Garden Communities

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Preferred Options Local Plan

Representation ID: 188

Received: 16/08/2016

Respondent: Cllr Peter Chillingworth

Representation Summary:

As one of the ward councillors for Rural North taking in Great Tey, I am aware of the concern of residents that such a large development is proposed for the area permanently changing the landscape and social structure.

However, I also recognise the need for new homes and accept that the Marks Tey area is potentially one of the most sustainable in the Borough.

I do strongly propose that no development is started at West Tey until the proposed new A120 route in decided on and work commences. No houses must be occupied until the new route is open.

Full text:

As one of the ward councillors for Rural North taking in Great Tey, I am aware of the concern of residents that such a large development is proposed for the area permanently changing the landscape and social structure.

However, I also recognise the need for new homes and accept that the Marks Tey area is potentially one of the most sustainable in the Borough.

I do strongly propose that no development is started at West Tey until the proposed new A120 route in decided on and work commences. No houses must be occupied until the new route is open.


Preferred Options Local Plan

Representation ID: 1167

Received: 12/09/2016

Respondent: Mr Derek Marriott

Representation Summary:

I write regarding the housing development proposed to the west of Marks Tey. The plan at the moment is a draft, so details are vague, but various reports suggest as many as 28,000 homes may be built which would change the character of the area immensely.

Infrastructure provision is inadequate or non-existent. A120 improvements, additional rail service provision, healthcare provision and employment considerations need to be specified and made part of an integrated plan for the area. Purely building houses is not a viable option since all local facilities are already oversubscribed or inadequate.

Full text:

Dear Sirs

I write regarding the housing development proposed to the west of Marks Tey. The plan at the moment is a draft, so details are vague, but various reports suggest as many as 28,000 homes may be built which would change the character of the area immensely.

Despite the proposal for such a large number of houses, there seems to be very little information with respect to the many other factors which need due consideration.

I would object to a large scale development at Marks Tey for the following reasons:

1 Because Marks Tey is to the west of Colchester, it is likely that any new residents would most probably commute to London rather than enrich the local economy.

2 There seem to be numerous proposals as to how and where the A120 would be improved making it difficult to see how housing can be developed without a firm an integrated proposal for the siting of the A120.

3 The railway line to London is already at maximum capacity and it would appear to be difficult to add the extra services necessary to acceptably satisfy an increased population.

4 The routes into Colchester from Marks Tey are not good and can only get worse with an increased population and yet there seem to be no plan to address this. We have noted the vastly increased traffic congestion at Tollgate and these proposals will only make that situation far worse.

5 The hospital is already under extreme pressure and it would seem that increasing the local population significantly can only exacerbate this situation.

6 Major housing development needs major infrastructure development and any plan needs to take this into consideration, which it currently does not.

7 The draft plan seems to have been successful in creating an east versus west antagonism which cannot be good for the borough in the grand scheme of community relations.


Derek Marriott


Preferred Options Local Plan

Representation ID: 1478

Received: 15/09/2016

Respondent: Cllr Tim Young

Representation Summary:

As the Portfolio Holder with responsibility for the Local Plan I have to be circumspect in my comments but rest assured that all reasonable comments will be taken on board by me and the administration. As a ward councillor for Greenstead I do support the comments made by my fellow ward councillors.

Full text:

As the Portfolio Holder with responsibility for the Local Plan I have to be circumspect in my comments but rest assured that all reasonable comments will be taken on board by me and the administration. As a ward councillor for Greenstead I do support the comments made by my fellow ward councillors.


Preferred Options Local Plan

Representation ID: 1501

Received: 15/09/2016

Respondent: Mr Nigel Sagar

Representation Summary:

The need for more housing is not in question. Garden villages have major potential drawbacks. The modern context is different from that of the original garden cities . Communities grow organically along with changing demands and density, making their design problematic. While Colchester is being re-imagined e.g garrison area, there remains huge potential to master plan further density to enhance heritage sites around St Botolphs, St Mary', New Town and many other areas. Garden villages risk being isolated, placing high loads on roads and infrastructure. Any building outside the town MUST be premised on improved roads before housing

Full text:

The need for more housing is not in question. Garden villages have major potential drawbacks. The modern context is different from that of the original garden cities . Communities grow organically along with changing demands and density, making their design problematic. While Colchester is being re-imagined e.g garrison area, there remains huge potential to master plan further density to enhance heritage sites around St Botolphs, St Mary', New Town and many other areas. Garden villages risk being isolated, placing high loads on roads and infrastructure. Any building outside the town MUST be premised on improved roads before housing


Preferred Options Local Plan

Representation ID: 2297

Received: 21/09/2016

Respondent: R F West, Livelands & David G Sherwood

Agent: Andrew Martin Planning

Representation Summary:

We support the emphasis in the paragraphs under this heading that refer to the importance of new communities within the wider spatial strategy for growth.

Full text:

See scanned copy


Preferred Options Local Plan

Representation ID: 2660

Received: 30/09/2016

Respondent: Historic England -East of England

Representation Summary:

Garden Communities

We would refer you to our comments made above in Chapter 2 and our previous comments made in our letter dated 27 February 2015.

Full text:

Ref: Preferred Options Local Plan Consultation

Thank you for consulting Historic England on Colchester's Preferred Options local plan. Historic England has published a number of Good Practice Advice and Advice Notes which you may find useful in developing your local plan. In particular:

Good Practice Advice in Planning 1 - the historic environment in local plans: <>

Good Practice Advice in Planning 3 - the setting of heritage assets: <>

Advice Note 1 - conservation area designation, appraisal and management: <>

Advice Note 3 - site allocations in local plans: <>.

We have confined our comments to the Local Plan Draft. Unfortunately, owing to current staffing capacity we have been unable to review and comment on the Settlement Boundary Review, Traffic Modelling Report, Strategic Land Availability Assessment, Sustainability Appraisal and Strategic Environmental Assessment.

We recommend that you review our advice entitled Strategic Environmental Assessment, Sustainability Appraisal and the Historic Environment:<>

We have also produced updated advice on the matter which is currently out for public consultation. This document, entitled Sustainability Appraisal and Strategic Environmental Assessment Historic England Advice Note 8 can be found at: <>

Our specific comments on the preferred options local plan follow.

Chapter 2 - Shared Strategic Plan for North Essex

The Vision

We welcome the reference to protecting and enhancing the rich historic environment of North Essex in paragraph 3.28.

Strategic Objectives

These high level strategic objectives for the wider area of North Essex are quite generic and the National Planning Policy Framework's (NPPF) requirement for sustainable development, including the historic environment, could be reflected more specifically in the text, for example through requiring developments to respond to the distinctive character of North Essex as part of providing sufficient new homes and ensuring high quality outcomes in paragraph 3.29.

SP4 Infrastructure and Connectivity

We note the aspiration set out in paragraphs 3.58-3.60 and policy SP4 for dualling the A120 between Braintree and the A12. We have been invited to be part of the Highways England Environmental Forum. We would note that the A120 is a historic route through Essex and as such there is great archaeological potential, alongside the potential impacts on heritage assets, which may vary, depending on the options developed.

In respect of broadband we would expect to see reference, though not a hyperlink, in the supporting text (paragraphs 3.72 and 3.73) to the Cabinet Siting and Pole Siting Code of Practice:<>

SP5 Place Shaping Principles

We welcome the commitment to creating quality places set out in paragraphs 3.74, 3.75 and Policy SP5. We would suggest that the first bullet point of the policy is clarified to read: "...enhance the quality of existing places." We would refer you to our comments below relating to specific sites and proposals.

SP6 Spatial Strategy for North Essex

We welcome the commitment that future growth will be planned so that settlements maintain their distinctive character, role and to avoid coalescence. We also welcome the aspiration for a high quality of built and urban design. We would suggest that what this means for North Essex should be set out in the supporting text and the policy.

SP7 Development and Delivery of New Garden Communities in Essex

Whilst we welcome some of the detail contained within the policy, particularly criterion x, it is difficult to comment on the impact of the proposed settlement and potential harm to heritage assets without seeing the boundaries of what is proposed. In particular, it is difficult to assess what harm would be caused to the historic environment by the New Garden Community and whether what was proposed was appropriate, in terms of the historic environment. This also extends to providing advice on the policy as set out. Notwithstanding this point, we would additionally recommend a criterion setting out how the historic environment and heritage assets can form part of the development of successful schemes.

SP8 East Colchester / West Tendring New Garden Community

Whilst we welcome some of the detail contained within the policy, particularly identifying heritage assets and topography as being key for design, it is difficult to comment on the impact of the proposed settlement and potential harm to heritage assets without seeing the boundaries of what is proposed. In particular, it is difficult to assess what harm would be caused to the historic environment by the New Garden Community and whether what was proposed was appropriate, in terms of the historic environment. This also extends to providing advice on the policy as set out.

SP9 West of Colchester/East of Braintree New Garden Community

Whilst we welcome some of the detail contained within the policy, particularly identifying heritage assets and topography as being key for design, it is difficult to comment on the impact of the proposed settlement and potential harm to heritage assets without seeing the boundaries of what is proposed. In particular, it is difficult to assess what harm would be caused to the historic environment by the New Garden Community and whether what was proposed was appropriate, in terms of the historic environment. This also extends to providing advice on the policy as set out.

Chapter 3 Vision and Objectives

We welcome the reference to how Colchester's character reflects the rich history of the town in paragraph 3.4. We support the inclusion of the historic environment within the vision for Colchester as a strategy for the historic environment, as per paragraph 126 of the NPPF, will be embedded in the vision for an area. We support the text in paragraph 3.9 which sets out that surrounding settlements will remain 'distinctive and thriving villages' and that landscape will be protected and enhanced. We would recommend a similar vision for the historic environment, setting out how it will be protected and enhanced across the Borough.

We welcome the identification of protecting the environment, good quality design, and streetscapes as key objectives in paragraph 3.15. Whilst we welcome the references to sustaining Colchester's historic character through its buildings, townscape and archaeology; more explicit reference to the historic environment should be made in the previous bullet point relating to the whole Borough.

Chapter 5 Environmental Assets Policies

ENV1: Natural Environment

We recommend that the Natural Environment Policy section and Policy ENV1: Natural Environment are renamed given the inclusion of this historic environment within this section and policy. We suggest the Natural and Historic Environment Policy and Policy ENV1: Natural and Historic Environment Policy.

We welcome the description of Colchester's environment in paragraph 5.1 which encompasses landscape character, archaeology and cultural heritage. However, we would recommend a slight amendment to the wording so that is reads: " terms of its natural and historic environment including biodiversity, landscape character....."

In paragraph 5.9 we would suggest clarifying what is meant by: "....without harm to the built environment" in respect of the historic environment in its widest sense (buildings and structures, archaeology, townscape and landscape). We welcome the commitment in paragraph 5.10 to preventing coalescence and maintaining settlement identity.

We welcome paragraph 5.11 on the protection of the historic environment and the references to Townscape Character Assessment, Characterisation, and the Urban Archaeological Database.

ENV 2: Coastal Areas

We recommend the use of the term 'heritage asset' rather than 'historic environment asset' throughout this section and policy ENV2 for consistency with the terminology in the NPPF. We would suggest that the supporting text paragraph 5.13 should be redrafted as currently statutorily protected aspects such as habitats and heritage assets have been described as 'competing interests' with recreational activities and fishing. We suggest: "As a consequence there are a number of diverse planning considerations and land uses which all need to be managed in an integrated way within the Borough's coastal belt. These include internationally important habitats, land and water-based recreation, fishing, and heritage assets (including archaeological). Climate Change including sea level rise..."

ENV 4: Dedham Vale Area of Outstanding Natural Beauty

We welcome a specific policy within the plan for the AONB linked to its special qualities. We would recommend a small amendment to Policy ENV4: "Application s for major development within or in close proximity to the boundary of the Dedham Vale Area of Outstanding Natural Beauty will be refused unless in exceptional circumstances and where it can be demonstrated that the development is in the public interest and this outweighs other material considerations."

CC1: Climate Change

Paragraph 5.45 should be amended in respect of the types and groups of heritage assets and traditionally built buildings which are exempt and those where special considerations apply in respect of certain energy efficiency measures. The information can be found on pages 14 and 17 of Historic England's advice Energy Efficiency and Historic Buildings - Application of Part L of the Building Regulations to historic and traditionally constructed buildings <> Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. Any policy encouraging energy efficiency should note that the application will be different in relation to these classes of buildings. In policy CC1, we recommend the addition of 'where appropriate' after "supporting energy efficiency improvements to existing buildings in the Borough where appropriate."

Chapter 6 Places

Please note that we are unable to comment at this time on the capacity of each suggested site allocation to accommodate the number of dwellings proposed. Any comments on allocations do not extend to agreement of the proposed dwelling numbers.


TC1: Town Centre

We welcome the identification of the important historic character of the town centre within the policy and the commitment that it must be protected and enhanced by all development, with links through to the historic environment policy. We support the aspiration for attractive public spaces and streetscapes which will further enhance the character of historic Colchester.

TC3: Town Centre Allocations

We welcome the requirements for St Boltoph's in respect of archaeological investigation and consideration of the conservation area and listed buildings.

Vineyard Gate should make reference to the scheduled town wall, part of which forms part of the Vineyard Gate site, its setting, and archaeological potential.

We welcome the reference in the Britannia Car Park proposed allocation to the setting of the scheduled monument, the Priory, and archaeological potential. However, the proximity to the conservation area, therefore consideration of how its setting could be enhanced should also be included.

We welcome the archaeological provision for Nunns Road Car Park but it also should reference its location within the conservation area and require development to preserve and enhance the character of the conservation area. In addition, any impact on the listed buildings in proximity to the site should be considered.

We would note that some of the Local Economic Areas are within or adjoining the conservation area and any proposals relating to those sites should preserve or enhance the conservation area and its setting.

EC1: Knowledge Gateway

We are surprised that reference is not made through the policy and supporting text to the numerous heritage assets that form part of the area. Grade II* Wivenhoe House set within grade II Wivenhoe registered park and garden and with a number of ancillary grade II buildings. We recommend that consideration of these assets and their setting is incorporated into the policy.

EC2: East Colchester - The Hythe Special Policy Area

Hythe has been a conservation area at risk for a number of years. We note that the policy sets out how improvements for the natural environment will be made, but measures to address the at risk status for the designated heritage asset have not been explicitly made. We would suggest consideration in the supporting text, linked to an objective within the policy on how this will be addressed.

EC3: East Colchester

We welcome the information in the supporting text for the East Bay Mill site, although note that there are a number of heritage assets within this proposed allocation which will require consideration.

The Magdelen Street proposed allocation supporting text would benefit from references to the designated heritage assets within the area, including the conservation area. This also should be reflected in the policy wording.

WC1: Stanway Strategic Economic Area

We would note that whilst Stanway has an established economic role and has seen much new development, there remain a number of listed buildings in the area whose setting and use should be considered as the area is identified for growth.

WC3: Colchester Zoo

We welcome the reference to the scheduled monument in the supporting text but would recommend its inclusion within the policy wording.

WC4: West Colchester

We welcome the policy wording for the Land at Gosbecks in respect of the scheduled monument and archaeological potential. We welcome the policy reference to the Essex County Hospital Development brief.

Garden Communities

We would refer you to our comments made above in Chapter 2 and our previous comments made in our letter dated 27 February 2015.

Sustainable Settlements

SS1: Abberton and Langenhoe

We welcome the identification of the proximity of grade II Pete Tye Hill to the proposed allocation. We welcome reference in the policy to archaeological considerations as well as design and landscaping in respect of Pete Tye Hill.

SS2: Birch

Consideration should be given to the setting to the rear of the grade II buildings of the Hare and Hounds Public House, Heath House and The Manse in respect of the proposed allocation. We also note that Birch is on the Conservation Areas at Risk Register.

SS3: Boxted

As noted in the Boxted Neighbourhood Plan, grade II Hill House and a separately listed grade II wall are immediately north of this allocation and any proposals for this site should take account of the setting of these heritage assets.

SS4: Chappel & Wakes Colne

We welcome the identification of the proximity of grade II Hill House, Martyn's Croft and Brook Hall to the proposed allocation. We welcome reference in the policy to good design and landscaping.

SS5: Copford & Copford Green

We welcome the identification of grade II Brewers Cottage, but note that grade II Old Mill House and grade II Shrub House appear to share boundary with the propose allocation at land to the east of Queensbury Road and consideration should be made to their setting. We welcome that design and landscaping in respect of heritage assets appears in the policy in relation to both proposed allocations and the requirement for archaeological consideration.

SS6: Dedham and Dedham Heath

We welcome the identification of grade II Old Church House next to the proposed allocation at land north of Long Road East. We welcome reference in the policy to archaeological considerations as well as design and landscaping in respect of Old Church House.

SS7: Eight Ash Green

We would note that the broad direction of growth for Eight Ash Green, to be determined by a Neighbourhood Plan, potentially impacts on the setting of grade II listed building. As the Neighbourhood Plan and the site allocations are developed consideration of this heritage assets and its setting is required in order to determine appropriate locations and densities for growth.

SS8: Fordham

We welcome the identification of the proximity of a listed building to this proposed allocation. We welcome reference in the policy to archaeological considerations as well as design and landscaping.

SS9: Great Horksley

We welcome the identification of heritage assets in respect of both proposed allocations in Great Horkesley. We welcome reference in the policy to good design and landscaping.

SS10: Great Tey

We welcome the identification of grade II Rectory Cottage but would note that the proposed site allocation abuts the conservation area boundary, which is not mentioned in the supporting text or policy. This should be amended. We welcome reference in the policy to archaeological considerations as well as design and landscaping.

SS11: Langham

We welcome the identification of listed buildings in respect of the School Road sites, but would highlight the potential impact of the Wick Road proposed allocation on the setting of grade II Mantons. We welcome reference in the policy to archaeological considerations as well as design and landscaping.

SS13: Marks Tey

Given the substantial proposals relating to Marks Tey, we are surprised that the supporting text does not reference the significant number of grade II listed buildings in Marks Tey, the scheduled brick kilns and the grade I Church of St Andrew. At this stage it is difficult to comment as which heritage assets will be affected is unknown. However, we note that the broad areas of growth indicated on the maps, to be brought forward through the Marks Tey Neighbourhood Plan may affect designated heritage assets. As the Neighbourhood Plan and the site allocations are developed consideration of these heritage assets and their setting is required in order to determine appropriate locations and densities for growth.

SS15: Tiptree

We note that the broad areas of growth indicated on the maps, to be brought forward through the Tiptree Neighbourhood Plan may affect designated heritage assets. As the Neighbourhood Plan and the site allocations are developed consideration of these heritage assets and their setting is required in order to determine appropriate locations and densities for growth.

SS17a: West Mersea

We welcome the identification of the proximity of grade II Brierley Hall to the proposed allocation at Brierley Paddocks. We welcome reference in the policy to archaeological considerations at Dawes Lane as well as design and landscaping at Brierley Paddocks.

SS17b: Coast Road

We recommend under criterion ii 'historic environment assets' is replaced with 'heritage assets'.

SS18: Wivenhoe

We note that one of the proposed site allocations borders grade II 14, 15 and 16 Colchester Road. As the Neighbourhood Plan is developed consideration of these heritage assets and their setting is required.

OV1: Other villages

We welcome the commitment to high quality design which is distinctive to the character of the village.

Chapter 7 Development Management Policies

DM5: Tourism, Leisure, Culture and Heritage

We welcome the recognition that Colchester's rich heritage is a benefit and attraction to people who live, work and visit the Borough. We would suggest that in paragraph 7.22 " historic heritage.." be amended to either " historic environment..." or " heritage.." We welcome that new development should not detract from the aspects that make the Borough attractive and distinctive. Whilst the policy covers a wide range of different development types and locations, we would suggest that the policy could not only require development to "...minimise their impact on neighbouring areas..." but also ensure that consideration is given to how such developments could make a positive contribution.

DM6: Economic Development in Rural Areas and the Countryside

We welcome the consideration of re-use of existing buildings and the link in the supporting text, paragraph 7.31, to policy DM16 for historic rural buildings. In paragraph 7.30 it may be better to use the NPPF term 'heritage asset' rather than 'heritage building' as the term is not defined in the glossary. In respect of (c) in the policy itself, it should be clarified that there is a presumption that heritage assets in a poor state of repair will be retained rather than replaced, otherwise heritage assets which have not suffered deliberate neglect or damage as per paragraph 130 of the NPPF may fall within the scope of replacement.

DM7: Agricultural Development and Diversification

We welcome the link in the supporting text, paragraph 7.39, to policies DM6 and DM16. We welcome the inclusion within the policy of the requirement that re-use of historic farm buildings should maintain and enhance the historic environment.

DM9: Housing Density

We welcome the requirement in the policy that density should respond to the character of a site and its surroundings. Appropriate density will vary significantly across the Borough owing to the variety and location of sites coming forward. However, density on a site could also be affected by consideration of the setting of heritage assets and this should be reflected in the policy and supporting text.

