MM5
Object
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 8171
Received: 09/11/2021
Respondent: Mr. Graham Barney
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
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 facilties 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.
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
Object
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 8261
Received: 12/11/2021
Respondent: Mr Jeremy Hagon
Legally compliant? No
Sound? No
Duty to co-operate? Yes
An amendment to ADD 100 units to Stanway New Allocations total to reflect modification to WC2 by increasing Lakelands West from 150 to 250 dwellings should be reconsidered due to excessive housing growth without required community and highways infrastructure in the Stanway area.
Retain existing allocations.
An amendment to ADD 100 units to Stanway New Allocations total to reflect modification to WC2 by increasing Lakelands West from 150 to 250 dwellings should be reconsidered due to excessive housing growth without required community and highways infrastructure in the Stanway area.
Object
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 8313
Received: 13/11/2021
Respondent: Mr Rhys Smithson
Legally compliant? Yes
Sound? Yes
Duty to co-operate? Yes
It is unclear whether the 400 dwelling housing allocation for Tiptree is incremental to or replaces the existing commitment to provide 326 dwellings. The public require certainty as to the final number. If the existing 326 dwelling commitment are unlikely to be delivered why are they not removed from the plan?
Clarification of the total dwelling allocations including existing and incremental commitments should be explicit.
It is unclear whether the 400 dwelling housing allocation for Tiptree is incremental to or replaces the existing commitment to provide 326 dwellings. The public require certainty as to the final number. If the existing 326 dwelling commitment are unlikely to be delivered why are they not removed from the plan?
Object
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 8442
Received: 15/11/2021
Respondent: Dr Michael Monk
Legally compliant? No
Sound? No
Duty to co-operate? No
There is a gross inequity in the allocation of housing numbers.
Copford has an allocation of 120 homes with half of those proposed on greenfield sites.
Marks Tey has 0 homes allocated despite being a more 'sustainable' village.
Reduction in housing allocation for Copford and fairer distribution across the Borough.
No acceptance of building on greenfield sites.
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.
Object
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 8937
Received: 15/11/2021
Respondent: Dr Michael Monk
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Inequity in allocating housing numbers – Copford has 120 homes, other sustainable village settlements West Bergholt 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
Marks Tey has no housing allocations at all despite being most sustainable of the village settlements
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.
Marks Tey has an imbalance between demographics and housing mix; the Primary School is undersubscribed and consequently is experiencing financial difficulties. Copford Primary School is heavily oversubscribed and already stretched beyond capacity.
Housing provision Number for Copford with Easthorpe is disproportionate to neighbouring areas elsewhere in Colchester. Should be a provision for housing made in Marks Tey
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.
Object
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 8945
Received: 07/11/2021
Respondent: Andrew Waters
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Part 2 of the Local Plan was not revised following the rejection of Part 1 of the Plan (demise of West Colchester/Braintree Borders Community).
1.Marks Tey has no housing allocations 2.Examination of process rather than an examination of the Planning Proposals. 3.Projected housing provisions indicate over estimation of housing units required by 2033. No need for development of so many greenfield sites in more rural areas.4. Not possible to know current numbers on the books for each village or if figures are accurate and up to date5.Inequity in allocation for sustainable settlements.
6.Final report sought to be amended to reflect emerging government policy to restrict housing provision in the overburdened South East and emphasis on using brownfield rather than greenfield sites. Several justifiable grounds to reduce or even withdraw housing allocation for Copford.
In my opinion, the Inspector's report reveals several shortcomings in the process and the examination.
Part 2 of the Local Plan was not revised following the rejection of Part 1 of the Plan namely the demise of the West Colchester/Braintree Borders Community Settlement known as West Tey. A result is that much of the inspector's modifications are simply proof reading corrections.
1. A second result is that Marks Tey the most sustainable of the village settlements due to its main line rail station, the direct access onto the A12 and Al20, a reasonable range of shops and substantial employment opportunities bas no housing allocation at all!
2. Apart from some modest changes the examinations comes across as an examination of process rather than an examination ofthe Planning Proposals. A significant number of detailed representati ons in writing and on-line to the inquiry were made yet there is a complete absence of comment by the Inspector contrary to natural justice. Many are of the view it has diminished this consultation as there has not been an opportunity to question or challenge any reasoning of the Inspector. In a democracy it is important there is a feeling that representations are heard and fairly considered.
