Vision for the Strategic Area

1.The principle behind Garden Communities are fine, and probably well-founded, the existing urban centre of Colchester is constrained in its ability to grow further, primarily by its ancient central road network. But we must also be clear that as these Garden Communities will be large scale developments, there must be large scale infrastructure upgrades that pre-empt these developments. For once let's do the infrastructure first, and build the houses afterwards.

2.The sustainable development principles within the Vision for North Essex are absolutely correct but these must be adhered to in their entirety - with no allowances based on short termism.

3.The problem I have is that this vision should have (and should in future) been developed from the communities up, not centrally designed. The new Garden Communities principle would've been a perfect vehicle for trialling the double devolution of housing planning - through something like ResPublica's suggestion for Local Place Partnerships. This way you could've avoided the animosity and anger that these planned Garden Communities have brought, particularly West Tey.

4.The strategic objectives are broadly correct but there needs to be a value judgement against each of these. From my perspective, economic development and providing new and improved transport & communication infrastructure should be the initial highest ranked priorities - with these two objectives satisfied, other objectives such as sufficient housing growth and education and healthcare needs would be far more easily delivered. Yes, housing should be a priority, but Colchester has yet to have much issues delivering their Objectively Assessed Need annual allocation - the problems will begin to arise as infrastructure is beginning to be choked and not enough high value jobs existing in the town meaning we can't reap the benefits of highly skilled residents within our local economy.

Whilst the Borough Council, working in partnership with Tendring and Braintree District Councils, is best placed to assess, and set, the most appropriate strategy for accommodating future growth across the Strategic Area, the University supports the overarching aims and objectives and the principles underlying the Garden City proposals.

The University supports the Strategic Objectives and, in particular, the acknowledgement (para 1.31) that there is a current deficit in transport infrastructure and that further investment, and provision, is needed to support new development with proposals being delivered in a phased and timely manner.

The University also offers its assistance, and expertise, and looks forward to working closely with the Council, to achieve its objectives and providing good quality educational opportunities across the Strategic Area.

The Vision for Garden Communities is good in theory; but on past performance the local population do not trust CBC to deliver this.
Community assets have not been delivered (at Myland and Tollgate), and Transport & Communication Infrastructure (A12, A120, and railway) have been delayed.

The vision for the Strategic Area is fully supported, but we have reservations about the likely effectiveness of the proposed "new approaches to delivery". Further detail of our concerns and reasons are set out in our response to Policy SP7 in respect of our proposals for Land at East Marks Tey.

The vision should include reference to the need to have regard to appropriate integration or relation with existing communities in full collaboration with those communities.

The infrastructure (ie.water, drainage, internet ) of Abberton and Langenhoe cannot cope now , so will grind to a halt with extra building in the area. Facilities such as Drs., School, are already struggling to manage due to high numbers. The traffic will increase dramatically as we have no village shop, dentist, pub which means villagers have to travel to other villages/towns. we who choose to live in the countryside do so to enjoy the wildlife and green spaces, so we do not want to see every inch built on.

1.6 Vision for the Strategic Area

We have reservations in respect of the manner in which the Vision has been expressed. Whilst there may be "constraints in many existing urban areas" across North Essex, these are not so significant as to frustrate the greater proportion of future development needs that the respective districts face, in particular, in Colchester.

Indeed, at paragraph 1.41 and 1.42 the focus on growth is very fairly put in the context of "the urban area of Colchester" and in "Clacton and Harwich with Dovercourt are classified by Strategic Urban Settlements and...will accommodate around 5,000 new homes".


Indeed, Policy SP2 whilst recognising that the garden communities will be "part of the sustainable strategy for growth" it explains that they will accommodate around 7,500 additional homes within the plan period. In the context of the growth that existing settlements will be tasked with accommodating, this is a relatively modest proportion.

The Vision therefore needs to better articulate the manner by which the existing urban areas will meet these challenges going forward. Such a challenge is recognised in respect of the garden communities, for example later at paragraph 1.83 but that and the challenge for the existing urban areas could be better articulated as part of the Vision.