DM13: Domestic development - residential alterations, extensions and outbuildings

Whilst we welcome the commitment to design for replacement dwellings in the countryside, we also recommend that the presumption to retain buildings which are heritage assets should be referenced. As it is drafted, the policy also would allow the replacement of a building which makes a positive contribution to a rural conservation area. This should be clarified.

DM15: Design and Amenity

We welcome a policy on design and in particular the reference to the Essex Design Guide and supporting text paragraph 7.83.

DM16: Historic Environment

We welcome a local policy on the historic environment. We particularly welcome the commitment to a local list which can help local authorities and local communities define aspects of the historic environment that are locally significant. As such, we would recommend that the list cover character areas, parks and gardens, structures etc. as well as buildings. More information can be found in Historic England Advice Note 7 - Local Listing: <>.

We would recommend that heritage at risk forms part of any policy on the historic environment, particularly with a number of long-standing assets on the Heritage at Risk Register, including Hythe and Distillery Pond Conservation Areas.

DM25: Renewable Energy, Water, Waste and Recycling

Please see our comments above on Policy CC1.

Chapter 9 Monitoring

We support the Council's aspiration to promote high quality design and sustain Colchester's historic character. We welcome a specific and measurable target relating to the historic environment. We would be happy to discuss further with you data and options for monitoring progress.


Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

We hope that the above comments of assistance. Please let me know of you have any queries. We look forward to further engagement on the Local Plan review.


Preferred Options Local Plan

Representation ID: 3099

Received: 14/10/2016

Respondent: CAUSE

Representation Summary:

Object - see response to part one - insufficient evidence to support the selection of sites. No infrastructure plan, external costs ignored, no appropriate traffic modelling and no acceptable viability study. Sustainability Appraisal conclusions flawed.

Full text:

