order for the Local Plan to be compliant with the NPPF, it should not only seek to meet objectively assessed development needs of the Borough in full, but also unmet needs of its neighbours where it is sustainable and reasonable to do so.
2.2 We fully support the identification of Wivenhoe within Policy SG1 as a District Centre. It is noted that Wivenhoe is identified in the second tier of the settlement hierarchy, sitting only behind central Colchester and its respective growth areas in sustainability terms. It will be therefore be important for the Local Plan to facilitate the sustainable growth of Wivenhoe.
Policy SG1 - Colchester's Spatial Strategy
2.3 Policy SG1 adds that development will be focused on highly accessible locations to reduce the need to travel. District Centres are considered by the Council to have the potential to accommodate approximately 1,200 homes` with a developmental focus on highly accessible locations to reduce the need to travel
2.4 We support the preferred approach of directing an element of housing growth to the Borough's towns and villages to maintain their vitality and viability. Both the NPPF (see for example paragraph 55) and the NPPF (paragraph: 001 Reference ID: 50-001-20160519) recognise the importance of planning in ensuring smaller centres are sustained and can continue to perform their important roles for the local communities they serve. Facilitating housing growth is recognised as an important part of this. Additionally, such an approach is considered appropriate due to the functionally separate nature of the various settlements within the Borough.
2.5 In assessing locations and their capacity to support sustainable development, CBC assessed sites against the following framework:
* Access to sustainable transport (Railway station; bus stop - including crude
consideration of quality of service; good accessibility is considered to be a
distance of up to 2,000m to train station with a frequent service at least six
days a week, or up to 400m of a bus stop with a frequent service at least six
days a week.
* Environmental constraints such as flooding, protected landscapes, etc.;
* Proximity to community facilities with good accessibility being judged for most
as judged as a distance up to 400m including;
o Public open space
o Primary school
o Small shops to meet local needs
o Community / village Hall;
o Doctors Surgery
o Proximity to Secondary School;
o % of people who travel less than 2km to work;
2.6 Paragraph 4.20 of the Preferred Options Consultation confirms that Wivenhoe has automatically been included in the Sustainable Settlements category due to its larger population and concentrations of jobs, facilities, and services and function. Against the sustainability assessment set out above, District Centres represent the most sustainable settlements to support further development. The land at Elmstead Road and Colchester Road represent a suitable, achievable and deliverable opportunity to come forward for residential development in the early stages of the Emerging Plan to meet CBC's objectively assessed need.
2.7 The Preferred Options consultation identifies that 250 dwellings be allocated for
Wivenhoe across the plan period, which equates to approximately a 7.8% increase in the number of dwellings within Wivenhoe Town. The Preferred Options advises that in meeting this need, due regard should be given to locally specific physical and social considerations which could constitute developmental constraints.
2.8 Both the land at Elmstead Road and the land at Colchester Road are allocated as
suitable sites to assist the requirement for settlement growth given their sustainable
position and lack of environmental constraints. It is critical that the Local Plan supports the sustainable growth of the settlement of Wivenhoe, to ensure it can continue to perform its important role for residents of the settlement and surrounding area.
Policy SG2 - Housing Delivery
2.9 We support the proposal to deliver at least 920 homes per year between 2017 and 2033. This approach is supported in principle by the NPPF which not only calls for a significant boost to the supply of housing (paragraph 47), but also makes clear that Local Plans should ensure a strategy is in place to meet objectively assessed
development needs of not only the administrative area in question, but also unmet
needs of neighbouring areas where it is sustainable and reasonable to do so
2.10 It is crucial that the strategy for delivering homes to meet local needs is not overly reliant on large, strategic sites that are a) unable to contribute towards housing need in the short-term; and b) are likely to prove highly challenging to deliver, requiring the coordination of multiple parties and agencies. The NPPF not only highlights the importance of ensuring strategies are deliverable (paragraph 182), but that a constant five-year housing land supply is sustained over the plan period (paragraph 47), and that the strategy for meeting objectively assessed housing needs is sufficiently flexible in order to respond to change (paragraph 14). As such, it is important to ensure that a range of sites capable of delivery sites for the various communities that make up the Borough, and across the plan period are identified. Further, it is also key that the Local Plan treats the identified housing need figure as a minimum, enabling the plan to respond to changing circumstances over the plan period (e.g. identified sites failing to coming forward, increase in housing need, etc.).
2.11 Whilst capable of making a significant contribution towards meeting housing needs, the land at Colchester Road and the land at Elmstead Road at 3.06 and 0.93 hectares respectively, are not of such a large, strategic nature (when compared, for example, the proposed New Garden Communities) as to require major additional infrastructure or to be complex from a delivery perspective. The sites are capable of contributing towards meeting housing need in the short to medium term. This is particularly important given the need for a five-year supply housing land supply to be in place throughout the plan period - the Local Plan cannot rely solely on large, strategic sites unlikely to contribute towards housing need until towards the end of the plan period.