In particular, the Vision needs to reflect the particular challenges and issues for delivery wherever development is to be located (see the reference at 1.30 in terms of providing growth in sustainable forms and at 1.83 where the garden communities will face particular "challenges").

The Vision also fails to address the needs to have secured economic success across the District particularly in light of the strategic objectives at paragraph 1.31 explaining the need to "foster economic development" which is defined as including the need to "strengthen and diversify local economies...".

We reiterate that this section should include a high level strategic objective which addresses the need to protect and enhance the natural environment, including landscape, and the challenges surrounding climate change adaptation and mitigation, to comply with paragraph 156 of the NPPF.

We advise that the Section 1 plan needs to have a specific overarching policy to protect and enhance existing assets, which would include biodiversity, geodiversity, water, landscape, green infrastructure and open space etc. This is currently only covered in the Section 2 plan under policies ENV1,2,3,4,5. We refer you to the North Northamptonshire Joint Core Strategy (adopted July 2016) as a good example.

We note the comments in respect of the A120 route improvements referred to in paragraphs 6.9 and 6.10 and the strategic priority for a dualled A120 between the A12 and Braintree. Historic England was invited to participate in the Highways England Environmental Forum for the A12 & A120 improvements and we reiterate 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.

Our comments on the August 2016 consultation, in respect of broadband provision, sought reference in what are now paragraphs 6.29 and 6.30, though not a hyperlink, to the Cabinet Siting and Pole Siting Code of Practice: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/205744/Final_Cabinet_and_Pole_Siting_COP_Issue_1_2_.pdf
We reiterate that comment in respect of the pre-submission draft local plan.

Officer NB: Please see summary for appropriate summary for each rep. The full representations submitted are attached to all representations on JDi (The consultation portal).

The attached representations are submitted on behalf of Andrew Mattin, in relation to his land at Livelands, Marks Tey.
The following documents have been submitted:

Representations on the Publication Local Plan Statement, and this has also been split into the relevant response forms for ease of reference:
o Response Form General
o Response Form SG1
o Response Form SG2
o Response Form SG8, SS11 and the Sustainability Appraisal
o Response form SP2
o Response Form SP3
o Response Form SP7 and SP9
o Response Form Vision
o Sustainability Appraisal Comment Form
 Copy of correspondence to CBC regarding the SHLAA (dated 14th September 2016)
 Additional evidence relating to the site access:
o Road Safety Audit Stage 1
o Request for Road Safety Audit
o Designer Response by Create Consulting Engineers Ltd
o Site Access Arrangements Existing
o Site Access Arrangements Proposed
o Correspondence with Essex County Council
If you require any further clarification on the above please let me know. I would be grateful if you
could confirm receipt.

A have a number of issues with the draft plan: The plan does not have a real vision. The plan is tactical rather than strategic. Where is tbe economic generator for East Anglia akin to a 3rd runway at Heathrow or HS2 etc. Significant infrastructure development should be a key ingredient of any local plan to make it both viable and sustainable long term to create prosperous new communities that can thrive and succeed rather than create communities that would have a higher risk of dependencies on the public purse. The plan has no economic case and there is a big difference between having a genuine economic generator and economic activity that will simply derive from the local plan. The plan labours on about Harwich as a port, but Harwich is not significant in comparision to Felixstowe. Felixstowe Port is one of the biggest economic generators that East Anglia has. It also drives significant road and rail freight volumes on strategic roads in the area i.e. A12 and A120 and the Greater Anglia from Ipswich into London and vice versa, using up scarce commuter train capacity. Greater Anglia capacity is already full from Colchester to London. Standing room only on peak trains from Kelvedon to London. Where is the plan to add capacity? Rail car parks are full or close to full already and are not capable of growing in line with GDP on a sustained basis. Road networks that service local rail stations are already clogged e.g. Blue Anchor junction of B1023 with London Road at Feering is already backed up at peak times to such an extent that you have to allow considerable extra time to get to Kelvedon station. These sorts of bottlenecks need to be fully addressed as part of the local plan. In the draft, they are not considered. If A12 widening and new A120 will both involve compulsory purchase, why not purchase wider strips of land to be able to add a new train line from Marks Tey to Stansted and new additional track from Marks Tey to Shenfield to link to new Cross Rail - such ideas are visionary and strategic and would form part of an economic generator for the region. What has been Abellio Greater Anglia's contribution to the draft plan? What has been network rail's contribution to the draft plan? What has been the Department of Transport's contribution to the draft plan? How does this local plan fit and integrate with regional and UK master plans? The draft plan describes having retail within the garden cities in order to curb traffic in the area. Any retail development needs to be focused on essential services for 2 reasons 1) shopping behaviour is changing, more and more people are shopping online. Generation X and Y shop online as standard and this will become more prevalent on time. The plan should include a strategy for home deliveries and this is more important than retail development. Traffic will not be curbed because these garden cities will not support a dedicated Ikea or a B&Q, so people will travel. Retail development should be limited to haridressers, medical services, dentists, convenience stores. Any attempt to replicate high street stores within these garden cities is unlikely to be sustainable long term. The draft plan misses the opportunity to introduce new housing solutions, such as could be delivered by pension funds which would be interested to invest and match their rental charges to their long-term pension liabilities. Such an approach has been a long term and successful feature of the housing mix in The Netherlands and could both (a) offer longer term rentals and (b) afford better protection to the tenant vs. today's short-term tenancy agreements that are loaded in the landlord's favour. The finalisation of the local plans offers an opportunity to be visionary, strategic and ambitious. The draft, thus far, falls along way short of fulfilling any of these aspects and this must be remedied in the next stage.

