MM4

Change the allocation of homes for Copford with Easthorpe to ensure equitable numbers are given to this area.

Ensure that the Transport Assessment and bespoke travel plans are detailed and take into account local circumstances leading onto main roads, the numbers of homes leading onto roads is in line with guidance notes and does not exceed these numbers.
Ensure adequate health provision is made

MM4 Housing Delivery timescale and numbers allocated to Copford with Easthorpe not appropriate given limited facilities within Parish area when compared to other locations.
MM5 Colchester Housing Provision the number allocated for Copford with Easthorpe is disproportionate to neighbouring areas and other parished areas of Colchester. Copford with Easthorpe is deemed ‘sustainable’ but has only two facilities, a pub and village School. Neighbouring areas with significantly more facilities including local shops, garage, post office and school have a ‘zero’ allocation of homes.
The Appendix SG2 shows 1 home built in Copford during 2017-2020 period this number is incorrect.
MM36 Transport Assessment ‘Bespoke travel plans’ are required where ‘traffic constraints cannot be adequately achieved’ Both allocated Copford sites have significant issues with access, one through a very narrow lane which does not allow for two vehicles passing and pedestrians. Both sites open onto a very busy B1408 and both cannot accommodate the proposed number of homes when measured against guidance notes for road widths and homes leading on to these
roads. The health effects on residents from increased noise and atmospheric pollution have not been adequately considered.
MM58 This may be helpful in ‘conserving’ and ‘where possible enhancing heritage assets’
MM76 No provision is made for increased Health Provision and this will have a damaging effect on both Physical and mental well-being

Indefensible use of greenfield sites contrary to need and government policy. There is thus no justification for the arguably premature and irreversible development of many greenfield sites in more rural areas such as Hall Road Copford. Projected housing numbers show that Colchester Borough Council over estimated the number of housing units required by 2033

As residents of Copford we believe that the Inspector’s Report has failed in its objective of a balanced examination of the Planning Proposals. By failing to provide comment on the numerous and detailed representations submitted to the enquiry there is no possibility of questioning or challenging his reasoning. As such the examination does not appear to be democratic and transparent. The Inspector seems to have undertaken an examination of process rather than of the actual Proposals and their real-world impact.


It appears that following the rejection of Part 1 of the Local Plan - West Colchester/Braintree Borders Community Settlement - there has been no revision of Part 2 of the Plan to take account of this. The Inspector’s modifications are simply corrections to the text rather than an addressing of the underlying planning issues.


1. Inequity in allocating housing numbers
Copford has an allocation of 120 homes, with half of these proposed on greenfield sites in direct contravention of emerging national policy. If we look at other sustainable village settlements, the inequity and unfairness of the allocation to Copford, is striking. West Bergholt, which is more than twice the size of Copford, drops from 120 to 50 homes, Great Horkesley drops from 93 to 13 and Langham from 80 to 40.


As a result of the failure to revise part 2 of the Local Plan following the rejection of Part 1, Marks Tey has no housing allocation at all. This is despite the fact that Marks Tey is the most sustainable of the village settlements; it has the main line rail station, access onto the A12 and A120, a good range of local shops and employment opportunities.


It is worth pointing out that since 1988 the number of Marks Tey dwellings have grown by 10%
against 52% for Copford. On the Council’s plans, Copford will be at 78%, at least, by 2033.


At present, Marks Tey has an imbalance between demographics and housing mix; the Primary School is undersubscribed and consequently is experiencing financial difficulties. In contrast, Copford Primary School is heavily oversubscribed and already stretched beyond capacity.


There is no explanation or reasoning for the housing allocation decision by the Inspector.


2. Indefensible use of greenfield sites contrary to need and government policy
There is thus no justification for the arguably premature and irreversible development of many greenfield sites in more rural areas such as Hall Road Copford.
Projected housing numbers show that Colchester Borough Council over-estimated the number of housing units required by 2033. Although 1350 units at West Tey, and another 200 at the former Sainsbury’s site at Stanway have been removed, there will be 1299 more homes than the estimated requirement of 18400 for the period 2013-2033.


In reality, that additional housing has, and will continue to come forward from the existing urban areas; in many cases brownfield sites, leaving greenfield untouched.


The Inspector’s Final Report has failed to take account of recent Government Planning Housing Policy, which has been outlined by the Prime Minister, restricting housing provision in the South East and redirecting new housing to the North of the UK. Again, the emphasis was on the preference for brownfield rather than greenfield sites.


3. Failure to consider the ‘setting’ of Listed Buildings
We believe that the Inspector has failed in his duty to consider the desirability of preserving the setting of Listed Buildings and also of non-designated heritage assets. Hall Road and Keepers Co)age are non-designated heritage assets requiring special consideration in planning terms. Hall Road itself is an ancient and historic lane with protected status, of huge amenity value, and forming a boundary to the Roman River Valley Conservation Area.


It is quite obvious that the Inspector has not considered the setting of Listed Buildings, and the impact which a development at the greenfield Hall Road site would have on heritage assets such as Hall Road itself, Keepers Co)age and Brewers Co)age. The NPPF is clear that such heritage assets require special consideration by planning authorities. We see no evidence that this consideration has been applied.


Furthermore, as the High Court pointed out in Steer v SSCLG (2017) EWHC 1456 (Admin) the
setting of a Listed Building is not defined in purely visual terms. The expression used in the NPPF is “surroundings in which a heritage asset is experienced” and the word “experienced” has a broad meaning which is capable of extending beyond the purely visual which has been confirmed by policy and practice guidance.


These points lend weight to the argument by residents that the Conservation Area at Swan Green, Stanway which includes the historic buildings bordering the Green, The Swan Inn, and the Grade II Listed Structure of Stanway Bridge, should extend across the Roman River and the parish boundary, to include the immediately proximal Brook Co)age, Copford Place and the greensward
in front of Copford Place, Hall Road, Brewers Co)age, Old Mill House and Shrub House (all Grade II Listed). This is a historic landscape, which demands preservation for current and future
generations and we see no evidence that this has been considered. The protection afforded by the
NPPF has not been considered by the Inspector, and is omitted from the Report.