Village Settlement Boundary

It is unclear from the current map provided the extent of the revised settlement boundary as the colour is not distinctive and it appears that an area that is proposed for removal is shown in a darker grey, but no key is provided to clarify this. The map should be updated to show only the revised settlement boundary (excluding areas removed), and this should be easily distinguishable. This is to provide clarity.

My client, Hopkins Homes, have serious concerns that the submission Neighbourhood Plan (SNP) is predicated on the delivery of single site allocation and that the site selection process is fundamentally flawed. As part of the Neighbourhood Plan process my client has previously promoted site 039, which is one of the sites that has not been included in the SNP.

Polices VSB1 and FF1 essentially deliver the same outcome, which is the accommodation of the 150 dwellings that are proposed to be allocated to the village through the emerging Colchester Borough Local Plan 2017 to 2033 (ELP), at a single site to the far west of the village. This site was originally identified as site 226 and is known as Fiddlers Field.

Site Selection Process

The Neighbourhood Plan Call for Sites process included an assessment of the 10 sites that came forward based on a Checklist of 31 criteria. Criterion 24 of the Call for Sites Assessment Checklist looked at how many existing properties would be affected by close proximity to the site and how. Paragraph 7 of the Site Selection Process document identifies that residents attached significant weight to minimising disruption with existing housing when assessing sites. This factor together with the offer of a relief road for Wood Lane clearly influenced the allocation of the Fiddlers Field site on the far west of the village.

Criteria 25 to 29 of the Checklist looked at the proximity of sites to schools, retail and health services. However, there is no criterion in the Checklist that looks at the proximity of sites to places of employment. Given that travel to work is a key generator of traffic the fact that the site selection process did not consider this important factor calls into question the robustness of the selection process.

The ranking exercise for sites 039 and 226 was heavily based on traffic impacts, with site 226 being considered to reduce impacts through the proposed 'relief road' and work to the A1124. Site 039 was considered to result in localised traffic impacts through using The Walk as its main vehicular access. Whilst site 226 was considered positively as it is near to the school and shops any dwellings on site 039 would be similar distance from both the primary school and village shops. Though the ranking process did not take this into account, neither did it take into account proximity to wider retail facilities to the east of Eight Ash Green in Colchester.

The Neighbourhood Plan Group site assessments table in Annex P of the Site Selection Process document shows that site 039 failed to meet two of the four Primary Criteria due to the lack of highway access onto the A1124 and loss of open views. It is only the sites that were considered to meet all the Primary Criteria that were then assessed against the Secondary Criteria. At this point the remaining sites were then considered with regards to their proximity to village services and facilities.

The table below shows that on all counts site 039 performs better than site 226, other than proximity to the primary school, where site 226 is presently only 0.09km nearer.

Secondary Assessment Criteria 5 to 10
Site 039
Site 226
Proximity to primary school
1.15km
1.06km
Proximity to secondary school
2.63km
3.45km
Proximity to doctor's
2.06km
2.85km
Proximity to pharmacy
1.74km
2.56km
Proximity to supermarket
1.74km
2.56km
Proximity to bus stops
Adjacent (A1124)
50m (Fiddlers Hill) 200m (A1124)

It is also noted that site 39 also outperforms site 226 in respect of the travel distance to the other facilities in the village listed that are below.

Site 039
Site 226
Proximity to public house
0.8km
1.77km
Proximity to allotments
0.48km
1.44km
Proximity to sports pitches
0.96km
1.93km
Proximity to site of new community facility
0.16km
1.12km

The second criterion of the Single Strategic Site table in Annex Q of the Site Selection Process document states that 'The Site must have direct access on to the A1124'. This is clearly a factor why site 039 was rejected. The accompanying remarks state that "150 houses additional houses potentially means 300 cars + entering or leaving the Site". Such a statement demonstrates that little consideration was given to the transport modelling that would be carried out to support any detailed proposals. This modelling would demonstrate that vehicular movements from a development site would be dispersed throughout the day and that not all residents would use private motor vehicles to meet their daily travel needs.

To the layman considering the proposed sites a statement that 300 cars + would enter and leave the site is misleading and would have clearly influenced residents' decisions on what site to vote for. There is no evidence that the positive impact that travel planning could have in generating a modal shift away from private car use, especially in sites like 039 where existing public transport routes are in place and a greater number of services, facilities and employment opportunities would be within walking and cycling distance of the new dwellings.

After reviewing the evidence base for the SNP it is clear that through the site selection process significant weight was given to minimising the impact on existing residents, rather than considering the most sustainable location for the new dwellings to be located. The fact that none of the four Primary Criteria related to the sustainability of sites meant that my client's site was not then considered against the Secondary Criteria, where it outperformed site 226.

Clearly this approach is at odds with the aim of achieving sustainable development through minimising vehicular traffic from new development as limited weight has been given to sustainable travel to village facilities and employment through this process. In fact, there is a distinct absence of robust technical evidence to adequately assess the travel impact of new residents. Instead the allocation is based on limiting the impact of new development and existing traffic on the village.

Basic Condition A of Schedule 4B of the Town and Country Planning Act 1990 requires a Neighbourhood Plan to have regard to national planning policies and guidance. In this case the National Planning Policy Framework (NPPF) and National Planning Policy Guidance (NPPG). The NPPF and NPPG place great emphasis on the importance of achieving sustainable development with paragraph 7 of the NPPF identifying that the purpose of the planning system is to contribute to the achievement of sustainable development. Indeed, achieving sustainable development is also Basic Condition D in preparing a Neighbourhood Plan. Paragraph 32 requires that significant adverse impacts on the three objectives of sustainable development should be avoided and wherever possible, alternative options which reduce or eliminate such impacts should be pursued.

The decision not to allocate my client's site has not taken into account the benefits of delivering sustainable development in accordance with Paragraphs 7, 8 and 9 of the NPPF. This is specifically with regards to encouraging sustainable travel to the employment and retail areas of Colchester and the existing and proposed community facilities of the village. In both cases the Fiddlers Field site offers less opportunities to encourage sustainable travel as a result of its location to the far west of the village.

In light of the above the SNP is in conflict with Basic Conditions A and D as it would not result in the most sustainable site being allocated for the delivery of new housing in Eight Ash Green. This would be a clear conflict with the policies of the NPPF and the need to deliver sustainable development.