Fiddlers Field (formerly Site 226) Development

I write on the subject of the Eight Ash Green Neighbourhood Plan and the proposed adoption of Site 226 for development.

My major concern is the increase in traffic that any such development would cause and if the proposal is to go ahead mitigating factors must be implemented.

Firstly, I would like to complain about this process which, in and of itself, has all along precluded options which would have minimised the impact of additional traffic; clearly, a village the size of Eight Ash Green, and its associated road infrastructure, would more easily accommodate additional houses if they were spread over several sites. However, it has always been presented as a choice of a site in an "all or nothing" manner.

There are already significant problems of traffic in the evenings caused by cars wanting to turn right onto Spring Lane and Wood Lane. The Spring Lane junction is a particular problem and traffic can back up as far as the A12 roundabout. Clearly, this will be exacerbated by any more traffic trying to reach any part of the village. Mini-roundabouts are required at the Spring Lane and Wood Lane junctions to reduce the back up of traffic. The cost of this should fall to the Council as it is an existing problem.

I am also firmly of the view that if Site 226 is to be developed then a footpath is needed all the way from Fiddlers Folly down to Fiddlers Farm so that pedestrians have a chance of getting to Fordham via footpaths with less of a risk of being run over. The cost of this should fall to the developer.

We contest that residents were aware of the tiered voting process to determine the final site location. The notices/newsletters/website did not make it clear at the point when 9 sites were selected that there would be a ranking process and voting. The consultation sessions were advertised as awareness sessions not voting.

We also contest that describing site 226 as a single site is mis-leading with the plan to establish an HGV traffic link road right through the middle of the development. There seem to be two developments here - one on one side of the road and one on the other. This will squish the housing into small pockets and will be less appealing for residents and will not join the village together.

The introduction of a mini-roundabout + a bus stop at the entrance to the development on the A1124 side will increase the amount of standing traffic outside of the existing houses (particularly Choats cottages to the south of the development). This will be a detrimental impact to existing residents. While those residents currently experience high speed traffic - at least it is not sitting idle outside of homes.

The plans are still unclear as to how traffic will access the existing businesses at Fiddlers farm. will there be a route through the new housing development or will there be access directly from fordham road?

Policy FF10. Essex County Council as Lead Local Flood Authority request the following additional wording to FF10 '... in line with the Essex SuDS guide. Where possible SuDS should incorporate above ground features to maximise the provision multifunctional green infrastructure.'

Essex County Council (ECC) make the following comment on Policy FF14. This may be read as a comprehensive list of infrastructure requirements. ECC as Local Education Authority may, for example, also require a secondary school contribution. It should be made clear that these are the priorities of the Parish Council and that other parties may seek other contributions, through the planning process (via the Local Planning Authority).

Reference is made to the preparation of a scheme to demonstrate appropriate surface water drainage is provided within the allocation site.

The Revised National Planning Policy Framework (February 2019) states that major
development sites will be expected to incorporate Sustainable Drainage Systems (SuDs) unless it can shown to be technically unfeasible.

Anglian Water support the requirement for applicants to include the provision of Sustainable Drainage Systems (SuDS) so as not to increase flood risk and to reduce flood risk where possible. The use of SuDS would help to reduce the risk of surface water and sewer flooding.

We therefore ask that Policy FF10 be amended to refer to the provision of Sustainable Drainage Systems as follows:

'f) Adopting best practice in sustainable drainage with development proposals incorporating the provision of Sustainable Drainage Systems (SuDS) unless it can be demonstrated to be technically unfeasible.'

To provide clarity of the proposed extent of the allocation, a policies map should be included.

Clause FF14 should be updated to provide greater flexibility of how developer contributions could be secured. This clause should be updated to "A Section 106 Agreement and/or, through a Community Infrastructure Levy (CIL) payment or other planning obligation".

As noted in the Eight Ash Green Strategic Environmental Assessment (SEA) Report (January 2019), an additional clause should be added to the Fidders Field Policy in relation to the adjacent Local Wildlife Site (LWS). This clause could read as:

FF15 - Without adversely affecting the Local Wildlife Site, provision of sufficient open space to meet the daily needs of future residents.

Policy SG2 of the ELP identifies a borough wide need to accommodate "at least 14,720" new homes between 2017 and 2033, as such, the allocation of 150 dwellings in the ELP should be viewed as a minimum number. This approach accords with paragraph 59 of the NPPF that states the Government's objective to significantly boost the supply of homes.

Paragraph 33 of the NPPF states that plans are likely to require early review if local housing need is expected to change significantly in the near future. If site 226 does remain the preferred site then it is recommended that my client's site be identified as a preferred option for the future growth of the village. Given the proximity of Eight Ash Green to Colchester it is inevitable that it is an area where growth will be directed in the future.