3. The projected housing provision indicate the Borough Council over estimated the umber of designated housing units required by 2033. Despite the removal of 1350 at West Tey and 200 at the former Sainsbury's site at Stanway there wlll b~ 1299 more homes than the estimated requirement of 18400for the period 2013-2033. The reality is that additional housing has and come forward from the existing urban areas. Many from the redevelopment of brownfield sites or the conversion of commercial buildings. There can be no doubt that this additional provision will continue.
Accordingly the evidence is that there is no need for development of so many of the greenfield sites in the more rural areas.
4. An assessment of the Inspector's report would be enhanced by a greeter breakdown in the housing numbers available in Appendix 1. At the moment it is not possible to know the current numbers on the 'books' for each villag e or whether these figures are accurate and up to date.
5. There is striking inequity in the allocation for the sustainable settlements.
Copford (northern part only excluding the village of Easthorpe and Copford Green) still has 120, Whereas, West Bergolt, more than twice the size, drops from 120 to 50, Great Horkesley drops from 93 to 13, Langham drops from 80 to 40. Whilst
neighbouring Marks Tey is on 0. Although Marks Tey has in recent years had 39 new units on the brownfield development at Point Chase in the procee ding period back to
1988 they had less than 100 additional dwellings compared to about 240 in Copford As a consequence Marks Tey has an in-balance in the population demographics and the housing mix available resulting in the School having growing spare capacity and resultant financial stress. The reality is that Marks Tey would benefit from additional housing especially if their location drew the various segments of the village together. The alternative is that some landowners/developers will seek to exploit the weakness in the Plan in a way that is not beneficial for the existing community.
6. Finally the final report ought to be amended to reflect the emerging Government Planning Housing Policy, outlined by the Prime Minister at the Conservative Party Conference in restricting the housing provision in the overburdened South East and instead redirecting more of the new housing to the northern regions. Secondly the reemphasis on use of brownfield rather than greenfield sites. Recent statements my Michael Gove confirm this change in emphasis.
The above evidence and comments demonstrate there are several justifiable grounds to reduce or even withdraw the housing allocation for Copford.
The above evidence and comments demonstrate there are several justifiable grounds to reduce or even withdraw the housing allocation for Copford.
Looking at the detail within the plan there is en opportunity either in the Plan or in the Planning Departm ent to recognise that Hall Road Copford and Keepers Cottage Hall Road are non designated heritage assets. The former was a protected Historic Lane. Secondly that the conservation area at Stanway Green should extend across the Roman River and the Parish Boundary to include the listed bridge, Brook Cottage, Copford Place, the greensward in front of Copford Place and arguably up to Brewers Cottage
Object
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 8948
Received: 18/11/2021
Respondent: Mrs Kay Barker
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Climate Change. More houses can not be built without causing more pollution. The roads are not good now, so more traffic is not going to help. Saying people should cycle or walk is not an option for some people. Building Drs Surgeries is not an option either, we have not got enough doctors for the surgeries or hospitals now.
The drainage in Colchester is not good. If sewerage is allowed to be put into the local rivers etc adds even more to pollution. If more houses are allowed to be built we will have less green space than London.
Climate Change. More houses can not be built without causing more pollution. The roads are not good now, so more traffic is not going to help. Saying people should cycle or walk is not an option for some people. Building Drs Surgeries is not an option either, we have not got enough doctors for the surgeries or hospitals now.
The drainage in Colchester is not good. If sewerage is allowed to be put into the local rivers etc adds even more to pollution. If more houses are allowed to be built we will have less green space than London.
Object
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 8949
Received: 18/11/2021
Respondent: Mr. Graham Barney
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
The projected Housing Numbers for Colchester show that the Borough Council over estimated the number of housing units required by 2033, with this in mind and the recent government changes to reduce use of 'greenfield' sites it would seem that many of the required new homes could be built without significant use of existing greenfield sites such as Hall Road and East Queensberry. This does not appear in the modifications.
As has already been pointed out the SG2 Appendix of homes built for Copford is incorrect, others are likely also to be wrong due to the time delay. This would give more than the required number of homes in the plan period.
The fact that Copford has an allocation of 120 homes for a relatively small area of the Parish - Copford Green and Easthorpe are not included - makes the allocation even more disproportionate when compared to our neighbouring parish, particularly Marks Tey which has an allocation of zero.
In addition to these comments made on the response form and emailed on 9 November, we would wish to make the following observations
The projected Housing Numbers for Colchester show that the Borough Council over estimated the number of housing units required by 2033, with this in mind and the recent government changes to reduce use of 'greenfield' sites it would seem that many of the required new homes could be built without significant use of existing greenfield sites such as Hall Road and East Queensberry. This does not appear in the modifications.