2.12 In line with the justification for Local Plan flexibility and deliverability we fully support that, as identified in Table SG2 in the Preferred Options, Wivenhoe's allocation for 250 houses is taken as a minimum housing provision target across the plan period. Indeed paragraph 2.79 of the Preferred Options consultation document sets out that 1,200 homes will be allocated in Rural District Centres, which includes Wivenhoe, Tiptree and West Mersea. Furthermore, the Sustainability Appraisal at page 215 identifies that Wivenhoe may be expected to accommodate a higher number of new homes than the 250 it has been allocated. It is therefore important that the figure of 250 houses is considered to be a minimum housing target.
3 SS18 - WIVENHOE
3.1 The CBC Preferred Options Proposals Map identified both the land at Elmstead Road and the land at Colchester Road for residential development in accordance with the Wivenhoe Neighbourhood Plan. We support this approach and submitted
representations supporting the Neighbourhood Plan during the September 2016 presubmission consultation. A copy of this representation is available at Appendix 3.
3.2 The Preferred Options identifies Wivenhoe as a District Centre which should
accommodate a proportion of additional housing growth. It is reasonably well
contained, and functionally separate from other settlements within the Borough - as
such it is important that its growth is planned for in the settlement, and not directed
elsewhere within the area. In addition, it is important that the settlement is allowed to growth to ensure its vitality, and that its local facilities and services, which are important to residents of Wivenhoe itself and surrounding rural villages, are sustained.
Consequently, the approach within SS18 to allocate a minimum of 250 houses across the settlement is supported.
Wivenhoe Neighbourhood Plan
3.3 Policy SG1 - Colchester's Spatial Strategy and SG7 - Neighbourhood Plans set out that the allocation strategy and matters of detail relating to development sites will be dictated by Neighbourhood Plans in settlements which are in the process of preparing a new Neighbourhood Plan. To this end, Policy SS18 places the onus for identifying detailed development strategy within Wivenhoe to the Wivenhoe Neighbourhood Plan.
SS18 requires the Neighbourhood Plan to :
i) Identify the settlement boundary for Wivenhoe
ii) Identify specific sites for housing allocations needed to deliver 250 dwellings.
iii) Set out any associated policies needed to support this housing delivery i.e. housing mix, type of housing and density for each site allocated for housing.
iv) The Neighbourhood Plan will also set out the infrastructure requirements to
support new development.
3.4 Mr Charles Gooch has engaged with Wivenhoe Town Council throughout the formation of the emerging Neighbourhood Plan. As part of the recent pre-submission
Neighbourhood Plan consultation (2016), representations were submitted which set
out broad support for the emerging plan, subject to some matters of detail. A copy of this representation is included at Appendix 3.
The land at Elmstead Road and Colchester Road
3.5 The sites benefit from a lack of constraints that would prevent residential development. The Council will be aware from our previous submissions and that the sites are sustainable and deliverable. Both sites are located entirely within Flood Zone 1.
3.6 The site is not within or adjacent to any areas designated for their ecological
importance. It is not considered to be of any significant biodiversity value, and any
ecological impact could be managed through the development management process.
Indeed, development of the site would give rise to the potential for ecological
enhancements to the area. Further detail on the approach to the sites delivery is
contained within the Delivery Statement which supports this representation.
3.7 The sites are not within or related to any areas identified as being of concern in respect of air quality.
3.8 The development of each site would be neither near to or result in the generation of significant levels of noise which would have an adverse impact on residential amenity.
3.9 There are no insurmountable constraints to providing a suitable level of vehicular access to each site in accordance with the requirements of Essex County Council.
3.10 Nevertheless, it will be important that CBC are aware that we have made comments on the detailed manner in which the Town Council are considering the development of these sites, ;particularly with regard to development deliverability and viability. This is included in the representation at Appendix 3.
3.11 Further, with particular regard to the land at Elmstead Road, we note that Policy WIV30 of the Wivenhoe Neighbourhood Plan identifies a 1.5 hectare parcel of land for use a a cemetery. Whilst we general accept this land use, we note that it is not included within Policy SS18 the Colchester Borough Council Local Plan, nor do we have clarity as to how this use will be implemented and operated. Mr Gooch is a farmer and is therefore not in a position to implement
3.12 We are committed to working positively and constructively with the Parish Council in respect of the development of Land at Colchester Road and Elmstead Road and the Neighbourhood Plan. However, it should be borne in mind that the NPPF requires the Local Plan to provide an effective, deliverable strategy that will meet housing need (paragraph 182), and one which is sufficiently flexible to respond to changing circumstances (paragraph 14). In the event that a Neighbourhood Plan which allocates sufficient sites to deliver at least 250 new homes fails to materialise it will be important that the Local Plan provides sufficient flexibility to react to such circumstances, to ensure the Borough's housing need can still be met and that sufficient land is available to support the sustainable growth of Wivenhoe - one of the Borough's District Centres.
4.1 Land at Elmstead Road and Colchester Road represent sustainable allocations for
residential development to help meet housing need and to support the sustainable
growth of the established District Centre of Wivenhoe. The allocation of the sites will
assist in ensuring the Borough has an adequate, deliverable housing land supply in
4.2 Neither the land at Colchester Road or the land at Elmstead Road are subject to
constraints that would prohibit their development and is being actively promoted - the Council can therefore have confidence in their delivery for residential development.
4.3 We welcome further discussions with the Council regarding the delivery of these sites to contribute towards a sustainable strategy for accommodating development in the Borough.