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We wish to object to the proposed housing allocations defined under Policy SS5 and as shown on the accompanying plan.
Two housing allocations are proposed. One of some 70 dwellings off Queensberry Avenue, Copford and one of about 50 dwellings on land west of Hall Road, Copford. No housing is proposed in Copford Green.
We have a number of comments on these two site allocations.
Firstly, we note that both housing allocations are clearly in Copford and no allocations are proposed in Copford Green. We consider that to be inappropriate given the existing pattern of development and the location of key facilities such as the Church of England primary school. It is also the case that there is an established need for provision of some affordable housing in Copford Green and one way to ensure the delivery of such affordable housing is for this to be provided as part of a mixed affordable and market housing scheme. We are therefore of the view that new housing should not be concentrated solely in Copford but there should also be adequate provision in Copford Green in accordance with SG1. Clearly the proposed housing sites are not 'proportionate' for the growth of Copford Green nor do they take account of the Housing Needs Assessment that has been undertaken.
Secondly, we have a number of concerns about the Queensbury Road site. This site is approached along an existing cul-de-sac and the road currently serves a considerable number of dwellings (130+). It does not seem sensible for an additional 70 dwellings to be served by a single point of access for two reasons. In the am peak hour all outgoing traffic will have to use the existing junction of Queensbury Road and London Road and this is far from satisfactory given the London Road traffic flows. Secondly, it is not sensible to have so much housing development served from one point in the event of emergency access. An accident at the Queensbury Road/London Road junction could have the effect of blocking access for the police, fire and ambulance services.
The proposed site allocation at Queensbury Road should therefore either be reduced in scale or the site needs an additional point of access onto London Road.
Thirdly, the proposed site west of Hall Road is to be served by a single point of access from Hall Road. At present, the northernmost section of Hall Road is narrow in width, it lacks any footway provision and it lacks street lighting. It would appear to be totally unsuitable to serve a development of 50 houses. At peak hours, turning right out of Hall Road into London Road is extremely difficult and there seems to be limited visibility to the east due to boundaries and vegetation.
To compound the above, it would not appear that Hall Road has the capacity for any physical improvement so as to enable it to serve 50 houses. There are no highway verges and private residential properties lie close to the road on both sides. In addition, Hall Road is an important local pedestrian route and a bridleway which is designated as a Protected Lane in the adopted Local Plan. Any significant increase in vehicle usage of this road would be incompatible with its current role as an attractive and peaceful rural lane. It is probably the case that Hall Road does have a modest level of capacity to accommodate a few further vehicles and therefore the capacity of the identified housing site should be determined by the potential traffic capacity of the road itself if this is to be the principal access. A housing allocation of, no more than 10 - 15 dwellings, may be more appropriate in this location.
The proposed housing site west of Hall Road should therefore either be deleted or significantly reduced in scale due to inadequate access arrangements.
Our client (The 2008 Angora Bare Trusts) owns land and property in and around Copford Green. It wishes to see a modest residential development (comprising market housing, affordable housing and some local open space for the village) provided in a comprehensive scheme developed in consultation with residents and the Parish Council.
In 2010, an affordable housing needs assessment was undertaken by Essex Rural Community Council (RCC) and the results of that assessment were presented to the Parish in November 2010. The conclusions of that assessment were that 9 or 10 affordable homes were needed in the village. Following the RCCs assessment, the Parish Council formally resolved to support in principle 9 or 10 affordable homes in the village. No affordable housing has been provided in the village since that assessment and it is likely that needs will have increased in recent years.
Following the Needs Assessment, Iceni Homes have approached our client and the Parish Council with a view to developing an affordable housing scheme in the village of Copford Green. That matter has not been concluded but the landowner is very willing to work with Iceni Homes and other parties to deliver an appropriate package of development in Copford Green to meet the identified need for affordable housing.
In addition to the need for affordable housing, a key issue in the village is the existing primary school which has expanded greatly in recent years. The school has a very good Ofsted assessment record and is held in high regard locally. One of the problems of this growth and success is that many pupils are driven to the school from nearby Copford - i.e. very short local car journeys. That results in considerable on-street car parking close to the school on School Road, during drop off and pick up times.
Our client is able and prepared to provide two infrastructure improvements which may help alleviate these existing problems. Firstly, a school drop-off facility could be provided in association with a modest housing development and the most appropriate location for this would probably be on the east side of School Road in the vicinity of the school. A drop off facility could allow other traffic management measures which could then prevent on-street car parking, for example. Secondly, as part of a development scheme, it is possible to introduce a combined footpath/cycleway link from the school to the southern end of Hall Lane which leads northwards to the built up area of Copford. This could provide a safe and convenient means of access to Copford Primary School from a large area of Copford and hence reduce the short distance car journeys and resultant on-street car parking.
Therefore, we believe that the Local Plan should allocate land for a modest residential development (say, about 30 or so dwellings) including some affordable housing (at 20 % under draft Policy DM8 subject to viability) and local open space on the east side of School Road in Copford Green. As well as being proximate to the established primary school this location is also close to the village Hall and the recreational space at The Pits. That development could include the transport measures outlined above and we believe such an approach would be endorsed by both the Parish Council and by local residents as well as a registered provider such as Iceni Homes. School Road is a good quality road link with adequate visibility and there are no significant constraints to creating a new access in this location. The road easily has the capacity to accommodate an additional development of this scale and there would be no adverse effects for existing residents further to the north.
We can confirm that the land in question (east of School Road, Copford Green) is in single ownership, it is available for development and it is potentially deliverable in the short term. We believe it is relatively free of constraints and suitable for an appropriate level of development. A plan is enclosed which broadly identifies a potential location for a development of this nature and we suggest that a scheme of the order of 30-35 dwellings would be appropriate. A greater level of housing could potentially be provided subject to local consultation and resident views.