See attachment for full formatted version including charts and maps.
Response to Strategic Part 1 for North Essex Authorities Local Plans
Thank you for the opportunity to comment on the joint strategic plan. The Campaign Against Urban Sprawl in Essex (CAUSE) recognises the need for more housing, but believes it has to be located correctly and that the supporting infrastructure has to be built first.
Plan soundness
We set out in detail in this response why we have significant concerns about the soundness of this Plan, with particular regard to West Colchester Garden Community. In light of our significant and legitimate concerns this Plan should not proceed, for the reasons set out later in these representations.
The failure to properly assess infrastructure delivery constraints, phasing and funding mean that Part 1 of the Plan is not 'positively prepared' (see Appendix 8). The OAN figures cannot be sustainably delivered through the Local Plan; and should be legitimately reduced on the basis of work we have undertaken (see Appendix 5).
Neither is this Part 1 'Justified'. It ignores reasonable and legitimate alternatives (Colchester Metro Plan and North Colchester Garden Community). Both have been rejected on the basis of flawed and inconsistent analysis of the evidence base (see Appendices 2,3, 4 and 10). An additional example of inconsistent decision-making is the inclusion of West Colchester in the Preferred Options despite uncertainties about the A120 and the impact of traffic implications. This is contrary to the correct rejection of 'Temple Border garden village' by officers on May 9 2016 for the very reason that there are uncertainties about the A120 and traffic implications.
Finally, we do not believe that this Part 1 is 'Effective' i.e. deliverable over its period, ensuring both viability and deliverability. The NPPF is clear that Local Plan proposals should be deliverable, whilst being aspirational yet realistic. The Local Plan is not promoting a deliverable or realistic option. CAUSE has significant concerns about the deliverability of three garden cities simultaneously by local authorities.
2 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
We have specific concerns about the viability and deliverability of West Colchester Garden Community. Major upgrades to the road and rail network and station (see Appendices 7 & 8) are required there to meet current demand, let alone taking account of planned growth, and there are uncertainties about timing, funding and delivery (see Appendices 10 & 11).
In addition, there is no employment strategy for West Colchester Garden Community (see Appendix 6) and no strategy for long-term healthcare provision in north Essex (see Appendix 9)
CAUSE is a volunteer organisation that seeks a better solution for North Essex. We have prepared a sustainable, transport-oriented vision for growth: "Colchester Metro Plan", which we launched at a conference on 'Visions for Growth in North Essex' in November 2015 (see Appendix 4). Notwithstanding that we have no financial interest in any of the development land under consideration, the "Colchester Metro Plan" is a deliverable alternative growth option and includes a focus on growth around Essex University, yet has been rejected by the Local Planning Authorities. Our fund-raising has enabled us to build a professional team which includes a planning solicitor, urban designers, and planning, transport and rail consultants - experienced people whose views on alternatives merit consideration in the context of tests on 'soundness'.
We, and local people, have particular concerns about the proposed garden city at West Colchester (SP9: 2,500 dwellings in the Plan period, rising to between 15,000/20,000 according to Preferred Options and up to 28,000 according to Aecom). At this location there is a mismatch between economic activity and housing, such that commuting will be encouraged on inadequate infrastructure. A CAUSE petition gathered over 7,600 signatures and CAUSE held a series of well attended village meetings in 2016 (see appendix 12, Community Engagement).
This submission provides a serious and constructive contribution to the debate on a Local Plan which needs some major changes in order to meet the tests of soundness.
Yours sincerely,
Rosie Pearson
On behalf of CAUSE
Campaign Against Urban Sprawl in Essex: a company limited by guarantee, registered in England, Co. no. 09684557. Registered office: Abbey Mill House, Coggeshall, Colchester, Essex CO6 1RD
1 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
CAUSE consultation response to North Essex Authorities 'Part 1'
We set out in detail in this response why we have significant concerns about the soundness of this Plan, with particular regard to West Colchester Garden Community.
In light of our significant and legitimate concerns, this Plan should not proceed, for the reasons set out later in these representations. Part 1 of the Local Plans should be delayed until proper infrastructure plans and a delivery vehicle are in place.
The chosen option (West Colchester Garden Community) is not sustainable or deliverable and will not achieve the OAN in the Plan period and therefore should be dropped.
There should be a focus on the most deliverable and sustainable of the options, East Colchester, and in addition alternatives (Colchester Metro Plan and Colchester North) should be properly considered.
In addition, the housing need figures (OAN) should be reduced over the three boroughs to ensure sustainable delivery through the Local Plan
This response comes in three sections, together with twelve Appendices:
1. Location of Garden Communities and consideration of alternatives;
2. Deliverability and viability
3. Improving the Plan
Section 1: Deciding on the location of Garden Settlements:
CAUSE supports the principles behind garden settlements, delivered properly and in the right place, and sees merit to proposals for growth at East Colchester, with the University and its Knowledge Gateway as a focus.
However, very little of the analysis needed for sound decision-making has been done. Key reports (Infrastructure Delivery Plan, transport modelling, viability appraisal, SHLAA) have been unavailable during the consultation period such that the we question how the consultation is valid. In particular the Councils have refused to disclose their viability appraisals and there are worrying signs that the conclusions in Part 1 are not supported
2 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
even by the Councils' consultants. CAUSE has been refused meetings with Aecom and Atlas when requested in an attempt to gain a further understanding of the Plan.
The NPPF requires a proportionate evidence base. Given the scale of what is being proposed it follows that the evidence base, purporting to underpin the Local Plan, should be wide ranging and significant in scope. Finally, a legitimate reasonable alternative has been wrongly sidelined: the CAUSE Metro Plan has been inappropriately rejected in the Sustainability Appraisal1 and ignored by Aecom despite repeated requests that it be considered. This failing goes to the heart of soundness.
Section 2: Deliverability and viability.
CAUSE supports growth at East Colchester, adjacent to Essex University, an area which has many merits in terms of proximity to employment, sustainable transport and the town centre. However, we do have concerns about the deliverability of all garden communities proposed. These are untested in market terms and therefore delivery rates and lead-in times require forensic analysis, particularly as competing concurrent garden communities present cumulative impacts.
We have particular concerns about West Colchester Garden Community. Major upgrades to the road and rail network are required there to meet current demand2. A Plan which includes West Colchester Garden Community cannot be sound given the lack of Infrastructure Delivery Plan, lack of economic proposition and the lack of credible development expertise plus uncertainties about the timing and funding of the infrastructure improvements needed.
Section 3: Improving the plan.
We suggest that Part 1 of the Local Plans should be delayed until proper infrastructure plans and a delivery vehicle are in place. The chosen option (West Colchester Garden Community) will not achieve the OAN in the Plan period and therefore should be dropped. There should be a focus on the most deliverable and sustainable of the options, East Colchester, and in addition alternatives (Colchester Metro Plan and Colchester North) should be properly considered. In addition, the housing need figures (OAN) should be reduced over the three boroughs to ensure sustainable delivery through the Local Plan (see Appendix 5).
We set out in a series of appendices our evidence and findings to support our main response:
Section 1: Deciding on the location of garden settlements
One of the tests of soundness of a Local Plan is that it is 'justified'. The NPPF states that it should be the most appropriate strategy, when considered against the reasonable alternatives. CAUSE believes that the Plan's location of settlements is not justified: major decisions are proposed affecting the lives of thousands of people without proper consideration of the alternatives. A flawed analytical approach has produced distorted evidence3 and wrong conclusions. In starting from a flawed position, everything in the Plan which flows from it cannot be relied upon.
The underlying principle of the NPPF is that planning for housing, economic land uses and community facilities / services should be integrated, so that the demand for labour is fulfilled and there is no unsustainable commuting. The call for sites process does not enable this principle to be fulfilled. Development land isn't scarce4, but infrastructure and high value jobs are and these should, instead, be the starting point. Other land can deliver the OAN in a more sustainable manner than the current proposals.
Neither external infrastructure nor job creation are considered properly in the AECOM report (see Appendix 10) or the sustainability appraisal (see Appendix 2).
 Housing should be located near to the strategic economic areas of North Essex including Essex University, Northern Gateway, Skyline 120 and international gateways of Stansted and Harwich. In North Essex, much of the road and rail infrastructure is stretched and a sustainable transport strategy will be essential. Matching housing locations with economic activities is an inherently sustainable approach.
 Our councils should make use of underused infrastructure such as the Colchester-Clacton rail line. A settlement at West Colchester, selected through the call for sites process, will further overload the GEML and roads and will need to contribute its share to the upgrades required.
Alternatives: Alternatives have not been properly considered, nor is their consistency in decision-making. Two clear alternatives, North Colchester and Colchester Metro Plan, have been wrongly rejected following the Sustainability Assessment (see Appendix 2). A third, Temple Border, was rightly not included in the preferred options yet the reasons given by officers not to recommend it apply equally at West Colchester, which has been included.
Alternative 1: North of Colchester was said to be "potentially viable" in the AECOM report, along with all four settlements studied. But it has been dropped, despite offering greater sustainability and viability than West Colchester following the sustainability study which we believe is illogical and riddled with contradictions (see Appendix 10). CAUSE's own evaluation based on the same evidence has North Colchester as the second most desirable of all the options.
3 Comments on Sustainability appraisal, appendix 2. Comments on Employment appraisal, Appendix 6. Comments on Aecom, Appendix 10
4 Land value uplifts from £10,000 per acre to £100,000 or even £1m provide a huge incentive for farmers to participate, and even if one or two may hold out there should others to take their place in whichever location is chosen.
5 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Alternative 2: CAUSE's Colchester Metro Garden Communities plan was prepared by Dr Nicholas Falk, a recognized expert on garden communities, and is supported by CAUSE's professional advisers. It was first presented at the November 2015 "Visions for Growth" conference to which Officers and Councillors were invited. It has been reported on in the journal of Urban Design Magazine and presented at the Design South East Conference. It is shortly expected to feature in a CPRE publication.
The Metro plan has been briefly, but inaccurately, evaluated in the Sustainability Appraisal (see Appendix 2) and ignored in the AECOM analysis. On 10th February 2016 CAUSE met with officers from all three North Essex local authorities, demonstrated that the Metro Plan meets garden community requirements and requested meetings with Aecom and Atlas to ensure that the Metro Plan was fully explained and understood. This request was rejected. There has been no attempt by council officers, Aecom or Place Services to contact CAUSE to resolve those areas where questions are raised about our proposal.
Alternative 3: A separate proposal for a 4,000 dwelling new village at 'Temple Border' (by the same consortium proposing the West Colchester Garden Community), on the eastern edges of Braintree, was not recommended by officers nor subsequently included in the draft Local Plan: "The proposed site is substantial and would create a new village on the edge of Braintree. Given the uncertainty over the future location of the A120 in this vicinity and the traffic implications for this site, it is not considered appropriate for development." This applies equally at West Colchester and therefore there is no rationale for including it in the Preferred Options.
AECOM's four-volume feasibility study does little to inform the choice of location. Most of the infrastructure costing is done on a "per dwelling" basis which provides no differentiation between locations. Jobs are assumed to be created by allocations of employment land with little thought given to the growth opportunities provided by the University in the East and Stansted airport in the West, or the risk that commuters will outbid locally employed people for housing near Marks Tey station.
The study ignores external infrastructure costs where they are borne by other parts of the public sector. The main example is rail infrastructure: long distance rail commuting to London is clearly unsustainable but no attempt is made to put a cost on it. Appendix 7 argues that commuting is likely to be more popular at West Tey, and that a capital cost allowance of around £170,000 per extra commuter should be allocated to it.
The report states that four locations are "capable of becoming viable". We have asked for copies of the viability studies but these have been refused. It is apparent from the report that Aecom are unable to reach "conclusions" on viability calling them "observations" instead. Cushman & Wakefield, who appear to have done the detailed viability work, state that no conclusions should be drawn.
It is "surprising" that the Councils are recommending preferred options on location based upon such weak analysis. The Plan is being taken forward without a proportionate evidence base.
The sustainability appraisal prepared by Place Services, a part of Essex County Council, also ignores external rail costs and does little to inform the choice of location. Our detailed comments are in Appendix 2.
6 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
It concludes that West Colchester should be favoured as a location because it will "stimulate required infrastructure delivery". This may be logical political reasoning but it is economically perverse and its presence in a sustainability appraisal is highly inappropriate. A location should be chosen to maximise the net benefits for everyone, not because it will stimulate more spending from other parts of the public sector.
The correct approach is to establish locations which require the least intervention to mitigate the impact on infrastructure; this is a fundamentally sustainable approach. Thus any mitigation required deals with residual impact rather than having to deal with a root cause sustainability defect.
We assume that the "required infrastructure delivery" refers to the improvements needed to the A12 and A120. These improvements are needed for the benefit of the whole region, not just the fields alongside. There is no economic sense in locating development directly alongside major roads when reasonable alternatives exist. It is also noteworthy that, where possible, new access points off strategic routes including trunk roads and non-trunk roads should be avoided in accordance with Circular 02/2013. An objective and independent sustainability appraisal would not allow its key conclusion to be dependent on such a political argument.
Section 2 - Deliverability
A further test of the soundness of a Plan will be whether it is deliverable. This is fundamental to the success or otherwise of the Plan. The NPPF states that the plan should be deliverable over its period and based on effective joint working on cross-boundary strategic priorities.
CAUSE believes that that WCGC will not be delivered as promised (i.e. with full supporting infrastructure) because:
1. There is no transport or Infrastructure Delivery Plan;
2. There is no usable viability study5;
3. There is no delivery vehicle in place.
No transport plan:
● AECOM suggest that 500-900 dwellings could be delivered using existing infrastructure (Volume 3, section 7.5). There is no indication of how the A120 will cope: there are already long tail backs during peak periods, and total gridlock if there is a minor accident or delayed delivery.
● AECOM suggest that Marks Tey station needs to be moved towards the centre of the settlement. It isn't clear how this can be achieved. Our understanding is that the costs are substantial and disproportionate notwithstanding the time delays that will ensue in obtaining statutory undertakers agreement to the proposed works. The junction with the Sudbury line will need to be realigned and this will involve buying land and demolishing buildings, for which a lengthy CPO is likely. It isn't clear why this is needed in option 4 (27,841 dwellings) but not in options 1,2 or 3 (16,861, 17,182 or 13,105 dwellings).
5 See page 122 of AECOM report. Cushman & Wakefield have used the ATLAS model. They state that "no conclusions are drawn or intended within this work regarding the viability of the sites and options.
7 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
● AECOM suggest that employment land should be located between the A12 and GEML. It isn't clear how this will be accessed or whether some of the land is needed to widen the A12. It is premature to lay out the settlement until the road and bridge layout is known.
● Highways England / ECC are planning a consultation in early 2017 on how the A12 should be tripled, and the A120 dualled. This has a fundamental impact on the layout and viability West Tey and it would make sense to delay West Colchester GC until the consultation is complete. Until capacity issues are set out and a strategy for resolution of existing capacity issues is identified, a baseline for the Local Plan doesn't exist and therefore mitigation cannot be set out.
● Local people need a guarantee that no significant development will take place at West Tey until both roads are complete and rail improvements made. The Local Plan must consider the impacts for meeting the OAN in the context of the works to the A12/A120 not being completed until 2030, and the strategy for delivering development in the event that the highway works are delayed beyond 2030.
Public transport:
CAUSE regards public transport as a key differentiator between the sites (including North Colchester) under consideration.
We challenge AECOM's methodology, which allocates a mass rapid transit contribution of £1500 per dwelling to every North Essex garden community option. This ignores crucial differentiators between the garden community sites under consideration:
● Houses built along an underused railway such as the Colchester - Clacton line will require a significantly lower rapid transit contribution than those on the overstretched GEML (which will need costly major upgrades). Those near the GEML will require a road-based solution, from scratch, because there is no capacity remaining for a local train rapid transit service;
● North Colchester GC already has park and ride from the southern corner;
● Mass rapid transit is already planned between the Severalls site, the town centre and the University.
● North and East Colchester will require a lower cost allocation for public transport because their proximity to jobs and the town centre will mean that cycling and walking take a higher percentage of the modal share. In addition, there are already cycle-ways in place.
Under AECOM methodology none of these factors make a difference. The methodology needs to be changed to properly reflect the 'situation on the ground' otherwise our local authorities will continue to reach the wrong conclusions.
AECOM say that "without sub-regional public transport intervention, it is highly unlikely that the sites benefit from the levels of uptake in sustainable transport use required and car borne travel will prevail" (page 136).
They suggest three transit options for West Tey ranging from a heavy rail built from Marks Tey to Stansted (option 1a costing £2bn), through to a partially segregated BRT system which involves replacing the Braintree railway with a guided busway (option 2 costing £25m).
They take no account of the cost of upgrading the GEML, a key differentiator against WCGC. CAUSE concurs with AECOM's view that "The GEML is constrained in terms of current and future
8 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
capacity...6" Upgrading it on a 'predict and provide' basis will be extraordinarily expensive and it is vital that such costs are included in any viability appraisal.
Bus Rapid Transit proposal
AECOM outlines three public transport options to support the garden settlements. Of these the two rail options are unlikely to ever be done due to cost. The third, a bus rapid transit system is costed at £25m including some partially dedicated pathways. If existing roads are to be used this will just add to congestion. If it is to be done properly as per the Cambridge guided bus route the £25m budget is likely to be inadequate: the Cambridge route was based on an existing railway, and even then cost £181m for 16 miles, a cost of £11m per mile.
No usable viability study.
As stated above Cushman and Wakefield make it clear that their financial viability assessment is not to be used to draw conclusions7. It appears that the Plan is trying to draw very serious conclusions on the location of settlements from a heavily caveated report. There is no other evidence base to rely upon beyond the Cushman and Wakefield report. This is a fundamental failure of the evidence base.
This is not just a technicality: the key differentiators are ignored and as a result the output could be seriously misleading. Huge sums could be wasted by locating settlements in the wrong place.
3. Delivery vehicles
The North Essex Authorities are currently investigating the best ways to deliver development on the garden communities (page 47).
This is inconsistent with the statements in SP8, SP9 and SP10 which all say that the "masterplan will be produced in partnership with development interests". Whilst this approach may suit Colchester's existing development programme, it would be inappropriate for garden settlements. Master planning would be a key role for any meaningful delivery vehicle, with developers working on smaller sites within the master plan area.
CAUSE fears that without a delivery vehicle the North Essex Authorities will quickly lose control once the land has been allocated. There is a risk that developer led master-planning will aim to maximize profit, not serve the community over the long term and that infrastructure promises will be renegotiated.
Stonger public sector leadership is needed. It is worth remembering that no major new town has been delivered in SE England since Milton Keynes in the 1960s, and that had its own development corporation. Despite considerable infrastructure advantages, progress at Ebbsfleet has been slow, a Development Corporation has been imposed, and £300m of Government funding has been required to date. The North Essex Authorities aim to develop, with no relevant experience and a poor track record of infrastructure delivery, three Ebbsfleets at the same time. They are unlikely to succeed. The consequence is the failure of three Plans.
6 AECOM volume 2 page 36
7 AECOM volume 3 page 122. "The financial appraisal provides an indicative assessment of the costs and sales values associated with the schemes. Given the high level of information available, the use of the Model at this stage is for indicative purposes only, and to identify key input values and assumptions that future, more detailed modelling should take account of. As such, no conclusions are drawn or intended with this work regarding the viability of the sites and options.
9 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
CAUSE believes that a strong delivery vehicle is a pre-requisite to ensure proper master planning and that infrastructure is delivered before housing. The vehicle needs planning and CPO powers within designated areas: the Councils and other public bodies should all have a stake in it, but it should be protected from political interference. Private and community interests must also be represented. Its job would be to locate a new settlement, communicate its benefits, negotiate proper infrastructure funding, capture land value uplift, produce an attractive visionary master plan and co-ordinate private sector delivery.
Major decisions on the location of settlements should be postponed until the delivery vehicle is in place, along with a CEO and Chairperson who can build consensus and provide expert leadership.
Section 3 - improving the plan
CAUSE is keen to play a constructive role in the planning process, and Appendix 1 sets out how the Plan can be amended to be sound. The changes proposed are of a scale to warrant delay of the Plan to allow further evidence base to be identified, scoped and prepared; and for this to be consulted upon as part of a Further Focused Consultation before the Plan is taken forward to the stage of preparation.
Step 1: Postpone Part 1: the Councils should postpone decisions on Garden Settlements until proper infrastructure plans and a delivery vehicle are in place. The time pressure created by current deadlines in the process is leading to rushed decisions and the wrong answers in the context of substantial levels of development which will span a number of decades in the preparation and construction phases alone.
This is both realistic and practical: the three section 2s on smaller settlements can go ahead independently. With a lower OAN, section 1 can be removed from all three plans. Braintree and Colchester will have sufficient housing numbers without it. Tendring will have a 1250 dwelling shortfall over 15 years but they have plenty of realistic options: they can assume that a start can be made on East Colchester, the least unrealistic of the garden settlement proposals. Alternatively, more development could be located around stations on the underused Colchester / Clacton line as suggested in CAUSE's Metro Plan.
Step 2: Review the OAN: CAUSE recommends a wholesale review of housing need which would legitimately lead to a reduction in the OAN (Objectively Assessed Need) figures for Colchester and Braintree (see Appendix 5). The current figures are unnecessarily high, and undeliverable through a sustainable Plan, and should be more in line with demographic forecasts of the DCLG household projections as recommended in the Planning Practice Guidance.
Such a reduction would allow Councils to drop Part 1 without compromising the validity of their plans. Taken together the Part 2s provide enough housing to meet a sensible OAN forecast. Housing need would be met even with a lower OAN.
Step 3: Develop proper funded infrastructure plans: Infrastructure plans must cover the following points before a decision can be made on the location of garden settlements:
● Conditionality and triggers to ensure that infrastructure is in place before building can begin. Cast-iron guarantees about delivery are required.
● A road plan with an agreed layout for the A12 and A120 between Braintree and the A12 is needed. The junction between the two also needs to take account of the needs of Tiptree
10 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
and the villages to the South of the A12 whose traffic is currently congesting Kelvedon High Street.
● The plan also needs to revive the old plan for a South Circular road around Colchester linking the Tollgate through to a Colne Crossing and the A120 somewhere near Elmstead Market. This will serve the villages to the South of Colchester and significantly reduce congestion within the town.
● A credible transport plan for Colchester itself is required. Reducing through traffic with a South Circular road is only part of the solution.
● Much more detail on the proposed bus rapid transit system8 from the AECOM report is needed. Examples elsewhere lead us to suspect that the £25m budget will be inadequate if it is to be done properly with dedicated bus routes.
● A credible funded plan for dealing with the forecast increase in commuters and freight along the Great Eastern Mainline is urgently needed but unlikely to appear: in its absence North Essex should do everything it can to build the local economy rather than commuter settlements.
When a proportionate evidence is prepared and a delivery vehicle is in place and the infrastructure plans are complete, the Councils will be in a position to make rational decisions on the location of garden settlements.
We therefore recommend that Part 1 of the Local Plans should be delayed until proper infrastructure plans and a delivery vehicle are in place. The chosen option (West Colchester Garden Community) will not achieve the OAN in the Plan period and therefore should be dropped.
There should be a focus on:
 the most deliverable and sustainable of the options, East Colchester;
 alternatives (Colchester Metro Plan and Colchester North) should be properly considered;
 reducing the OAN in line with realistic sustainable delivery.
In the mean-time the Part 2 plans, combined with a more balanced approached to OAN, will provide adequate delivery of development.
No garden community should commence until external infrastructure is upgraded to meet both current needs and the needs of the future population of the planned community.
8 We assume that the rail options mentioned in the AECOM report will never be delivered due to their high cost - £500m and [£1.5 billion.]
11 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Appendix 1
Proposed changes to the Local Plans Part 1
We suggest how the Plan can be improved to meet the tests of 'soundness'
SP1 - Presumption in Favour of Sustainable Development
The need, driven by the NPPF (SP1), for growth to be sustainable is emphasised, stating that "new development should be accessible by sustainable forms of transport, including cycling and walking" and that "sustainable development principles will be at the core of the strategic area's response to its growth needs". The vision for the Strategic Area should therefore place greater emphasis on connectivity and transit-oriented development.
CAUSE would like to see an "infrastructure first" qualification added to the general presumption in favour of development and a statement that "where a planning permission results in significant land value uplift, developers are expected to contribute to related infrastructure costs, whether through CIL or (for larger sites) through a s106 agreement.
As drafted, SP1 allows development to go ahead without consideration of external infrastructure requirements, the cost of which must be borne by the public sector. This is not the intention of the NPPF and could lead to further "infrastructure last" development in the region.
SP2 - Meeting Housing Needs
CAUSE suggests that modestly lower OAN figures should be adopted based on demographic trends. See Appendix 5 which concludes that the OAN figures are unnecessarily high.
SP3 - Providing for employment
The stated aim is ' achieve a better balance between the location of jobs and housing, which will reduce the need to travel' and to strengthen and diversify local economies.
However, the preamble to SP3 ignores the biggest credible generator of employment in the area, the University. The impact of the university should be properly assessed. It should mention the aspiration for 50% growth in student numbers over the next 5 years, partnerships with business, the Knowledge Gateway, the need for more staff at the University, and the multiplier effect of student and staff spending in the area.
The employment policy itself needs significant rewriting because it over-regulates and shows no understanding of how jobs are created9. CAUSE recommends retaining only clauses b, c and d from the existing draft.
The rewrite should state that development will be supported to meet the needs of business except where there are infrastructure constraints, unnecessary use of greenfield land or other external costs.
9 CAUSE believes that this approach to regulation has been behind the debacle at Stane Park
12 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Top down targets for hectares of B use employment land should be abandoned, and it should be clear that development will be supported in smaller locations (including farmsteads) as well as the large industrial estates which seriously overload the transport infrastructure at peak hours.
Such a policy will generate much more diverse, well paid and sustainable employment.
CAUSE's Appendix 6 argues that just allocating land to employment uses is unlikely to generate the high value jobs needed to support a thriving Garden Settlement at West Tey.
SP4: Infrastructure and Connectivity
'The challenge is to provide a sustainable transport system, while providing good access to jobs and services, and to support economic growth'. This needs more detail:
Paras 2.63 - 2.66 need to show more appreciation of the constraints along the GEML particularly along the stretches towards London.
Clause 2.66 contains a reckless assumption that "these improvements are assumed to provide the gross capacity required along the line". It should instead say that there is significant doubt about the capacity of the line, and that the plan will therefore do everything it can to reduce dependency on jobs in London.
Para 2.71 on healthcare infrastructure gives no comfort that adequate hospital facilities will be provided in advance of development: it needs to recognize that new hospital facilities take decades to plan, and to demonstrate that there is a credible course of action. In its absence there should be a condition that "new garden communities will not be started until healthcare provision in the Boroughs has been raised to at least the national average". Garden communities can only become popular if existing infrastructure shortfalls are addressed.