Whilst Policy SS5 identifies that the allocation can be at a site or sites the Site Selection Process document demonstrates that significant weight was given to the allocation of a single site during the Neighbourhood Plan allocation process. The allocation of a single site to accommodate the requirement of at least 150 dwellings does not provide the necessary flexibility to allow for other residential development to be delivered elsewhere in the village if through valid design and placemaking reasons the allocation at site 226 does not come forward. Moreover, Policy FF1 does not allow any flexibility if, through the examination of the emerging Colchester Local Plan the allocation numbers were to increase.

The selection process has given a disproportionate amount of weight to the delivery of the entire allocation at a single site. This has resulted in a less sustainable site being allocated. As such my client believes that the SNP conflicts with Basic Conditions A and D.

Policy FF2 is not consistent with Policy SS5 of the emerging Colchester Local Plan as it includes the wording 'up to' 150 new homes. The removal of 'up to' from a previous draft of Policy SS5 and the reference to at least 14,720 new homes in Policy SG2 demonstrate that the figure of 150 dwellings should not be seen as a maximum limit for Eight Ash Green, which accords with paragraph 59 of the NPPF that aims to significantly boost the supply of homes.

This reinforces the argument the allocation of a single site for Eight Ash Green to the far west of the village does not give sufficient flexibility to accommodate future growth in more sustainable locations that promote greater opportunities for residents to use sustainable modes of travel. It also demonstrates that the SNP is in conflict with Basic Condition E as it would not be in general conformity with the strategic policies contained within the emerging Colchester Borough Local Plan.

Proposed Policy Change: Policy FF2 should be amended so the words 'up to' are
replaced by 'at least'.

From the Site Selection Process document it appears that the promoter of site 226 offered road access via a new link road between Fiddlers Hill and A1124 with a roundabout at each end to help divert heavy traffic from going past the school entrance as well as off Wood Lane and that no houses would 'front' on to the new link road. This developer promise has clearly been incorporated into the specific wording of Policy FF4. The accompanying text to Policy FF4 identifies that the proposed link road and associated junctions were key reasons why villages chose to allocate the Fiddlers Field site.

However, the specific requirement to deliver a new direct access road to accommodate HGV traffic with access by way of a priority junction cannot be guaranteed and will be subject to the agreement of the Local Highway Authority. Moreover, having a road that has no dwellings fronting onto it running through the centre of the new development is not conducive to supporting pedestrian and cycle movements to destinations like the primary school, or other community facilities in the village, which are some distance from the proposed allocation.

From a design point of view the proposed road would clearly be designed to accommodate vehicular traffic rather than being a street at the heart of a people focused development. This would fail to comply with CBC Policies UR2, TA1 and TA2 and paragraphs 78, 102, 110 of the NPPF that seek to enhance the places where people live and promoting walking and cycling. Clearly the emphasis of the site selection process was to improve the situation for existing residents with little regard for the living condition of future residents.

There are clearly aspirations for community facilities to be delivered as part of the
proposed allocation both on-site and off-site. Given the significant financial requirements of providing the highway infrastructure identified in Policy FF4 there is the potential for viability to be a material consideration in the determination of any planning application. This could negatively impact upon the provision of off-site community facilities and wider road network improvements identified in Policy FF14. This could also result in a negative impact upon the level of affordable housing that the development would be capable of delivering in conflict with CSP Policy H4 and NPPF paragraphs 20 and 34.

The selection process has given a disproportionate amount of weight to the delivery of this piece of infrastructure for site 226 to be accepted by the village, which cannot be guaranteed. This has resulted in a less sustainable site being allocated. As such my client believes that the SNP conflicts with Basic Conditions A and D.

Criteria 10 of the Call for Sites Assessment Checklist looked at how far is the site from existing public transport. Based on this criteria site 039 performs better that site 226, which is at the far western end of the village, the furthest away from Colchester, the Stanway retail area and the nearest secondary school. At present, the nearest bus stop on the A1124 to the proposed allocation is some 200m away and Policy FF8 seeks to deliver new bus stops on the A1124. In contrast to this, there is an existing bus stop to the south of site 039 on the A1124 that presently connects the village with Colchester.

There is no guarantee that the Fiddlers Field development will deliver new bus stop on the A1124 or that the provision of a new bus stop would not have an adverse impact on the existing service for the village. Moreover, depending on the timing of any new bus stops and the phasing of the new homes it could be that new residents move in before the bus stops are provided. Once residents move in and establish travel habits using the private car it will be difficult to encourage use of public transport. The need for a bus stop to make the allocation acceptable reinforces the lack of robustness of the site selection process that identified it. Therefore, it is inevitable that a greater number of residents of the preferred Fiddlers Field site would use private cars to access most of the village facilities and the employment and retail areas of Colchester. This would result in additional traffic on the already heavily used A1124.

Whilst the bus stops are required to increase the sustainability of the site by allowing
greater access to public transport there is no guarantee that they can be delivered.
Therefore, greater weight should have been given to sites that are presently well served by public transport through the site selection process. This has resulted in a site being allocated that will not deliver a sustainable form of development. As such my client believes that the SNP conflicts with Basic Conditions A and D.

See attachment.