Strategic Objectives - 1.31
In the context of the vision for North Essex including reference to providing leisure and recreation opportunities, the importance attached in Government planning policy (paragraph 69 of the NPPF) to promoting healthy communities and the corporate health and well-being priorities of the three local authorities it is surprising that there is not a strategic objective that specifically covers creating healthier and active communities. While one of the objectives covers addressing healthcare needs, this only represents part of what is required to create healthier communities. In particular, providing opportunities for people to be physically active through leisure and recreation opportunities will be an essential requirement to help encourage healthier lifestyles

To ensure that the plan is sound in terms of meeting the 'justified' and consistent with national policy' tests It is therefore requested than an additional strategic objective is added to those listed in paragraph 1.31 (or the 'Addressing Education and Heathcare Needs' objective is extended) which focuses on creating healthier communities through providing opportunities for physical activity in development by designing development to provide opportunities for healthy and active lifestyles, meeting leisure and recreation facilities needs (as well as providing for conventional health care needs) .

SP5 - Infrastructure and Connectivity

It is of concern that the strategic infrastructure types focused on in policy SP5 do not include leisure (including sport) and recreation facilities. Such facilities offer potential to make a major contribution to delivering the vision and strategic objectives in the shared local plan as well as delivering the wider health and well-being priorities for both existing and future communities in North Essex. This is pertinent in view of much of the planned led growth being proposed in garden communities where strategically planned leisure/sports facilities and open space will be essential for assisting in successfully delivering such communities which is recognised in the relevant policies (SP8, SP9 and SP10) for these communities.

All three authorities have recently prepared (or are preparing) evidence bases for sports facilities, playing pitches and open space (in accordance with paragraph 73 of the NPPF) and these should be used for informing strategic infrastructure needs across the North Essex area. As well as the concern about this infrastructure type not being given appropriate consideration in policy SP5, there is a potential concern that opportunities for co-ordinating strategic leisure/recreation provision with other infrastructure types (that are addressed in the policy) may be missed if they are not considered together and given a similar degree of focus. For example, new schools provide the opportunity for jointly provided leisure facilities such as leisure centres and sports halls to be delivered while health hubs can provide leisure facilities as well as health care facilities. As well as the potential benefits of co-location in terms of capital and revenue efficiencies, there are also benefits in terms of encouraging active lifestyles. Furthermore, opportunities for cross-boundary facility provision may be missed which is particularly relevant in terms of the cross-boundary garden communities that are proposed and addressing this would help meet the 'effective' soundness test.