Para 1 of the policy should add the words in italics: "Development must be supported by provision of infrastructure, services and facilities that are identified to serve the needs arising from the new development and provide net betterment for existing residents whose lives are affected."
The strategic priorities should include an extra bullet point as follows: "A link road between the A133 and A120 close to Elmstead Market to relieve traffic pressures on East Colchester, to be constructed before any new dwellings are occupied in the East of Colchester Garden Settlement".
Additional last paragraph to the policy: "No planning permissions will be granted for development within the garden settlements until
 The developer can demonstrate that the infrastructure improvements listed above will be delivered before or alongside housing: AND
 the developer can demonstrate that the standards of existing road, rail, shool and hospital services exceed the national average"
SP5: Place shaping principles
Preamble 2.74: "New development must reflect high stands of urban and architectural design. It must also be functional and viable. Major new developments will be planned carefully with the use of masterplans and design codes where appropriate. Severance issues will be properly addressed before land is allocated and each community will be designed with a centre and a distinctive character with the advice of a recognized master planning architect."
Policy SP5: All new development should reflect the following principles:
13 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
 It should reflect the principles of transit-oriented development, which require that existing transport infrastructure is considered and that transport issues are addressed at the earliest stage of the planning process
 Respond positively to local character etc.
SP6: Spatial strategy for North Essex
CAUSE requests that paragraph 5 of SP6 be deleted. It prematurely incorporates three huge garden settlements at East Colchester, West Colchester and West Braintree into three Local Plans. Formal inclusion has the effect of driving up "pre-scheme" land values10, making it more difficult to capture land value uplift for infrastructure spending.
These settlements must be reconsidered only when credible infrastructure planning is complete and a delivery vehicle is in place.
No garden community should commence until external infrastructure is upgraded to meet the current needs and the needs of the future population of the planned community.
Two valid and viable alternatives, in the form of 'North Colchester' and 'Colchester Garden Metro Communities' have been have not been included in Part 1. These must be reconsidered.
SP7: Development and delivery of garden communities in North Essex
(NB SP7, SP8, SP9 and SP10 should be dropped from the formal plan at this stage to allow for proper analysis of other options and full modelling and Infrastructure Delivery Plans as set out elsewhere in this resposne . If they must remain they should be amended as follows.)
SP7 needs to acknowledge the disconnect between lofty ambitions and the resources presently available to the Councils. It needs to build a credible business case for the government funding needed to start a development corporation and plan the supporting infrastructure.
SP8: East Colchester / West Tendring Garden Community
Section D on Transportation should be amended to state that
i) the A120/A133 link road will be constructed before new dwellings are occupied.
ii) The promised transit link between the settlement, Colchester and the University should be operational at a specified service level before new dwellings are occupied
SP9: West of Colchester / East of Braintree Garden Community
Para 2 on the Master Plan framework should be amended to make it clear that the delivery vehicle will be responsible for master planning.
The policy on "Place Making and Design quality" should
 contain a statement about the need to create an identifiable centre for the community
 require that the masterplan deal with the severance problems created by the A12, A120, GEML and Sudbury lines.
The policy on Transportation D6 isn't strong enough. It should state that no new housing in the garden community will be occupied until the A12 is tripled and the A120 is dualled.
Policy D7 should be removed. It suggests that the reconfigured A120 will provide access to the site which is inappropriate because:
10 In the event of CPO
14 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
 It predetermines the outcome of the upcoming ECC consultation on the road and
 It conflicts with ECC's preferred options from 2005 which propose a direct link between the McDonald's roundabout in Braintree to the A12 near Feering with no intermediate junctions and
 It reveals an illogical connection between improving the A120, a part of the Trans European road network from Cork to Moscow, and the location of new settlements.
Policy D8 needs to be stronger. West Tey should not be started until dedicated bus routes11 are established between Braintree and Colchester town centres. This will cost much more than the £25m budgeted in the AECOM appraisal for a bus rapid transit system for the whole area.
Policy D10 needs to be stronger. West Tey should not be started until we know that the station will be properly connected to the community. The present statement about "exploring opportunities" is much too vague.
Policy D11 should incorporate the promises made by the developers for living bridges connecting the disparate parts of Marks Tey.
A new policy D12 is required stating that West Tey will not be started until there is a credible funded plan to enable the GEML to meet forecast increases in long term commuter demand.
Policy E12 should be strengthened to clarify that school and health facilities will be provided to incorporate the needs of the full 15-20,000 dwelling development as well as improving facilities available to the existing population.
SP10: West of Braintree new garden community
Para 2 on the Master Plan framework should be amended to make it clear that a delivery vehicle will be responsible for master planning, not developers.
Policy D6 needs strengthening. Transport-oriented development requires that transport is considered first, not retrofitted after the location is decided.
Policy D8 needs to be strengthened to make it clear that the development will not be started until dedicated12 bus routes are in place.
Delivery arrangements
CAUSE supports the Council's exploration of delivery options and has outlined a vision of how a delivery vehicle might work on page [7] above.
2.88 should be amended to "ensure that infrastructure and residents requirements for the new community are developed ahead of or in parallel to the building of new homes." It should be clear that the price for garden settlements is "infrastructure first".
2.89 should be dropped. The Councils don't have the expertise to exercise large scale CPO powers if there is an unacceptable delay in development and/or infrastructure. The policy sounds unduly threatening and does nothing to enhance the credibility of the plan to landowners or the public.
11 Dedicated bus routes should be defined to include bus lanes, guided bus routes as in Cambridge or use of a dual carriageway with sufficient capacity even at peak hours.
15 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Appendix 2
CAUSE comments on the Sustainability Appraisal for Part 1, prepared by Place Services
The Sustainability Appraisal contains a number of serious inconsistencies and omissions. This commentary focuses on
1. The erroneous inclusion of West Colchester Garden Community in the Preferred Options and the equally erroneous rejection of North Colchester Garden Community.
2. The erroneous exclusion of CAUSE's Metro Plan, prepared by CAUSE's professional team. This alternative has received recognition in the wider planning community but has been misunderstood by the authors of the sustainability appraisal. It is a matter of regret that CAUSE has been unable to explain it to the appraisers, despite repeated requests to do so.
The principal argument in favour of West Colchester GC appears to be that the location will 'stimulate required infrastructure delivery'. This political argument is highly inappropriate in a sustainability appraisal. Garden settlements should be located in the most sustainable locations from the point of view of society as a whole, not with the intention of securing funding from other parts of the public sector.
We conclude that the infrastructure requirements to ensure that West Colchester succeeds as a garden community are too high, both in terms of financial viability and practical deliverability. The location does not support the NPPF principle of reducing journeys and it appears that the sustainability appraisal favours it for political rather than economic reasons.
West Colchester compared to North Colchester
Marks Tey already suffers from severe severance by the A12, the A120 and the GEML. Shops are severed from the village hall which is itself is severed from the main residential area. The industrial area between road and railway has unsatisfactory and dangerous linkages to both A12 and A120.
Without huge infrastructure investment these problems will be exacerbated in the expanded settlement. The Appraisal acknowledges the severance caused by the A12 and the GEML. It neglects to mention the additional severance caused by the current A120, the Sudbury line and the new A120 which will join the A12 in the area. Therefore, West Colchester will be a community severed in five directions. See map of Marks Tey, below.
North Colchester is capable of forming a coherent community with its own centre and identity. The A12 forms a natural boundary which can can be bridged to link the community to Severalls Industrial Park.
There is no logic to why such extreme severance is considered acceptable at West Colchester yet the significantly lesser severance at North Colchester is not considered acceptable. The Appraisal should
16 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
make more attempt to compare the search areas and analyse the differences.
Sustainability and accessibility.
There are significant sustainable transport and accessibility issues at West Colchester GC highlighted by Place Services and by Aecom. The impact on the transport network will be exacerbated by the need for many residents to travel to work elsewhere. This is not highlighted sufficiently in the Appraisal.
a. Road congestion. It is clear from the Appraisal that road infrastructure represents the main barrier to development at West Colchester GC. The Appraisal contradicts itself, stating, despite its own references to congestion, that the A12 and A120 at West Colchester GC are 'beneficial'. Negative concerns that North Colchester GC will be reliant on the A12 and 'could' increase congestion are therefore also contradictory if the Appraisal believes that location on the A12 at Marks Tey is beneficial when it is considered a negative a few miles away.
The Appraisal must compare like with like. The congestion effects on the A12 will be high at both North Colchester GC and West Colchester GC, arguably higher at West Colchester GC due to the larger settlement proposed and the distance from any of North Essex's designated strategic economic areas.
b. Rail. It is extraordinary that the Appraisal neglects to discuss the capacity issues on the GEML. Aecom is clear in its assessment of the long term capacity constraints on the line, stating that Network Rail's own proposed interventions will be insufficient. West Colchester's location to encourage rail commuting is flawed.
17 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
In addition, the accessibility issues at the station raised in the Appraisal 'limit any meaningful expansion'. Relocation of Marks Tey station is suggested, but only in the 'Maximum Land Take' option in the Aecom analysis - yet another illogical piece of analysis. The station must be central in any West Colchester GC option.
The location of the station in the new community and the Anglia Route Study capacity forecasts make it clear that the station is not the advantage it is purported to be.
c. Bus. The bus service from Little Tey & Marks Tey is cited as a clear advantage for developing a sustainable transport system and BRT, a clear sign that the appraisers have yet to appreciate the scale of development proposed or of infrastructure needed. This is not a location differentiator as there are bus services from all rural areas into the centre of Colchester. Nor does it form the basis for a BRT system, something which is a complex and expensive undertaking!
By comparison, at North Colchester GC not only is there already a Park & Ride (referred to in the Appraisal) in place but already the planned provision of a dedicated bus corridor to support existing plans for 1,500 homes at Severalls Hospital (not mentioned in the Appraisal - why?). Nor does the Appraisal refer to the Rapid Transit Option Appraisal being investigated to link the Severalls site, University and town centre, which would bring benefits to (and could be extended to) the North Colchester options.
It is clear that public transport options under consideration in the north Colchester area are well advanced and would offer considerable benefits to the residents of North Colchester GC. Meanwhile proposals for the West of Colchester still range from heavy rail (cost £2bn), adapting existing rail (cost £500m) or developing a new Bus Rapid Transit system for £25m, which we suspect will do little other than further congest existing roads.
d. Cycling & walking. Aecom notes that there are no external cycle and pedestrian ways near the West Colchester GC search area, and a quick glance at the map above makes it clear that retrospective provision will be difficult. The Appraisal neglects to mention this, nor does it refer to the distance of the settlement from Colchester and Braintree, which would discourage cycling and walking.
With reference to North Colchester GC, the Appraisal does not cite the benefits of the 'well-established Colchester walking and cycling network linking the [North Colchester] site, the P&R, Stadium and importantly the employment and leisure area on the south side of the A12' (Aecom Garden Communities Concept & Evaluation).
e. Reducing journeys. West Colchester, as a new and stand-alone community, offers none of the benefits of existing employment which the North Colchester settlement offers. It is not a Strategic Economic Area and there is no focus for employment (Aecom refers to home-working and touch-down spaces as the employment strategy). Whilst land will be provided for employment, Aecom notes that residents of West Colchester will be attracted to Severalls and the Northern Gateway to work, which will require residents to travel by car on the A12.
18 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
By contrast, Colchester GC will be adjacent to employment at Colchester's Strategic Economic Area of Severalls and the Northern Gateway. Aecom's schematic demonstrates this relationship:
The Appraisal asserts that all Garden Community Options will have broadly the same employment opportunities. This is clearly not the case and nor does the conclusion meet with the NPPF aim to reduce journeys to work and to locate houses for employment.
Taking each of the three options:
o East Colchester benefits from and supports the growth of the University, the Knowledge Gateway (one of Colchester's three Strategic Economic Areas), and the town centre.
o North Colchester benefits from and supports the Strategic Economic Area of the Northern Gateway, Severalls (and the town centre).
o West Braintree benefits from and supports the strategic employment zones of Skyline 120 and Panfield, and is on the 'right side' of town for employment at Stansted, where sustainable transport solutions are proposed.
o West Colchester GC is located far from any strategic employment zone and town centre.
19 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Place Services reminds us that the deliverability of West Colchester is directly linked to investment decisions by Highways England. There is no such constraint at North Colchester. Aecom and Place Services believe that the road network in its existing state must constrain development at West Colchester to between 500-900 homes.
CAUSE believes that the GEML must be additionally considered as a constraint and questions why the Appraisal has not taken it into account.
Finally, North Colchester GC carries a lower deliverability risk being entirely within Colchester's boundaries.
Other environmental
Pollution. It is evident that West Colchester, situated between the A12, current A120 and new A120, will suffer from pollution and air quality issues as evidenced by the image below (Source 14 September 2016). This topic is not mentioned in the Appraisal's summary comparison between options although in the detail it does state that the main air quality issues for Braintree relate to traffic on the A12 and A120. Once again, the report contradicts itself, stating that cumulatively the garden communities will have a positive impact on air quality due to availability of sustainable transport but that there would be an A120 and A12 air pollution impact of North & East Colchester combined. Air quality issues need to be given far greater consideration and the inconsistencies ironed out.
20 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Water. We challenge the assertion that there are major constraints on water delivery at North Colchester because Anglia Water's response to Colchester's Issues & Options consultation did not differentiate between locations (see table below). We have been unable to find the references in the Appraisal which refer to constraints at North Colchester GC.
Solar farm. We do not agree that a 26 hectare solar farm at North Colchester GC (within a total site of between 457ha and 681ha) prevents garden city principles being applied. This is something that could be addressed through masterplanning and exclusion zones (as required at West Colchester for underground and overhead power cables).
Impact on existing residents / protected zones. At North Colchester GC, protection could be afforded to the Dedham Vale AONB through masterplanning and green buffers, and the areas of importance at West Colchester can be protected in the same way. Too little thought is given to the entire villages (Marks Tey and Little Tey) which will be engulfed at West Colchester and the Appraisal simply states that this impact is not 'positive'. There needs to be greater consideration of the impact on the existing local residents of West Colchester.
Brownfield. The plan states a preference for building on brownfield land as opposed to greenfield. But there is no mention of the brownfield element at North Colchester - the Boxted airfield. The whole CO4 5 postcode is treated as brownfield in the report from BPS Chartered surveyors. It is unclear why the SA favours West Colchester which is treated as greenfield by BPS.
Conclusion on North Colchester / West Colchester comparison
The Sustainability Appraisal concludes that for North Colchester GC that there is limited scope for maximum sustainable benefits associated with adhering to Garden City principles. This is contradicted by much of the report's own evidence and the research prepared by Aecom and Colchester's Part 2.
The conclusion for West Colchester GC that the location will 'stimulate required infrastructure delivery' is also flawed and makes the report look like a political attempt to secure funding rather than a genuine sustainability appraisal. A location for a garden settlement should not be chosen to stimulate infrastructure delivery, nor because it is proposed by land owners. The infrastructure requirements to ensure that West Colchester succeeds as a garden community are too high, both in terms of financial viability and practical deliverability. The location does not support the NPPF principle of reducing journeys. Planners are trying to fit a square peg to a round hole at West Colchester GC.
Reasons given for excluding CAUSE's Metro plan
Assessment of CAUSE Metro Plan in the Sustainability Appraisal relating to North Essex authorities 'Part 1'
The Sustainability Appraisal assessment of CAUSE's Metro Plan strategy is disappointing and inadequate. The absence of appropriate testing goes to the heart of soundness.
The Appraisal takes a very narrow view of the Metro Plan, failing to acknowledge that this was part of a broader strategy which included not only the 'pearls' but also a garden community development to the East of Colchester focused on the fast employment growth zone of the University. It aims to make the area more self-supporting, with a new rail 'halt' proposed as an early win.
It is extraordinary that the Appraisal has "assessed" the CAUSE option as if it was intended to address the total growth through concentrated development around stations on the Colchester-
21 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Clacton/ Walton-on-the-Naze line, rather than as a contribution to growth, which could reduce the scale of development (and associated infrastructure requirements) which is being relied upon to meet growth requirements in less sustainable locations, including West Tey. The Metro Plan was never intended to address Braintree District's housing need and nor does the East of Colchester/West of Tendring garden community included in Tendring and Colchester's Preferred Options do so.
We strongly believe the thinking about large stand-alone garden settlements is outdated as URBED's Wolfson prize submission showed. Instead of thinking in terms of bureaucratic convenience in handling one scheme (and the associated risks to delivery by an overconcentration of development in one location), the authorities need to think in terms of what will work in our stressed circumstances with increasing concerns about access to affordability and housing delivery to meet changing housing needs. A quick look over the water to the Netherlands shows what would work better and pay off for everyone. The CAUSE Metro Plan merely extends the garden communities concept away from the creation of two very large garden communities to a network of smaller garden communities which can start to be developed during the current plan period and continue to be developed beyond 2030. (See case study page 26 Garden villages are, in fact, strongly promoted in the latest DCLG garden communities' prospectus but this approach is not reflected in the strategy for North Essex authorities.
One of the advantages of the Metro Plan is flexibility; if one area of development is delayed due to unforeseen circumstances the entire Plan does not fail. Flexibility is a key component to Plan making as set out in the NPPF.
The Metro Plan is an innovative and sustainable concept based on principles of transit-oriented development which links the strategic allocations in Tendring's Preferred Options, including the East Colchester Garden Community, Weeley, Frinton and Clacton, which would constitute the first pearls - see below:
22 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
In undertaking Sustainability Appraisals, a key consideration should be impact on modal share or congestion. A scheme that makes better use of existing rail capacity should score better than one that puts more load on already congested road infrastructure. The connectivity benefits of CAUSE's Metro Plan are key and it supports Tendring's stated objective under Connected Places: "The Local Plan's strategic objectives for Infrastructure Provision are to make efficient use of existing transport infrastructure and ensure sustainable transport opportunities are promoted in all new development." However, despite this stated objective, the Preferred Options totally ignore the benefits of the Colchester-Clacton line.
The view expressed in the Sustainability Appraisal that CAUSE's Metro Plan has "potential for negative impacts associated with the distribution," especially, "regarding increasing visitor numbers to the coast" contradicts the Preferred Options policy statements and Tendring's site allocations along the Colchester-Clacton rail spine (see map above) in the Preferred Options. The Metro Plan meets with Development Strategy Objective 1 to support Tendring's growth locations, particularly Clacton and West of Colchester. In addition, the Metro Plan supports Objective 5, to 'facilitate population growth where it supports economic objectives' by linking regeneration areas with strategic economic areas.
Tim Pharoah's December 2015 transport report (pp 27-29) indicates that there is already considerable land available within the 800m catchment of stations, identified in the "call for sites", especially at Weeley and at and Kirby Cross (Walton branch). Once the stations have been identified as growth points, it is likely that other landowners will come forward to promote sites for development.
23 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
The infrastructure costs for the Metro Plan pale into insignificance when compared to the infrastructure upgrades required at other sites, in particular Marks Tey, and thus we reject the assertion that viability is an issue. It is significant also to note that Highways England has stated that it would not wish to see development in this location before the A120 is upgraded which would require significant upfront investment in infrastructure provision which must present a significant risk to delivery within the plan period. The Colchester-Clacton line is a transport asset with spare capacity to meet the NPPF sustainability criteria.
The Sustainability Appraisal's conclusion regarding the Metro Plan is unsound and for this reason, we believe the Metro Plan option must be re-assessed.
24 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Extracts from the CIL report by BPS Chartered Surveyors which suggests that the land used for Colchester North is "brownfield" while that used for West Tey is "greenfield":
Anglia Water assessment of options:
25 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Appendix 3
CAUSE ranking of the 5 options*
North Essex authorities: Strategic Part 1 for Local Plans
CAUSE regards West Colchester Garden Community as the least viable, deliverable and sustainable of the five North Essex garden community options.
See attachments for table in readable format
Appendix 4
CAUSE Metro Plan
All documents available on under 'A Better Way'.
CAUSE's proposal takes advantage of employment and infrastructure opportunities to the east of Colchester and across Tendring District. It provides a network of integrated, sustainable, garden communities, benefiting the economies of both Colchester and Tendring.
Settlements along the under-used resource of the Colchester-Clacton electrified railway, and one as proposed by Colchester and Tendring near Essex University, could provide up to 19,000 homes. All would be within a 10 minute walking catchment of high quality transport and deliverable within the 15 year plan period.
Early implementation would be possible without waiting for major infrastructure, thus removing delivery and viability risk. Each settlement would offer low order services and the 15 minute rail service would connect residents to high order services in the towns. The concept is more in line with the original garden city vision than freestanding large settlements.
Overview document:
Also a CPRE report about the benefits of transit-oriented development entitled "Making the link" in which CAUSE's Metro Plan is a case study on page 26:
CAUSE Metro Plan and garden city principles
Planning report
Joanna has over 30 years' experience in the public and private sectors and has been responsible for a range of strategic planning, master-planning and regeneration work in the
28 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
UK and overseas, focusing on development feasibility studies, strategic planning, master-planning, project management and public consultation and participation. She has worked in partnership with the private sector, agencies, local authorities and communities to help bring about more sustainable neighbourhoods, high quality development and lasting renewal. Recent project experience includes working with Maldon District Council on the delivery of new Garden Suburbs and masterplan frameworks for Clacton-on-Sea, Dovercourt and Walton-on-the-Naze. Joanna is passionate about place making and good design and her professional ethos is based on building a climate of collaboration. She established Changing Cities in January 2012 as an independent consultancy focusing on partnership working to help overcome barriers to the delivery of sustainable development and regeneration.
Transport report 1 CAUSE Metro Plan
Tim is a transport and urban planning consultant working independently. He has more than 40 years' experience of transport, land use planning and urban regeneration in local authorities, private consultancies, and the academic sector. He is a keen advocate of planning for vibrant urban communities through integrated planning, low-impact accessibility, and public realm design. Tim's second report for CAUSE forms Appendix 8.
The scope for high-quality rail services to support sustainable urban development
Jonathan started his railway career as a British Rail Traffic Apprentice in 1962 after which he went to BR Headquarters to develop the MONICA demand model. From 1976 to 1982 he was the British Rail Lecturer in the University of Birmingham. In 1983 he became an independent consultant, trading as Passenger Transport Networks, in which capacity he has worked on a range of projects, concentrating initially on geodemographic market analysis for the rail passenger business and from 2000 on timetabling policy and construction.
Consultants assisted by:
DR NICHOLAS FALK BA (Oxon), MBA (Stanford), PhD (London), Hon FRIBA
Nicholas founded URBED in London in 1976 to offer practical solutions to urban regeneration and local economic development. Over the last few years he has focused on new communities, the future of the suburbs, historic centres, and the adaptive reuse of old buildings. He has recently been advising on an urban extension to Oxford, and previously produced the Cambridgeshire Quality Charter for Growth. With David Rudlin, he won the Wolfson Economics Prize 2014. He has extensive experience in creating visionary, economically viable and popular urban plans and designs.
Alan is a locally based architect-planner and urban designer. He was Head of Heritage and Urban Design at Essex County Council and Chair of the Urban Design Group (the
29 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
professional body for urban designers in the UK). He was also co-author of the Essex Design Guide, and chaired the campaign group that saved Liverpool Street Station from demolition in the 1970s. He lives locally and is currently Secretary of the A12 Villages Traffic Action Group and of the Kelvedon and Feering Heritage Society.
Conference podcast available under 'Conference' and full pack here:
30 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Appendix 5
Critique of housing need projections and Local Plan proposals
Alan Wenban-Smith, Urban & Regional Policy
1 Introduction
Purpose of this report
1.1 The three North Essex Districts of Braintree, Colchester and Tendring share a common Part 1, covering the strategic elements of employment, housing and transport of their three Local Plans currently being produced. I have been commissioned by CAUSE to critically examine the housing proposals. My relevant qualifications and experience are given in below.
Documents consulted
1.2 The work has been carried out as a desk-study of the evidence for the housing provision being proposed in the three Districts. In addition to relevant national sources for policy and data, the following key local documents have been consulted:
a) The 'Objectively Assessed Housing Needs Study' (OANS) prepared by Peter Brett Associates (PBA), published July 2015. This covers the whole Housing Market Area (HMA), which includes Chelmsford as well as the three Districts discussed in this report.
b) The 'SHMA update', prepared by HDH Planning & Development (HDH), published December 2015, providing further analysis of affordable housing needs for the four Districts in the HMA. Together with the OANS this is stated to comprise the Strategic Housing Market Assessment (SHMA) required by national policy (see 2.3 below).
c) 'North Essex authorities: Strategic Part 1 for Local Plans'. This is the common strategic component of all three. The text consulted was contained in the Colchester Local Plan published for consultation in July 2016 (assumed to be substantively the same in all three).
General conclusion
1.3 I have reviewed the evidence referred to above, and my detailed analysis follows. The broad conclusion I reach is that the strategic Part 1 of the North Essex Local Plans is unsound. This is because, while mostly following the processes set out in national Planning Policy Guidance (PPG) to quantify housing needs, it fails to meet the requirements of the National Planning Policy Framework (NPPF) in respect of securing sustainable development.
1.4 The remainder of this report, fleshing out this conclusion, is in four sections:
Section 2 sets out the relevant elements of NPPF and PPG on housing provision in Local Plans.
Section 3 compares local and national housing need projections with the strategic proposals for provision of housing land in the three North Essex Local Plans.
Section 4 reviews the provision proposed against four issues derived from NPPF:
 Meeting needs: will the Local Plans really help to meet the housing needs which justify the level of new housing they propose?
31 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
 Feasibility: is the proposed scale of development feasible in the context of the level of effective demand demonstrated by past construction?
 Local labour markets: is the proposed distribution of housing land between Districts well-founded in terms of meeting future local labour market needs?
 The wider context: how does the proposed provision relate to housing and labour markets, and consequent travel demands, across a wider area (including London)?
1.5 Section 5 summarises my conclusions.
2 National policy context
2.1 The National Planning Policy Framework (NPPF, approved in 2012) is the top level of national policy on planning, and requires Parliamentary authority to modify. NPPF makes clear that purpose of the planning system is to further the economic, social and environmental dimensions of 'sustainable development' (paras 6 and 7). It stresses (para 8) that because of their mutual dependence "to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system" which "should play an active role in guiding development to sustainable solutions.". However, within this context, NPPF also stresses the need to "support sustainable economic growth" (para 19) and to "boost significantly the supply of housing" (para 47).
2.2 Economic growth and housebuilding have not in fact recovered to the levels experienced before the economic crisis of 2008. Although (as discussed later) this has little to do with the planning system, modifications to NPPF are under consideration by DCLG following a consultation period that ended on 22 February 2016. According to its website (16/8/16) DCLG is still 'analysing feedback'. No other consultations are referenced, though a Local Plans Expert Group reported its recommendations in March 2016. Both sets of proposals could affect the treatment of housing in Local Plans, possibly in major ways. These uncertainties, affecting an already over-complex process, are a concern for all involved in local planning.