As has already been pointed out the SG2 Appendix of homes built for Copford is incorrect, others are likely also to be wrong due to the time delay. This would give more than the required number of homes in the plan period.
The fact that Copford has an allocation of 120 homes for a relatively small area of the Parish - Copford Green and Easthorpe are not included - makes the allocation even more disproportionate when compared to our neighbouring parish, particularly Marks Tey which has an allocation of zero.
The inclusion of Grade 2 listed buildings within MM58 SS4 is to be broadly welcomed but the Grade 2 listed Stanway Bridge, Swan Green Cottages, Shrub House and the Old Mill should also be included. In addition to protection for the settings of these listed buildings, 'setting' could be applied to beyond visual effects to include noise and pollution both of which will significantly increase with further development close to these locations.
Object
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 8963
Received: 15/11/2021
Respondent: L&Q, Cirrus Land and G120 Land
Agent: Barton Willmore
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Paras 2.5 to 2.13
Officer Summary:
Middlewick Ranges - Do not believe dwellings will start to be delivered between 2025/26 given extent of work developer will need to go through given the constraints of the site.
East Colchester/Tendring new community - Concerns around delivery rates. DPD document has someway to go before it is finished. DPD is not likely to be adopted until mid/late 2023 at the earliest. Unrealistic to expect delivery of homes from 2024/25.
New policy should be interested which requires the Council to review the Local Plan early and against a set timetable
See attachment for full representation
Object
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 8978
Received: 15/11/2021
Respondent: Marden Homes Ltd
Agent: Strutt & Parker
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Summary: Reduction of units allocated to Tiptree unjustified. (see attachment for full representation)
See accompanying letter for recommendations
See attachment for full representation
Object
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 8985
Received: 15/11/2021
Respondent: Bloor Homes
Agent: Strutt & Parker
Legally compliant? Not specified
Sound? No
Duty to co-operate? Not specified
Officer Summary:
Not considered modifications are necessary to make the Plan sound. Modification itself is not sound. Particular concern with Tiptree proposed figure changes.
See attachment for full representation
Support
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 8989
Received: 15/11/2021
Respondent: Tollgate Partnership Limited
Agent: Barton Willmore
Officer Summary: TPL support MM5 and MM8 which are consistent with the agreed Statement of Common Ground
Please see attachment for full representation
Please see attachment for full representation
Object
Draft Schedule of Main Modifications to Section 2 Colchester Local Plan
Representation ID: 9011
Received: 10/10/2021
Respondent: Mrs J Radford
Legally compliant? Not specified
Sound? Not specified
Duty to co-operate? Not specified
Loss of flora and fauna to development.
Need to respect history, value green spaces and stop becoming a modern urban jungle
High street inaccessible, lack of parking, loss of local shops and seating places which collect more rubbish
Town centre has become sad, dirty and unkempt
Green spaces devalued, covered in concrete in pursuit of money Global warming, loss of more than 50% ecologically sensitive areas and open space
Middlewick only space left on this side of town, green lung Where is individually of Colchester?
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So England has lost more than half it’s flora and fauna to development So what are you doing about it? Making it worse I think.
We have a wonderful ancient town and some lovely green spaces and coastal attractions so it really makes me angry and sad at what you at Planning have allowed to be done to this place over the years.
We need to respect our history and value our green spaces but the town you say is ‘England’s first City’, is fast becoming a modern urban jungle of the worst sort. The high street in inaccessible to many of Colchester’s residents because of lack of parking and loss of local shops and unnesseccary seating places which just seem to collect more rubbish.
The town centre has become sad, dirty and unkempt, the buildings left to rot because there is not the will to preserve and clean what we have.
Regarding green spaces, again the Borough council and County council, makes note of them and then devalues what we have, and again covers it in concrete of one sort or another as soon as you see fit in the pursuit of money.
At this time when we are aware of global warming the loss of more that 50% of our ecologically sensitive areas and flora and fauna and the need of our pollinator insects, bees, butterflies an much, much more in the way of rare and protected species and landscapes. Also for our open air space for people’s good health emotional, psychological and physical. The value of any open space in uncountable and Middlewick even more because it is the only space left on this side of town which can be the green lung and place of restoration of the soul for residents.I have to be ASHAMED of our planning officers for allowing this tragedy which is turning our ancient historic and once beautiful town into just another mass produced centre just like any other. Where is the individuality of Colchester. What have you done to it and allowed to be done to it? Are you able, or even willing, to change planning attitudes to preserve what remains of out once beautiful town and it’s valuable surroundings.