To address this concern, it is requested that leisure and recreation is added to the infrastructure types that are covered by policy SP5 and that the policy sets out the principles of meeting needs for this infrastructure type e.g. addressing the leisure and recreation facility needs identified in the respective evidence bases including any specific facility needs that are of strategic importance across the three local authority areas, using the garden communities and other developments to maximise the opportunities for encouraging healthy and active lifestyles through the use of 'Active Design' principles, safeguarding and enhancing existing facilities that help meet existing and future needs etc. The supporting text should refer to the authorities evidence bases for sport and recreation and provide more detail about how leisure and recreation objectives will be met on a strategic basis.

This suggested amendment would improve the soundness of the plan in relation to meeting the 'justified', 'effective' and consistent with national policy' tests

SP6 - Place Shaping Principles
Sport England is supportive of the principles especially those relating to creating well connected places that prioritise the needs of pedestrians/cyclists and providing an integrated network of multi-functional public open space. These principles would help encourage healthy and active lifestyles as well as addressing other objectives. They would also be consistent with Sport England's and Public Health England's Active Design guidance principles https://www.sportengland.org/facilities-planning/active-design/ which seek to create the opportunities in development to encourage physical activity. The review of the Essex Design Guide which is under preparation and has been commissioned by the Essex local authorities, will be a material consideration in assessing the quality of the design of new developments. Sport England is supporting Essex County Council and the districts in the preparation of the review and its has been confirmed that the Active Design principles will be embedded into the guidance. It will therefore be important that local plan policies are consistent with the Essex Design Guide.

While the policy is broadly supported, to complement its implementation it is requested that reference is made in the policy's supporting text to the Active Design guidance as this would provide more detail about how the relevant place making principles could be applied in practice. This addition would improve the soundness of the plan both in relation to meeting the 'justified' and consistent with national policy' tests

SP7 Development and Delivery of New Garden Communities

Principles (iii), (viii), (x) and (xiv) are particularly supported as they align with the principles in Sport England's and Public Health England's Active Design guidance which seek to create environments in developments that encourage physical activity.

SP8 - Tendring/Colchester Borders Garden Community

Principle 15 is welcomed as it would provide the policy basis for ensuring that provision is made for green infrastructure (including outdoor sports facilities), that provides opportunities for residents of the new community to be active, to be a key part of the infrastructure of the development. Both Colchester and Tendring councils have prepared or are at an advanced stage of preparing an outdoor sports evidence base. The collective evidence base documents should be used for informing how this development makes provision for outdoor sport.

Principle 16 is also welcomed as it makes provision for indoor leisure and sports facilities to be provided within the new community or off-site. Colchester Borough Council has an up-to-date and robust evidence base for informing current and future facility needs for indoor sport within its area which Sport England supports. Tendring District Council also has recently prepared a similar evidence base. The collective evidence base documents should be used for informing how this development makes provision for indoor sport.

SP9 - Colchester/Braintree Borders Garden Community

Principle 16 is welcomed as it would provide the policy basis for ensuring that provision is made for green infrastructure (including outdoor sports facilities), that provides opportunities for residents of the new community to be active, to be a key part of the infrastructure of the development. Both Colchester and Braintree councils have prepared an up-to-date outdoor sports evidence base. The collective evidence base documents should be used for informing how this development makes provision for outdoor sport.

Principle 17 is also welcomed as it makes provision for indoor leisure and sports facilities to be provided within the new community or off-site. Colchester Borough Council has an up-to-date and robust evidence base for informing current and future facility needs for indoor sport within its area which Sport England supports. Braintree District Council also has recently prepared a similar evidence base. The collective evidence base documents should be used for informing how this development makes provision for indoor sport.

SP10 - West of Braintree Garden Community

Principle 15 is welcomed as it would provide the policy basis for ensuring that provision is made for green infrastructure (including outdoor sports facilities), that provides opportunities for residents of the new community to be active, to be a key part of the infrastructure of the development. Braintree District Council has recently prepared an outdoor sports evidence base which should be used for informing how this development makes provision for outdoor sport.

Principle 16 is also welcomed as it makes provision for indoor leisure and sports facilities to be provided within the new community or off-site. Braintree District Council has prepared an evidence base for informing current and future facility needs for indoor sport which should be used for informing how this development makes provision for indoor sport.