2.3 National Planning Policy Guidance (PPG) is subordinate to NPPF, but is much more voluminous and can be varied at will by DCLG. The current version for housing was published in March 2014, and no relevant update is registered on the DCLG website. In respect of housing needs PPG requires a Strategic Housing Market Assessment (SHMA) to be carried out for a Housing Market Area (HMA) that covers the whole of the area that is functionally interdependent in housing market terms with the Local Plan area. The OANS and SHMA update for North Essex cover a Housing Market Area (defined in these terms) which includes Chelmsford as well as the three Districts sharing a strategic context for their Local Plans. The implications of this mismatch are considered later.
2.4 The starting point specified by PPG for examination of housing needs is the latest official household projections produced by DCLG. PPG implies a cautious approach to any proposed adjustments:
32 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
"The household projections produced by DCLG are statistically robust and are based on nationally consistent assumptions. However, plan makers may consider sensitivity testing, specific to their local circumstances, based on alternative assumptions in relation to the underlying demographic projections and household formation rates. Account should also be taken of the most recent demographic evidence including the latest Office of National Statistics population estimates."
2.5 The household projections for local authority areas are themselves based on subnational population projections (SNPPs) by the Office for National Statistics (ONS). The ONS and DCLG projections are 'policy neutral': that is, they take past trends and project them forward on the assumption that the same policies and processes are in place in both the past 'reference' period and the future 'projection' period. Note that the headship rates in the household projections rely on much longer-term trends than the corresponding population projection (the reference period is 20 years for household projection compared with 5 years for population).
3 Housing need projections and planned housing provision in North Essex
3.1 Housing needs for the whole HMA (4 Districts) on the basis of the DCLG 2012-based trend projection would be 2,916 dwellings pa (dpa). The OANS makes allowances for additional employment in each District and for more migration from London, adding a further 221 dpa. This 'uplift' of 8% is stated as all that would be needed to meet future employment needs and 'market signals', as well as London-related migration (OANS 9.12). The Local Plan reference to a 15% uplift for these purposes (Local Plan Part 1, para 2.36) is therefore clearly mistaken13. The relationship of the DCLG, OANS and Local Plan figures for the three Districts in North Essex is set out in Figure 1 below. While Local Plan periods differ from the OANS and from each other (Figure 1, Note 4), when all are expressed in terms of provision per annum the comparisons are valid.
Figure 1: See attachment for readable formatted table
3. OANS includes an 'uplift' of 8% across the 4 Districts forming the HMA
4. Local Plan periods: Braintree, 2016-33 (17 yrs); Colchester, 2013-2033 (20 yrs), Tendring, 2013-2033 (20 yrs)
5. DCLG (2014-based projection - July 2016) over period 2013-2037 (24 years)
3.2 The OANS estimates of additional housing needs vary markedly between Districts because of estimated differences in local employment prospects (+159 (23%) for Braintree, +52 (6%) for Colchester, -108 (-15%) for Tendring, and +118 (18%) for Chelmsford). However, in the Local Plan Part 1 a still lower figure is adopted for Tendring: -155 (-22%). For the three North Essex Districts the proposed provision (2,315 dpa) is only 56 dpa (2.5%) above the corresponding DCLG trend figure, compared with the 221 dpa (8%) increase at the 4 District HMA level. The effect is to transfer the resulting housing need obligation to other Districts within the HMA, in particular Chelmsford, which would have to find a difference of 165 dpa.
3.3 It is notable that the latest household projection (DCLG 2014-based) suggests a baseline housing need figure 115 dpa below the 2012-based figure that has been used. This is commented upon later.
3.4 Variation within the HMA may well be justified by the need for a distribution of development that is more 'sustainable' in the terms of NPPF, and this seems to underlie the general correspondence with employment projections. The principle of matching housing and employment changes arises from the idea that commuting will thereby be reduced, but as will be discussed later (paras 4.16-23), this is mistaken. The Local Plan itself refers to uncertainties arising from Unattributed Population Change (UPC) as the reason for an additional reduction in the case of Tendring. This is also mistaken: UPCs have been the subject of a study by ONS14, which concluded that because the 2012-based SNPPs are fresh forecasts, with reference period Mid-Year Estimates adjusted for the 2011 Census, they should not be adjusted for UPCs. The Tendring figure is therefore anomalous on these grounds as well.
3.5 The total 'objectively assessed need' (OAN) estimated to 2033 by the three N Essex Local Plans is some 43,765 dwellings on a 2013 starting point of about 200,000 (+22%). The proposal for accommodating this growth is that new development should be focused on the principal settlements in each District, but with the addition of up to 7,500 dwellings (in total) in three new 'garden communities' (one in each District).
4 Critical review
4.1 While the overall housing growth proposals are substantial, they are close to the DCLG projections, and so in broad conformity with PPG. The main outstanding issue is whether the 'adjustment' for additional employment is well founded, though (as already noted) this adds only 2.5% for the three Districts. However, there are other critical issues relating to the broad planning principles stated in NPPF. In summary these are:
a) The justification for the new housing provision proposed in the Local Plan is the housing need identified in the SHMA. Will it help meet these needs?
b) Is the proposed scale of development feasible in the context of the level of effective demand demonstrated by past construction?
14 ONS (2014) Report on Unattributable Population Change
34 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
c) The proposed distribution of housing land between Districts is justified by reference to meeting future labour market needs. Is this well-founded?
d) How does the proposed provision relate to the pressures being experienced by North Essex to its position relative to London?
4.2 Whether or not the housing needs assessment conforms to PPG, analysis of these issues give grounds for serious concern that the planning strategy for the three North Essex Districts is not compatible with NPPF. As already noted, NPPF has precedence over PPG.
(a) Meeting needs
4.3 The DCLG projections include analyses of the age profile of households. In the context of the widening gap between the incomes of different age groups this information is important. It reveals an impending (if not already present) crisis because while newly-forming households are in the younger age-groups, these are also the groups whose incomes have been hit hardest by changes in the economy since the global financial crisis in 2008 (a recent report by the Institute of Fiscal Studies shows that while average incomes have recovered to their pre 2007/8 levels, those of under 30s have dropped by 7%). These younger age groups have also been hit by increasing insecurity of employment (eg 'zero hours' contracts) and a range of increasing costs (eg rising housing prices and rents, house purchase deposits, higher child-care costs, and student loan repayments).
4.4 Figure 2 shows the pattern of dynamic change between household age groups in North Essex over the period 2013-33 (which approximates to the Local Plan periods)15. The underlying numbers are set out in Appendix Table A1.
15 This analysis uses the DCLG 2012-based projection statistics (Tables 406 and 414) but presents them in a new way. By following each 10-year age group through the plan period it provides an insight into the dynamic process of household formation.
35 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Figure 2. Household age groups in Welwyn Hatfield: dynamic changes 2011-31
4.5 Within an overall increase of about 43,000 (22%) the pattern of change by age group is similar to elsewhere in England. There is:
 An increase of about 59,000 households (nearly ten-fold) from those under 25 in 2013 to those under 45 in 2033;
 An increase of about 26,000 (+20%) from those between 25 and 65 in 2013 to those between 45and 85 in 2033; and
 A decrease of about 41,000 (-70%) from those between 65 and 85 in 2011 to those over 85 in 2031.
4.6 It can be seen that the youngest age groups form the overwhelming majority of newly-forming households over the period 2013-2033 (59,000 out of 85,000 (70%))16. But while most new households are young, they are not the target market for new housing provided by the private sector. While the average price of a new house in the Eastern region was £258k (2015, Q2), the average price paid by first time buyers (FTBs) was £181k and the average paid by existing owner-occupiers was £272k, while the income levels of these categories of buyer were £51k and £121k respectively (ONS House Prices (2015, Q2), Table 12 and 15, East Region).
4.7 In fact new houses form only about 10% of the annual flow of property on the market, with the other 90% being provided by the 'churn' of the existing stock. First time buyers must necessarily make their choices mainly from the cheaper end of the existing stock, while builders of new housing rely almost exclusively for custom on present owner-occupiers. Any
16 This is even though households of over 65s increase by some 35,000 over the period, and form a higher proportion of the total (about 40% in 2033 compared with 30% in 2013). This increase is the effect of longer survival of single elderly, though because they are generally already housed this does not in itself generate a need for additional housing.
36 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
benefit to FTBs depends on 'trickle down' - and many obstacles obstruct that trickle. The effect on household formation is only beginning to felt because of the 20 year 'reference period' for projections (see 2.5 and 3.3 above), but may be expected to continue.
4.8 The high proportion of existing stock in the housing market also ensures that prices are insensitive to the volume of new housing. The Barker Report in 2004 estimated that an additional 70,000 dpa in England would 'price into the market' only 5,000 more new households per year (and then only after 10 years)17. Moreover, if for any reason house prices were to fall, builders would reduce, not increase their output (as experience since 2008 has demonstrated - see Figure 3).
4.9 The implication is that in terms of meeting the needs identified in the OANS new houses are not relevant unless they are genuinely affordable (whether to buy or rent). 'Affordable housing' as defined for planning purposes (80% of market prices/rents) is largely irrelevant. The Chancellor's 2015 Autumn statement included proposals for £8bn of public investment in 400,000 'affordable homes' by 2020/21 including 200,000 'Starter Homes'. However, at £20k per unit this provision would clearly depend mainly on existing money. Recent analysis by Shelter showed that a FTB wanting a Starter Home would need an income of over £55k (and much more in London).
4.10 The shared Local Plan Part 1 only refers to 'affordable housing' in the context of the new settlements, where it states that a figure of 30% "is supported by the evidence base" (para 2.40), a total of 2250 over North Essex if adopted as policy18. The SHMA suggests 30-35%, but this is unrealistic in the light of the evidence reviewed above about how future housing needs will arise. This conclusion is strongly reinforced by examination of past levels of output, discussed in the next section.
(b) Feasibility of the level of output
4.11 The past level of effective demand for housing in North Essex (needs backed by money) is indicated by sales over the last 16 years. Appendix Table A2 sets out the level of output achieved in the three North Essex Districts in the 8 years from 2000/01 to 2007/8 and the 8 subsequent years, and this is summarised in Figures 3 and 4.
17 HM Treasury (2004) Barker Review of Housing - Final Report, Table 1.1 Housing requirements in England
18 I have not studied the individual District Local Plans, but note that Colchester proposes only 20% on sites over 10 dwellings (Policy DM8), because of the likely effect on viability, implying an overall level significantly less than this. This is in spite of a SHMA assessment of 30-35% need.
37 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Figure 3.
See attachment for readable formatted table.
Figure 4. Housing output in North Essex, by District and year (2000/1 to 2015/6) and LP target
4.12 Although the level of development proposed in the Local Plan Part 1 was achieved in the two years 2006/7 and 2007/8, the average levels achieved, both before then and since the events of 2008, are significantly lower. Overall output over the 16 years was only two-thirds of the Local Plan target level, and since 2008/9 it has averaged less than half.
4.13 If national economic circumstances improve, as all would wish, the low current levels of housing output may recover. However, unless there is also a redistribution of income in favour of the age groups forming most new households, the whole housing market will eventually be compromised by the lack of new entrants. This could lead to a major market correction to reduce prices, but while improving affordability that would also be likely to reduce output of new homes19.
4.14 The average level of output achieved over the last 16 years (1,572 dpa) would represent a highly optimistic view of the level of effective demand likely over the Local Plan periods. The
19 Landowners tend to hold on to land in depressed market conditions in the expectation of later improvements, making land prices insensitive to lower final demand. Land already held by builders would effectively be devalued by lower house prices, affecting their ability to finance construction.
38 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
level of provision in the Local Plans (2,315 dpa) could only be justified by evidence of radical changes in the structure of housing provision and/or income distribution. One such change might be large scale provision of subsidised homes for rent, but that seems unlikely at the present time (see 4.9-10 above). The proportion of social rented housing over the last 16 years was only 12%, and local plan provision would be unlikely to deliver much more (see Footnote 6). Increased levels of sharing and private renting are more likely outcomes.
4.15 The implication of allocating land on the basis of the OANS is that builders will be able choose from a large surplus of land those sites that offer the most profitable development prospects for their actual target markets. These will tend to be greenfield sites in attractive surroundings, which are likely also to make disproportionate demands on services and infrastructure, competing for limited (mainly public) resources for these purposes20.
(c) Accommodating the labour market - the roles of new and existing housing
4.16 It has already been noted (3.3 above) that the variation in provision between Districts responds to the differences in District level employment forecasts. The OANS references two different sources of local employment forecasting: the East of England Economic Forecasting Model (EEFM) created by Oxford Economics, which (with further analysis of the relationship to housing needs by Edge Analytics) and there is also reference to forecasts by Experian.
4.17 The EEFM/Edge population forecasts are jobs-led at District level. The results suggest that the official household projections would lead to lower growth in numbers of workers than in numbers of jobs in Braintree and (to a lesser degree) Colchester, and the reverse in Tendring. The housing numbers in the OANS are those required to balance housing and jobs growth in Braintree and Colchester, and these are carried straight through into the Local Plans (Figure 1). However, in the case of Tendring the same procedure produces a lower figure than DCLG (597 dpa compared with 705), and this is further reduced to 550 dpa in the Local Plan. As already discussed (3.3) there is no good reason for this, though it is perhaps a minor issue compared with concerns about (a) the validity of the EEFM, discussed next, and (b) the principle of balancing growth, discussed at 4.20-23 below.
4.18 The EEFM procedure is not discussed in depth in the OANS, but a similar model by Cambridge Economics at around the same time is familiar to me from my critical review of the Oxfordshire SHMA (2014). I reviewed the Oxfordshire forecast and concluded that it was on the high side, for two main reasons:
a) The reference period was much longer than for the ONS sub-national population projections (SNPPs) - 15 years rather than 5. The trends thus reflected pre-2008 conditions to an unrealistic degree (like the DCLG household projections).
b) The economic assumptions about the future global context were also optimistic, even then, and look more so now21.
20 Policy SP4 states a wide range of infrastructure as being necessary to support the levels of development proposed (transport, education, healthcare and broadband), but offers no evidence that the resources will be available for funding this. I have not made a study of individual Local Plans, but Colchester's states that planning permission will not be given unless there is adequate provision both on and off-site. While reference is made to Community Infrastructure Levy and Obligations under s106 of the Planning Act (Policy SG8), it has not yet produced an Infrastructure Delivery Plan endorsed by public providers. In the context of the comments previously noted about ensuring viability of development (Policy DM8) it seems unlikely that the resources will become available from private sources either.
21 "in the medium term, global growth is expected to accelerate slowly from the historically low levels of 2012 and 2013, with strong growth in China, India and the oil-producing countries making a greater contribution to
39 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
4.19 Cambridge Economics carried out an economic modelling exercise for Essex County Council in 2013/4, the results of which are regarded by the OANS as not worthy of further discussion because they 'show less growth than the others' (OANS 6.16). This perhaps demonstrates the tendency for inflation to be built in to both the commissioning and the use of economic projections, or might simply be indicative of the vagaries of local economic forecasting. Whichever it is, while the growth uplift proposed for the HMA is not enormous, it does not appear particularly well-founded.
(d) Housing provision and travel demand and the wider housing market area
4.20 Turning to the question of distribution, there is no straightforward equation between new homes and more jobs. All employers - new and existing - need housing for those who work for them, but workers choose from the whole supply, of which new housing (as noted above) is only a small part. Higher paid workers will be able to choose from a wider area and a wider range of both new and existing, while lower-paid workers will depend more on the cheaper end of the existing stock or renting (private or social). An area's attraction for employers and workers will therefore depend on the mix of all these, plus the quality of local services and environment.
4.21 The market for housing in North Essex - new and existing - is the product of these factors, and the following considerations are relevant to the appropriate planning response:
a) Although most movements are local there are well-established patterns of migration and commuting further afield. In particular gross inward migration from London Boroughs is equivalent to about 1100 people pa - equivalent to 400 dpa in terms of housing demand (OANS Figs 2-2, 2.4, and 2-6). Meanwhile commuting to London runs at about 8,000/day (OANS Figs 2-9, 2-11 and 2-12), implying use of about 4% of North Essex housing stock by households with a commuter to London. These features underlie past migration trends already incorporated into the DCLG household projections (and the London component that is an explicit part of the OANS 'uplift').
b) Because builders target existing home owners (as reviewed above) additional provision is more likely to be aimed at attracting better-off commuters to London and retirees than at providing scope for an increase in the local labour force. Increasing housing provision to accommodate these demands would therefore tend to attract more migrants and commuters.
4.22 North Essex forms a small part of the much wider London commuter belt, and much of the pressure for housing arises from migration from London. The net migration in Figure 6-12 of the OAHNS varies between 500 and 1500 persons pa from 2001 to 2013. Translated into housing requirements this would imply between 200 and 600 dpa, or closely equivalent to the total amount of housing built in North Essex over the same period (see Figures 3 and above).
4.23 The common presumption is that 'sustainable development' means minimising growth in travel demand; that this in turn requires a local balance of jobs and homes, and further, that any increase in the number of local jobs should be matched by an equivalent increase in housing. However, while a local balance might mean no change in net commuting (commuting-in minus commuting-out), the amount of traffic depends on the sum of these flows (commuting-in plus commuting-out), not their difference. People commute to find the
the global economy. Over the long term, world GDP growth is expected to accelerate to 41/2% pa, with emerging Asia, the EU12 and the economies of some other developing countries leading the way. The US will be just behind, growing at 2-2¼% pa". Communication to the author from Cambridge Economics, May 2014
40 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
best match for them between the type and quality of job, and the type and quality of home they are looking for. The amount of traffic depends on how well both sets of preferences can be met locally from the incomes generated by local jobs, not on whether the number of homes in an area balances the number of jobs (let alone whether the number of new homes matches the number of new jobs).
5 Conclusion
5.1 The main findings of this analysis are:
a) The housing proposals in the North Essex Local Plans would not help meet the greatest part of the OAN - the needs of newly forming households over the plan period.
b) The level of provision of housing land is so far in excess of past or likely future effective demand for housing as to compromise the renewal of services and infrastructure in existing communities. Far from meeting the needs of newly-forming households, it is likely to undermine their housing prospects. Deep-seated economic and social processes are likely to continue to supress new household formation, exacerbating this effect.
c) The distribution of housing provision between Districts is based upon employment forecasts which are not robust. In addition, it incorporates a false premise regarding the relationship between location of new development and growth of travel demand.
d) Local employers need attractive and affordable housing for all levels of staff. This depends much more on the quality of existing places and stock than on new development.
e) The achievement of the proposed levels of development depends mainly on purchases by existing owner-occupiers. This would require an influx of migrants and commuters to above the levels already incorporated in official population and household projections.
5.2 In my opinion Part 1 of the three Local Plans fails on these grounds against the central NPPF objective of sustainable development (para 2.1 above), and the Local Plans should therefore be ruled 'unsound'.
41 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Appendix 1 Tables
See attachment for readable formatted tables
Alan Wenban-Smith, Urban & Regional Policy
This submission has been prepared on behalf of CAUSE by Alan Wenban-Smith. He is a Member of the Royal Town Planning Institute, and was a member of its Policy and Research Committee from 2005 to 2015. He is RTPI's representative on the Board of the Transport Planning Society.
He has extensive relevant professional experience in spatial planning in local government, including leading development planning, housing, transport and economic development projects at local, city, conurbation and regional levels. Between 1981 and 1996 he was responsible for planning and transport policy for Birmingham City Council, and also chaired conurbation- and region-wide collaboration on planning and transport issues in the West Midlands. In these capacities he led a number of joint projects, some later adopted at national level: the first big city Unitary Development Plan, the first regional Strategic Planning Guidance (later rolled out nationally as Regional Planning Guidance), the first conurbation-wide transport investment programme (rolled out nationally as Local Transport Plans), and the first Regional Transport Strategy (later incorporated into Regional Spatial Strategies).
As a consultant since 1996 (trading as Urban & Regional Policy) he has led several projects touching on housing issues in the South East and elsewhere, including advising CPRE on housing in SERPLAN (author of its 1999 report on 'Plan, monitor and manage'); acting as a Special Adviser to the Commons Select Committee Inquiry into the South East Growth Areas (2003/4); advising DfT on integrating transport planning with regional spatial policy (2004); conducting regional case studies on land for affordable housing for the Housing Corporation (2008), chairing a Peer Review of London's land-use transport modelling for TfL (2008/9); and reviewing the Oxfordshire Strategic Housing Market Assessment for CPRE (2014).
43 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Appendix 6
Providing for employment in North Essex
CAUSE believes that there are three reasons why the employment land allocations implied by policy SP3 (Providing for Employment) are unsound:
 Credible local employment opportunities are key to the viability and sustainability of the garden communities, and they are not created by land allocations alone;
 North Essex's job generation must be sufficient to support the growing population
 West Colchester's potential to generate employment is limited.
Given the backdrop of high out-commuting in the Housing Market Area, over-supply of employment land, outdated employment policy, transport constraints and the current market challenges to developing land outside strategic and central urban areas highlighted by the ENLAs and Aecom, CAUSE does not believe that the employment land to be allocated at West Colchester Garden Community will be developable and viable.
West Colchester Garden Community has little to offer as an independent employment hub, and will inevitably have a disproportionate number of long distance commuters, principally to London and Stansted. When comparing it to other locations significant long term rail costs should be factored in as well as the sustainability impacts of long distance commuting.
1. Credible local employment opportunities are key to the sustainability of garden settlements
The stated aim of SP3 is ' achieve a better balance between the location of jobs and housing, which will reduce the need to travel' and to strengthen and diversify local economies.
A new West Colchester Garden Community (WCGC) does not meet this aim. A focus on the commuter line not only weakens the local economy but creates pressure on a line which is already stressed and forecast by Network Rail's Anglia Route Study to be standing room only by 2043. Commuter-focused development simply encourages long distance travel. Housing should be located near to thriving jobs hubs otherwise there will be more long distance commuting - unsustainable in terms of economic cost, lifestyle and NO2 emissions.
Setting aside land for employment and hoping for jobs growth is not sufficient. Businesses will have a wide diversity of requirements, and will not necessarily favour land set aside by the public sector. Many will favour locations with a network of supporting businesses and a positive image. This is backed up by Colchester and Braintree's Employment Land Needs Assessments (ELNA), which argues that employment land must be focused around town centres and the identified strategic economic areas and employment clusters of the Borough and District where market demand is strong, rental values high and viability good. Aecom's economic strategy for North Essex also points to the need to reduce out-commuting by focusing on the local economy - the ports, creative industries in Colchester and the two main drivers of employment, the University of Essex (2,000 net jobs forecast) and Stansted (20,000 net jobs forecast). (The multiplier effects of the University and Stansted should not be ignored).
Outside these areas ELNA market analysis demonstrates that viability is questionable. West Colchester suffers the additional disadvantage of competing for labour against the higher wage economies nearer to London. It is regarded as the least sustainable location for employment growth.
There are other garden settlement locations better suited to balancing jobs and housing.
44 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
 North Colchester, which has been prematurely abandoned, is located adjacent to Severalls and the Northern Gateway and can be connected by sustainable transport including Park & Ride, already in place;
 CAUSE's Metro Plan, which has been roundly ignored, links homes to jobs in Colchester, Clacton and the University area via a frequent and regular sustainable metro train service.
 East Colchester is close to the University of Essex and its Knowledge Gateway;
 West of Braintree is close to Panfield & Skyline 120 and within easy reach of Stansted;
In addition, the ELNA, backed up by the recent Planning Inspector decision at Stane Park, reminds us that Colchester has "sufficient employment floorspace in quantitative terms to meet future needs up to 2032 under all scenarios of future growth." At a current development rate of only 1 hectare per annum, Colchester has a 65 year supply of employment land and this surplus will be greater when garden communities are taken into account.
North Essex's job generation must be sufficient to support the growing population
Colchester, Tendring and Braintree are all net exporters of labour. Colchester's self-containment rate has reduced over the last ten years, from 71% in 2001 to 63% in 2011, with a net outflow 1830 workers. Workforce job growth has historically lagged behind working-age population growth: 98% of job creation is part-time and start-ups and self-employment are at low-levels. In Braintree District, there is also low self-containment. The ELNA concludes that more residents leave the district than remain to work and growth is influenced by London, London-Cambridge Corridor, Stansted and Haven Ports.
In addition, in both Colchester Borough and Braintree District congestion is a deterrent to economic investment. Outlook for demand for employment sites using A12/A120 route will decrease as inhibited by the road, which is not suitable for HGVs. Market feedback suggests that peak hour traffic levels in and around Colchester and on the A12 has had, and continues to have, an adverse effect on its commercial property market.
The map below shows where job growth exceeds population growth. This map supports the hypothesis that the University and Stansted are generating the growth.
This is important for two reasons.
 First it supports the CAUSE view that OAN figures should be based on demographic projections, and that the 15% added to allow for job growth is unrealistic and unnecessary
45 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
 Secondly it supports the view that garden settlements should be located in Tendring and near Stansted where there are credible sources of local employment growth
2. WCGC's potential to generate employment is limited.
CAUSE has long expressed concerns about the ability of a new town at Marks Tey (West Colchester Garden Community or WCGC) to be self-contained and to generate sufficient employment to support its working age population. WCGC does not meet NPPF requirements to plan for sustainability by locating housing near to employment. There is no existing employment focus at Marks Tey and, being located at some distance from North Essex's allocated strategic economic areas and town centres, and adjacent to a main commuter line and trunk road to London, WCGC will be an exporter of labour. To build adjacent to the overcrowded GEML (acknowledged by Aecom to be a constraint) is a flawed strategy.
Aecom has been unable to propose an economic strategy to support WCGC, suggesting only that home-working, flexible office space near the station and logistics might prove attractive.
The ENLA notes that out-of-town business parks are no longer the preferred option for many businesses, and growth sectors (services and creative) favour town centre locations. The allocation of land for employment at WCGC will be insufficient to create employment for the inhabitants of a settlement of between 13,000 and 28,000 dwellings. Land promoters have focused on the construction phase of the scheme as an employment generator, not the long-term needs of the settlement.
The evidence from Colchester and Braintree's ENLAs indicates a very high chance that WCGC will export labour and be unable to support a viable employment offering for the working age population. Aecom adds, on page 126 Options and Evaluation, that there is softer B1 demand at Marks Tey compared to the Colchester northern business parks, hence a slight discount on the rent per square foot, and that some units on local business parks currently struggle to let.
(On a point of consistency of evidence, Aecom's concluding observation, four pages later, that there is good evidence of local demand directly contradicts its earlier statement. The same contradiction is evident at east Colchester, where, in the detail it is cited as unproven for employment delivery yet in the strategy the University is put forward as a beacon of employment growth)
This aerial photo of Marks Tey above shows Long Green, the proposed area for employment land in West Colchester Garden Community. It is sandwiched in a narrow wedge between the GEML, the
46 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
A12 and, possibly the new A120. Access to the A12 is difficult (with one dangerous direct access point onto the A12 northbound and a circuitous loop past The Food Company and shops near the petrol station to reach the southbound A12). The location of the new A120 junction is not yet known. Existing buildings are available for as little as £3 per square foot and at these levels building new class B employment buildings will not be viable.
47 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Appendix 7
External Rail Costs
Decisions are being made by North Essex authorities about the location of up to three garden communities. The largest, 'West Colchester Garden Community' (WCGC) or West Tey, is planned at Marks Tey, adjacent to the Great Eastern Main Line, and could contain as many as 28,000 homes. This settlement in particular will generate the highest number of rail commuters yet there has been no analysis of the impact on the GEML of this (or other garden communities).
Network Rail's Anglia Route Study forecasts a 75% increase in peak hour passengers on the GEML. Interventions to meet this demand are, as yet, un-costed and there is no schedule for delivery. Aecom states that even with the interventions outlined in the Anglia Route Study demand would not be met.
CAUSE believes that, in line with the first principles of Economics, external rail costs22 must be factored into any decision on the location of new settlements. They tend to be ignored because they are long term, difficult to quantify and responsibility lies in other parts of the public sector. In order for externalities of rail capacity improvements to be included in site modelling for WCGC, Network Rail must provide full costings for all interventions required by 2043. Until then WCGC cannot be considered.
Ideally for the Preferred Options consultation process, Network Rail costed, funded and scheduled plans for improving the GEML to meet forecast demand over the next 30-50 years should be available. In their absence it is necessary to look at the cost of other major commuter rail projects. In reality, the only solution to meet the demand on the GEML forecast by the Anglia Route Study (which many believe to be on the low side, and does not include the population of the garden communities proposed in north Essex) is a new rail line. This paper therefore calculates the capital cost per extra commuter implied by the emerging plans for Crossrail 2. This is the best indicator of the magnitude of cost that should be factored in to new commuter settlements such as WCGC.
This paper's conclusion that external rail costs are in the order of £170,000 per commuter should serve as a sharp warning against building commuter orientated settlements such as WCGC when there are better alternatives available.
How is the figure of £170,000 per commuter calculated? See attachment 2
Crossrail 2 will cost between £27 and £32 billion to build - we've taken £30bn23. It will result in up to 30 extra trains per hour into central London in each direction, each with a
22 'External rail costs' refer to the wider costs of meeting capacity demands on the Great Eastern Mainline ie. outside the immediate locality. These external costs have been largely excluded from both the AECOM feasibility study and the Sustainability Appraisal.
23 Source: Crossrail 2 website. Relevant extract shown in attachment 2.
48 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
capacity of 1500 people. From this we can calculate the cost per commuter at £170,000 - see attachment.
The assumptions behind this figure are the most conservative we can find. We have accepted the 30 trains per hour figure for the tunnelled section mentioned in the publicity material which sounds extreme: it implies that trains can consistently slow down, unload, reload and clear a station within 2 minutes. We have included standing commuters as well as seated ones, and based our figures on the class 345 trains which aim for nearly double the capacity of existing underground trains but are as yet unproven. There is no allowance for cost escalation. If any of these assumptions proves to be optimistic the figure of £170,000 will increase.
Surely the costings should take account of the benefits to non-peak passengers
We have allocated all the cost of Crossrail 2 to peak hour travellers. Other travellers may see some benefit and should arguably bear some cost. However peak hour travellers drive the demand, and they will create the bulk of the extra fare income. Train operators discount off-peak fares towards marginal cost, at which level there is very little capital cost recovery. Thus capital decision-making should be focused on peak hour users.
Surely people will commute wherever you build?
There are four good reasons why WCGC is likely to create more demand for commuting than the alternatives to the North or East of Colchester.
1. Colchester season tickets cost 6.5% more, equivalent to £607pa in pre-tax salary24.
2. Marks Tey will naturally attract those moving out of London. It already has a strong commuting tradition and to those looking at a map of rail lines and house prices it is an obvious choice. Marks Tey experienced a 94% increase in passenger numbers 1998 - 2015, according to
3. Commuters on London salaries are likely to outcompete locally employed people for housing at WCGC, and this is already reflected in house prices25. Housing built elsewhere may be more attractive to locally employed people, although if development to the East of Colchester is a Cambridge style success, this may reverse.
4. The lack of employment offering at WCGC will lead to a high proportion of residents commuting to work, London being a particular magnet.
CAUSE acknowledges that some people will commute wherever settlements are located in North Essex. But planning needs to tilt the balance in favour of the local economy wherever it sensibly can.
Surely capacity on the GEML can be upgraded for less than Crossrail 2?
There are major problems in dealing with the competing demands on the GEML, and it is difficult to see how capacity can be increased to cope at any cost. CAUSE believes that the "interventions" mentioned in the Anglia Route Study won't be sufficient to meet the demand.
24 Assuming a marginal tax rate of 40%. £5936 - £5572
25 See Aecom report volume 3 page......
49 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
AECOM clearly agree: their report says,
 "There is a clear capacity gap on the GEML by 2043 even with Network Rail's identified interventions" and,
 " is likely that without radical public transport solutions in the regions, the southern sections of the GEML will continue to be constrained." (Baseline Compendium 1.4)
Other pressures on the GEML may worsen the existing service for mid-range commuters
The competing demands on the GEML are principally:
 Freight - an increase of up to 182%26 is forecast from Harwich and Felixtowe. Although freight trains can often be scheduled to run at non-peak times, they run to a different pattern to commuter trains and sometimes break down causing major disruption. There is an urgent need for infrastructure improvements at Ely and [Haughly] Junction to free up GEML capacity between Ipswich and Stratford. It would be unwise to further overload the GEML until these are scheduled and funded which is not the case at present.
 Norwich in Ninety - high speed trains to Norwich are a high priority. They may be few in number (..... per hour) but they use up disproportionate track capacity as slower trains need to be put into sidings. Dynamic loops between Witham and Chelmsford will help commuters from Norwich, but not those from intermediate towns.
 Suburban services - the Elizabeth line (Crossrail) will significantly increase capacity for suburban commuters when it is fully open in 2019. But extra trains will be run between Shenfield and Stratford and no extra tracks are being built. Mid-range commuters may suffer.
No line improvements are currently scheduled to improve mid-range commuter services to stations such as Colchester, Kelvedon and Marks Tey, and we fear that the competing demands will worsen them.
To meet the 75% forecast increase in peak demand, significantly more radical interventions than those outlined in the Anglia Route Study March 2016 will be required:
 75% more platforms at Liverpool Street? A new station at Shoreditch was mooted in the draft Anglia Route Study but has been dropped. The Study also states that there will be fewer platforms: "Following the introduction of Crossrail services, the number of platforms at London Liverpool Street station is planned to be reduced from 18 to 17. This is to enable Platforms 16 and 17 to be lengthened to accommodate Crossrail trains; Platform 18 will be taken out of commission."
 75% more paths through the signalling system? Much reliance is placed on signalling headway reduction and untested new signalling equipment, but CAUSE's rail consultant questions whether this can deliver what it promises.
26 Source: Essex County Council response to Network Rail Strategic plan 2013. 182% increase in container traffic forecast from 2005 to 2030
50 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
 75% more spaces at the car parks? None are listed by Aecom in the infrastructure required at WCGC and the franchise prospectus lists Marks Tey as number three, after Cambridge and Ely, out of 63 stations for occupancy already.
 75% more carriages? Twelve carriage trains across the board will mop up some of the short-term demand. Double-decker trains have been discounted. There is no more scope for meeting the long-term demand through rolling stock.
In reality, nothing short of a new, second line would provide for the projected peak hour capacity increases, hence our comparison with Crossrail costings. CAUSE believes that in practice peak hour demand will be choked off either through unaffordable season tickets, or by severe over-crowding, which will cause great suffering for existing commuters. The solution is clearly to try to build for the local economy, not for London.
In order for externalities of rail capacity improvements to be included in site modelling for WCGC, Network Rail must provide full costings for all interventions required by 2043. Until then WCGC cannot be considered.
Attachments to External Rail Costs Paper:
1. Extract from Anglia Route Study showing increases in demand
2. Calculation of capital cost per extra commuter from Crossrail 2
3. Funding
4. Class 345 trains for Crossrail
5. Crossrail 2 route
Attachment 1 - Extract from Anglia Route Study showing increases in demand
51 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Attachment 2 - Calculation of capital cost per extra commuter from Crossrail 2
Attachment 3 - Funding
Attachment 4 - Class 345 trains for Crossrail
52 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Attachment 5 - Crossrail 2 route
53 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Appendix 8
Infrastructure & connectivity analysis
By Tim Pharoah, Living Transport
5th September 2016
This report concerns the efficacy of the proposed patterns of housing growth in and around Colchester, as set out in the Preferred Options consultation document, 2016, particularly in terms of transport.
Main points
The preferred options consultation is considered flawed in three respects.
 The decision process leading up to the conclusions has been inadequate;
 The evidence base on which decisions have been made is too narrow, and in some cases of poor quality;
 As a result, the chosen ("preferred") options are not the best available options in terms of either transport sustainability or deliverability.
Preferred Options - a flawed process
[See also Appendix A for more detail]
First, the process by which the preferred options were arrived at is considered to have been inadequate, with insufficient attention paid to the main development objectives set out nationally, through the NPPF, and locally for both North Essex and Colchester itself. The preferred options have been chosen in advance of any clear strategy for the provision of public transport or walking and cycling infrastructure, that will be necessary to avoid heavy reliance on private cars in the growth areas. No information on the scale, form or cost of transport infrastructure has been produced, and so the feasibility and viability of the preferred options cannot be assured. Nor has any indication been provided on the timing or phasing of transport measures in relation to the growth proposals.
The National Planning Policy Framework requirement that "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised" (para 34) has not been met. The NPPF states that "All developments that generate significant amounts of
Main points
Appendix A - Preferred Options - a flawed process
Appendix B - The Ringway Jacobs traffic modelling report (July 2016)
Appendix C - Some comments on AECOM documents
Appendix E - Other public transport issues relating to West Tey
54 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
movement should be supported by a Transport Statement or Transport Assessment." Plans and decisions should take account of whether: "improvements can be undertaken within the transport network that cost effectively limit the significant impacts of the development. Development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe." (para 32).
Neither a TS nor a TA has been produced for the growth options, and no assessment has been made of whether transport improvements can mitigate the impacts of the developments. Were assessments of the growth options to be undertaken, and were these to indicate cumulative impacts of development that are "severe", this would constitute grounds for refusal. Although "severe" is not defined, it seems likely that the West Colchester will produce severe impacts on both the rail and road system, not all of which may be possible to mitigate.
The Preferred Options consultation process as a consequence is constrained and premature.
Inadequate evidence
[See also Appendix B for critique of the traffic modelling report]
Second, the evidence regarding transport does not include adequate information about the public transport services and transport infrastructure required to support the proposed developments. No indication is provided of the impact of infrastructure requirements on development viability. Nor is any indication given about the relative performance of the alternative locations for growth in terms of the quality of place, or quality of life outcomes. The traffic modelling report is too narrowly conceived and poorly executed to throw light on these crucial aspects. The AECOM report contains potentially useful information, but also provides misleading assumptions regarding, for example, the mode split for travel in the growth areas [see also appendix D]. In any case, it is not clear whether the decision on preferred options has taken any account of the AECOM report, which is not mentioned in the consultation document.
CONCLUSION: West Colchester: the worst location for major growth
West Colchester (Marks Tey) is the location least capable of having sustainable transport outcomes, by virtue of its distance from Colchester and other established major centres, its position on the GEML attracting commuting to London, and the absence of any significant prospect for upgrading bus services to Colchester.
The option for a new "Garden Community" at West Colchester is likely to generate a significant increase in commuting by rail to London, requiring additional peak hour capacity that is neither committed nor funded, and which may in any case be difficult to deliver at reasonable cost. Dependence on London commuting also increases the need to travel.
The identified West Colchester site west of Marks Tey is further from Colchester than either the eastern or northern flanks of Colchester, and would thus result in a greater need to travel than those alternatives. There is no prospect of a significant amount of travel to Colchester
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being made by rail, and there are no proposals for rapid bus services. Unlike East and North Colchester growth options, no rapid bus service route to link with Colchester has been identified, let alone developed. Travel other than to London from West Colchester will therefore be heavily dependent on the private car. The A120 between Braintree and the A12 is under heavy traffic pressure and would require upgrading and re-rerouting to enable major development West of Marks Tey to take place without being severed by a major road. There are suggestions of relocating Marks Tey station. In total, the cost of infrastructure requirements at West Colchester could undermine development viability, but no assessment of this risk has been made.
According to the Ringway Jacobs traffic modelling report, development at West Colchester Garden Community produces higher levels of traffic delay than the east and north Colchester alternatives [see Appendix B].
It should be noted that neither Colchester nor the other districts in north Essex have policies that unambiguously aim for a reduction in the rate, let alone the number, of trips made by car. This is true of both existing urban areas and the growth areas. Existing high rates of car trips in north Essex appear to be regarded as acceptable provided they don't cause traffic congestion and delay. No emphasis is given to the adverse impact of increased traffic on the quality of life. It appears that transport sustainability is not a driver of the emerging local plans. It is therefore perhaps unsurprising that the growth options have not been assessed for their relative ability to deliver sustainable transport outcomes. This leaves the ambitious mode split targets in the AECOM report, requiring car use in the growth areas to be less than half current levels, looking fanciful.
Overall, the Preferred Options consultation provides little insight or evidence on the relative strategic merits of the different growth locations. Below, by way of example, is a broad brush assessment of the relative merits in terms of some key transport indicators, as perceived by CAUSE from the limited evidence available. A more rigorous and evidence-based assessment along these lines could and should have been undertaken for CBC in advance of the preferred options consultation.
Intuitive (sample) assessment of Colchester growth options (CAUSE)
See attachments for formatted readable table.
Appendix A
Preferred Options - a flawed process
This appendix argues that the transport component of the emerging local plans for Colchester (and Tendring and Braintree) is inadequate to enable proper assessment of different options for growth.
The Colchester objectives most relevant to transport are:
 Sustainable growth "Ensure new development is sustainable and minimises the use of scarce natural resources and addresses the causes and potential impacts of climate change, and encourages renewable energy." "Focus new development at sustainable locations to create new communities with distinctive identities whilst supporting existing communities, local businesses, and sustainable transport." "Focus development at accessible locations which support public transport, walking and cycling, and reduce the need to travel." "Secure infrastructure to support new development."
 Places
Improve streetscapes, open spaces and green links to provide attractive and accessible spaces for residents to live, work and play.
Because of the all-pervasive impact of traffic and transport activity, transport objectives should not just be about the mobility and accessibility function, but should also include quality of life indicators. Examples are impacts of traffic, parking and road infrastructure in terms of noise, air pollution, road safety and the attractiveness of streets and other public spaces. These are implied in the "Places" objectives in the Preferred Options report, though they are not explicit.
The objective of "securing infrastructure to support new development" is important in ensuring the deliverability of planned development. The extent, form, cost, feasibility and desirability of such infrastructure are critical in determining development viability and risk. As a consequence, the necessary infrastructure must be specified, at least in broad terms, before development options can be tested against the objectives.
(Reference: DCLG "Guidance Local Plans: Preparing a Local Plan"
Paragraph: 018 Reference ID: 12-018-20140306
"How can the local planning authority show that a Local Plan is capable of being delivered including provision for infrastructure?")
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The information provided is insufficient for a proper assessment to be made of the merits or otherwise of the various development options. It follows that the Preferred Options have been selected by CBC without full regard to the relative merits of the wider range of development options.
The options have been selected:
 Without identifying the type, form, extent, feasibility, or desirability of infrastructure necessary to ensure the development will have high quality outcomes in terms of quality of life;
 Without specifying whether or in what ways the infrastructure requirement would differ as between the different growth options;
 Without identifying the costs of such transport (or other) infrastructure;
 Without identifying sources of funding for the infrastructure, and how this would impact on development viability;
 Despite the traffic impact evidence from the Jacobs modelling report, which suggests the West Colchester option is the worst performing option;
 Without any estimate being made of the transport modal split in new developments, and hence of the degree of transport sustainability likely to be attained;
 Without any target mode split for all travel generated by the growth option alternatives, or any assessment of the relative ability to meet such targets.
Even taking into account the very limited indicators in the Jacobs modelling work, West Colchester was selected despite the probability of worse traffic performance than North Colchester, which has been rejected. (See Appendix B)
It is noted that CBC proposes monitoring travel and transport outcomes of the growth strategy only in terms of the journey to work via the National Census (see page 211 on monitoring) and traffic levels on "key routes". This is inadequate to assess the performance of the growth options in terms of the factors that influence quality of life, which involve travel for all journey purposes, not just work, and the impact of traffic levels on streets where people live as well as "key" routes. Moreover, the Census is undertaken only ever 10 years, and only one set of results is likely to be available during the life of the Local Plan.
The Colchester options document para 2.60 says in relation to the A120 "The scale of new development envisaged will also need to deliver public transport improvements, including improved rail infrastructure and potential for rapid transit services into Colchester." The word "potential" confirms that no detailed plan or commitment is being offered at this stage. It is therefore not possible to judge whether transport sustainability - as measured by high proportions of travel undertaken by walk, cycle and public transport - can be delivered. Moreover, because of the lack of information about the types of transport to be provided, it is not possible to assess which of the development options are "more sustainable" or "more deliverable" than others. All of the options seem to rely on a generic assumption that walk, cycle and public transport facilities can be provided with the new developments, and that people will choose to use these modes in each case. In effect, therefore, transport sustainability criteria cannot be brought to bear on the choice between development
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alternatives, because there is insufficient information to enable any distinction to be made between them.
Appendix B
The Ringway Jacobs traffic modelling report (July 2016)
The modelling undertaken was inadequate in many respects, as set out below. Setting aside the limitations of the modelling exercise, the outputs indicate that scenario 2a (West Colchester only) despite having fewer dwellings, produces a worse outcome in traffic terms than scenario 3a (East and North Colchester), and that is despite the extra car trips attracted by the A133-A120 link road included in the east and north Colchester scenarios.
The report describes an exercise that is inadequate in the following key respects:
1. The modelling report does not answer the question of which growth scenario is most likely to enable a sustainable transport solution. The SATURN is unsuitable for informing strategic planning questions;
2. The model confines itself to delays to general traffic, congestion and network traffic speeds. The latter is given only for the entire CBC road network. No indices are provided that would assist in assessing the quality of place and quality of life outcomes on the road network (such as bus service journey speed and reliability, pedestrian and cyclist safety and convenience, air quality, noise, landscape and townscape). The model therefore is of limited use in assessing the growth locations against the national (NPPF) and local objectives.
3. The model assumes that people's first choice for trips will be the car (trips are not transferred to public transport in the model until the road network becomes unacceptably congested). This runs contrary to national and local policy, which is to ensure that development and transport policies prioritise and promote public transport and active travel modes. The modelling approach reflects the out-dated and much criticised "predict and provide" approach to transport planning.
4. The modelling exercise appears to bear no relation to the AECOM North Essex Garden Communities Concept Feasibility Study.
5. The model transfers trips away from car to public transport in order to produce a workable result in terms of traffic congestion. However, nothing is said about the ability of public transport services to accept such increases in passengers, or what improvements might be needed to enable them to do so.
6. The impact on traffic conditions of the allocated housing (12,263 dwellings) will far outweigh the impact of the tested scenarios, since these include 2,500-5,000 additional dwellings. Therefore, by excluding the impact from allocated housing from the tests, and in presenting (page 12) fairly modest reductions in average traffic speeds (2-3 kmph), the report is giving a falsely optimistic impression of the traffic impact of development up to 2032 compared to today.
7. The scenarios tested have differing assumptions about the number of new dwellings to be built, limiting the direct comparisons that can be made (despite the purpose stated in paragraph 1.2).
8. The modelled area is mostly confined to the CBC area, when the traffic impacts of the proposed new developments will extend well beyond the Borough boundary, especially west of Marks Tey and east of Colchester;
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9. The "reference case" is hypothetical since it includes the currently committed or allocated housing growth. It therefore is not possible to compare the model outputs (for example in terms of traffic speeds, and indicators of congestion and delays) with the present day;
The report was not made available to the public until July 2016. It would appear from the AECOM Baseline report (page 21), however, that the work was complete in January 2016.
Critique in more detail
Limited outputs
It is claimed in para 1.2 that "The modelling was commissioned to give a strategic context for potential spatial options". The outputs of the model in fact give a very limited indication of the impact of different growth options, and do not justify the term "strategic context". The traffic speed and congestion outputs are only "strategic" in the sense that they apply to the entire road network. There is no indication of other important strategic aspects that should in form the choice of growth locations, such as the environmental quality of roads and streets, the operating environment for and the degree of priority afforded to bus services, conditions for walking and cycling, and the relative journey times by different modes of travel.
Deterioration in traffic and environmental quality ignored
The model identifies only links and junctions with a capacity problem (para 1.2). No account is taken of the fact that the additional traffic would not only overload certain links and junctions, but would result in a general deterioration in the conditions experienced on many other parts of the network. Busier roads in general make life more unpleasant, and can have a direct negative impact on the use of the sustainable modes, especially walking and cycling.
By excluding the traffic impact of allocated housing, the report gives an impression of negative impacts that are much more modest. The deterioration in traffic conditions that would be experienced in 2032 compared to todays conditions, would be very much worse than those presented in the report. The number of dwellings (12,263) on allocated land excluded from the test results far outweighs the 2,500-5,000 dwellings included in the three tested scenarios for 2032.
Non-work travel ignored
Only the peak hours were modelled (para 1.2). The journey to work accounts roughly for only a fifth of all trips, and so deterioration in conditions for the other trip purposes and at off-peak times are ignored. In fact, with suppression of peak hour car trips due to limited network capacity, proportionately the degree of deterioration could be greater at off peak times than during the peak hours.
Confusing dwelling numbers
There is a discrepancy in the housing numbers between the bulleted scenario descriptions on page 5, and Table 1. There is also a discrepancy within para 2.1, with text referring to "an additional" 9,000 and 20,000 dwellings respectively for east and west Colchester, but the bulleted descriptions referring to these figures as the "total" number of dwellings. Also, on
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page 36, it is stated that Scenario 2a includes "up to 1,600 dwellings in East Colchester (which come forward but not as a Garden Community, and without a link road)." This is not mentioned in the scenario descriptions in 2.1.
Inconsistent trip rates unexplained
The number of "additional" trips generated by each of the scenarios is described in para 4.1, but these imply different trip rates for the different scenarios. For example, the same number of additional trips are given for scenarios 1a, 2a and 3a, despite the fact that scenario 2a has half the number of new dwellings of the other two scenarios. Presumably either the number of dwellings in 2a or the stated number of additional trips is a reporting error. Moreover, the trip rates for the additional dwellings in the 2017 scenarios (1b and 3b) are lower than for the 2032 scenarios, but the reason for this difference is not explained.
Results do not support the preferred options
In section 4.2.1, the summarised outputs indicate that scenario 2a (West Colchester only) - despite having fewer dwellings - produces a worse outcome in traffic terms than scenario 3a (East and North Colchester). "It indicates that highway trips from West Colchester result in a greater level of delay compared to the other scenarios." It is not stated whether this is due to longer average trip distances from West Colchester compared to north and east Colchester.
Lack of integration in planning approach
The modelling exercise appears to bear no relation to the AECOM North Essex Garden Communities Concept Feasibility Study. The AECOM report (Vol 3) puts forward extremely ambitious mode split targets for the Garden Communities, but the traffic modelling report provides no information that would throw light on the feasibility of these targets, or how they might be achieved. The AECOM Garden Communities report takes a normative stance, assuming that development and infrastructure plans should lead to more sustainable transport outcomes. The traffic modelling report by contrast assumes a "business as usual" future in which car use is limited only to the extent necessary to keep congestion to acceptable levels. It is therefore more aligned to the discredited 20th century "predict and provide" approach to transport and traffic planning.
The Colchester modelling report is mostly limited to the CBC area. A sub-regional modelling approach could have been more useful in assessing the impacts of North Essex growth as a whole. The AECOM Baseline report (page 21) refers to Jacobs having provided modelling support to Tendring as well to Colchester, which might have provided more insight on the east Colchester growth option. However, The Tendring modelling report does not appear to be available on their local plan portal website.
False or missing assumptions
There are no assumptions given on transport investment in the area (road, public transport, walking, cycling, parking), and the affects that such investment would have on road network capacity. The exception is the proposed A133-A120 link road east of Colchester. The model outputs otherwise assume that there would be no investment in transport during the period(s) being modelled, either to mitigate the modelled increase in congestion, or to bring about a more desirable mode split outcome. This is unrealistic, and also reflects a very limited view of capacity as motor vehicle capacity on the road network, rather than a more
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integrated view in terms of people capacity of all the transport networks, and is not helpful in devising a sustainable transport strategy.
Impact of mode shift ignored
The variable demand model identifies road links with excess traffic volume over capacity, and "transfers" excess trips to other modes, other destinations, or from peak to off-peak. The report gives no information on what transfers would be likely, or what the impact of these transfers would be on, for example the public transport network. In particular, there is no information provided on the relative ease or costs of accommodating the modelled transfers, and hence no possibility of comparing these costs as between the different spatial options.
Appendix C
Some comments on AECOM documents
(North Essex Garden Communities Concept Feasibility Study, Vols 1, 2 and 3, 2016)
Mode split
A fundamental indicator of transport sustainability is the mode split of all trips made by residents. Unfortunately, AECOM was not able to supply the current mode split in Colchester (because the data do not exist). The AECOM options report gives expected peak hour (but not total) trips generated for each growth option, but gives a standard mode split target for all of the sites:
AECOM Target Mode Split for Growth Areas
Car 30%
Public transport 30%
Walk/cycle 40%
For comparison, the mode split for journeys to work in the constituent authorities (2011 Census) are:
Car 67%
Public transport 15 %
Walk/cycle 18%
Car 75%
Public transport 12%
Walk/cycle 13%
Car 75%
Public transport 9%
Walk/cycle 16%
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Looking at these comparative data, it is clear that the expectations by AECOM for the outcome mode split in the garden community options are fairly heroic. They expect car use to be less than half that achieved in existing settlements (30% as opposed to 63-75%). Concomitantly they expect public transport use and walking/cycling to be more than double existing norms.
Unrealistic transport and development expectations
I am surprised that in adapting/modifying the TCPA transport principle for garden cities, the phrase "most attractive" has been retained by AECOM: "walking, cycling and public transport designed to be the most attractive forms of local transport" (AECOM Vol 3 options report pages 11 and 12). The phrase also appears in the North Essex SA (objective 4, page 17). If this policy objective were to be carried through to the letter, then logically cars would not be used at all for local transport. Why would anyone choose anything other than the most attractive forms of transport? We must assume, therefore, that the term "most attractive" is not to be taken literally, but to mean something like "more attractive than usual".
However, it is noted that none of the three Districts has included this principle in the consultation documents.
The Options and Evaluation report (Vol 3) explores possible ways of providing high quality public transport at each of the potential growth locations. These are mainly based on the provision of segregated bus ways within the sites themselves. However, the report is very sketchy in terms of how such busways would plug into the existing road network in Colchester.
Further comparison can be made looking at the method of travel used (mode split) for all trip purposes for different location types in England and Wales, as given by the National Travel Survey (2013-14).
The mode split for "rural town and fringe" locations is:
Car 74%
Public transport 5.5%
Walk/cycle 21%
The mode split for all trips in "Urban city and town" locations in England and Wales (2013-14) is:
Car 63%
Public transport 7%
Walk/cycle 23%
The mode split for the East of England is:
Car 69%
Public Transport 7%
Walk/cycle 21%
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The suggestion of a regional tram-train network does not appear to have been tested in terms of feasibility. It relies heavily on the use of the GEML, where any capacity improvements are likely to be fully taken up in accommodating levels of demand already expected.
Flawed Transit Oriented Development (TOD) concept
The Options and Evaluation report (Vol 3) claims to promote TOD, but with 800 (10 min walk) catchments this is not feasible. A 10 min walk is unrealistic as a catchment for bus-based public transport, which would apply to most of the development at East, North and West Colchester. 800m is acceptable for rail, however, and so would include part of the area for development around Marks Tey station.
The structuring of development around Bus Rapid Transit (BRT) is inconsistent between the sites:
 East of Colchester, the catchments can be 400m
 North of Colchester also 400m
 West Tey (West Colchester) - up to 800m
 West of Braintree - up to 800m
There are no proposals that would boost non-car use other than infrastructure within and adjacent to the sites. Such infrastructure is likely to be expensive and difficult to deliver in advance. Nothing is said about other measures that could help to achieve the desired mode split outcome, such as limiting and pricing parking in the nearby centres, or prioritising public transport on the road system, or limiting the supply of road space for general traffic, or reallocating road space for walking and cycling. Crucially, nothing is said about restricting car-based developments off-site, although mode outcomes will be heavily influenced by this. To the contrary, the main off-site proposals put forward are road enlargements, which will generally enable and promote car use, and encourage proposals for car-based developments.
[Note: Car-based developments are defined here as developments that depend for their viability on high levels of car access, for example large supermarkets, leisure facilities or other attractors drawing on large "drive time" catchments and with large car parks. These are car-based whether or not they are served by public transport.]
Planning with 800 m public transport catchments is totally inappropriate. Accepted standard max in 400m. (AECOM charter pdf page 10). Apart from this, there is no emphasis on PT orientation or structuring of development. The example of "well structured" development illustrated is in fact car-based (p18). Diagram on p9 shows 800m "walking zones", but these bear no relation to a transit route(s). Also the 800m could refer to the diameter, not the radius, which may have translated into an error in saying planning within 800m catchments. Either way, it all displays a lack of understanding of TOD.
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Garden Communities Charter (AECOM June 2016)
Scale - the authorities and AECOM see scale as important to deliver range of homes and employment and facilities (see AECOM charter pdf page 4). But scale can also work against deliverability, because of having to coordinate everything in one place, and being dependent on the early delivery of infrastructure, with potentially heavy up-front costs.
Self containment - The suggestion of self-containment in the garden communities seems very ambitious. Comparable developments such as in Bicester (Oxfordshire) and Kings Hill (Kent) have found it very difficult to achieve a reasonable degree of self-containment. In Kings Hill, for example, only 15% of the 3,000 or so homes has someone working at the adjacent business park (source: Kings Hill Brochure).
Appendix D
Other public transport and infrastructure issues relating to West Colchester Garden Community
The site(s) identified west of Marks Tey as an option for major growth is unsuitable, and also less suitable than the CAUSE Metro option, for the following reasons:
 It requires heavy investment in transport infrastructure, and much of it in advance of major growth taking place. This includes: - Relocation of Marks Tey railway station - Consequential building of a new railway link to the Sudbury branch - Consequential widening and rebuilding of the A120 railway overbridge - New road link(s) between the "triangle" site and the A12
 It will rely heavily on London (i.e. long distance) commuting, and as principally a commuter settlement it will struggle to produce community cohesion;
 To the extent that it forms part of an economic axis (as presented by AECOM) between Stansted and Harwich, this axis is entirely road based, and so high levels of car traffic generation can be expected, compared to new communities that are based on linkages to town centres (such as Colchester and Clacton) which provide a degree of traffic limitation.
Cycle-ways and walk ways
West Colchester is considerably further from Colchester town centre (8-13 kilometres crow-fly distance) and it would be considered too far for regular cycling by most people. Also, there is almost no cycle provision on the London Road (B1408) corridor, and re-configuring the 5 mile route to accommodate safe cycling as well as BRT would be expensive and challenging, if not impossible, as it is built-up for most of its length.
Mass rapid transit
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It may be concluded that for linkages between new developments and Colchester town centre, the main option for sustainable travel would be public transport:
North Colchester BRT (already planned in part)
East of Colchester BRT (already planned in part)
West of Marks Tey BRT (plus limited rail* hourly service)
"Colchester Metro" (CAUSE) Rail* (infrastructure already exists)
* Rail is considered to be to Colchester Town. Colchester North station requires bus interchange to reach the town centre, and thus would be unlikely to compete with direct BRT in terms of time, convenience and cost.
In addition, as was concluded by Jonathan Tyler earlier, the use of parts of the GEML for frequent (10 minute interval) local journeys between Marks Tey and Colchester is not realistic without major and very expensive upgrades. Marks Tey (either existing or relocated) is therefore mostly about providing for peak hour commuting towards London. Development around Marks Tey is therefore likely to be characterised more as a commuter suburb of London than as an integrated component of a North Essex sub regional economic area. Local public transport to link so-called West Tey to Braintree and Colchester centres will for the most part be BRT, with rail performing a secondary role to Colchester.
AECOM have put forward aspirational rail and tram-train options. There are numerous practical, financial and operational difficulties to overcome before these can be considered realistic. In the absence of the an Infrastructure Delivery Plan it is not possible to comment.
In the absence of an Infrastructure Delivery Plan (IDP) it is impossible to test the viability of the Park & Ride proposal.
Marks Tey station relocation
To improve the accessibility to rail services from the proposed development, it has been suggested by AECOM (Vol 3, p 58) to move the station to a more central area of the development.
Moving the station would involve:
 Building a new single track line from the existing Sudbury branch line, via a new London-facing chord, to a third platform at the new station;
 Building the new station itself, with interchange facilities (bus, taxi, car park), and pedestrian and cycle paths, and cycle parking;
 To accommodate this new line, rebuilding and widening the bridge carrying the A120 over the railway would be required. (This would be required anyway if the A120 were to be widened to dual carriageway on its current alignment, although not if the enlarged A120 were to join the A12 further west);
 Land acquisition and possible demolition of 6-12 existing dwellings that sit adjacent to the railway at this location;
 Closure of the existing station, and probable removal of the existing Colchester-facing chord (releasing land for other purposes);
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 Building new access roads and paths to the station, involving a road either through the development to the north of the station to the existing A120, or from the A12 to the south of the station, or more likely both, and involving a new road bridge over the railway.
 A "land bridge" has been suggested by AECOM to link development north of the railway with development south of the A12. Such a link would seem to be essential if a cohesive development were to be sought both north of the railway and south of the A12, whether or not a new relocated station is built.
 The cost of the station and land bridge alone are estimated by AECOM to cost £35m.
 Operationally, there may be problems arising from the relocated station being only around 3.5 kms from Kelvedon station.
 AECOM have suggested that the existing station could be retained as the terminus for the Sudbury branch. This would leave the Sudbury branch with no interchange with the GEML, thus cutting it off from the majority of its passengers. (There is no possibility of trains stopping at both a new and the existing Marks Tey stations.)
Large transport infrastructure requirement
The west of Marks Tey development option carries with it a large transport infrastructure requirement, and hence a high burden of costs to be included in the overall viability calculation. The items can be summarised as follows:
Acknowledged by the development consortium
 An upgrade for Marks Tey station
 Upgrade of the A120 to dual carriageway (on current alignment)
Included in AECOM report
 Upgrade to strategic road junctions in vicinity of Marks Tey station
 Segregated busway (BRT) with "green" pedestrian and cycle route
 Upgrade of pedestrian bridge over the A12 for cycles as well
 "Land bridge" to overcome severance of GEML and A12
 Possible tram-train conversion of Sudbury branch, (with electrification, or use of dual motive power system) and its extension through the development west of Marks Tey.
 Relocated Marks Tey station to within the new development (with possible tram train extension to serve it).
While the total costs may not be accurately assessed, it is clear that the infrastructure burden to create a large scale successful and sustainable development would be considerable. More importantly, growth elsewhere (East or north of Colchester, or Colchester Metro) is likely to require infrastructure support that is much less expensive and easier to deliver than that set out for west of Marks Tey.
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Appendix 9
Healthcare planning to support the proposed garden communities
September 2016
North Essex Authorities: Strategic Part 1 for Local Plans sets out proposals for 2,315 new dwellings per annum across Braintree, Colchester and Tendring, with three garden cities in the pipeline, to commence in the Plan period. Beyond the Plan period the growth of the garden cities will see thousands more homes, with West Colchester Garden Community options under investigation containing up to 28,000 additional dwellings.
A review of Part 1 and supporting documents gives cause for concern about the lack of strategic planning for healthcare provision given the anticipated scale of housing growth and therefore extra demand on health services.
Inadequacy of Local Plan with regards to Healthcare provision
The lack of high level healthcare planning to support the proposed garden communities is striking:
 Mark Prentice, Head of External Relations, Colchester Hospital University NHS Foundation Trust has been unable to provide any planning information, other than to state that the North East Essex CCG will take the lead in assessing the health needs of the population. No provider based planning appears to have been initiated. Without it, the additional capacity required will not be met at Colchester hospital.
 James Archard, Deputy Director of Transformation & Strategy, NHS North East Essex Clinical Commissioning Group, has confirmed that there is no internal documentation available (as at August 2016) relating to ANY analysis of the impact on healthcare provision of new garden communities. This is despite a statement in Colchester's Preferred Options (4.58) stating that the Infrastructure Delivery Plan will identify the needs of the North East Essex Clinical Commissioning Group;
 Whilst there are general references to the need for "necessary infrastructure" and community services in the Local Plan Strategic Infrastructure Policy (p74 Colchester Preferred Options) there is no specific reference to healthcare, let alone to the need for strategic planning for hospital beds etc;
 In SP4 (Infrastructure & Connectivity), SP5 (Place-shaping principles) and SP6 (Spatial strategy) there is one mention of healthcare, however, it refers only to provision within a development: "Ensure that essential healthcare infrastructure is provided as part of new developments of appropriate scale in the form of expanded new doctors' and dentists' surgeries.";
 AECOM CONCEPT FEASIBILITY STUDY deals only briefly with the issue of healthcare:
o "There is an overall deficit in provision of GPs across the wider 5km buffer. This is a theoretical assessment and the actual pressures are potentially more pressing. There is only one facility with a strong GP to patient ratio."
o "Colchester healthcare infrastructure projects in the pipeline have 'been abandoned, so at present there are no identified healthcare needs'"
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It appears that healthcare provision is considered relevant only on a development-by-development basis at planning application stage. Whilst this may be appropriate for primary healthcare, the sheer scale of development proposed by this Local Plan requires a more strategic approach to healthcare provision for the area since the lead time for planning and delivering investment in expansion of acute services will be several years if not decades. AECOM has estimated a requirement of up to 164 additional hospital beds (Concept Feasibility Study - Vol 3), but no business plan to provide these seems to be available from the NHS Local Health Economy.
Part 1 requires a focus on healthcare implications for the area of beds needed, A&E and other acute services, together with implications for the non-acute services including mental health and community services.
The highest level NHS planning document is currently the "NHS Five Year Forward View" published in October 2014 by Department of Health. This includes:
"New town developments and the refurbishment of some urban areas offer the opportunity to design modern services from scratch, with fewer legacy constraints - integrating not only health and social care, but also other public services such as welfare, education and affordable housing."
In July 2015, NHS sought registration of interest in the "healthy new towns" programme with a closing date of September 2015. This programme was part of putting the "Forward View" into action and ten demonstrator sites were established, including Ebbsfleet Garden City, Kent (up to 15,000 new homes).
Unfortunately, the garden community's development was not included in the programme and the local health economy seems to have missed the opportunity.
Current acute healthcare situation in North Essex
 Colchester Hospital University NHS Foundation Trust has two main sites: Colchester General Hospital and Essex County Hospital. The Trust provides healthcare services to around 370,000 people from Colchester and the surrounding area of north east Essex and south Suffolk. It has around 619 beds.
 Overall, the Trust is rated "Inadequate" by CQC, despite being in "special measures" for over two years.
 Statistics for June 2016 (latest available at time of writing) show that Colchester failed its A&E target (86.2% seen within 4 hours against a target of 95%). This is of particular relevance when planning for local population growth because A&E is a local service which cannot be outsourced by the CCG. The problem of overstretched A&E services will clearly get worse as the population increases and if no mitigating actions are taken by NHS acute providers.
 The Trust is in deficit of £22.3 million and recently applied for cash support from Department of Health. There is therefore little prospect of the necessary self-generated capital funds to provide required additional capacity.
69 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
 Trust income last year rose only £0.9 million against upward operating costs of £16.5 million.
 Borrowing for Capital investment is restricted by Monitor setting a Prudential Borrowing Limit. As a Foundation Trust, borrowing (including working capital) is capped at around 40% of the asset base and then only if its Monitor rating is at its highest level (currently at its lowest level). A PFI option for centralising services on Colchester hospital site with 70 additional beds has been explored in recent years but was abandoned at a late stage in the bidding process due to the scheme not meeting economic tests.
 A partnership agreement with Ipswich Hospital NHS Trust has been established because of inadequate improvement during the "special measures" phase. The Board of Ipswich Hospital NHS Trust is now effectively overseeing Colchester Hospital University NHS Foundation Trust. Capital investment decisions will be led by Ipswich, and services are likely to be reconfigured at the two Trusts to save money and improve services. This raises a question about the additional traffic on the A12 between sites and longer journeys for patients, particularly given the ambitious North Essex growth plans.
 Whilst acute services form the lion's share of commissioners' budget and will feel the greatest impact of population growth, there will also be demands on non-acute services including mental health and community services.
Assumptions on acute healthcare in the AECOM report
AECOM's feasibility study makes the same assumption about acute healthcare provision for all locations. It assumes 1 new acute bed for every 267 dwellings (Source: volume 3 project lists). It has nothing about where or how the beds will be provided. On this basis another 164 acute beds will be needed during the 15 year plan period, rising to 260 if all three garden settlements are completed (using option 1s). These figures take no account of any current shortfall in acute service provision.
The conclusions from AECOM's crude figures are alarming. A significant increase in capacity is required, implying new buildings on new hospital sites. 164 extra beds is a very significant number, equivalent to 26% of the beds currently available to Colchester General. It is
70 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
recognised that they are crude estimates prepared for a feasibility study, but disappointing that no better forecasts or plans appear to be available.
There appear to be no plans in place to meet the majority of the additional healthcare demands that would result from the "North Essex Garden Communities" project proceeding.
Furthermore, if plans were formulated that required capital investment; the Local Health Economy does not seem ideally placed to either fund this themselves given the current deficit, or borrow given Monitor's prudential borrowing limit at Colchester.
In these circumstances it is hard to regard the plans for North Essex Garden Communities as sustainable.
Paul Aitchison
Short Form CV "Paul Aitchison has held senior positions within the private sector equity investment and service provider arenas across public sector areas, including healthcare. He was Director PFI for Sodexho Ltd (1998-2003) and represented Sodexho in the Business Services Association (chairing the Public Sector Market Group). He also gave oral evidence on PFI at HM Treasury Select Committee. He has provided PFI-related facilities management advice to the Department of Health (PFU lead adviser on FM issues (2003-2007)), and served as the Commercial Director on the Mid Essex Hospital Services NHS Trust Board procuring services under a PFI scheme (2007-2012). Paul also currently acts as a Care Quality Commission Specialist Advisor in healthcare facilities management and estates matters"
71 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Appendix 10
CAUSE analysis of Aecom 'Concept Feasibility Study': Suitability for deciding the location of new settlements
AECOM's four-volume feasibility study contains useful data but does little to inform the choice of location, concluding vaguely that four locations are "capable of becoming viable". In particular:
1. It largely ignores the key differentiators of location - high value jobs and infrastructure constraints
2. It ignores CAUSE's Metro Plan
3. There is no viability appraisal (just assumptions), and no infrastructure plan
4. It was prepared before the transport modelling was done, and makes no reference to it
5. Differences between infrastructure cost per dwelling calculated by AECOM are spurious and should be ignored because:
 They don't compare like with like. The cost of external road upgrades for West Tey are excluded, but included for East of Colchester.
 They are based on round sum estimates without paying attention to the characteristics of each location
 They ignore all external infrastructure, in particular the cost of providing increased GEML capacity for extra commuting from Marks Tey27.
We understand that DCLG gave the Boroughs £640,000 to develop a joint strategy. The AECOM report was a missed opportunity to take a genuine strategic overview.
CAUSE once again requests a meeting with AECOM to avoid wasted time at the upcoming planning enquiry.
Infrastructure cost per dwelling
AECOM's report indicates that infrastructure cost per dwelling is significantly lower at West Colchester. This implies West Colchester is more viable than other locations. CAUSE asserts that no such conclusion can be drawn from the figures and that AECOM are right to be cautious on them.
27 The report points to capacity constraints on the GEML but does nothing to quantify them.
72 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Source - AECOM volume 3 page 123
CAUSE has analysed the infrastructure cost per dwelling for the 10 options in volume 3 of the AECOM report. The red dots on the graph below show the infrastructure cost per dwelling excluding road and rail cost. They are very similar in all locations, because most inputs are calculated on a per dwelling basis: for example the report assumes a cost of £7500 per dwelling for education without defining how many schools will be built or where.
The gentle downward slope hints at scale economies from building larger settlements: if there were genuine scale economies Great Tey would be favoured because it is the largest of the settlements. However on closer examination the scale economies turn out to be spurious. The differences arise
73 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
because £14m of round sum fixed costs have been inserted for all settlements irrespective of size or location:
Country Park Landscaping
This assumes that the same sized country park will serve settlements from 6661 dwellings to 27841 dwellings
Potable water costs - 5km trunk mains on primary routes and distribution mains from Ardleigh Reservoir for water supply
Assumes the same water deliver cost irrespective of settlement size or location. No supporting engineering analysis. North and East Colchester are located near Ardleigh Reservoir and might be expected to have significantly lower costs
Any suggestion that there are scale economies from larger settlements is unsupported in the AECOM report, and should be ignored.
The remainder of the cost differences arise due to different road and rail assumptions, and the conclusions here are equally flawed. The main difference arises because the EC models all assume expenditure on the A120 / A133 link road and associated junctions, whereas all external roads are ignored in WC perhaps because the improvements are all to the A120/A12 trunk roads. CAUSE believes that the sites should be appraised including like with like, and that arbitrary road classifications should not determine the location of settlements.
74 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Appendix 11
Viability appraisal assumptions
The viability appraisal behind the AECOM report appears to have been prepared by chartered surveyors Cushman & Wakefield using the Atlas appraisal methodology. CAUSE has requested a copy of the appraisal but this has been refused. Our only indicators of viability are:
1. The lack of any conclusion from Cushman & Wakefield (page 122 of volume 3)
2. The cautious observations (not conclusions) by AECOM that all four settlements are capable of becoming viable
3. The cost and income assumptions stated on pages 122 to 133 of volume 3 of the AECOM report
Cost assumptions
Many of the assumptions are confusing and mean little without seeing the appraisal. However, they appear to be significantly more optimistic than the assumptions normally used by major house-builders. For example:
Land costs: the viability appraisal assumes that land can be bought for £100,000 per acre. Although this exceeds agricultural value by a multiple of 10x, it is below accepted development land values which are judged to be £242,000 per acre for purposes of the Colchester's proposed CIL calculation.
It may well be that 'new' or 'virgin' land can be acquired at this price, but the land at West Tey in particular has been optioned and expectations will be high. Landowners can wait indefinitely, and the threat of CPO on such a large scale is hollow. Even if a CPO was successful, landowners will be able to prove high "pre-scheme" values on land that has been optioned and discussed for years.
Land acquisition costs: page 123 states that no SDLT or other land acquisition costs have been allowed for. Normally these would be 6-7%.
Housing construction costs of £99psf contingency are unrealistically low. Including external works, garages and driveways £125psf would be realistic. CAUSE has knowledge of a development where the equivalent figure is £166psf.
There is no allowance for levelling, piling or treating land contamination. There is nothing for major utility diversions. This is highly imprudent, even for greenfield land. There are always problems to deal with, and no commercial developer would ignore these costs. The 10% contingency gives partial comfort, because its higher than the 5% norm.
External infrastructure costs are ignored completely. No upgrades for reservoirs for the water supply or sewerage treatment works for foul water discharge are included. Nothing for external road or rail costs which should be the key differentiators between locations.
75 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Finance costs: page 123 quotes a discount rate of 2.5%. It is not clear what this refers to: is it envisaged that the land will be bought by a public body? The Local Plan has nothing about this.
Page 124 quotes a finance rate of 6.5% which is more realistic, but still below the 7.5% used by our big four house-builder. House-builders need to charge developments at their weighted average cost of capital, not just their cost of borrowing.
Developer profit is taken at 17.5% of GDV which is on the low side and only realistic if a development corporation has done the master planning and removed most of the public sector risk (planning permission, master planning, infrastructure provision). 20% is normal, to cover developer office and overhead costs, and the cost of risk taking. CAUSE knows of a major big four house-builder which won't shift below 23%.
It is clearly too early to draw conclusions on either viability or location: and there is an element of wishful thinking in the studies done so far. Some of the assumptions behind the viability study appear to be optimistic to the point of recklessness. The extreme caution shown by both AECOM and C&W in their conclusions suggests that there are problems.
Choosing the location of settlements and incorporating them in three Local Plans is a serious long term decision, and it is quite inappropriate to make it until realistic appraisals are publicly available.
76 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
Appendix 12
Community engagement - North Essex garden communities
The NPPF requires 'meaningful' engagement and consultation, and the DCLG garden communities prospectus makes it very clear that community engagement is paramount. Paragraphs 17-18 and 55-56 state that proposals should set how the local community is being, or will be, engaged at an early stage, and strategies for community involvement to help ensure local support.
The level of community engagement on the important strategic issue of where to locate growth on the scale proposed by the North Essex authorities is inadequate and has not been meaningful. There is no local support for West Colchester Garden Community and there has been no attempt to engage with local people.
CAUSE has made strenuous attempts to influence debate in a positive way by organising a half day conference in November 2015, attended by over 100 people, to discuss what 'good development' looks like. Internationally-recognised urban designer, and Wolfson Economics Prize-winner, Dr Nicholas Falk, was our key-note speaker. He is at the forefront of thinking on garden communities, having beaten 260 firms in their attempts to win the Wolfson prize.
CAUSE's team of urban designers, transport consultants and planning consultants prepared a vision for North Essex based around principles of transit-oriented development, which was unveiled at the conference. This has been dismissed by the North Essex local authorities whilst simultaneously being recognised in urban design circles outside Essex as truly visionary. All information available at .
The consultations are not fit for purpose for settlements of 2,500 dwellings, let alone the options up to 28,000 dwellings. The process to date does not meet with garden city principles on community participation, nor the local authorities' own new garden communities charter. In the article from The Planner, below, Colchester's Ian Vipond expressed frustration about the difficulties of engaging with local communities yet CAUSE has made three requests to meet with Mr Vipond in order to gain a better understanding of the North Essex authorities' strategy, all of which were turned down.
Engagement by CAUSE with the community
CAUSE, a group run by volunteers, has made rigorous efforts to fill the void left by our local authorities. To stimulate engagement with local people and to raise the level of debate, CAUSE activities have included:
 January 2015 Flyer drop to 2000 houses to advertise Issues & Options consultation;
 Summer 2015 onwards, online petition against a new town at West Tey and door-to-door petitioning. During the door -to -door petitioning, we estimated 40% of people had not heard of West Tey. Over 7,600 people have signed. The Petition was given to Colchester Council on 8 September 2016
 November 2015 'Visions for Growth' conference attended by over 100 people. 80 local councillors invited, 7 attended. Two council officers from the three North Essex authorities involved in the garden communities project attended;
 November 2015 CAUSE Metro Plan unveiled and subsequently submitted to local authorities and Aecom. Meetings with Aecom and Atlas refused. No discussion or engagement to ensure understanding of our proposal. Metro Plan rejected on spurious grounds (dealt with separately in this consultation response)
 Six village meetings held to explain the garden communities project to local people; about 600 hundred attended;
77 CAUSE Response to Strategic Part 1 for North Essex Authorities Local Plans, September 2016
 PR Campaign including Facebook page, Twitter feed, website and press coverage/letters to press to raise awareness of garden community proposals;
 Summer 2016 13,000 home flyer drop to advertise Preferred Options consultation and regular attendance at local authority drop-in events and local fetes etc;
 Formal CAUSE responses to Issues & Options for Braintree, Tendring & Colchester; to Air Quality Action Plan for Colchester; to Sustainability Assessment Criteria for Colchester; to DCLG Local Plan group consultation.
Preferred Options Consultation:
Information available during consultation period:
 Dwelling numbers are inconsistent. The Preferred Options refer to 15,000- 20,000 houses but yet the Aecom report is up to 28,000 houses;
 The information contained on the CBC website/ draft Local Plan gives no concise information on West Colchester Garden Community and key items of the evidence base are missing.
 The 'blob' map shows West Colchester Garden Community in the wrong location.
 Braintree has sent a flyer advertising the consultation to every household whilst Colchester's Policy Manager stated, at a Local Plan Committee meeting, that there was no plan to advertise the consultation.
 Those emailing their objection to the advertised address ( are told to register online. The portal is cumbersome and off-putting, thus restricting the number of responses;
 In some cases comments have been inaccurately added to the portal by Colchester;
 BDC on the other hand are accepting email comments to and have generally published comments in full very soon after receiving them;
 Many people wrote in advance of the consultation period to raise concerns about West Colchester Garden Community but these concerns are not being taken into account;
 The consultation is being held over the summer period.
 No records of attendance are being made at 'drop-in events' and there is no means of leaving comments at the events. The amount of information on West Tey is very limited and buried in a folder.


Preferred Options Local Plan

Representation ID: 3225

Received: 13/09/2016

Respondent: R F West Ltd

Agent: Andrew Martin Planning

Representation Summary:

This text confirms the importance of the proposed Garden Communities to the spatial strategy for growth in the new Local Plan. Paragraph 6.94 refers to the 'broad locations' that have been selected and "made on the basis of their levels of sustainability and deliverability, using evidence gathered on environmental constraints, infrastructure requirements, development capacity, and viability". It is submitted that the Plan is not supported by a plan indicating these broad locations. Identification of the new communities is shown on a key diagram that is not on an Ordnance Survey base.

Full text:

The full text here is the Executive summary as submitted in the Representation. A summary for each representation has been entered. The full representation plus the supporting appendicies have been uploaded as attachments. The representations referenced in this submission are logged against each element of the Plan.

1.1 Andrew Martin-Planning is instructed to make representations to the emerging Local Plan for Colchester on behalf of R F West Ltd, in respect of land at Stanway. Previous representantions submitted to Colchester Borough Council in respect of this site are attached at Appendix 1. These include a site location plan.
1.2 The site comprises some 46 hectares of land to the west of Stanway, which forms a district suburb of Colchester. It is bordered by the A12 dual carriageway to the north, Wyvern Farm site (the subject of residential development, under construction by Persimmon Homes Essex and Bellway Homes) to the east, the B1408 London Road and properties fronting onto it to the south, and the unclassified Turkey Cock Lane and properties fronting onto it to the west.
1.3 The predominant existing use is agriculture but there are also a number of existing structures within the site including a garden centre, a public house/carvery, restaurants, a children's nursery and the first Strokes swimming pool.
1.4 This land was promoted via the call for sites process. The proposals include up to 630 dwellings, employment, a primary school and substantial public open space and structural planting. Further representations were submitted to CBC in respect of this land in response to the Issues and Options Plan and SAR in February 2015 (see appendix 2).
1.5 The adopted development plan for Colchester identified Stanway as a Growth Area to deliver some 1800 dwellings (including 800 on greenfield land) plus employment. This Growth Area has now largely been built or is under construction. Part of this site, now being promoted at Stanway, lies within the designated Growth Area. The remainder represents a logical extension that is required to meet a significantly increased housing target for the Borough.
1.6 The site is highly sustainable in the context of the National Planning Policy Framework (NPPF). It has excellent access to a range of services and facilities via different modes of transport and is within easy walking distance to most of these. It also lies adjacent to existing bus stops.

1.7 The emerging draft Local Plan Preferred Options was taken to the Local Plan Committee on 5 July 2016 with a recommendation that it be approved for public consultation. This confirmed Colchester's Spatial Strategy for growth (Policy SG1) that provides for a settlement hierarchy ranking areas of the Borough in order of their sustainability merits and the size, function and services provided in each area. This spatial hierarchy focuses growth on the urban area of Colchester, with the Town Centre at its heart, reflecting its position as the main location for jobs, housing, services, and transport. The town centre sits above other parts of
urban Colchester, which includes Stanway. Thereafter the next tier of preferred growth includes new Garden Communities to the east and west of the Borough and below that proportionate growth in 3 District Centres and 15 large villages.

1.8 The site subject of these representations was included as an allocation in the draft plan presented to members on 5 July and highlighted on the West Colchester Proposals Map (see extract at Appendix 3), as a proposed site for housing. Paragraph 6.75 of the draft plan clarified the following:
"Land between London Road and A12 Stanway 6.75 The site is situated to the west of the Colchester and runs south of the A12 and north of London Road. It is in a sustainable location, well placed for public transport connections and job opportunities at the nearby economic area. Planning permission was granted for 358 units in 2015 on land to the east at Wyvern Farm. This allocation extends development further west and will provide for approximately 500 additional dwellings together with open space and community facilities as required including primary school provision. Development of the site will need to have regard to specific site constraints including archaeology, mineral safeguarding and drainage and water treatment 119 management. It will also be important to retain a significant break between the site and Turkey Cock Lane/Copford."

1.9 On the night of the Committee meeting a schedule of changes was referred to. These were described as "corrections/omissions identified since the publication of the Local Plan for the Committee Agenda" and "further minor amendments which relate to grammatical corrections and cross referencing." Significant change was however made in relation to table SG2 Housing Provision. The table continued to make an allowance for 678 dwellings at Stanway, but subject to a note confirming that the site for 500 dwellings to the west of Stanway would not be determined until the boundaries of the West Colchester Garden Community has been defined. Associated text at paragraph 6.75 was deleted, as was reference to the site allocation (Policy WC2) on the West Colchester Proposals Map. Similar
changes were made in respect of land to accommodate 930 dwellings to the east of
Colchester, adjoining the proposed new settlement area of search. Additional text was proposed to paragraph 4.29 of the plan to explain/justify these changes. This reads:
"The housing provision table SG2 makes an allowance for an additional 930 dwellings to be located to the east of Colchester, and 500 to the west of Stanway, the sites for which will be determined once the boundaries for the Garden Communities to the east and west of Colchester have been defined. This will allow for opportunities to deliver appropriate linkages between the new Garden Communities and the existing urban areas to the east and west of Colchester and ensure that sufficient green buffers are maintained between the new and existing communities."

1.10 These representations submit that the above changes are not minor adjustments to the consultation plan. Furthermore it is not accepted that there are similarities between land at Stanway (500 dwellings) and North Colchester (930 dwellings) that would justify the same treatment in the context of the Local Plan and the need to determine these sites following identification of the new Garden Community boundaries. Land to the north of Colchester adjoins the area of search for the East Colchester Garden Community whilst to the west of
Stanway is separated from the West Colchester Garden Community by up to 1.5 miles. Policy has already been established to ensure significant green buffers between new and existing communities on the edge of Stanway and Copford Village.

1.11 All aspects of a local plan must be realistic and deliverable but the NPPF makes specific requirements in relation to planned housing land supply. Paragraph 47 bullet points 2 and 3 and footnotes 11 and 12 confirm this point. These require authorities in their local plans to identify and update annually a supply of specific, deliverable sites sufficient to provide 5 years worth of housing against their housing requirements, with an additional 5% (moved forward from later in the plan period), or 20% where there has been a record of persistent under delivery of housing. Thereafter plans should identify a supply of specific developable sites or broad locations for growth for years 6 - 10 and wherever possible years 11 - 15.

1.12 The housing chapter of the consultation plan, as supported by the Sustainability Appraisal, leaves no doubt that to provide 678 dwellings at Stanway (as confirmed in Policy SG2:
Colchester's Housing Provision) will require the development of the land at London Road, subject of these representations. This is further clarified in paragraph 4.29 that refers to 500 dwellings to the "west of Stanway". In the context of the NPPF it makes no proper sense in planning terms, not to identify the site on the accompanying Proposals Map. This is also contrary to the requirements of the Town and Country Planning (Local Planning) (England) Regulations 2012.
1.13 The failure properly to identify this land is also contrary to the background evidence to the Plan in the form of the Sustainability Appraisal. This states in Paragraph 1.1.3 that the Colchester Borough Council Local Plan Part 2 provides the specific policies and allocations for Colchester Borough. This part of the Local Plan is said to include allocations and policies organised by area, so that residents will be able to easily find planning information specific to their local community. This place-based approach is said to align with the latest best practice put forward by the Local Plans Experts Group in their March 2016 Report to Government, Discussion Paper No. 5, which states:
"The policies and site allocations within the Plan should, where possible, be placestructured, enabling a user to quickly identify what the Plan proposes for their
geographical area of interest, and should also include a succinct vision and strategy for the main places."

1.14 The draft Local Plan at paragraph 1.23 states that it will set out the overarching spatial vision for development of Colchester to 2033, including broad allocations for strategic growth as well as other detailed allocations. Part one of the Plan does not appear to meet the Town and Country Planning (Local Planning) (England) Regulations 2012. This matter will be advanced in separate representations to the local plan on behalf of R F West Limited, in relation to
proposals for land at Marks Tey. Part two as drafted does set out a number of land use allocations that are site specific and these are shown on the Proposals Maps. Indeed the Council's website clarifies the purpose of Proposals Maps to support policies found in the Local Plan as follows:
"The Proposals Maps are to be read together with the documents that make up
Colchester Borough Council's Local Plan. Allocations are shown on the Proposals
Maps and these reflect policies within the Development Plan Documents (DPD) that the Council has produced to date. The maps cover the entire Borough and will be a key tool in the determination of planning applications and growth of the Borough over the plan period."
1.15 It is submitted that proposals in the emerging plan for 500 dwellings west of Stanway should be identified on the Proposals Map, in order to meet the requirements of Part 3 (5) and Part 4 (3) of the 2012 Regulations as referred to above. These require site allocation policies and allocations of sites to be shown on an OS map that illustrates geographically the application of the policies in the plan, sufficient to guide the determination of planning applications.

1.16 Until the recent amendments to the emerging Plan, land to the west of Stanway had been viewed by the Council as unconstrained land that is available to meet the demand for new homes in the Borough. In preparing the Plan it was recognised that "the Borough has a limited and diminishing supply of brownfield sites that can contribute to accommodating new growth. Accordingly, development sites for the 2017-33 period include new greenfield sites which have been selected on the basis of their sustainable location and deliverability."
(extract from Policy SG2).
1.17 Paragraph 4.27 refers to a Housing Trajectory. No trajectory is appended to the plan. The most up to date trajectory appears to be that set out in the Authority Monitoring Report 2015. This only deals with existing commitments. It is at odds with paragraph 47 of the NPPF that requires a housing trajectory for the plan period that demonstrates the housing implementation strategy and how the delivery of a five year housing land supply will be maintained to meet the housing the housing target.

1.18 Furthermore, Planning Policy Guidance accompanying the NPPF confirms in Paragraph: 002 Reference ID: 12-002-20140306 what a Local Plan should contain. It states:
"The Local Plan should make clear what is intended to happen in the area over the life of the plan, where and when this will occur and how it will be delivered. This can be done by setting out broad locations and specific allocations of land for different
purposes; through designations showing areas where particular opportunities or
considerations apply (such as protected habitats); and through criteria-based policies to be taken into account when considering development. A policies map must illustrate geographically the application of policies in a development plan. The policies map may be supported by such other information as the Local Planning Authority sees fit to best explain the spatial application of development plan policies." (our underlining).
1.19 National Planning Policy sets clear expectations as to how a Local Plan must be developed in order to be justified, effective, consistent with national policy and positively prepared to deliver sustainable development that meets local needs and national priorities. To accord with this guidance it is submitted that paragraph 6.75 of the draft Plan taken to Committee on 5 July, should be reinstated, together with identification of the land to the west of Stanway on the Proposals Map as a housing allocation. (see Appendix 3).